During an occupational health inspection, the Labour Inspectorate checks three documents first: the contract with the occupational health service provider, a current risk assessment, and health surveillance certificates. The inspector also checks employee notification records, the workplace accident register, and the three-year situation analysis. Missing documents are an independently sanctionable violation - up to EUR 32,000 for a legal entity (TTOS § 27-1 - § 27-5 lg 2).
Why is documentation a duty in its own right?
Many employers assume that organising occupational health is the primary obligation and that documentation is secondary. The Labour Inspectorate takes the opposite view: an inspector cannot assess actual working arrangements without documents. If there is no document, it is treated as though the activity never took place.
TTOS establishes documentation requirements directly - for example TTOS § 13 lg 1 p 1 (the risk assessment must be prepared and recorded in writing), TTOS § 13³ (employee notification must be documented), and TTOS § 23 lg 1 (a workplace accident register must be maintained). Good intentions are not sufficient to satisfy these obligations; you need a physical or digital document.
Inspectors ask for documents as their very first step. If documents are missing, enforcement proceedings begin immediately, regardless of whether working conditions are actually safe.
Document list: first tier - core documents
Every employer must hold these documents, irrespective of company size, sector, or number of employees.
A. Risk assessment (TTOS § 13 lg 1 p 1)
| Requirement | Detail |
|---|---|
| Status | Mandatory for all |
| Content | Identified hazards in the workplace, their evaluation (likelihood x consequence), mitigation measures, responsible persons, date of assessment, and signatures |
| Updating | After every significant change (new workplaces, new equipment, following a workplace accident, change of activity). The law does not set a fixed periodic deadline; good practice is to review the risk assessment regularly together with the service provider |
| Retention | Current version must always be accessible; risk assessments are retained for 55 years (TTOS § 13-4 lg 9; in the working environment register § 24-1 lg 4 p 5) |
| Format | Written (paper or digital). Signatures required. TT24 template document: /vormid/riskianaluus.html (in Estonian) |
B. Contract with the occupational health service provider (TTOS § 13¹)
| Requirement | Detail |
|---|---|
| Status | Mandatory for all |
| Content | Provider's licence (medical activity licence), the named occupational health physician in the contract, terms for organising health surveillance, and fee |
| Validity | The contract must be current. A company operating under an expired contract is in violation even if health surveillance has taken place |
| Retention | Throughout the contract period and for at least 5 years after the contract ends |
| Format | Written contract with signatures from both parties |
C. Health surveillance documents (TTOS § 13¹)
| Requirement | Detail |
|---|---|
| Referral for health surveillance | Before each health surveillance appointment, the employer must issue a referral for the employee stating: the employee's job title, hazards at the workplace, and the date of the previous health surveillance. TT24 template document: /vormid/suunamiskiri.html (in Estonian) |
| Health surveillance certificate (decision) | The occupational health physician's decision on the outcome of health surveillance. The employer receives only the decision (fit for work / fit with conditions / unfit). Medical details remain with the physician. The employer must retain the decision |
| Health surveillance schedule | The employer's documented plan of when each employee is due for health surveillance. The inspector checks that the schedule is realistic and complies with TTOS frequency requirements. The frequency of periodic health surveillance is determined by the occupational health physician as appropriate, but the interval between appointments must not exceed 3 years (TTOS § 13-1 lg 8); for night work, noise, and chemical exposure it is often more frequent |
| Retention | The occupational health service provider retains health surveillance data for 30 years; the employer retains service administration data for 10 years (TTOS § 13-1 lg 16). Data relating to exposure to carcinogens or mutagens must be retained by the employer for 40 years, and to reproductive toxins for 5 years (TTOS § 13-1 lg 17) |
D. Employee notification records (TTOS § 13³)
| Requirement | Detail |
|---|---|
| Status | Mandatory for all |
| When to prepare | With every employee at the start of employment (before work begins) and whenever the risk assessment changes or working conditions change significantly |
| Content | Which hazards are present at the employee's workplace, how to protect against them, personal protective equipment (where required), first-aid arrangements, emergency procedures |
| Evidence | Employee's signature on the notification record. Verbal notification is not sufficient; written confirmation is required |
| Retention | Throughout the employment relationship plus at least 5 years after it ends |
| Format | TT24 template document: /vormid/teavitamine.html (in Estonian) |
E. Workplace accident and occupational disease register (TTOS § 23 lg 1)
| Requirement | Detail |
|---|---|
| Status | Mandatory for all |
| Content | All workplace accidents, including minor ones. Each entry must include: date, employee name and job title, description of the accident, nature of injury, number of days of incapacity (where applicable), and results of the investigation |
| Reporting duty | Serious workplace accidents must be reported to the Labour Inspectorate immediately. Minor workplace accidents must be entered in the register within 5 working days |
| Retention | The register is kept as a permanent archive; workplace accident data does not expire, as occupational diseases may emerge years later |
Browse TT24 template documents
All of the documents listed above are available as ready-to-complete templates in the TT24 document library.
Document list: second tier - additional mandatory documents
These documents are mandatory under certain conditions, depending on company size, sector, or events that have occurred.
F. Three-year working environment situation analysis (TTOS § 13 lg 1 p 6)
Mandatory for employers with an occupational health service contract
The three-year situation analysis differs from the day-to-day risk assessment: it is a broader summary prepared by the occupational health service provider together with the employer. The analysis covers: a summary of working environment hazards, an overview of health surveillance results (anonymised), an analysis of workplace accidents and occupational diseases, and recommendations for the next three years.
The analysis is prepared every three years; the precise schedule is set out in the occupational health service contract. The Labour Inspectorate requests the analysis as a general indicator of the maturity of the employer's working environment management.
G. First-aid arrangements document (TTOS § 13²)
Mandatory for all
The document sets out: who the first-aiders are (name, certificate expiry date), the location of first-aid equipment at the workplace, and the inspection schedule (recommended: once per quarter). TT24 template document: /vormid/esmaabi.html (in Estonian).
First-aiders' certificates are separate documents that the employer must archive. A list of first-aiders holding expired certificates is a violation.
H. Appointment of the working environment specialist and representative election records (TTOS § 17)
Mandatory for employers with 10 or more employees
Employers with 10 or more employees must have a designated working environment specialist (the employer's representative) and a working environment representative (the employees' representative). Both appointments must be documented: an appointment decision or agreement for the specialist, and an election record for the representative.
Working environment council meeting minutes are mandatory at least once a year and whenever significant working environment matters are discussed. TT24 template document: /vormid/volinik.html (in Estonian).
I. Workplace accident investigation report (TTOS § 23)
Required for each workplace accident
An investigation report must be prepared for every workplace accident, including minor ones. The report covers: a description of events, witness statements, an analysis of causes, and preventive measures. For serious workplace accidents the report is particularly important - the Labour Inspectorate may request it immediately. TT24 template document: /vormid/tooonnetus.html (in Estonian).
J. Hazardous chemicals register (TTOS § 13 in conjunction with the Chemicals Act)
Mandatory for employers working with hazardous chemicals
Where hazardous chemicals are used at the workplace, a register must be maintained: chemical name, CAS number, classification, quantity at the workplace, and reference to the safety data sheet. TT24 template document: /vormid/kemikaalid.html (in Estonian).
What actually happens during a Labour Inspectorate inspection?
Labour Inspectorate visits are generally unannounced. The inspector arrives at the premises and, after identifying themselves, issues a written request for access to documents. You are entitled to ask for a brief moment to locate the documents, but in principle they should be available immediately.
The first questions the inspector asks
Typically, the inspector asks for the following first:
- "Please show me the current risk assessment."
- "Please show me the contract with the occupational health service provider."
- "When was the most recent health surveillance, and do all employees hold a current decision?"
- "Please show me the employee notification records."
- "Do you have a workplace accident register? Please show me."
For each of these five points, the outcome is either "present and current" or "missing". Missing is a violation.
Common shortcomings that inspectors flag
- Outdated risk assessment - the area of activity has changed but the risk assessment has not been updated. Particularly common in growing businesses where new workplaces have been added.
- Missing health surveillance for some employees - a situation often arises where most employees' health surveillance is in order but one or two have lapsed. Even a single missing health surveillance record is a violation.
- Unsigned notification record - notification has taken place but the record has not been signed. The inspector treats this as a failure to notify.
- Expired first-aider certificates - the list of first-aiders exists but training took place more than 3 years ago. An expired certificate means first-aid arrangements do not meet requirements.
- No workplace accident register kept - the company has had no serious accidents, so the register is empty. The inspector will still ask for the document; the register must exist even if it contains no entries.
Fine for missing documentation: the maximum fine for violating occupational health and safety requirements is up to EUR 32,000 for a legal entity (TTOS § 27-1 - § 27-5 lg 2); up to 300 fine units for an individual (employer or their representative). Missing documents are an independently sanctionable violation - not only when an accident has occurred. Inspectors draw a distinction between a first violation (typically a notice with a deadline for remediation) and repeated violations (fine).
Format requirements: paper versus digital
TTOS does not require paper. Digitally signed documents (signed with an ID card or Mobile-ID digital signature) are fully accepted. Most employers today use a combination: risk assessments prepared digitally, notification records signed on paper (because the employee is present), and contracts signed digitally.
What matters is that you can present the documents during an inspection visit. If a document exists only in cloud storage and you cannot access that service at the time, that is a problem. Keep critical documents on a local drive or in printed form as well.
Language rules
Occupational health documentation in Estonia is prepared in Estonian. Where employees do not speak Estonian, notification (TTOS § 13³) must be provided in a language the employee understands, and the notification record must state in which language notification was given. The simplest solution: prepare the notification record in Estonian plus the employee's own language in parallel.
Document retention: quick summary
| Document | Minimum retention period |
|---|---|
| Risk assessment | 55 years (TTOS § 13-4 lg 9; in the working environment register § 24-1 lg 4 p 5) |
| Contract with the occupational health service provider | 5 years after the contract ends |
| Health surveillance referral | 5 years after the health surveillance appointment |
| Health surveillance decision (result) | Service provider: 30 years; employer's service administration data: 10 years (TTOS § 13-1 lg 16). Carcinogen/mutagen: 40 years; reproductive toxin: 5 years (TTOS § 13-1 lg 17) |
| Employee notification record | 5 years after the employment relationship ends |
| Workplace accident register | Permanent archive; does not expire |
| Workplace accident investigation report | Permanent archive |
| First-aider certificates | At least for the duration of the certificate's validity and for a reasonable period after it expires |
| Three-year situation analysis | Until the next analysis plus 5 years |
| Working environment representative election record | Representative's term of office plus 5 years |
Step by step: conducting a documentation audit
Compile a list of all employees and their workplaces
The audit begins with an employee list. For each employee there must be: a notification record, a health surveillance decision (where required), and a referral. An employee with a missing entry means a missing document.
Check the risk assessment is current
Look at the date of the last update. Does the assessment cover all current workplaces? Have new workplaces, equipment, or activities been added since then? If so, the risk assessment needs updating. Further guidance: Risk assessment guide (step by step).
Check the occupational health service contract
Is the contract current? Does the service provider hold a valid medical activity licence? Is the occupational health physician named in the contract? If the contract has expired, conclude a new one before the next health surveillance appointment. On the need for a contract: /artiklid/kas-vaja-lepingut.html (in Estonian)
Review the validity of health surveillance decisions
Every employee for whom health surveillance is mandatory must hold a current decision. Check the dates: the frequency of periodic health surveillance is determined by the occupational health physician as appropriate, but the interval must not exceed 3 years (TTOS § 13-1 lg 8); for night work, noise, and chemicals it is usually more frequent. Use the TT24 schedule tool to track deadlines.
Check notification records
Do all employees have a signed notification record? Have new employees been notified before starting work? If the risk assessment has changed in the meantime, have employees been informed of the new risks and a new notification record signed?
Confirm the workplace accident register exists
The register must exist even if no accidents have occurred. If it is missing, create it now and add all past workplace accidents that you are aware of.
Check that first-aider certificates are current
First-aider training must be renewed as required (typically every 3 years). An expired certificate means first-aid arrangements do not meet the legal standard.
Labour Inspectorate notice versus fine: a first inspection visit often ends with a notice - the inspectorate gives a deadline for remedying the deficiencies. Repeated violations or inherently dangerous situations (for example, serious risk of a workplace accident) result in a fine. Running a preventive documentation audit before your first inspection visit is therefore a sensible step.
Related articles and resources
For template documents to complete, visit the TT24 document library.
Occupational health documentation is inseparable from the risk assessment - the risk assessment is the foundation of all other documentation. Guide to preparing a risk assessment: Risk assessment step by step.
Where an employee refuses health surveillance (and therefore lacks health surveillance documents), see: /artiklid/tootaja-keeldub-tervisekontrollist.html (in Estonian).
Documenting a workplace accident is a separate block of obligations. On liability at the intersection of missing health surveillance and a workplace accident: /artiklid/tooonnetus-vastutus.html (in Estonian).
The tax treatment of occupational health costs (including whether having documentation affects tax calculations): Are occupational health costs income-tax-exempt?
The most common mistakes that lead employers to be caught out during a Labour Inspectorate inspection: /artiklid/7-levinumat-viga.html (in Estonian).
Frequently asked questions
What does the Labour Inspectorate ask for first during an occupational health inspection?
The inspector's first step is to ask for the contract with the occupational health service provider and a current risk assessment. These are the two core documents; if either is missing, enforcement proceedings begin immediately. The inspector then checks health surveillance certificates, employee notification records, and the workplace accident register.
How long must a risk assessment be retained?
The risk assessment must be kept up to date. The current version must always be accessible. Risk assessments are retained for 55 years (TTOS § 13-4 lg 9; in the working environment register § 24-1 lg 4 p 5).
Must occupational health documents be held on paper?
No. TTOS does not require paper. Digitally signed documents are fully accepted. What matters is that the documents can be presented during an inspection visit - whether printed, shown on screen, or sent by email. The Labour Inspectorate accepts both paper and digital storage.
What is the three-year situation analysis?
The three-year working environment situation analysis (TTOS § 13 lg 1 p 6) is mandatory for all employers who have a contract with an occupational health service provider. It is a broader review of the working environment, health risks, a summary of health surveillance results, and recommendations - distinct from the day-to-day risk assessment. It is prepared every three years together with the occupational health service provider.
Must small businesses also maintain a workplace accident register?
Yes. The workplace accident register is mandatory for all employers regardless of the number of employees (TTOS § 23 lg 1). The register must include all workplace accidents, including minor ones for which no sick note is issued. A missing register is itself a violation during a Labour Inspectorate inspection.
Must a new employee be notified before starting work?
Yes. TTOS § 13³ requires that an employee is informed of workplace hazards before they begin performing their duties. Notification given a day after starting work does not comply. The notification record is signed immediately on commencement - it forms part of the onboarding process.
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Related topics
Sources: the State Gazette (Riigi Teataja), the Labour Inspectorate (ti.ee).