OSH in a Physiotherapy Practice

Mark has run a physiotherapy practice for three years. When he hired a second physiotherapist and a receptionist, he received a letter from the National Labour Inspectorate (PIP): an inspection in 14 days. The inspector's first question was: "Could I see the occupational risk assessment for your job positions?" Mark had no idea what that was. It ended with an order to prepare the documentation within a month.

This scenario catches out many practice owners who think OSH (occupational health and safety) only applies to factories. In reality, anyone who employs even a single person becomes an employer under the Labour Code -- with a full package of obligations. In this article we'll show you what an occupational risk assessment is, how to prepare one for a physiotherapy practice, and what OSH documents you need to have.

When does OSH start to apply to you?

The key line is crossed the moment you hire your first employee on an employment contract.

• You work alone (sole practice) -- the OSH provisions of the Labour Code don't apply to you, because you're not an employer. You're only responsible for your own safety.
• You hire someone on an employment contract -- you become an employer and are subject to the full OSH regime (Article 207 et seq. of the Labour Code).
• You work with people on B2B or mandate contracts -- an employer must provide safe and hygienic working conditions also to people working on a basis other than an employment relationship at its workplace or at a place it designates (Article 304(1) of the Labour Code), though the full apparatus of employee training does not cover them.

The legal basis is the Labour Code (Section X) and the Regulation of the Minister of Labour and Social Policy of 26 September 1997 on general occupational health and safety provisions. Assessing and documenting occupational risk is required directly by Article 226(1) of the Labour Code.

What is an occupational risk assessment?

An occupational risk assessment is a document in which you identify hazards at each job position, estimate the probability and severity of their occurrence, and set out measures to reduce the risk.

In a physiotherapy practice there are, contrary to appearances, quite a few hazards:

• Musculoskeletal strain -- the therapist performs massage and mobilisations, working in forced positions
• Biological hazards -- contact with patients, potentially infectious material, bodily fluids
• Chemical hazards -- disinfectants, gels, oils
• Electrical hazards -- equipment (TENS, ultrasound, laser, magnetotherapy)
• Slips and falls -- wet floors, equipment cables
• Psychological strain -- working with patients in pain, stress, time pressure

Risk assessment method -- the simplest approach

Article 226(1) of the Labour Code requires you to assess and document the risk, but does not prescribe a method. For a small practice a practical choice is a simplified three-level scale, as in the table below. We did not check the standards (including PN-N-18002) or PIP's position on specific methods, so describe the method you choose in your own document.

Risk level	Probability	Consequences	Action
Low (L)	unlikely	negligible	monitoring
Medium (M)	probable	moderate	plan mitigating measures
High (H)	highly probable	severe	immediate action

For each hazard you record the risk level and the measures to reduce it. Example for musculoskeletal strain on the therapist: medium risk, measures -- height-adjustable treatment couch, breaks between patients, ergonomics training.

What OSH documents do you need to have?

A PIP inspection at a physiotherapy practice most often checks this set:

1. Occupational risk assessment for each position (physiotherapist, receptionist)
2. OSH training records -- initial (before admission to work) and periodic
3. Referrals for medical examinations and certificates from the occupational medicine physician
4. OSH instructions for operating equipment and position-specific instructions
5. Register of workplace accidents (even if empty)
6. Measurement documentation for harmful factors (if present)
7. Safety data sheets for chemical products (disinfectants)

OSH training -- who, and how often?

The rules are set by the regulation on occupational health and safety training (consolidated text, Journal of Laws 2024 item 1327):

• Initial training -- a general briefing before newly hired employees are admitted to work (§ 10(1)) and a position-specific briefing before admission to work at a given position (§ 11). Completing both is confirmed in an initial training card kept in the personnel file (§ 12).
• Periodic training of administrative/office staff (e.g. reception) -- at least once every 6 years (§ 15(2)).
• Periodic training of employees in manual positions -- at least once every 3 years, and once a year for particularly dangerous work (§ 15(1)). Whether a physiotherapist's position counts as "manual" is determined in the training programme and the risk assessment. The regulation does not settle it for you.
• Employers and people managing employees -- periodic training at least once every 5 years (§ 15(2)). An employer's first periodic training takes place within 6 months of starting in that position (§ 15(4)).

You can organise training yourself or commission a training provider (§ 4(1)). Training of people who are employers is delivered by organisational units conducting OSH training activity (§ 4(2)). Periodic training of employers and office staff can take the form of a course, a seminar or guided self-study (§ 15(2)). We found no exemption of office staff from periodic training in the text of the regulation. We did not check training prices.

Medical examinations and occupational medicine

Persons taken on for work undergo pre-employment medical examinations (Article 229(1) of the Labour Code), with the exceptions in paragraph 1[1], and an employee is also subject to periodic and follow-up examinations (paragraph 2). The examinations are carried out on the basis of a referral issued by the employer (paragraph 4a), at the employer's cost (paragraph 6). The referral describes the working conditions, for example harmful factors, physical strain or work at a monitor. The period of validity comes from the physician's certificate, and we do not give it here as a fixed number of years.

An employer must not admit an employee to work without a current medical certificate stating no contraindications to work in the given position (Article 229(4)). We did not check statistics of penalties imposed by PIP.

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Employer liability for negligence

Whoever, being responsible for the state of occupational health and safety or managing employees or other natural persons, fails to comply with OSH rules or principles is liable to a fine of PLN 2,000 to PLN 60,000 (Article 283(1) of the Labour Code). The provision used to set a fine of PLN 1,000 to PLN 30,000, and you will still find that amount in many publications. In the current consolidated text the lower limit is PLN 2,000 and the upper limit PLN 60,000. The change was introduced by the Act of 11 March 2026 amending the Act on the National Labour Inspectorate and certain other acts (Journal of Laws 2026 item 473).

Instead of referring the case to court, a PIP inspector may impose a fine by way of a penalty ticket of up to PLN 5,000 (Article 96(1a)(1) of the Code of Procedure in Petty Offences), and for a person punished at least twice for an offence against employees' rights who commits one again within two years of the last punishment, up to PLN 10,000 (Article 96(1b)). A higher fine within the limits of Article 283(1) is imposed by a court. We did not check the appeal procedure for a penalty ticket or other sanctions, for example for a workplace accident.

Beyond fines, liability for the consequences of an accident matters. It is worth having liability insurance for physiotherapists, which protects against the financial consequences of such situations. We did not examine that thread (damages, accident insurance benefits) in this article.

Workstation ergonomics -- the practical minimum

Beyond the paperwork, it's worth genuinely taking care of working conditions:

• A treatment couch with electric height adjustment (reduces strain on the therapist's spine)
• A chair with lumbar support for reception staff
• Lighting at workstations compliant with regulations and standards (we do not give lux values because we did not check them)
• Ventilation and temperature compliant with regulations (not lower than 18 °C in work rooms where light physical work is done and in office rooms, § 30 of the regulation of 26 September 1997)
• A first-aid kit with up-to-date supplies

Frequently asked questions

As a sole practitioner, do I need to carry out a risk assessment?

No, if you work alone and don't employ anyone on an employment contract. The obligation arises the moment you hire your first employee. It's still worth knowing the hazards for your own safety, especially when working with electrical equipment and chemical products.

Who can prepare the occupational risk assessment?

The employer can do it themselves using a ready-made template, or commission an OSH specialist. The law doesn't require an external OSH specialist to carry it out -- what matters is that the document is reliable, signed, and updated after every significant change at the workstation.

How often should the risk assessment be updated?

The assessment is updated after every significant change: a new position, new equipment, a change in technology, or after a workplace accident. There's no fixed annual deadline, but in practice it's worth reviewing the document once a year so it's up to date in case of an inspection.

Does the National Labour Inspectorate announce inspections in advance?

It doesn't have to. Labour inspectors are entitled to inspect compliance with labour law, in particular the state of OSH, without notice and at any time of day or night (Article 24(1) of the Act on the National Labour Inspectorate). Common triggers are an employee complaint or a workplace accident, but we did not check inspection statistics. That's why it's worth keeping your OSH documentation in order on an ongoing basis, rather than only before a visit.

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Legal status as of: 3 November 2026

Legal basis: Act of 26 June 1974 - Labour Code (consolidated text Journal of Laws 2026 item 1245), Articles 226(1), 229(1), (2), (4), (4a) and (6), 283(1) and 304(1); Act of 24 August 2001 - Code of Procedure in Petty Offences (consolidated text Journal of Laws 2026 item 1336), Article 96(1a)(1) and (1b); Act of 11 March 2026 amending the Act on the National Labour Inspectorate and certain other acts (Journal of Laws 2026 item 473); Act of 13 April 2007 on the National Labour Inspectorate (consolidated text Journal of Laws 2024 item 1712), Article 24(1); regulation on occupational health and safety training (consolidated text Journal of Laws 2024 item 1327, amended by Journal of Laws 2025 item 1640), §§ 4, 10-12 and 15; regulation of 26 September 1997 on general occupational health and safety provisions (consolidated text Journal of Laws 2003 No. 169 item 1650), § 30. We did not check: the remaining provisions of that regulation (including the 2007-2021 amendments and lighting requirements), PN standards, the scope and dates of preventive examinations beyond Article 229 of the Labour Code, the rest of Article 304 et seq. of the Labour Code, workplace accident rules or the appeal procedure for a penalty ticket.

Last reviewed: 3 November 2026

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