Occupational Risk Assessment Template

You are hiring your first receptionist or a second physiotherapist on an employment contract. The contract is signed and the medical examination referrals are issued, but one document is missing from your binder, and the labour inspector will ask for it first: the occupational risk assessment. There is no official form you can simply print, so many practices put the topic off.

This article does not repeat the general overview of OSH (occupational health and safety), which you can find in the article on OSH in a physiotherapy practice. It is about the document itself: what the regulation says it must contain, what a sample card for a physiotherapist and a receptionist looks like, and how to keep it alive instead of letting it become a dead file.

Key points

• The duty to assess and document occupational risk rests with the employer, which includes a natural person who employs even one worker (Articles 3 and 226(1) of the Labour Code).
• The regulation (§ 39a of the Regulation on general OSH provisions) lists what the document must contain. It does not prescribe a template or a method of calculating risk.
• You prepare a card for each job position: description of the position, factors, assessment result, preventive measures, date and the people who carried out the assessment.
• The worker must be informed about the risk (Article 226(2)), and the employer consults the workers on the assessment (Article 237¹¹ᵃ).
• If you work alone, or only with B2B collaborators, the Labour Code works differently. Below we separate what follows from the provisions from what is our own interpretation.

Does a practice have to have an occupational risk assessment

Start with who you are under the Labour Code. A natural person is also an employer if they employ workers (Article 3). If you have at least one person on an employment contract, Article 226 applies: the employer assesses and documents the occupational risk connected with the work performed, applies the necessary preventive measures and informs workers about the risk and the rules of protection against hazards.

The duty does not depend on the size of the business. These provisions contain no employment threshold below which you can skip the assessment.

Three situations come up most often:

Situation	What follows from the provisions	What it means for the risk assessment
You work alone and employ nobody	You are not an employer within the meaning of Article 3	The Labour Code does not require a card. You can still use it as a checklist of your own hazards
You employ a worker on an employment contract	Article 226(1) and (2) apply	A card for each position is mandatory
You work with a physiotherapist on a B2B basis or take a student for a placement	Article 304(1)-(3) requires safe and hygienic working conditions also for people who are not employees, including students (paragraph 2)	Article 226 speaks of employees. A card is not directly required here, but it is a natural way to show that conditions were assessed and secured. This is our interpretation, not a provision

Student placements are a separate topic, covered in the article on a student intern at your practice.

What the risk assessment card contains

Under § 39a(3) of the Regulation on general OSH provisions, the document confirming the assessment should take into account, in particular, four things. Below is that requirement in a practical layout.

1. Description of the job position. Which machines, tools and materials are used, which tasks the worker performs, which hazardous, harmful and burdensome factors are present, what collective and individual protection measures are in place and who works at the position.
2. Assessment results for each factor of the working environment, together with the necessary preventive measures that reduce the risk.
3. The date of the assessment.
4. The people who carried out the assessment.

The assessment must cover all factors of the working environment and the ways work is performed, in particular when selecting workstation equipment, chemical substances and mixtures, materials containing biological agents, and when changing the organisation of work (§ 39a(1)).

In the provisions we read, we did not find a specific method of calculating risk or an official card template. That is why you can choose the simple three-level scale described below. What matters is that it is understandable and applied in the same way at every position.

Typical hazards for a physiotherapist and at reception

The list below is material to think through for your own practice, not a closed catalogue. If you use a laser or diathermy, or treat children, add your own items.

Physiotherapist:

• strain on the musculoskeletal system (working in a bent position, lifting and supporting the patient, prolonged pressure with the hands),
• biological agents (contact with patients' skin, secretions, reusable instruments),
• chemical agents (surface and hand disinfectants),
• electrical and equipment hazards (electrotherapy devices, ultrasound, lasers),
• slips and trips (cables, mat, wet floor after cleaning),
• psychological strain (working with a patient in pain, time pressure, difficult conversations).

Reception:

• work at a monitor (eyesight, body posture),
• contact with an aggressive or upset patient,
• carrying boxes of supplies and documents,
• contact with cleaning products, if reception cleans or refills dispensers.

For chemical agents, use the safety data sheets of the products you actually use. The regulation requires that instructions for work with hazardous substances and mixtures take into account the information in those sheets (§ 41(2)).

One novelty worth adding to your review plan: the amending regulation of 9 July 2026 (Journal of Laws 2026 item 927) adds § 30a on temperature in workrooms. It enters into force 6 months after publication, that is in January 2027. When the temperature in a workroom exceeds 28 °C because of the weather, the employer must provide technical or organisational solutions that limit its effect on workers' health. If your practice heats up in summer, that is a hazard to add to the card.

A template, step by step

Below is a sample card filled in for the physiotherapist position. Scale: L (low), M (medium), H (high). The risk levels shown are an example, not a model assessment of your practice. You assess your own conditions.

Step 1. Description of the position. Physiotherapist, 14 m² treatment room, one height-adjustable couch, an electrotherapy device, a surface disinfectant. Tasks: interview, examination, manual therapy, exercises, documenting the visit. One person works at the position. Personal protective equipment: disposable gloves.

Step 2. Hazards and assessment.

Factor	Hazard	Risk (example)	Preventive measures
Physical	Strain on the spine and wrists	M	Height-adjustable couch, breaks between visits, ergonomics instruction
Electrical	Electric shock from a damaged device cable	L	Device inspections according to the manufacturer's instructions, withdrawing damaged equipment from use
Biological	Contact with the patient's skin	L	Hand hygiene, gloves, couch disinfection between patients
Chemical	Skin or airway irritation from a disinfectant	L	Safety data sheet available in the practice, ventilation, gloves
Accident	Tripping over a cable	L	Routing cables along the wall, keeping the floor clear
Psychosocial	Stress, a difficult patient	M	Procedure for responding to aggression, right to refuse further service

Step 3. Date and people. The date of the assessment, the name of the person who carried it out and of the person who approved it (in a small practice often the same person).

Step 4. Informing the worker. The worker confirms with a signature and date that they have read the risk assessment for their position. This is how you meet Article 226(2).

For reception you prepare a separate card based on the same table, but with different factors (monitor, contact with patients, sedentary work).

Consultation, training and first aid

The risk assessment does not end with one document. A few related provisions:

• Consulting workers. Article 237¹¹ᵃ § 1(2) requires the employer to consult workers or their representatives on the occupational risk assessment and on the way of informing about that risk. In a small practice, a conversation with the employed person before the card is signed and a short note of their comments is enough.
• Training. The employer provides OSH training before the worker starts work and periodic training (Article 237³ § 2). An administrative and office worker may be exempt from periodic training under certain conditions, but not where the risk assessment shows that training is necessary (§ 2² and § 2⁴). This is one reason why the reception card is not a formality.
• The employer personally. The employer must complete training to the extent necessary to perform their duties and repeat it periodically (Article 237³ § 2¹). An employer with up to 10 employees who has completed the training needed to work in an OSH service may perform its tasks personally (Article 237¹¹ § 1(1)). In a small practice, you therefore do not have to hire an OSH specialist.
• First aid. Article 209¹ § 1 requires the employer to provide the means for giving first aid and to designate employees to give it. The scope is adjusted to the type of activity and the number of people.

Updating the card

The provisions we checked set no fixed review deadline. The regulation does, however, point to situations in which risk is assessed again, among others when the organisation of work changes and when workstation equipment is selected (§ 39a(1)). A good habit is to review the card again when:

• you buy a new device or change a disinfectant,
• you change the layout of the room or the number of workstations,
• a person joins the team in a new position,
• an accident or a near-accident has occurred,
• a new provision enters into force, like the § 30a on temperature mentioned above.

Write the date of every update on the card. The old version stays in the file, the new one gets a new date.

The most common mistakes in a PIP inspection

We describe an inspection by the National Labour Inspectorate (Państwowa Inspekcja Pracy, PIP) in a separate article on a PIP inspection at a physiotherapy practice. Here are only the mistakes connected with the card itself:

• One card for everyone. Reception and the physiotherapist face different hazards. The document must describe the position (§ 39a(3)(1)).
• A card without a date and without the people who assessed. These are two of the elements the provision lists.
• Copying someone else's template without adapting it. If the card lists a device you do not have, or omits a laser you do have, nobody takes it seriously.
• No confirmation that the worker has read it. Informing about the risk (Article 226(2)) should leave a trace in the documents.
• An assessment done once and never changed, despite new devices and new people in the team.

For breaching OSH provisions, Article 283 § 1 of the Labour Code provides a fine of PLN 2,000 to PLN 60,000 for the person responsible for the state of OSH. We did not check how the authorities apply this provision to a missing risk assessment, so we do not give a typical penalty.

Hiring your first employee and putting the papers in order? See also hiring a physiotherapist and the documents and onboarding a new person at your practice.

Frequently asked questions

Do I have to do an occupational risk assessment if I work alone?

The Labour Code puts the duty to assess risk on the employer, and an employer is someone who employs workers (Articles 3 and 226). If you employ nobody on an employment contract, the duty does not follow from these provisions. Writing down the hazards at your own workstation still makes sense as a checklist.

Does the risk assessment card have an official template?

In the provisions we read (the Labour Code and the Regulation on general OSH provisions), we did not find an official form. The regulation only specifies what the document must contain (§ 39a(3)). You choose the table layout and the risk scale yourself.

Can the practice owner prepare the assessment personally?

The provisions do not require an external specialist to carry out the assessment. An employer with up to 10 employees who has completed the relevant training may perform the tasks of the OSH service personally (Article 237¹¹ § 1(1)). Make sure the card names the people who carried out the assessment.

What about a physiotherapist collaborating on a B2B basis?

Article 304(1) and (3) requires safe and hygienic working conditions for people who perform work on a basis other than an employment relationship at your establishment. The Labour Code does not speak directly about a risk assessment for such people. It is sensible to cover them with the same position card and to state this in the contract.

How often should the card be updated?

The provisions we checked give no fixed deadline. Update it at every significant change: new equipment, different organisation of work, a new position, an accident. Write the date of every update.

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Legal status as of: 2 November 2026

Legal basis: Act of 26 June 1974, the Labour Code (consolidated text Journal of Laws 2026 item 1245), Articles 3, 207, 209¹, 226, 237³, 237¹¹, 237¹¹ᵃ, 283 § 1 and 304; Regulation of the Minister of Labour and Social Policy of 26 September 1997 on general occupational health and safety provisions (consolidated text Journal of Laws 2003 item 1650, as amended, among others, by Journal of Laws 2007 item 330 and Journal of Laws 2021 item 2088), § 39a and § 41(2); amending regulation of 9 July 2026 (Journal of Laws 2026 item 927), § 30a (enters into force 6 months after publication). We did not check: Polish Standards on risk assessment methods, provisions on biological and chemical agents in the working environment, provisions on preventive medical examinations, fire safety provisions, or case law and PIP practice on penalties for a missing risk assessment.

Last reviewed: 2 November 2026

You have the template in this article. The rest of your practice's documentation, that is the patient record, therapy plan, treatment log and treatment consent, is organised by the TARCZA package. See the TARCZA package or compare all packages.

Related articles:
- OSH in a physiotherapy practice - occupational risk assessment
- A PIP inspection at a physiotherapy practice
- Hiring a physiotherapist: contract and qualifications
- Onboarding at a physiotherapy practice: documents