Dying to start work

poses particular hazards for young people, but many employers seem oblivious to
the specific dangers their younger employees face. Are we doing enough to
educate youngsters about health and safety at this crucial point of their
working lives?  By Linda Maynard

seems work is still a risky business for the young. Health and Safety Executive
reported figures for 2000 show six under-19s were killed during work-related
activities, 1,551 young people sustained major injuries and 5,310 were off work
for over three days because of a work-related illness or injury1.

well as a general legal responsibility to provide risk assessment, taking
account of lack of experience and maturity, employers would appear to be
missing the opportunity to educate and train young people about health and
safety at the beginning of their working lives.

backed by the Trades Union Congress in 2002 showed 37 per cent of a poll of 355
workers aged 15-to-24 years had not had any health and safety training, even
though they are legally required to receive it. A further independent study
entitled Dying to Start Work, commissioned by the insurer Norwich Union, claims
four in five businesses are failing to carry out the correct health and safety
procedures for the under 18s3.

are the legal obligations?

specific legal requirement, initially introduced by the Health and Safety
(Young Persons) Regulations, has recently been incorporated within the
Management of Health and Safety Regulations 19994. Young workers are defined as
anyone under 18 years.

law concerning working time uses a slightly different definition. This
legislation defines a young worker as below 18 years of age and above the
minimum school leaving age – which may be just before or just after their 16th
birthday. Children below the MSLA must not be employed in industry such as
factories or construction sites except when on approved work experience, and
children under 13 years are generally restricted from doing any kind of work.

13 of the MHSWR states that employers should pay particular attention to the
needs of young workers when carrying out risk assessments and reviews to help
determine the level of training and competence needed for safe working. A basic
health and safety induction should be provided, which includes information on
the company’s health and safety policies and an outline of the arrangements for
first aid and fire/evacuation procedures. Regulation 19 describes the need to
carry out a risk assessment before employing a young person. The particular
areas to pay attention to are listed in Table 1.

updated HSE guidance Young People at Work HSG 165 for employers was published
in January 20015. It explains employers’ duties as well as information
concerning specific hazards, risks and ways of avoiding them – the hazard
groupings are listed in Table 2. Other relevant legislation concerning hazards
is also detailed in the annex.

Working Time Regulations 19986 and 19997 have some additional provisions that
apply to young workers. These rights translate to:

Four weeks paid holiday a year

Minimum 30 minute rest break when the working day is more than four-and-a-half

A rest period of 12 hours every working day

A rest period of 48 hours once every seven days

A ceiling of 48 hours on the maximum average working week

A ceiling of an average of eight hours night work in every 24 hours

A free health and capacities assessment for young night workers (this differs
from a health assessment as it should take into account areas such as physique,
maturity, experience and competence to undertake night work, complementing
regulation 3 of the MHSWR)

Department of Trade and Industry is currently consulting on proposals to amend
the ending of the UK opt-outs from certain provisions of the European Directive
on the Protection of Young People at Work (the Young Workers Directive).
Proposals would prohibit under-18s from working at night between midnight and
4am. The Directive allows some exceptions, for example, the armed forces,
police and hospitals. Further exceptions are proposed in "specific areas
of activity" for night work between 10pm and 6am or between 11pm or 7am.
The changes would also limit a young person to working eight hours a day and 40
hours a week with some possible exemptions. No averaging hours over the usual
17-week reference period or provision for individual opt-out to these changes
is proposed.

consultation paper also asks if existing health and safety legislation should
be integrated with guidance on working time provision to cover areas such as
safety when young persons are travelling to work at night8.

role of occupational health

health specialists can start to help managers meet their health and safety
legal obligations by advising on the relevant policies and systems. Those
already in place may need to be audited to check they meet the requirements of
young workers.

companies, in complying with other health and safety law, will already have
carried out risk assessments to identify hazards and taken measures to control
or eliminate risks. But have young workers been remembered? General risk
assessment information will establish a base for determining whether the
employment of young people should be restricted or refused. A review of the
accident and incident statistics may also reveal a problem in this group as
well as help identify hazards.

will need advice on any pre-placement health considerations – advising if young
workers are physically strong enough to operate machinery designed for adults,
for example, or assessing fitness for night work.

possible restrictions outlined in Table 1, which may have significant risks, do
not apply if the young workers are in training. Jobs such as Modern
Apprenticeships, where proper supervision from a competent person and risk
reduction has been undertaken, are excluded.

HSE advises that generic risk assessments can be developed and modified as
required, particularly if the work is temporary or transient. As for all
workers, young people should be informed of risks identified in any assessment.
This includes informing the parents or guardians of work experience students.

positive approach

training and supervision has led to many documented cases of accidents
involving young workers, some of which have led to death as a result of  injuries sustained. For example, cases such
as a young male aged 18 years, working as a steel erector, who, through
inadequate supervision, sustained a fractured foot after falling from a beam,
or an 18-year-old warehouseman who died from head injuries after driving a
forklift truck at speed. Again, inadequate supervision was found to be a reason
for the accident.

case involved an 18-year-old who sustained serious burns after being exposed to
molten metal. Among other reasons for the accident was inadequate training9.
Training is needed when starting the job as well as effective supervision by
competent people to monitor the young person’s competence, attitudes and capability.

people should be involved in the risk assessment process as well as in the
planning and development of health and safety training programmes. By
demonstrating good practice supervisors and employers can ensure the key
messages are being reinforced and that awareness is being raised. Mentoring
programmes are used in some organisations so that a mentor is available for
guidance and when problems occur. Equally, a questioning approach to urge young
people to think about what they are doing should be encouraged.

approaches to health and safety training which use educational resources young
people are familiar with can help to inform and instruct. Internet information
aimed specifically at young workers has been created by external organisations
such as the TUC, the Department for Education and Employment, and a joint site
set up by the Royal Society for the Prevention of Accidents and Norwich Union,
together with useful publications and videos. Larger companies with intranet
facilities may wish to follow this example and consult with young workers in
establishing a computer health and safety resource that uses language which
young people can engage with.

young people

good news is that health and safety is now being covered in parts of the
National Curriculum. Under the government document Revitalising Health and
Safety10, this has been extended to include coverage of risk concepts and
health and safety skills (from September 2000 in England and August 2000 in

health professionals may be involved with delivering this message in schools
and colleges, especially if there is participation in local projects such as
Health Action Zones launched to target areas of high health inequality. Indeed,
this may be an excellent opportunity to reach young people who through economic
circumstances, are often forced into low paid hazardous work, usually without
any occupational health provision.

reality is many younger school children do carry out paid work during term time
as well as during the summer holidays. Further TUC research, Class Struggles,
published in March 2000, shows one in 10 children admitted playing truant in
order to do paid work.

a quarter of those surveyed worked before 6am. These are jobs such as
baby-sitting, paper rounds, cleaning or working in a shop11.  Educating children about health and safety
in schools will increase awareness of the risks encountered in all kinds of
employment no matter how "light" or small.


health professionals need to continue to raise employers’ awareness of the
issues surrounding young people in the workplace. This means looking beyond
establishing effective health and safety procedures for the new school or
college leaver and remembering those students who attend for work experience.
Under the Health and Safety (Training for Employment) Regulations 1990,
students on work experience are regarded as the placement providers’ employees
for the purposes of health and safety, and measures to control risk equally

Peter Graham, Head of the HSE’s Strategy and Analytical Support Directorate
said, when launching the HSE guidance on young people at work, "Starting
work should be a time of considerable excitement and opportunity for young
people, but they also face unfamiliar risks from the job they will be doing and
from the working environment…Bosses also have a responsibility to give young
people a firm grounding in health and safety which will serve them well
throughout their working lives."


HSE (2001) Press Release E002:01 – 16.

Trades Union Congress (2000) Train me. Hazards, 71: 22-23.

Norwich Union (2000) Dying to Start Work. Occupational Safety and Health, 30
(10): 4.

HSE (1999) Management of Health and Safety at Work Regulations: Approved Code
of Practice. L21. HSE Books, ISBN 0 7176 2488 9.

HSE (2000) Young People at Work – a guide for employers. HSG 165. HSE Books ISBN
0 7176 1889 7.

Working Time Regulations (1998) SI 998/1833. The Stationery Office ISBN 0 11 079410

Working Time Regulations (1999) SI 1999/3372. The Stationery Office ISBN 0 11
085698 8.

Department of Trade and Industry website: www.dti.gov.uk/er

Joint Norwich Union/RoSPA website: www.young-worker.co.uk

DETR,HSC,HSE (2000) Revitalising Health and Safety. HSE Website

TUC (2001) Class Struggles.

for attention

employing a young person, consider whether the work is:

Beyond his or her physical or psychological capacity

Involves harmful exposure to agents affecting human health

Involves harmful exposure to radiation

Involves risks of accidents which young people may not recognise

Involves risk to health from extreme heat or cold, noise or vibration


Awkward postures, repetitive movement, excessive physical loads
– Machine-paced work paid by results
– Psychological capacity (coping ability, crisis management)
– Extreme heat or cold
– Noise
– Hand/arm vibration
– Whole-body vibration
– Ionising/non-ionising radiation
– High pressure atmospheres
– Biological agents
– Chemical agents
– Flammable liquids/gases
– Gas cylinders
– Large vessels containing chemical agents
– Structures liable to collapse
– High voltage electricity
– Explosives
– Fierce or poisonous animals
– Industrial scale animal slaughter

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