X Supplier Guidance on

Preventing, Identifying and

Addressing Child Labour
Supplier guidance on
preventing, identifying and
addressing child labour

International Labour Organization

 Copyright © International Labour Organization 2020
First published 2020
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FUNDAMENTALS
Supplier guidance on preventing, identifying and addressing child labour / International Labour
Organization, Fundamental Principles and Rights at Work Branch (FUNDAMENTALS), Geneva: ILO, 2020.

ISBN: 978-92-2-032195-9 (Print); 978-92-2-032194-2 (Web PDF)

International Labour Organization; Fundamental Principles and Rights at Work Branch

Acknowledgements
This publication was elaborated by CCR CSR HK LIMITED, Contractor, for FUNDAMENTALS and coordinated
by Mr Benjamin Smith and Ms Kassiyet Tulegenova from FUNDAMENTALS Geneva Office and has benefited
from valuable contributions from Mr Andrew Christian of LABADMIN/OSH and Ms Anne Ziebarth of
BETTERWORK.
The ILO Child Labour Platform (CLP) supported consultations with businesses for the development of the
Supplier Guidance.
This publication was elaborated under the framework of the “Project to strengthen policies and programmes
to prevent and remediate child labour in the Primark apparel supply chain” (GLO/14/35/PRI) funded by
Primark Stores Limited.

The designations employed in ILO publications, which are in conformity with United Nations practice,
and the presentation of material therein do not imply the expression of any opinion whatsoever on the
part of the International Labour Office concerning the legal status of any country, area or territory or of
its authorities, or concerning the delimitation of its frontiers.
The responsibility for opinions expressed in signed articles, studies and other contributions rests solely
with their authors, and publication does not constitute an endorsement by the International Labour
Office of the opinions expressed in them.
Reference to names of firms and commercial products and processes does not imply their endorsement
by the International Labour Office, and any failure to mention a particular firm, commercial product or
process is not a sign of disapproval.
Information on ILO publications and digital products can be found at: www.ilo.org/publns.

Visit our website: www.ilo.org/childlabour

Cover photo © Center for Child Rights and Corporate Social Responsibility (CCR CSR).
Printed in Switzerland
Photocomposed by Bip-Bip, Switzerland
Caption for photo cover
Contents
Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.1 W
 hy a supplier guideline to prevent, identify and address child labour and
provide protection for young workers?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.2 Key terms. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
1.3 Key elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
1.4 Guiding Principles.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Child labour prevention. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

2.1 The basics.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2.2 Steps to verify age . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Management of young workers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

3.1 Establishing special protective measures for young workers. . . . . . . . . . . . . . . . . . . . . . . 13
3.2 I dentifying hazardous work and conducting risk assessment for young workers. . . . 15
3.3 Create a low risk environment for young workers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Child labour remediation.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

4.1 What should you do when a young worker (above the minimum working age
but under 18) is engaged in hazardous work?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
4.2 W
 hat should you do when a child below the general minimum age
for work is found at the production facility? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Annexes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
Annex I. Checklist for factory self-assessment on employment policy and
procedures related to child labour and management of young workers
(above the minimum age but under 18). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
Annex II. Good practices for age verification. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
Annex III. Information included in a valid contract for young workers. . . . . . . . . . . . . . . . . . . . 30
Annex IV. Working hour regulations for young workers in key supplying countries. . . . . . . 31
Annex V. Information included in a valid contract for young workers. . . . . . . . . . . . . . . . . . . . 32
Annex VI. Worker interview guide for occupational safety & health hazards
identification. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Annex VII. Types of hazards in the garment and textile industry . . . . . . . . . . . . . . . . . . . . . . . . . . 35
Annex VIII. Hazardous work list for young workers regulated by the local laws in key
supplying countries. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
Annex IX. Basic hazardous risk assessment for young worker and action plan. . . . . . . . . . . . 40
Annex X. Identification of low risk work tasks and processes that are suitable
for young workers .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
Annex XI. Long-term best practice to prevent potential harm to young workers. . . . . . . . . . 43
Annex XII. Child labour notification form. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
iv Supplier guidance on preventing, identifying and addressing child labour

© ILO/Crozet, M.
 1

I.

Introduction
1.1 Why a supplier guideline to prevent, identify and
address child labour and provide protection for
young workers?

Child labour harms children’s mental and physical development.

It also harms business and can lead to legal sanctions, a loss
of productivity, disruptions in production, and lost orders.
It has no place in a modern, competitive and sustainable
garment industry. This document provides practical guidance
for factories and other production sites to prevent child labour
through effective age verification and the protection of young
workers, and to effectively respond to it if it does occur.
2 Child labour in tier III of the apparel and footwear industry

1.2 Key terms

The key terms used in this Guidance include:

Child The International Labour Organization (ILO) Worst Forms of Child

Labour Convention (No. 182) defines a child as all persons under
the age of 18

Child labour ILO defines child labour as work that deprives children of their
childhood, their potential and their dignity, and that is harmful to
physical and mental development. Child labour refers to one or
more of the following:
1) Work done by a child who is under the minimum age of
admission to employment for the type of work concerned;
2) W
 ork that interferes with compulsory education:
3) W
 ork that is likely to jeopardize a child’s health, safety or morals,
known as hazardous work;
4) O
 ther “worst forms of child labour” besides hazardous work.

Young worker For the purposes of this guidance, “young worker” refers to a
person who has reached the minimum legal working age, usually
15, but is under 18 years old (still a child).

Child labour Corrective measures taken to remove a child from child labour by
remediation providing alternatives and ensuring their safety and wellbeing.
 I. Introduction 3

1.3 Key elements

Child labour is a violation of fundamental human rights. According to international standards, work
must not be performed by anyone under the minimum working age (usually 15 or higher if stipulated by
national law).1 ‘Work’ refers to any work at your company, including work done under apprenticeships,
or training and work/study schemes; it includes contractual, temporary or casual work, as well as on-site
subcontracted work (waste, catering, delivery, cleaning, building works, etc.). This guidance applies to all
production sites, including lower tier suppliers (e.g., material suppliers and subcontractors).

X 1. Child labour prevention

Clearly state the minimum ages Hiring procedures and processes

for general work and hazardous must include a robust age
work in your hiring policy and job verification mechanism, which
announcements. includes checking ID documents
and in-person interviews.

See See
section section
2.1 2.2

Medical examinations are not an Risks linked to increases in

appropriate means of verifying age demand, recruitment agencies,
subcontractors and service
providers must be managed.

See
section
2.2

1 ILO Convention No. 138 sets a general minimum working age of 15, however it states that a country “…whose economy and educational
facilities are insufficiently developed may, after consultation with the organizations of employers and workers concerned, where such exist,
initially specify a minimum age of 14 years.” Some countries, however, have set a minimum age of 16 years.
4 Supplier guidance on preventing, identifying and addressing child labour

X 2. Create a non-discrimitory but protective workplace for young workers

Definition: young workers are children above the legal minimum age for work and under 18.

Special management measures on Make sure they are subject to

contracting: Young workers need strong OSH protection and never
contracts just like adult ones, but do hazardous work. To ensure this,
theirs should specifically mention create a system to identify hazards
the extra protections applying to and assess risks for young workers.
them.
See See
section section
3.1.1 3.2

Working hours: As a rule of thumb, Create a low-risk environment for

young workers should not work young workers by:
overtime or nightshifts.
X 1. Identifying low-risk jobs
X 2
 . Creating a list of low-risk tasks
See & processes, consistent with
section
3.1.2 local law
X 3
 . Through long-term measures,
reducing the risk levels of more
Take young workers’ needs positions to create more options
into account when setting for youth
up your onboarding and X 4
 . Continuously raising
orientation training, and in your awareness of factory
communication. management and young
See See workers on how to create a safe
section
section
3.3
workplace for young workers.
3.1.3
 I. Introduction 5

X 3. Child labour remediation (after identifying child labour)

If a child or young worker is When a young worker (above When a child below the
found to be in child labour, the minimum working age minimum age for work is
seek together with your but under 18) is engaged found at the production
buyers, and ideally an expert in hazardous work, the facility, the following actions
organization, solutions that following actions should be should be taken:
are in the best interests of taken:
1. Immediate actions,
the child or young worker
1. Job re-allocation including taking the child to
concerned.
a safe place
2. Health check
3. Training for the young 2. Providing a living stipend
worker 3. Enrolling him/her in a
suitable educational/
vocational

See See
section section
4.1 4.2

1.4 Guiding Principles

Preventing child labour and ensuring special protection for young workers under 18 is not always an
easy task and might not always follow the same pattern. Therefore, it is really important that you
follow the following set of principles, which will always apply no matter the case:

1. Always apply the stricter law: 2. Protect—but do not discriminate against—

e.g., in a case where international standards young workers:
differ from the local law, always operate suppliers should protect young workers who
based on the higher standards/stricter laws have reached the minimum working age, but
which provide a higher level of protection (for not exclude them from access to safe work.
instance, if the local minimum age to work is Young workers should never be involved in
set at 16, and the international standard is 15, tasks that are included in “hazardous work
you will have to apply the stricter of the two – lists” in national law.
that is 16!).

3. Children have a right to be heard: 4. All interventions are aimed at positively

children’s opinion should be taken into impacting the child and his/her family:
consideration in any decisions that concern our main concern should be to act in the best
them. interest of the children and to protect the
privacy of the children and their families.
6 Supplier guidance on preventing, identifying and addressing child labour

© Center for Child Rights and Corporate Social Responsibility (CCR CSR).
 II. Child labour prevention 7

II.

Child labour prevention

Making age verification a central part of a clear employment policy, as well as
managing the risk associated with recruitment agencies and subcontracting
play a vital role in the prevention of child labour.2

2.1 The basics

Clearly state the minimum age Recruitment and hiring should

for general work and hazardous follow standardized procedures
work in your hiring policy and job and include a robust age
announcements, e.g., “in order to verification mechanism. Ensure that
work at our company, you need to be recruitment and hiring, including
a minimum of 15 years old for general age verification, is handled by the
positions and a minimum of 18 years appropriate department (e.g., the
to perform hazardous work”. Make human resources or personnel
sure the minimum ages comply with department), by people trained to
international or national legislation do so. Recruitment and hiring should
(whichever provides greater not be managed informally, e.g., by
protection). a security guard, line supervisor, or
through family members.

Medical examinations are not an Manage the risk of child labour

appropriate means of verifying age. linked with any rapid increases in
Accuracy cannot be guaranteed, and demand for labour or the use of
an examination may cause a child labour agents, subcontractors and
unnecessary stress and violate his or service providers.
her right to privacy.4
8 Supplier guidance on preventing, identifying and addressing child labour

2.2 Steps to verify age

2.2.1 Pre-recruitment

Make sure your job announcements contain the following information:

X Expected education level
If the advertised
X Skills & experience required position is hazardous
X Minimum working age (e.g., requires
handling heavy
machinery);
you should indicate
Means of verifying age:
this and set the
X I ndicate that all applicants must present government-issued identification minimum working
documents to prove their age and identity; job announcements, application age at 18. However,
forms and notices at the facility should state that applicants with false or setting a minimum
invalid documents will not be considered or hired. age of 18 for non-
hazardous work may
be discriminatory
and should be
avoided.

2.2.2 During recruitment

Thoroughly check (and cross-check) original proof of age documents.

Use the following steps:
In countries where
If a reliable ID card is available:
a national identity
X M
 ake sure the photo and identity mark on the submitted documents match card is not available,
the appearance of the applicant. require applicants
to present two
X M
 ake sure the signature on the national ID card matches the applicant’s documents to
signature. verify their age;
X Check that the original seal between the photo and card is intact. examples include:
a birth certificate,
X T
 he date of issue should broadly tally with the condition of the card. It is household registry
suspicious if a card issued many years ago looks brand new. (family book), driver’s
license, right to vote
card, work permit,
If no ID card is available: or school testimony.
At least one of these
X E
 stablish the most reliable form of documentation in your country and documents must
request a minimum of two forms, such as a birth certificate, household contain a photo ID.
registry (family book), driver’s license, right to vote card, or work permit.
 II. Child labour prevention 9

Additional elements to consider:

X Certain
 countries require that a government agency3 (e.g., the Ministry
of Labour) be informed when a young worker is recruited.
X I f you suspect forged documents or are presented with a temporary
Note: When
identification card, check the document’s validity with local government
interviewing young
applicants, age offices and request other forms of ID.
verification must X C
 onduct in-person interviews with all applicants. At the interview,
not be based on applicants can be asked questions such as where their documents were
socially or culturally issued, where their father was born, or their date of birth. This information
constructed ideas of
can then be cross-checked with the card.
what an adolescent
should look like, or X E
 nsure that once the identity check has been completed the originals are
how they should immediately returned to the applicants.
behave or respond to
particular situations, X I f insufficient or suspicious ID is presented, support the applicant to
as children’s physical procure proper documents (e.g., by providing information on where/how
development varies they can apply for proper identification documents).
owing to factors
including diet, access
to health care, living
and environmental
conditions and
genes. Behaviour
also varies 2.2.3 After recruitment
according to cultural
backgrounds and Age verification does not stop with recruitment of staff. You should also
expectations. implement the following measures on an ongoing basis:
 repare and maintain a register4 of all workers’ application documents
X P
and records of employment, including daily workers, temporary workers,
young workers and interns/apprentices or student workers. This should
include at a minimum:
• a valid labour contract;
• a copy of the worker’s ID card;
• a recent photo (taken within the past 6 months);
• date of employment;
• main task(s)/position;
• work schedule; and
• manager’s name.
X R
 ecords of non-national employees must include records confirming their
legal status and working permit.
X Provide all of your employees with a facility-issued photo ID.
X A
 face scanning attendance system or fingerprint identification attendance
system reduces the risk of persons assuming the identity of workers in the
facility.

3 The labour laws of China, Thailand and Singapore, for example, stipulate that employers are required to
inform the Ministry of Labour before young workers begin to work.
4 In compliance with ILO C138, suppliers shall have an official list or documents that contain the names and
ages or dates of birth, duly certified wherever possible of the workers who are below 18 years old and the list
shall be available to competent authorities.
10 Supplier guidance on preventing, identifying and addressing child labour

2.2.4 Managing risk factors

During peak seasons or labour shortages, when large numbers of workers are
in demand, proper hiring processes and age verification may be neglected.
Moreover, the use of labour agents, subcontractors and service providers Do all of this BEFORE
may also increase the risk of child labour. Below are a few measures to help you are in urgent
you to manage this situation. need of more
X Ensure all your business partners are formally registered businesses. employees,
as you won’t have
X I nclude a child labour policy and procedure for prevention and remediation time when hiring
in contracts with subcontractors and service providers. becomes urgent!
X U
 pdate and maintain a subcontractors list. Regularly collect updated
information such as size of facility, production capacity and number of
workers.
X A
 void placing orders that exceed production capacity, taking into
consideration orders placed by other customers.
X K
 eep a record of workers hired by service providers as well as the relevant
documents.
X I f you engage labour recruiters, use only reputable companies that comply
with all relevant laws.
X V
 erify the documents and interview workers in your facilities, even when
you have not directly hired the workers. For your buyers, it will NOT make
a difference if the workers in your facilities are directly hired by you or
by a labour agent. This applies to any person working in your facilities
and includes situations in which you outsource production lines, waste
management, canteen services, security, dorm services etc.
X N
 o recruitment fees or related costs should be charged to workers or
jobseekers.
© Center for Child Rights and Corporate Social Responsibility (CCR CSR).
 III. Management of young workers 13

III.

Management of young
workers
Young workers below the age of 18 require special protection, but they are also valuable
employees who form the basis of your company’s future.
You should have systems in place to ensure a non-discriminatory but protective workplace
for young workers, in which their occupational safety and health (OSH) is ensured. This
includes implementing specific measures on contracting, working hours, onboarding
and orientation, communication and ongoing OSH protection specifically aimed at young
workers (see section 3.1). A system to identify hazards and assess risks (section 3.2)
is essential in order to create a safe working environment for young workers (see section 3.3).

3.1 Establishing special protective measures

for young workers

Adolescence is a time of dramatic physical and mental change and huge developmental strides.
Young workers therefore need special protection at the workplace. Some of the reasons for
this are:
X Y
 oung workers need more oxygen. They breathe in more air (and therefore any toxic
substances/pollutants and airborne diseases that may be present) relative to fully-grown
adults.
X T
 hey face health risks when assigned tasks beyond their physical capabilities, which
can lead to developmental problems and injuries. They are generally eager to please,
lack experience and their judgement is still in the process of developing. Without training
they may be more prone to taking risks.
X T
 hey need more sleep than adults. Quantity and quality of sleep directly affects young
people’s cognitive development. They must not work long hours, while work and study
programmes and vocational training must leave them time for enough sleep.
14 Supplier guidance on preventing, identifying and addressing child labour

3.1.1 Hiring young workers

As outlined in section 2.2, robust systems for age verification are key. Once you have
established that the applicant is of working age but under 18, take the following steps:
X E
 nsure the young worker has a valid contract just like an adult worker. It should include
standard terms of remuneration and benefits but also special protections related to
safety and health, working hours, rest time and leave, etc. See Annex III for a detailed list
of contract conditions.
X E
 nsure that all young workers fully understand the terms and conditions of their
contracts. The contract should be in a language understood by the worker.

3.1.2 Working hours

Many countries have specific working hour regulations for young workers (see Annex IV).
Unless your country’s regulations are stricter, you should respect the following guidelines:
X N
 o night work for young workers (night work may be allowed as of 16 if necessary, for
learning purposes during an apprenticeship, if such apprenticeship is approved by the
competent government authority, the apprentice receives training and is allowed at least
13 hours’ rest between shifts. Of course, the work must not be otherwise hazardous).
X No overtime.
X At least 12 consecutive hours of night rest each day.
X I f the young worker is still in compulsory education, their work must not interfere with
their school attendance nor the ability to study.

3.1.3 The first day of work for young workers: Orientation and occupational
safety & health training

Arrange an orientation and OSH training for all young workers before they begin
work, which includes a review of all key terms of employment (contract, hours, factory
regulations). Small group training, with interactive sessions and hands-on practice help
ensure full understanding of your factory’s OSH policies and regulations. Training should
include:
X A
 clear message to ensure young workers understand the importance of safety in the
workplace.
X A ‘walk and talk’ safety tour for young workers highlighting particular safety concerns.
X R
 eview of legal requirements for the protection of young workers, e.g., regular health
examination, working hours and types of work, processes or positions they CAN and
CANNOT do.
X E
 xplanation of existing OSH risk control measures, e.g., signage for hazards, and
resources available to support the health and safety of young workers.
X E
 xplanation of procedures for reporting workplace hazards/dangerous situations and
the follow-up steps to be taken to eliminate reported hazards.
X Explanation of procedures for evacuation in case of an emergency.
 III. Management of young workers 15

3.1.4 Ongoing protection during employment

Receiving feedback, concerns, complaints, suggestions and questions from

young workers is a good way to identify real or potential risks and hazards and
What are the to ensure workers are protected. An effective grievance system accessible to
elements for an young workers is essential in this regard.
effective grievance
system? Trade unions can provide a valuable channel for relaying feedback and grievances,
anonymously and without fear of reprisal. In addition, if not already in place,
Find out in
consider establishing an OSH Committee involving workers and management.
Annex V
Other channels may include accessible welfare officers, anonymous suggestion
boxes, hotlines, and web-based platforms (such as email, SMS, app, online surveys)
that are easily accessible to workers.

3.2 Identifying hazardous work and conducting risk

assessment for young workers

A sound OSH system identifies hazards associated with the tasks and processes in
which young workers are engaged, and estimates how likely it is that the hazard
will cause them harm. This process is essential to managing risk and keeping young
workers safe.

3.2.1 Identify hazardous work tasks and processes

and necessary protection measures

You should have Production observation

a detailed list of
all work tasks Walk through facilities with your key staff (production managers, HR, supervisors,
and processes. compliance & OSH experts) to identify hazardous tasks and processes, bearing
Ensure that this in mind national law and international labour standards.
list distinguishes
between similar tasks
and processes that Make sure the walk-through considers:
are found at different X A
 ctivities of all persons having access to the workplace (including contractors
workplaces. This is and visitors) including processing, materials storage, finished products, public
important because,
areas, offices, visiting areas and transport vehicles.
for example, a task
that is not in itself X I nfrastructure, equipment and materials at the workplace, whether provided
hazardous could by the factory or others.
become hazardous
if located in an area X T
 he design of work areas, processes, installations, machinery/equipment,
with high levels of operating procedures and work organization.
dust, noise, heat or X Planned and temporary work.
chemical usage.
X L
 ong-term hazards (e.g., high levels of noise or exposure to harmful
substances).
X Psychosocial hazards such as harassment.
16 Supplier guidance on preventing, identifying and addressing child labour

Manufacturers’ instructions
Check manufacturers’ instructions for equipment and safety data sheets
(SDS) for chemicals, as they can be very helpful in identifying hazards.

To obtain safety
information
about chemicals,
Worker and expert interviews
suppliers can check
Talk to workers, young workers and their representatives to obtain first-hand the International
experiences about the risks and hazards of different jobs. Workers may have Chemical Safety
noticed hazards that are not immediately obvious. Speak to OSH experts who Cards, which are data
have experience in the garment industry. sheets developed
by ILO to provide
Conduct individual or group interviews with workers, young workers and safety and health
their representatives. Prepare questions before the interviews to explore information on
potential risks and hazards (see Annex VI). chemicals:
https://www.ilo.
org/safework/
info/publications/
WCMS_113134/
Review previous accident reports
lang--en/index.htm
Reports on accidents and work-related ill health can help identify less obvious
hazards. For reference, Annex VII provides a detailed list of common hazards in
the garment and textile industry.
 III. Management of young workers 17

3.2.2 Risk assessment for identified hazards

After hazards have been identified, assess the risk arising from them (a risk assessment). Risk is defined
as “a combination of the likelihood of an occurrence of a hazardous event (probability) and the severity
of injury or damage to the health of people caused by this event (severity)”. Risk assessments will enable
you to assign a risk level (low to high) to individual tasks and processes, and take preventive action.
Firstly, the probability of the harm is estimated by rating it as “Likely”, “Possible” or “Unlikely”.

X Probability X Frequency of an event

Likely Could happen frequently

Possible Could happen occasionally
Unlikely May occur in exceptional circumstances

Please note: If there is any injury or accident mentioned in accident reports, the rating should be “likely”.

Secondly, the degree of impact that may be caused by the harm is estimated by rating it as “High”,
“Moderate” and “Low”.

X Severity of harm X Type of potential harm event (incident)

HIGH A high potential of causing fatality, permanent disability

Significant level of harm or long-term and serious injury.

MODERATE Potential to cause serious but non-life-threatening injuries

Moderate level of harm or temporary disability, that may require the worker to
take time off for recovery. A broken arm or minor fracture
is an example of a moderate injury.

LOW Very low potential of injury or illness that will not require
Minor level of harm a person to use first aid, or to temporarily suspend their
work involvement.

And then the risk can be assessed as “High”, “Medium” or “Low”, according to the combination of
severity and probability.

Level of risk = severity of harm x probability of harm

Severity

Low Moderate High

Likely Medium High High

Probability

Possible Medium Medium High

Unlikely Low Medium Medium

18 Supplier guidance on preventing, identifying and addressing child labour

3.3 Create a low risk environment for young workers

3.3.1 Immediate actions after risk assessment

Immediate follow-up actions should be taken to manage the identified risks.

Actions and risk controls Appropriate for
Level of risk (for all workers) young workers

Remove young worker from the task/position immediately X

and initiate child labour remediation processes. Assess if the Tasks and
right safety precautions are in place: processes
labelled as
Require detailed pre-planning and substantial safe work
High risk HIGH RISK
controls.
should never
Enhanced risk controls will be required. Closely monitor be assigned to
progress & compliance. young workers.

Remove young worker from the task/position immediately X

and initiate child labour remediation processes. Documented Tasks and
safe work procedure to be used: processes
labelled as
Detailed operational planning and controls.
Medium risk MEDIUM RISK
Risk controls to be introduced before any work. should never
be assigned to
Workers should understand requirements and implement
young workers.
risk controls.

Ensure the task and working environment are safe for young 
workers. Review current controls and, if they are inadequate, Tasks and
apply more effective measures: processes are
likely suitable for
Check local law (i.e., the national hazardous work list) in-
young workers.
Low risk dustry regulations and existing in-house risk assessment
reports to ensure position is not off-limits to young
workers (see Annex VIII).
Review work/tasks and discuss the task with the young
worker before they start working.

3.3.2 Develop a list for low risk tasks and processes

Based on your risk assessment you can now take the following steps:
X Analyse the low risk work tasks and processes (see Annex IX).
X C
 reate a list of work from the “Low risk” category that is safe for young workers and
complies with applicable laws.
X D
 evelop an action plan: identify gaps in current OSH management such as policy,
procedure, communication and training; formulate corrective measures and a timeline;
assign responsible staff; initiate corrective action, and monitor the progress.
X C
 onduct regular assessments (or whenever there are changes to existing process) and
update the low risk task list.
X Store and file risk assessment results and the low risk task list for easy reference.

You will find a table template table in (Annex X) to help you with that process.
 III. Management of young workers 19

3.3.3 Long-term measures

Effectively protecting young workers from hazardous work may mean physically removing a hazard,
isolating workers from hazards, changing work processes and procedures, or providing improved
working conditions. For more details on this process you may consult Annex XI.

3.3.4 Continuously raise awareness of factory management and young workers

In conjunction with OSH committees and trade unions, where present, ensure that awareness raising
and OSH training, taking into account the extra need for protection of young workers, is undertaken on
an ongoing basis. It is important to conduct regular monitoring in order to ensure compliance in daily
operations.

Good X How a factory adjusted tasks and processes to accommodate young workers
practice

ABC Packaging Co., Ltd. (note 1) is a factory that produces backpacks and bags for many US
and European buyers, and they are one of the first factories in Vietnam to hire young workers
under the age of 18. Before hiring young workers, the factory started identifying suitable jobs
that were low risk and safe for young workers. However, the location and the work settings
of these jobs was likely to jeopardize the health of the young workers. To create a safe and
decent working environment for young workers, the factory conducted a job analysis and the
following risk/challenge control measures were taken:

Task Hazards/challenges Elimination/minimization of risk

Ergonomic hazard: Work while Provide adjustable tables and chairs so

1 Thread trimming standing full time on a high that workers can interchange between
table, no chair provided. sitting and standing

Chemical hazard: Work inside Move the work location from inside the
Zipper puller lock-ing, the cutting unit, where dust cutting unit to the material ware-house
trimming zipper tape, levels are known to be high. where the safety and health risks
2 inserting the zipper are minimized, and it is easier for the
lock Safety hazard: Work location sewing lines to collect the zipper for
near electric cutters. next steps.
Challenges: Though the jobs in
the packing area are simpler
Processes in the
than in other areas, the More tasks were identified as suitable,
packing areas such as
em-ployer did not identify or so that young workers could do at
inserting acces-sories
3 spe-cifically point out the non- least two tasks in the same work area,
like paper, plastic
hazardous tasks and processes thus allowing them to rotate to the
parts, and folding or
suitable for young workers. other task when one of the tasks was
returning the lining,
As a result, no one considered completed.
fabric products
these positions as suitable
positions for young workers.

Food preparation Safety hazard: Risk of fire and Identify restricted area and non-
4 and serving in the burns in the kitchen and from restricted area in the kitchen to avoid
canteens hot food risks for young workers.

After the risks were removed and the work setting was re-adjusted, more non-hazardous jobs were
created for young workers and the factory successfully allocated suitable tasks to them.
© Center for Child Rights and Corporate Social Responsibility (CCR CSR).
 IV. Child labour remediation 21

IV.

Child labour remediation

Child labour remediation refers to the process of removing a child from a child labour
situation to ensure safe and adequate alternatives for them, such as reintegrating them
into the education system or, if they are above the minimum age for work, creating an
opportunity for them to work in a non-hazardous job.

4.1 What should you do when a young worker (above the

minimum working age but under 18) is engaged in
hazardous work?

If young workers are found working in hazardous tasks or processes:

X Remove the young workers from the hazard.
X Offer them access to “low risk” work, without reducing salary or benefits.
X A
 rrange health checks and ensure any necessary treatment is provided, including for
long term exposure to hazards (e.g., dust, vibration, excessive noise).
X M
 onitor the young worker’s situation regularly to ensure that children do not gradually
shift back to high-risk activities.
22 Supplier guidance on preventing, identifying and addressing child labour

4.2 What should you do when a child below the general minimum
age for work is found at the production facility?

An underage worker may be identified by staff or other parties at the production site, or a child may
accompany their parents or guardians to the production facilities and can either be playing or helping
their parents with some tasks to be kept busy. The first thing to do is ensure that the child is safe and
does not feel in any way threatened or scared by the situation. It is often preferable that a woman speaks
with the child, particularly in the case of girls.5

4.2.1 When a child below the general minimum age is working in the production facility
you should:

X T
 alk to the child in a calm manner, offer information about yourself and ask open-ended, general
questions to establish a rapport. Listen to the child to understand their needs. Assure them that
they have done nothing wrong and are not “in trouble”. In a kind manner explain why they can’t be
working.
X R
 emove the child from the workstation and arrange a safe place for the child e.g., office room,
dormitory or home.
X Contact the child’s parents/guardians and explain the situation to them.
X Ensure that the child has been paid for the time worked in the factory.
X G
 ood practice is to provide financial support to the child and their family to cover school fees and
living costs until the child reaches the end of compulsory schooling or the minimum age for work,
then rehiring the young worker to do non-hazardous work.
X Document and keep records of each child labour case.
X I f a local remediation expert is involved, inform the expert about the child labour case with a Child
Labour Notification Form (Annex XII), and support and cooperate with the expert on the child’s
remediation.
X I f no local experts are available, you may seek support from ILO offices and other UN agencies such
as UNICEF for guidance.

4.2.2 What to do when an auditor or buyer detects a child below the minimum age for
work

If a child below the minimum age is found during a factory audit, a remediation process will be initiated
with the involvement of the buyer. You are expected to:
X F
 ill in the Child Labour Notification Form (Annex XII), and cooperate with and support the child
labour remediation process. A local remediation expert will:
• interview the child concerned and their parents;
• interview factory management and review relevant documents;
• conduct a factory walkthrough; and
• if no local experts are available, you may seek support from ILO offices and other UN agencies
such as UNICEF for guidance.

5 For detailed guidance on interviewing children removed from child labour see: ILO: Psycho-social rehabilitation of children withdrawn
from trafficking and other worst forms of child labour (Geneva,2007). Available at: https://www.ilo.org/ipec/Informationresources/WCMS_
IPEC_PUB_14755/lang--en/index.htm.
 IV. Child labour remediation 23

X D
 iscuss the cost of a remediation programme with buyers and subcontractors if they are involved.
The cost usually includes:
• a stipend for the child;
• education fees for the child;
• additional training in child rights and child worker policies at the factory; and
• the local expert’s costs to monitor the factory.

4.2.3 What to do when a supplier or factory staff find a child in the factory who is not
working

If a child is not working but is present in the production facility due to parents lacking alternatives for
childcare, the supplier should:

X S
 peak kindly to the parents (if they are present) and explain why the child cannot be in the factory
and.
X Contact the child’s parents/guardians if they are not with the child.
X R
 emove the child from the workplace and arrange a safe place for the child e.g., child friendly
space, office room, dormitory or home.
X Explore whether the parents/guardians need childcare services.
X I f the factory has a day-care or a child-friendly space (a space with adult supervision where children
can play and do homework), place the child there.
X I f the factory does not have a day-care or a child-friendly space, assist the parents by connecting
them to local childcare services or a relevant organization.
X Document and keep a record of the case.

Good X Child friendly space eliminates parents’ need to bring their children
practice with them to the production floor

A factory in China had a large migrant workforce, many of whom were parents. During
the summer months when their children were off school, parent workers found
themselves without any viable childcare options while they worked. As a result, some
brought their children to the production floor, believing the children to be safer by their
side than unaccompanied at home. During an audit however, the children were flagged
as underage workers.
To prevent such problems in summers thereafter, the factory opened a Child Friendly
Space on their premises. This provided workers’ children with a safe space to spend
their summer holidays, while the parents could put their mind to rest and concentrate
on work. The programme proved to be a win-win solution: the children had a much
more interesting, fun, social and educational summer by doing arts and crafts, playing
games and taking part in parent-child activities than if they had stayed at home; par-
ents did not have to pay hefty childcare fees or take time off work to look after their
children; and the factory enjoyed lower absenteeism and turnover, and a happier, more
motivated workforce.
© ILO-IFC Better Work Programme.
 Annexes 25

Annexes
26 Supplier guidance on preventing, identifying and addressing child labour

Annex I.
Checklist for factory self-assessment on employment policy
and procedures related to child labour and management
of young workers (above the minimum age but under 18)

This checklist is a self-assessment tool you can perform to get a sense of how well your
employment practices and system currently help to prevent child labour and manage young
workers. You can use it to identify where you need to make improvements and what elements
to prioritize.

Item Remarks

I. Employment policy

Does the facility have child labour and young worker management policy? YES / NO

Does the policy clearly mention the minimum working age? YES / NO

Does the policy clearly define the terms under which young workers can be offered
decent work positions? YES / NO

Is the policy compliant with national and international law on minimum age and
conditions for the hiring of young workers? YES / NO

II. Age verification procedures

Does the facility have a hiring process that sufficiently verifies the age of workers before
recruitment, which includes ID check and interview with each applicant? YES / NO

Is there a proven authenticity verification step for age-related documents, including

steps to be taken in case there are doubts? YES / NO

Does the facility have formal channels to access the local authority in relation to
obtaining and verifying age documents for workers? YES / NO

Has this process been carried out by a staff member that has been trained on age
verification? YES / NO

Does the facility keep necessary documents in workers’ personnel files, including copies
of ID and specific age verification documents? YES / NO

Does the facility allocate a budget in fiscal plans to allow for child labour prevention
training, especially regular training for HR staff on age verification? YES / NO

Does the facility provide regular training to the HR, Production Manager, line managers
and others who are involved in the hiring process to equip them with sufficient YES / NO
knowledge on child labour and skills on age verification?
 Annexes 27

Item Remarks

III. Work hours and occupational safety and health management

Are your workers regularly required to work overtime? YES / NO

If yes, which workshops/stations?

(1) (2) (3)

(4) (5) (6)

(7) Others:

Are young workers allowed to work overtime if they work in these departments? YES / NO

Are young workers allowed to work on night shifts for urgent orders/shipments? YES / NO

Do you use chemicals in the production processes at the factory? YES / NO

Is heavy machinery used in the production processes at the factory? YES / NO

Does the factory employ young workers to work in these processes handling chemicals
and heavy machinery? YES / NO

Has there ever been a work-related injury or accident in the factory? YES / NO

If yes, where did it happen?

(1) (2) (3)
(4) Others:

Have you conducted an occupational health & safety risk assessment at your factory? YES / NO

How frequently? And when was the last one?

Have you conducted an overall working environment analysis/report of your factory? YES / NO

How frequently? And when was the last one?

IV. Employment of young workers

Does the facility maintain a separate procedure for recruitment, document filing and
management of young workers (including temporary workers, student workers, and YES / NO
interns)?

Does the facility keep a hazardous/non-hazardous work list of your production process? YES / NO

Is the facility’s hazardous/non-hazardous work list consistent with the national

hazardous work list specified by the government? YES / NO

Do the relevant managers regularly carry out on-site checks to ensure that young
workers are not engaged in hazardous work? YES / NO

Does the factory undertake risk management procedures on all the manufacturing
processes and controls of subcontractors and contract partners? YES / NO

Do you have a grievance system to communicate and receive feedback, concerns,

complaints, suggestions and questions from workers? YES / NO

If yes, does the grievance system have separate procedures for young workers, so that
they do not face the risk of reprisal for raising a grievance? YES / NO
28 Supplier guidance on preventing, identifying and addressing child labour

Item Remarks

IV. Child labour prevention and remediation procedure

Does the facility have a child labour prevention and remediation procedure in place? YES / NO

Does the above procedure consist of specific methods and detailed steps before, during
and after hiring processes, and specify the responsibilities of each level? YES / NO

Has the top management appointed a responsible person for supervising the
implementation of child labour prevention, including regular monitoring of age YES / NO
verification processes?

Does the appointed responsible person for supervising the implementation of child
labour prevention also oversee the processes to prevent young workers from being YES / NO
exposed to hazardous work?

Does the facility have a dedicated and trained HR department/staff who are familiar
with the legal requirements of employment and understand the local context of child YES / NO
labour?

Has the facility set aside a budget for child labour remediation? YES / NO

Does the facility have a procedure to check subcontractors and contract partners’
usage of labour, which includes age verification of the apprentices, contract workers,
temporary or casual labour used by on-site subcontractors in waste, catering, delivery, YES / NO
cleaning building works etc.?

Does the factory check the licenses of the subcontractors before starting production? YES / NO

Does the facility have a procedure to regulate the use of recruitment agents before they
are allowed to supply workers? This includes checking the labour agents’ license for
business and confirm whether it has any records of violating child labour regulations, YES / NO
conducting age verification processes and personal interviews even if the labour agent
has already taken those steps?

Do you know who to contact in case child labour is found at the factory? YES / NO

Are you aware of any organizations that can support the factory with remediation
processes in case child labour is found? YES / NO

If most of your answers are “yes”, congratulations! It means that your internal system relating
to Child Labour and Young Workers Management is relatively comprehensive. However, you
have to regularly review and improve the process when there are gaps.
If most of your answers are “no”, it means that you should make significant and positive
changes to improve the current system.
 Annexes 29

Annex II.
Good practices for age verification

Elements of a good age verification system must have:

X E
 ffective Child Labour Policy and Procedures in place (which include age verification), which are in
line with business partners’ requirements.
X H
 R staff trained on legal requirements who can carry out age verification as required and identify
the authenticity of the ID documents.
X R
 esponsible person appointed, who has the authority and resources to regularly supervise the age
verification process.
X R
 isk control measures in place, concerning resources utilized in hiring and operating processes,
including management of labour agents, subcontractors and sub-contract partners.
X M
 easures for preventing young workers from conducting hazardous work, which includes
maintaining a list of hazardous work, a regularly updated list of young workers, onsite checks to
ensure no young workers are engaged in hazardous work.
X Budget in place to allow for child labour prevention training and skills on age verification.

Sample questions related to age verification (to be used in addition to requested age verification
documents):
Questions related to age should be natural and may start with a casual chat about the family situation.
X C
 an you talk a bit about yourself? Where is your hometown? Do you like school? Why? Or why not?
Do you have to send money back home?
X How many members are in your family? What are your parents’ names?
X What are your parents doing? Where are they?
X D
 o you have siblings? Are they studying or working? How many years older/younger than you are
your siblings?
X What is your birthday by day, month and year? So, in this case, how old are you?
X What’s your animal sign/zodiac animal? What about the animal sign of your siblings?
X When did you start junior middle school? Have you ever skipped a grade or been held back a grade?
X W
 hich grade did you finish and when? In which grade are your siblings? Or when did they finish
school and at what grade?
X Was this a school in your hometown? Where is it?
X D
 o you have friends from the same hometown/school here? Do you still keep in contact with your
classmates? In which grade are your classmates now if some are still in school?
X Did you ever move from one place to another place? How old were you when you moved?
X I s this your first job? Have you ever worked before? What kind of job have you done before? How
long did you work for in the last job?
X H
 ave your heard from your parents if any important event occurred in the year you were born? If
yes, what?
30 Supplier guidance on preventing, identifying and addressing child labour

Annex III.
Information included in a valid contract for young workers

X P
 lease note that for the elements written in bold you will need to take into account special
considerations for the young workers:
X Employer’s name, residence & legal person (responsible person)
X Employee’s name, residence and ID
X Domicile or place of contact
X Duration of employment
X P
 robation: probation period, salary and benefit during probation, evaluation upon completion of
probation, termination during probation, etc.
X Job position, location & duties/tasks
X Working hours, rest time and leave
X R
 emuneration & benefits: Young workers enjoy the same remuneration and benefits as adult
workers.
X W
 orking conditions and occupational protection: The employee is entitled to a safe and hygienic
working environment; necessary protection against risks and hazards that are related to the
employee’s work should be provided
X T
 erms on termination: Both parties are entitled to terminate the employment contract, given a
notice period (30 days or legally required no. of days)
X O
 thers: e.g., training, confidentiality, factory regulations, confidentiality, settlement of labour
dispute.
 Annexes 31

Annex IV.
Working hour regulations for young workers in key supplying
countries

This checklist is a self-assessment tool you can perform to get a sense of how well your employment
practices and system currently help to prevent child labour and manage young workers. You can use it
to identify where you need to make improvements and what elements to prioritize.6

Countries Age range Basic Night/overtime Hazardous

of young working hours work work
workers

Not exceeding 8 hrs/shift and 40 Prohibited

CHINA 16- 17 Prohibited
hrs/week (From 10 pm to 6 am)

Not exceeding 8 hrs/day, and 40 Prohibited

TURKEY 15- 17 Prohibited
hrs/week, with a medical certificate (From 8 pm to 6 am)

Prohibited (night work

Not exceeding 8 hrs/day or 40 hrs/
VIETNAM 15-17 refers to work between Prohibited
week in garment in-dustry
10 pm and 6 am)8

Not exceeding 5 hrs/day or 30 hrs/

week in any factory
Not exceeding 36 hr/week in total
Prohibited
BANGLADESH 14-17 including overtime if young worker Prohibited
(From 7 pm to 7 am)
works overtime in a factory
Period of work is limited to two
shifts
Young workers WITHOUT
certificate to work as an adult:
Female - prohibited to work between
7 pm and 8 am; Male - prohibited to
work from 10 pm to 6 am
Young workers WITH a certificate
INDIA 14-17 Prohibited
of fitness to work as an adult:
Male & Female (15-16 years old):
prohibited to work between from 7
pm to 6 am; Female (17 years old):
prohibited to work from 10 pm to 5
am
Prohibited with
exceptions for
children who
Not exceeding 8 hrs/day and min. of
have attained
CAMBODIA 15-17 13 consecutive hrs. of rest between Prohibited
the age of
shifts
16 years
under certain
conditions*
Child worker: prohibited
14-15 child Child worker: not exceeding 4 hours (6 pm-7 am)
worker a day, with a certificate of fitness Adolescent worker:
MYANMAR 16-17 Adolescent worker: not exceeding allowed only with a
adolescent 8 hours a day, with a medical medical certificate that
worker certificate s/he is fit to work during
night time/overtime*

* Here the national standards are less strict than those recommended by the ILO. ILO strongly suggests to apply the stricter standards
and refrain from asking young workers under 18 to engage in overtime and hazardous work.

6 Even though the law says: “underaged workers may work overtime and at night in some occupations and jobs stipulated by the
Ministry of Labour, War Invalids and Social Affairs”, so far, the Ministry has not stipulated any occupation that could apply this exception.
32 Supplier guidance on preventing, identifying and addressing child labour

Annex V.
Information included in a valid contract for young workers

X B
 e easy to understand, so young workers fully understand how to submit complaints and
suggestions.
X Ensure confidentiality.
X H
 ave a policy to ensure workers who report a grievance can do so without fear of punishment,
dismissal or reprisal of any kind.
X I nclude proper management and handling procedures (the HR department should follow up on
reported grievances that are communicated by workers).
X I nclude a procedure so employees can report complaints about a supervisor to an impartial
individual or entity.
X Monitor the processing of complaints.
X Have an appeal system.
 Annexes 33

Annex VI.
Worker interview guide for occupational safety & health
hazards identification

Please note that the questions below do not cover all cases where risks and hazards may exist.

Factory environment

Do you find any uneven, slippery areas or holes on the floor? YES / NO

Have you seen any flammable substances such as white spirit or adhesives left on the
floor? YES / NO

Do you think the floor is always kept tidy and do you have enough space for walking
through? YES / NO

Do you see any boxes or objects left on the ground? Are they movable? If not, are they
marked? YES / NO

Do you think the ventilation is good? YES / NO

Do you think the workplace is dusty? YES / NO

Do you smell a strong sense of bleach or other substance in the factory? YES / NO

Do you think the lighting at the factory is sufficient? YES / NO

Do you know where the first-aid equipment is? Is it easily accessible? YES / NO

Did you receive any occupational safety and health training during orientation and
your employment period? YES / NO

Were you given general factory PPE such as a face mask, proper footwear, etc? YES / NO

Have you seen anyone get hurt or fall before? if yes, what was/were the reasons
causing the accident?
YES / NO
Reason(s):

Health

Do you find your eyes get tired easily during your work? If yes, what factor do you
think is causing that (large spatial variations in lighting, not enough lighting, excessive
contrasts in lighting, veiling reflections etc)? YES / NO

Factor(s):

Do you know if anyone has a problem or complaint about their eyesight? YES / NO

Do you think the machines are making a loud noise? YES / NO

Do you need to raise your voice when you talk to people in the factory? YES / NO

Have you noticed if you continue talking loudly to people after you finish your work? YES / NO

Do you feel excess stress and pressures when meeting tight deadlines? YES / NO

Do you frequently feel dizzy at work or after work? YES / NO

34 Supplier guidance on preventing, identifying and addressing child labour

Factory equipment and machines

Do you think the design of the workstation fits your physical or work process
movement? YES / NO

Can you adjust the position, such as the height of the chair and table? YES / NO

Do you see any damaged plugs, sockets, cables or lines? YES / NO

Do you notice any strange/unusual noise coming from the machines? If yes, where is it
and in which machine?
YES / NO
Location and machine:

Do you know how to use the machine properly?

Are you sure the safety button/device of the machine functions properly? YES / NO

Have you seen any parts falling off from the machines? YES / NO

Do you think the machine is properly safeguarded to prevent your body from being in
contact with the dangerous moving parts? YES / NO

Have you seen any accidents even when PPE is used? YES / NO

Chemicals and explosion

Do you know if hazardous chemical substances are used? Where are they stored?
Storage: YES / NO

Can you easily identify the substances that are hazardous? YES / NO

Do you think the chemical substances are stored far enough from high temperature
are-as? YES / NO

Do you know the emergency escape route? YES / NO

Do you know where the fire extinguisher and other fire-fighter equipment are located?
Do you think they are easily accessible? YES / NO
 Annexes 35

Annex VII.
Types of hazards in the garment and textile industry

Using the methods described above assess every task and process in terms of the following elements:

X Physical hazards X Ergonomic hazards

Excessive noise Poor ergonomic design of workstations and

work conditions
Improper lighting level
Badly designed machinery
Insufficient ventilation
Repetitive nature of tasks or movement
Excessive vibration
Awkward postures
Extreme heat
Lifting heavy loads
Poor air quality
Prolonged working hours
Untidy working environment
Spaces with inadequate circulation spaces
Blockage of exits (especially in case of fire)
Lack of shifts and rotation system
Absence of health and hygiene facilities

X Psychological hazards X Chemical hazards

Stress Emissions of toxic substances e.g., dyeing

and printing of fabric, knitting, cleaning,
Strain
coating and finishing
Excessive physical workload
Dust from materials or machines
Abuse/harassment
Exposure to dangerous chemicals (arising
Fatigue (might be linked to excessive from liquids, solids, dusts, fumes, vapours
working hours) and gas-es)

X Biological hazards X Safety hazards

Exposure to biological agents (bacteria, Being struck by objects, such as moving

viruses, infectious waste and infestations) machinery parts and transportation vehicles
(lift truck)
Poor nutrition
Working at heights
Problems due to imbalanced diets
Walking on untidy floors
Fire and explosion
Using dangerous machinery, equipment or
tools
Driving, riding or working near vehicles
Flammable or explosive materials or
substances
36 Supplier guidance on preventing, identifying and addressing child labour

Annex VIII.
Hazardous work list for young workers regulated by the local laws in
key supplying countries

Please note that the questions below do not cover all cases where risks and hazards may exist.

X China Legal minimum working age: 16

Hazardous tasks/conditions:

 mployers shall not engage juvenile worker (aged 16 but below 18) in the types of work and processes
E
defined by the Chinese Government.7 The following are hazardous work activities related to the garment
industry:
X W
 ork in contact with dust at or above grade 1 of the state stand-ards of classification of the peril for
work in contact with dust gen-erated through the production process including cotton wool, metal
dust, etc:
X W
 ork high above the ground at or above grade 1 of the state standards of classification of work
high above the ground;
X Work in cold water at or above grade 1 of the state standards of classification of work in cold water;
X W
 ork in high temperatures at or above grade 1 of the state stand-ards of classification of work in
high temperatures;
X W
 ork in low temperatures at or above grade 1 of the state stand-ards of classification of work in
low temperatures;
X W
 ork with grade N physical labour intensity of the state standards of classification of work of the
intensity of physical labour;
X W
 ork of continuously loading goods more than six times per hour and each time loading more than
20 kilograms; work of discontin-uously loading goods each time loading more than 25 kilograms;
X F
 low process in which the operators have to keep changing their bodily positions such as lowering
head, stooping, raising, squatting down for a long time, or maintain their actions each minute more
than 50 times; and
X Work of stocking boilers.

7 Ministry of Labour, the Provisions on Special Protection for Juvenile Workers - (LMI [1994] No. 498 issued by the Ministry of Labour on 9
December 1994). Entered into Force 1 January 1995.
 Annexes 37

X Turkey Legal minimum working age: 15

Hazardous tasks/conditions:

 mployers are prohibited from engaging young workers (having reached the age of 15 but below 18) in
E
the following jobs:8
X Jobs done in the night period as defined in Article 69 of Labour Law 48579
X Jobs in which people who are not yet 18 are forbidden to work as per the Regulations on Heavy and
Dangerous Work10
X Jobs which fall under the Regulations on Jobs which must be done in 7.5 hours or less per day from
the point of view of the Health Rules
X Jobs in wholesale or retail of flammable, explosive, harmful or dangerous materials or jobs in the
manufacture, processing or storage of such materials and every type of job which may leave them
exposed to these materials
X Jobs which are done in an environment which is noisy and/or has a lot of vibration
X Jobs which must be done in an extremely hot or cold environ-ment and jobs which are carried out
with materials which are harmful to health or lead to occupational illnesses
X Jobs which are done by the use of electrically powered machinery
X Jobs which require extra vigilance, and which require continuous standing up
X Jobs where the salary is paid on commission and on a bonus system
X Jobs which do not provide the opportunity to go home and be with the family at the end of work
(excluding jobs which are for the purposes of education)
X Jobs requiring a clear level of physical or psychological adequacy or with expert medical reports
X Jobs involving toxins, carcinogens, materials which harm the genes of offspring or are harmful to
unborn children or which influence human health harmfully in any way
X Jobs that carry a risk of work accidents believed impossible to avoid or notice which could expose
young workers because of a lack of education and lack of attention to safety

8 Regulations on the Fundaments and Principles of the Employment of Children and Young Workers of 2004, Article 71 of Labour Law 4857.
9 Turkish Labour Law, Article 69 provides that “night” means the part of the day beginning not later than 20:00 hours and ending not
earlier than 6:00 hours and lasting not longer than 11 hours in any case. Moreover, Article 73 provides that children and young employees
under the age of 18 must not be employed in industrial work during the night.
10 Turkish Labour Law, Article 85
38 Supplier guidance on preventing, identifying and addressing child labour

X Viet Nam Legal minimum working age: 15

Hazardous tasks/conditions:

Employers must not employ a minor (aged 15 but below 18) to under-take the following work:11
X Heavy, toxic and dangerous jobs, jobs that may adversely affect their personality
X Carrying and lifting of heavy objects that are beyond a minor’s physical strength
X Maintenance of equipment and machines
X Other jobs that are harmful to the health, safety or morality of minor employees
Work is prohibited in workplaces that:
X Are harmful to the health, safety or morality of young workers
X Include heavy and hazardous work, and work with exposure to toxic substances
X C
 reate a harmful influence to their dignities, as described in the list issued by the Ministry of
Labour, Invalids and Social Affairs in coordination with the Ministry of Health

X Bangladesh Legal minimum working age: 14

Hazardous tasks/conditions:

 o adolescent (aged 14 but below 18) shall be allowed to clean, lubricate or adjust any machinery while it
N
is in motion or to work between moving parts or between the fixed and moving parts of such machinery.12
 government order issued on 13 March 2013 identified processes and activities hazardous for children
A
in which the following are related to the garment industry:
X Tanning and dressing of leather
X Dyeing or bleaching of textiles
X Weaving
X Electric mechanic
 o child under the age of 14 years shall be permitted within the work rooms and godowns (warehouse
N
or storage area) of any factory at any time during which work is carried out.
According to Bangladesh Factories Rules, 1979, the following work is prohibited for children;
X “Manufactures of aerated water and processes incidental thereto
X Liming and tanning of raw hides and skins and processes incidental thereto
X Feeding of jute, hemp or other fibres into softening machines
X Printing presses and type foundries wherein certain load”.

11 Vietnam Labour Code (2012), Article 163 & Article 165

12 The Bangladesh Labour Act, 2006.
 Annexes 39

X India Legal minimum working age: 14

Hazardous tasks/conditions:

Employers are prohibited to hire children aged 14 years (but below the age of 18) in occupations and
processes that are hazardous to the children’s lives and health.13
The following list is in connection with the garment industry:
X Cloth printing, dyeing and weaving including processes, preparatory and incidental thereto
X Wool-cleaning
X Jute textile manufacture and coir making
X Manufacture of dyes and dye stuff
X Skinning, dyeing and processes for manufacturing of leather and leather products
X ‘Zari’ making (all processes)
X Processes involving exposure to excessive heat (e.g., working near a furnace) or cold

13 The Child Labour (Prohibition and Regulation) Act, 1986, India.

40 Supplier guidance on preventing, identifying and addressing child labour

Annex IX.
Basic hazardous risk assessment for young worker and action plan14

Factory:

Department:

Number of workers:

Assessment date:

Department Step 1: Identify

Work task
or process Potential factors Severity Level Probability Final Risk Level
What are the
and numbers for causing (high, moder-ate (likely, possible & (high, medium
hazards?
of workers hazards & low) unlikely) & low)
involved?

14 This basic hazardous risk assessment and action plan form is developed based on the ILO’s 5 step guide for employers, workers
and their representatives on conducting workplace risk assessments. Available at: https://www.ilo.org/safework/info/publications/
WCMS_232886/lang--en/index.htm.
 Annexes 41

Department Step 2: Decide

Work task
or process
and numbers What is already being done? What further action is neces-sary?
of workers
involved?

Department Step 3: Plan

Work task
or process
When was the action
and numbers Who will take action? By when?
completed?
of workers
involved?
42 Supplier guidance on preventing, identifying and addressing child labour

Annex X.
Identification of low risk work tasks and processes
that are suitable for young workers

Work task and Final job suita-

Job complexity Law compliance Risk assessment Notes
processes bility decision

Examples:
Suitable Suitable Suitable Suitable Job requires
1. Screw
handling
inserting Not Suitable Not Suitable Not Suitable Not Suitable chemicals
2. Ironing
 Annexes 43

Annex XI.
Long-term best practice to prevent potential harm to young workers

The following best practices aim to prevent potential harm to young workers on a long-term basis.
You should seek solutions in compliance with national laws and regulations to transform the tasks and
processes from “Medium Risk” to “Low Risk” by following the suggested order below. This chart provides
guidance and methods to remove or eliminate identified hazards and control risk in the most effective
way.

Ways of risk control Definitions

Elimination and Physically remove the hazard or replace the part/component Most Effective Risk
substitution which performs similar functions but is safer to use Control Measure

Engineering controls Isolate people from hazards, but hazards still exist
Change the way people work through procedure changes,
Administrative controls employee training, and installation of signs, warning labels,
and so on
Install and provide hygiene and welfare facilities to cope with
Hygiene and welfare
the risks to reduce the effects that are caused by the hazards

Provide workers with PPE such as gloves, Nomex/uniform,

Personal protective
respirators, hard hats, safety glasses, high-visibility clothing, Least Effective Risk
equipment
and safety footwear Control Measure

Wherever possible, hazards should be eliminated. If this is not possible look for the next most effective
risk control measure until the position can be rated as low risk. It is important to note that in most cases,
the use of PPE to protect young workers from hazards is not sufficient.
Here are a few examples of concrete actions of removing or eliminating hazards and reducing risk:
X R
 emoving or eliminating the risk or hazard completely, e.g., changing the composition of
components, materials etc., or changing work processes to a non-hazardous process; investing in
newer and safer machines with better risk control etc.
X M
 odifying workstations or the layout of the production line to protect young workers from
overheating, dust or hazardous chemicals.
X P
 utting controls in place to stop young workers from coming into contact with the hazard (such as
protective shields on machinery).
X R
 edesigning and setting up workstations to minimize bodily strain. This includes seating and
standing arrangements and the reach required to obtain tools.
X S
 ignage/warnings in a language or medium understood by all workers and/or administrative
controls; implement administrative controls to prevent people from coming into contact with the
hazard, such as marked areas to keep people away from hazardous machines or machine parts;
and graphics for hazardous substances to alert workers to stay away.
44 Supplier guidance on preventing, identifying and addressing child labour

Annex XII.
Child labour notification form

Notification form

Date and time call received:

Business partner contact person name:

Email and phone number:

Region where case is located:

No. of cases identified:

Business partner (importer or supplier) contact details (if applicable)

Importer and/or supplier’s company name:

Contact person name (Eng):

Title:

Email:

Phone number:

Factory site:

Factory name:

Address:

Contact name (Eng):

Email:

Phone number:
 Annexes 45

Case No. 1 (To multiply according to number of cases)

Name of the child:

ID number & copy as attachment (if any):

Date of birth:

Start date at the factory/site:

Salary:

Work position:

Current situation and location of the child:

Hometown or area of social registration:

Phone number:

Other means to keep in touch:

Family status including primary caretaker and location of parents:

Parents (legal guardian) name and contact number:

Main reasons why child was in employment:

Engaged in hazardous work: Yes / No

Immediate actions/steps have been taken by the factory & photos:

More information:
ISBN 978-92-2-032195-9

9 789220 321959