INTERNATIONAL LABOUR OFFICE

GUIDE FOR LABOUR
INSPECTORS

GENEVA
1955

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STUDIES AND REPORTS
New Series, No. 41

PUBLISHED BY THE INTERNATIONAL LABOUR OFFICE
GENEVA, SWITZERLAND

Published in the United Kingdom for the INTERNATIONAL LABOUR O F F I C E

by Staples Press Limited, London

PRINTED BY IMPRIMERIE GRANCHAMP, ANNEMAS3E (HAUTE-SAVOIE)

FRANCE

CONTENTS
Page
INTRODUCTION

1

PART I.

5

The Labour Inspection Service

Organisation of Labour Inspection
The Central Authority
Local Organisation
Inspection Staff
The Powers of Labour Inspectors
Measures to Facilitate Inspection
Methods and Standards of Inspection
Methods of Inspection
Efficiency of Inspection Visits
Frequency of Inspection Visits
Collaboration with Employers and Workers
Enforcement Measures

7
7
8
9
13
14
16
16
17
19
.20
21

Labour Inspection Reports
Inspectors' Reports
Annual Reports of the Inspection Service
Collaboration with Other Authorities and Bodies

22
22
24
25

PARTII.

Inspection Rules and Procedures

26

General Rules
Conduct and Obligations of Labour Inspectors. . . .
Inspection Visits

27
27
28

General Inspection Procedures
Hours of Work and Related Questions
Wages
Employment of Young Workers and Women
Safety and Health Inspection in Industrial Establishments .
General Remarks on Safety and Health
Buildings and Other Workplaces
Fire Prevention and Protection
Elevators and Hoists
Machine Guarding

32
33
36
37
47
48
55
59
63
66

IV

CONTENTS

Electricity
Boilers and Pressure Vessels
Furnaces, Kilns and Ovens
Handling, Transportation and Storage of Materials . .
Dangerous Substances and Radiations
Health and Welfare
Safety and Health Organisation and Training . . . .
APPENDIX.

Health

72
75
83
84
88
92
98

Selected Bibliography on Occupational Safety and
103

INTRODUCTION
The International Labour Organisation has always had a
deep interest in the promotion of effective systems of labour
inspection to ensure that the theoretical standards embodied
in labour laws will be given practical effect and thus become
the actual standards of protection for workers. This interest
culminated in the adoption by the International Labour
Conference at its 30th Session of the Labour Inspection Convention, 1947 1 , which has been widely ratified.2
In addition the International Labour Office is called upon
from time to time to advise governments on the application
of protective labour laws and regulations ; experience in response
to such requests has shown that it would be useful to publish
a guide for labour inspectors outlining the methods and procedures of inspection and including basic information on the
organisation and responsibilities of the labour inspectorate.
In drawing up the guide the Office has taken account of
the standards of the above-mentioned Convention which, it
may be useful to point out, is primarily concerned with inspection
in industrial and commercial workplaces and is therefore not
wholly appropriate for such activities as mining and transport,
which present special problems.
While practical inspection standards have been evolved on
the international plane it must nevertheless be recognised that
details of the organisation and operating practices of inspection
services vary in some respects from country to country. A
study such as this cannot, therefore, be based on the labour
law or enforcement machinery of any one country ; on the other
hand, it has been necessary to proceed on the basis of certain
assumptions so as to give the guide the desired practical
1

See International Labour Conference : Conventions and Recommendations, 1919-1949 (Geneva, I.L.O., 1949), p. 704.
2
On 1 J a n u a r y 1955 the Convention had been ratified by the
following countries : Austria, Bulgaria, Cuba, Dominican Republic,
Finland, France, Guatemala, Haiti, India, Iraq, Ireland, Italy, J a p a n ,
Netherlands, Norway, Pakistan, Sweden, Switzerland, Turkey, United
Kingdom.

2

GUIDE FOR LABOUR INSPECTORS

character, and to suggest certain methods and procedures of
inspection, well tested in practice, for the guidance of inspectors
in situations where the service may still be at an early stage of
development. The protective labour laws assumed in this guide
to be enforceable by inspectors are those dealing with hours
of work and related questions (e.g., meal and rest breaks,
overtime and night work), wages, the prohibition of child labour,
the various regulated aspects of the conditions under which
women and young workers are employed, and industrial safety,
health and welfare—in short, the laws and regulations concerning
conditions of work and the protection of workers while they are
engaged in their work. Although in some cases an inspector's
responsibilities may include arbitration of labour disputes,
administration of employment exchanges and the collection
of various types of statistics, such duties are not directly connected with the inspector's primary functions and are consequently excluded from consideration in this guide. 1
The above reference to the safety and health of workers
calls for some additional comment. Protection against the
hazards of accident and occupational disease embraces complex
technical matters with which the general labour inspector is
often not equipped to deal. In some countries this is the responsibility of specialised staff (e.g., specialists in engineering,
medicine and chemistry), who may form part of a unified,
comprehensive inspection service or be organised as separate
inspection bodies (such as a mines inspectorate) or attached to
branches of the public service other than the labour ministry.
In other cases, however, particular national conditions and the
stage of development of the inspection service may be such that
responsibility for these matters falls to a great extent on the
general labour inspector. While it cannot be over-emphasised
that the protection of the safety and health of workers requires
the technical skills of competent specialists trained to detect
and deal with industrial hazards, the assignment of such duties
to general labour inspectors must be recognised as an existing
1
It may be recalled that Article 3 of the Labour Inspection Convention, 1947, after defining the functions of the system of labour inspection, provides that " any further duties which may be entrusted to
labour inspectors shall not be such as to interfere with the effective
discharge of their primary duties or to prejudice in any way the authority and impartiality which are necessary to inspectors in their relations with employers and workers ".

INTRODUCTION

3

fact. Accordingly, the guide includes a section dealing mainly
with general problems of industrial safety and health ; and,
to assist inspectors who may wish to obtain more specific
guidance on the most common safety and health risks, a selected
bibliography of publications dealing with such problems is
appended.
Finally, while the guide contains indications concerning
administrative record and report forms, these are no more
than suggestions since the details in each case must be worked
out having regard to such matters as the particular legal provisions to be enforced and the administrative practice of the
country concerned and it is therefore impossible to elaborate
a uniform set of forms that would be generally applicable.

PART I
THE LABOUR INSPECTION SERVICE
Legislation for the protection of workers acquires real
meaning only when it is enforced by a body of specially qualified
officials who visit workplaces at frequent intervals in order to
carry out three essential tasks : (1) to see, through personal
examination and investigation, whether the legal provisions in
question are being applied and, if this is not the case, to take
appropriate action to secure compliance ; (2) to assist both
workers and management, by giving them the technical information and advice they need, to understand the requirements of
the law and how to comply with them ; and (3) to investigate
labour conditions for the information of the government and
to bring to the notice of the competent authority any defects
or abuses not specifically covered by existing legal provisions.
The machinery set up to ensure that these tasks are carried out
with maximum effect is the labour inspection service. This
service is primarily concerned with the enforcement of legislation regarding conditions of work and the protection of workers
while they are engaged in their work, such as provisions relating
to hours of work and rest, wages, safety, health and welfare,
and the employment of women and young persons. Labour
inspection is not, in itself, a direct protective instrument ; it is
rather a method of ensuring the enforcement of protective
legislation, of promoting improved labour conditions and of
investigating existing conditions for the information of the
government.
Historically, labour inspection in its early development as
regards industry was largely directed towards factories, in which
the need for protective legislation first made itself felt. The
introduction of mechanical processes of production, in factories
employing sizable concentrations of workers, including large
numbers of women and children, made it clear that measures
must be taken to protect workers against the worst effects of

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GUIDE FOR LABOUR

INSPECTORS

overwork and the special dangers to their health and safety
which arise in factory operations. From these beginnings,
protective legislation has been progressively extended to cover
other fields of economic activity, such as workshops and undertakings where work is carried on under factory conditions but
is not directly concerned with manufacture or production
(e.g., docks, warehouses, laundries), to commerce and distribution, to building and construction and to agriculture. As the
scope and complexity of legislation for the protection of workers
have increased, there has been a parallel development in the
organisation of methods and procedures of enforcement to
ensure that the objectives of the legislation are achieved in
actual practice.
While the value of labour inspection to the worker is selfevident and has been recognised from the beginning, there has
also been a growing recognition of its value to management and
to the social and economic interests of the community as a
whole. For the employer, the system of labour inspection
provides the means whereby he can get reliable information on
his obligations under the law and practical advice concerning
the means of complying with the legal requirements. He can
expect of the service that it will ensure uniform and impartial
application of the legislation so that he is protected against
unfair competition of others based on depressed labour
standards, and he shares in the benefits to the community
that flow from the efficient administration of labour laws.
The maintenance of sound labour standards in his undertaking,
in which he is assisted by the labour inspectorate, tends to
result in more efficient production from workers who work
reasonable hours, who are not employed in tasks that surpass
their physical powers, and who are provided with safe and
healthy workplaces and conditions.
These benefits brought to both employer and worker in the
workplace also redound to the general benefit of the community
in the form of higher and. more efficient economic productivity,
protection of the welfare of the population as a whole, and the
promotion of a harmonious industrial atmosphere.
To achieve these important social objectives—in a word,
to secure an efficient labour inspectorate—is by no means an
easy task. Much care and effort must be applied in tackling
a wide range of interrelated problems of administration, staff,

THE LABOUR INSPECTION SERVICE

7

methods and procedures. While the details of labour legislation, and consequently the problems of enforcement, vary from
country to country, generally in accordance with the stage of
economic and industrial development, experience has shown
that these problems arise in much the same form in all countries
whose public policy is to protect the welfare, health and safety
of its working population. Fortunately, however, there has
also been considerable experience in the best principles and
methods to be followed in ensuring the strict and uniform
enforcement of labour legislation and the organisation for that
purpose of systems of labour inspection.
The general survey that follows, based in large part on the
provisions of the Labour Inspection Convention, 1947, is
intended to give in broad outline the essential principles of
inspection and to indicate sound methods and procedures of
enforcement, advice and inquiry.

Organisation of Labour Inspection
T H E CENTRAL AUTHORITY

An essential object of the inspection service is to ensure
uniformity in the application of labour legislation throughout
the national territory. This can only be achieved through
direction and co-ordination of the work of inspectors by a
central authority, whose functions include responsibility for
formulating uniform methods and procedures of inspection, and
for supervising the enforcement activities of inspectors. The
central authority provides inspectors with documentation dealing
with sound labour conditions and the proper equipment of
workplaces. It organises inquiries whose scope may go beyond
the geographic limits of a particular inspector's district. When
problems of a general character arise, the central authority,
with greater resources of specialised staff and with access to
research or testing services, is better equipped than the individual
inspector to work out solutions useful in various parts of the
national territory, thus ensuring uniformity and relieving
inspectors of the need to work out problems individually. As
the focal point of the inspectorate, to which information flows
from the local or district branches of the service, the central

8

GUIDE FOR LABOUR INSPECTORS

authority has an over-all view of social and labour problems,
which enables it to keep the government informed of new
developments and needs.
The labour inspectors are the executive agents of the
service and carry out the actual work of enforcement. Close
co-operation between them and the central authority is essential
to the effective functioning of the service. They must carry
out their tasks in accordance with the procedures established
for the service as a whole, and must keep their superiors informed
of their activities and findings. This co-operation has a double
effect : for the labour inspector, it means that he can carry
out his duties with confidence that his colleagues are applying
the same interpretations and methods in their particular
districts and in the knowledge that he has the full support of
the central authority ; while, for the latter,' it means that
complete reliance can be placed on the accuracy of inspectors'
observations and the effectiveness of their work.
LOCAL ORGANISATION

Labour inspectors should be in a position to visit all the
undertakings under their supervision at regular and sufficiently
short intervals, and without undue expense or loss of time.
The local offices or branches of the service should therefore
be so situated that inspectors can remain in close touch with
the establishments they have to inspect and with the employers
and workers concerned ; the branches should also cover districts
of a size appropriate to the needs of the service.
However, even in small districts visits involving considerable expense may have to be made to outlying establishments.
Such expenses should in no case be borne by the inspector
himself and provision should therefore be made for granting
allowances for travel and out-of-pocket expenses. This is
most often done by refunding expenses the inspector has
incurred in the course of his duties.
While most of an inspector's time is spent in visiting
establishments, a substantial fraction must be devoted to the
preparation of reports, interviewing employers and workers,
correspondence, and so forth. If they are to carry out these
duties satisfactorily, inspectors must be provided with centrally
located and suitably equipped offices.

THE LABOUR INSPECTION SERVICE

9

INSPECTION STAFF

Status and Position of Inspectors
The successful execution of the work entrusted to inspectors
depends in large part on their impartiality, personal authority
and independence from improper external influence. It is
therefore necessary to provide for conditions of service in
keeping with the social importance of their mission and designed
to safeguard their position in these respects.
The inspection service cannot enjoy the authority it
requires unless the labour inspectors are guaranteed by their
conditions of employment a certain minimum of security and
a social position which places them above any influences that
might affect their impartiality. Nor can a labour inspector
carry out his duties in an independent and unbiased manner
if his continued employment in the service depends on political
influence or personal considerations. Hence it is necessary to
guarantee to inspectors stability of employment and equitable
remuneration. Only by providing such conditions can suitable
candidates be attracted to the inspection service.
In this connection article 6 of the Labour Inspection
Convention, 1947, provides that—
The inspection staff shall be composed of public officials whose
status and conditions of service are such that they are assured of
stability of employment and are independent of changes of government and of improper external influences.
Qualifications of Inspectors
The personal qualifications of labour inspectors have a direct
effect on the prestige of the service with employers, workers
and the general public. They should be persons with a highly
developed feeling for the human and social problems with
which they have to deal, and should carry out their duties
with integrity, tact, intelligence and good judgment. For
employers and workers alike, the labour inspector is the official
representative of the labour authority, and their opinion of
and respect for that authority will depend on their relations
with the inspector.
The inspector should have a knowledge of social and
economic questions in general and of their significance for the

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G U I D E FOR LABOUR

INSPECTORS

industries with which his work is concerned in particular, so
that his dealings with the many different kinds of people with
whom he comes in contact may be carried out intelligently and
on a practical basis. He may have to deal with all sorts and
conditions of people and should be able, by reason of his
acquaintance with their practical problems, interests and circumstances, to speak with them at their own level and in their
own " language ". The inspector must also, of course, be
technically qualified by experience and training for his work.
No precise rules can be laid down in this regard since it is evident
that the technical qualifications required of inspectors will
depend on their particular responsibilities ; an industrial safety
inspector, for example, must have certain technical skills
different from those required of, say, an inspector specialising
in questions of young persons' employment. In many inspection services, however, it has not yet been found possible to
institute a system of specialised technical inspectors, with the
result that responsibilities for technical inspection fall upon
officials to whom a wide range of inspection duties, both general
and technical, is assigned. Whatever may be the arrangements
in a particular service, a basic and essential qualification for
inspectors is that they must have technical skills commensurate
with the duties they have to perform and in any case a knowledge
of the technology of the different branches of industry they deal
with.
Training of Inspectors
In view of what has been said above, it will be readily
apparent that the directing officials of an inspectorate must
devote particular attention to the training of labour inspectors.
Two major purposes are thereby served : to attain a high level
of competence in the inspection staff and to ensure uniformity
in inspection standards.
While candidates for the service may be found who possess
the necessary moral qualifications, a good standard of general
education and a useful background of industrial experience,
the duties of a labour inspector will inevitably present many
new and unfamiliar problems. Both specialised training for
the particular problems of inspection and considerable practical
experience in the work itself are required if an inspector is to
become thoroughly competent to perform all his duties. It is

THE LABOUR INSPECTION SERVICE

11

particularly important (and indeed customary) that recruits
should undergo a period of probation—say, one to two years—
during which they are trained in the performance of their
duties and their abilities and personal qualifications are tested.
Training may consist of formal courses or new recruits may
simply be initiated in their duties by accompanying older
inspectors on their daily rounds, a method akin to " on-thejob " training. However, the latter method alone would not
appear to ensure adequate training and the most satisfactory
solution is probably to provide both general theoretical training
and specialised training in a particular branch or branches of
inspection work, and to supplement such formal training
courses by practical experience acquired under the supervision
of an older inspector.
Employment of Specialists and Technical Experts
The tasks of the labour inspectorate include the supervision not only of legal provisions concerning hours of work,
rest periods, night work, etc., but also of those concerning
conditions of safety, hygiene and welfare in workplaces. The
growth of industry using machinery and the development of
mechanical, chemical, electrical and other processes have made
the problems of safety and health with which the inspectorate
has to deal increasingly complex and difficult.
For these reasons the inspectorate must be able to count
on the services of technical experts and specialists. This need
is usually met either by attaching special technical sections
(consisting, for example, of doctors, engineers, chemists or
experts in youth problems) to the central service, or by including
technical specialists in the staffs of the various district branches.
Complementary arrangements may also be made whereby the
inspectorate secures the co-operation of laboratory or research
specialists who do not belong to the inspection service itself
but may be attached to other government departments (the
Ministry of Health, for example).
Whatever the arrangements made in this regard, however,
the general labour inspector should be given sufficient technical
training to be able to detect possible dangers to the workers'
safety and health in the course of his routine inspection work,
and to appreciate the need for calling upon the services of

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GUIDE FOR LABOUR INSPECTORS

specialists when he comes upon complex problems the solution
of which requires specialised skills that he may not himself
possess.
Employment of Women Inspectors
From experience acquired over a considerable period of
time by well-established inspection services, there can be no
doubt that women inspectors must be employed if a high level
of effective protection for women and young workers is to be
maintained. It is a common practice therefore to appoint
women inspectors in districts where the proportion of women
and young workers is high, and to assign special duties to them
in connection with the protection of these categories of workers.
Nevertheless, no distinction should be made between men and
women inspectors ; for example their selection, training, supervisory and regulatory powers, status and conditions of service
should be identical.
Duties of Labour Inspectors
The primary duties of labour inspectors have already
been mentioned. 1 The Labour Inspection Convention, 1947,
goes further and provides that—
Any further duties which may be entrusted to labour inspectors
shall not be such as to interfere with the effective discharge of their
primary duties or to prejudice in any way the authority and impartiality which are necessary to inspectors in their relations with employers
and workers.
This latter provision is of considerable importance for
inspection services in a relatively early stage of development,
since experience has shown that there is often a strong temptation to use the staff of an inspectorate for a variety of extraneous
duties at the expense of the work of visit and inspection. Among
such duties—which may include, for example, the collection of
industrial statistics or the administration of employment
exchanges—particular mention may be made of formal conciliation or arbitration duties in connection with industrial disputes.
When an inspector has to act also as an industrial conciliator or
arbitrator, there is a real danger that he may be tempted to
1

See above, p. 5.

THE LABOUR INSPECTION SERVICE

13

carry out his enforcement duties with some laxity in order to
win the employers' goodwill ; or he may find that, where he
has sided with one of the parties to a dispute, the other party
will tend to regard him with suspicion and to withhold its
confidence and collaboration from him in his capacity as
inspector.
The functions of a labour department are varied and numerous, and must be carried out, to the greatest extent possible,
by skilled personnel whose attention is focused on related and
compatible responsibilities. The assignment to inspection
officials of unrelated or incompatible extraneous duties, for
reasons of convenience in the matter of supervision or because
of the experience they gain in carrying out their principal
duties, should be carefully considered if the work of visit and
inspection is not to be prejudiced.
THE POWERS OF LABOUR INSPECTORS

Labour inspectors must be armed with certain powers to
enable them to carry out their duties effectively. These
essential powers are, briefly, the power of free access to, and
investigation in, workplaces subject to inspection ; the power
to initiate legal measures to enforce compliance and to bring
legal sanctions to bear in the case of serious or repeated breaches
of the law ; and the power to take measures to protect workers
against dangers to their safety and health.
The practical significance of the first power mentioned
above is that the inspector must be entitled to enter undertakings subject to inspection without hindrance and without
having to give previous notice to the employer.
Having entered a workplace, the inspector requires certain
rights of investigation to enable him to see for himself whether
the law is being applied and to observe whether there exist
any dangers to the safety and health of the workers.
Consequently, he is empowered to question the employer or
workers on any matters concerning the application of the
relevant legislation ; to require the management to produce for
his examination any registers, records or other documents the
keeping of which is prescribed by the legal provisions relating
to conditions of work ; to enforce the posting of notices prescribed
by the legal provisions with a view to keeping the workers
2

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GUIDE FOR LABOUR INSPECTORS

informed of conditions of work ; to take or remove, for purposes
of analysis, samples of materials and substances used or handled
in the undertaking ; and to examine the plant, layout,
machinery and other installations to see that adequate measures
are taken to protect the health and safety of the workers.
Finally, there are regulatory powers to be applied if the
inspector observes defects in plant, layout or working methods
which constitute a threat to the health or safety of the workers.
Under this heading falls the necessary power to issue orders
requiring such alterations to the installation or plant as may
be necessary to secure compliance with protective provisions,
such orders to be carried out within a specified time limit or,
where imminent danger is present, immediately. Depending
upon ,the administrative or judicial practice of a country, the
power to issue regulatory orders may be exercised directly by
the labour inspector or, on the information he supplies, by
another authority, usually the regional or central headquarters
of the service.1
In the application of these basic powers there must be
certain modifying safeguards, prescribed by law or by knowledge of what is good practice. Thus, while the inspector has
the right to enter workplaces without giving advance notice to
the employer, it is reasonable and proper that he should normally
notify the employer or his representative when carrying out a
visit of inspection. Again, the employer should be notified if
samples of materials and substances used or handled in the
undertaking are removed for analysis. And, finally, employers
should have the right to appeal to a judicial or administrative
authority against a regulatory order that they may consider
unjustified or illegal.
MEASURES TO FACILITATE INSPECTION

The granting to labour inspectors of specific powers of
entry and investigation is not in itself sufficient to ensure
effective supervision.
There can be no doubt that the work of supervision is
appreciably facilitated when the inspectorate is kept regularly
informed of the existence of undertakings that may be subject
1

See also pp. 21-22 below.

THE LABOUR INSPECTION

SERVICE

15

to inspection. This problem may be handled in such a variety
of ways, depending largely upon the administrative or legal
practice of a particular country, that no generally valid solution
can be indicated. The practice may be to require any person
who proposes to open an establishment, or to take one over,
or to make substantial changes in the nature of his business,
to notify the inspectorate accordingly. Such an arrangement
may be general in scope or it may apply solely to establishments
of such a nature that they require supervision from the point
of view of safety and health, or to establishments involving
special dangers on account of the operations performed or the
plant used. Another method sometimes employed is to require
persons opening new establishments to obtain an industrial
permit or certificate of registration from some general or
municipal authority other than the inspectorate, in which case
an administrative arrangement is made whereby the industrial
registration authority informs the inspectorate. Or, again, the
requisite information is transmitted to the inspection service
by a social insurance institution.
Not only should the inspectorate be notified of the existence
of workplaces but it should also be given an opportunity to
examine plans for new establishments, plant or processes of
production so that it may advise whether due account has
been taken of safety and health requirements. In a substantial
number of countries such plans may be carried into effect
only on condition that alterations ordered by the inspectorate
for the purpose of securing the health and safety of the workers
are made. The major reason for such an arrangement is that
it is much easier to make the required changes in the plans
than in premises already built or in construction, or in fixed
installations after an establishment has begun operating.
In the actual work of supervision the labour inspector
needs some degree of positive help from the parties concerned
to facilitate his task of checking compliance with the legal
requirements. In particular, certain records essential to inspection must be kept by employers and made available to the
inspector for examination. While here, too, the situation will
necessarily differ from country to country, it is possible to call
attention to the more common requirements, which experience
would seem to indicate are the essential minimum. These
include :

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GUIDE FOR LABOUR INSPECTORS

(a) staff lists and registers, showing the name, age, sex
and occupation of the workers ;
(b) records of all young workers under a specified age
(e.g., 18 years) ;
(c) records of hours of work and wages, including hours
of beginning and ending work each day, the time allowed for
meals and rest breaks, the weekly rest day and, in respect of
each worker, the total number of hours worked each week,
gross earnings, deductions from wages and the net amount of
wages paid ;
(d) accident records, showing the date of each accident,
the name of the person involved, his work assignment and duties
engaged in at the time of accident, the location of the accident,
its probable cause, time lost from work, the nature of the injury,
and the disposal of the case.
Furthermore, with regard to accidents, it is of great
importance that notice be given promptly to the local branch
of the inspection service so that an expert investigation may
be carried out into the nature and causes of the accident and
measures taken to prevent recurrence.

The inspectorate should

similarly be informed of cases of occupational disease.
Another aid to enforcement, although not of direct assistance to the inspector himself, is to require the posting of
certain notices in workplaces to inform the workers concerned
of such particulars as scheduled hours of work, shift arrangements, place and date of wage payments, and works regulations,
or of the name and address of the labour inspector for the district ; or to bring to their notice the texts or abstracts of certain
laws or matters connected with health and safety. For the
labour inspector, the effect of measures of this kind is that
workers will be better informed and hence in a better position
to collaborate in the enforcement of the legal provisions.
Methods and Standards of Inspection
METHODS OF INSPECTION

In carrying out his main duty—that of visiting workplaces
and investigating the conditions under which the legal provisions are applied—the inspector can initiate the application of

THE LABOUR INSPECTION SERVICE

17

legal sanctions in cases where he notes violations of the regulations, or he can persuade an employer to comply voluntarily and
spontaneously with the legal requirements by giving him expert
advice and assistance in understanding the provisions of the
law and the means of complying with them.
Both of these conceptions of the inspector's approach to
his responsibilities are important and useful, and neither should
be relied upon to the exclusion of the other. The use of repressive measures alone would be likely to create and maintain
among employers a state of hostility towards the inspection
service and labour legislation, which would prejudice the
enforcement of the law and might well create a source of irritation in relations between employers and workers. On the other
hand, exclusive reliance upon persuasion is also open to criticism,
since the absence of compulsion would not give guarantees of
uniform enforcement of the regulations and would favour
deliberate transgressors at the expense of the workers and of
those employers who faithfully carry out their obligations.
The most effective practice is to lay particular stress on
promoting understanding of sound labour conditions and of
the legal provisions, and on informing and advising employers
and workers of the most effective means of complying with
their legal obligations. At the same time, the way is left open
for repressive measures to be applied, if unavoidable, in cases
of serious or repeated offences and obviously intentional
violation.
This approach to the work of inspection lays great responsibility on the inspector and on his personal appraisal of a particular situation. Its successful application depends in large
part on his technical skill, impartiality and tact, and is a measure
of his ability to convince employers and workers that he can
assist them to secure practical application of the law and to
improve labour conditions in general.
EFFICIENCY OF INSPECTION VISITS

Without efficient visits of inspection the law would remain
a dead letter and the protection afforded to the workers would
be an illusion. The efficiency of inspection visits depends on
a number of factors already mentioned, such as the inspector's personal qualities of skill and tact and the measures

18

GUIDE FOR LABOUR

INSPECTORS

taken to facilitate the work of inspection, as well as on other
factors which should not be overlooked or neglected.
One of these is the degree of education of workers and
employers with regard to labour legislation, hygiene and safety,
for the value of the inspector's advice and recommendations
increases in proportion to the understanding shown by employers
and workers. The latter often do not take health or safety
precautions because they are not fully aware of the dangers
that may exist and the necessary preventive measures they
should apply ; or, being aware of dangers, they fail to take
precautions because of apathy or a feeling that the danger is
not personal. Moreover, a lack of knowledge of the law on the
part of workers may lead them to make unfounded complaints
the investigation of which is a waste of time.
Other factors that influence the value of visits are the
judicious selection by the inspector of the time of year, the day,
or the hour at which they are made ; their unexpectedness ;
and their duration and thoroughness. Visits to seasonal
establishments during a slack season are of little value since
it is during periods of full activity that there is a risk that the
rules concerning rest periods will be violated ; moreover the
possibility that daily hours of work may be extended beyond
the statutory limit arises more particularly at the beginning or
end of work spells, depending on the timetable of each establishment. If a visit is to be effective, it must be unexpected as
there are many violations that cannot be discovered if previous
notice of the visit is given. This is the case, for example, with
regard to violations of regulations concerning hours of work,
the minimum age for employment, and the employment of
women and young persons on dangerous or unhealthy operations
prohibited by law. Finally, the time devoted by the inspector
to the visit also has an influence on the standard of inspection.
Short visits, unless they are made for a specific and limited
purpose, are generally useless and often involve an excessive
loss of time in travel. No inspector, however experienced,
can in the course of a cursory inspection cover all the points
with which he is expected to deal ; moreover, in such a case,
his personal educational and advisory influence on the management of the undertaking can scarcely make itself felt.
It should be kept in mind that the inspector's effective
working time is the time spent in the actual visit to workplaces

T H E LABOUR INSPECTION SERVICE

19

under his supervision. Travel and the performance of certain
administrative and clerical duties, while necessary and unavoidable, reduce the time available for carrying out this basic task.
A useful criterion which may be suggested is that at least
three-fourths of the inspector's working time should be devoted
to the actual work of visit and inspection, and no more than
one-fourth to travel and administrative duties.
FREQUENCY OF INSPECTION VISITS

The standard of enforcement of labour legislation depends
not only on the methods of inspection and the degree of efficiency of the visits but also on their frequency. If routine
visits are not carried out at sufficiently frequent intervals, if
check visits are not made regularly to see that the measures
ordered by an inspector are being carried out, or if accidents,
occupational diseases and complaints are investigated only
after undue delay or at irregular intervals, the work of inspection will be largely ineffective. Moreover, irregularity in
the enforcement of labour law creates inequalities in conditions of production from which the employers who faithfully
observe the law are the first to suffer.
No particular problem arises in the case of a special visit
to check compliance with an order issued by the inspector,
since such orders usually lay down a final date for compliance,
and it follows that the visit should be made within a reasonably
short time after that date has passed. With regard to the
investigation of complaints there is likewise little difficulty in
prescribing a standard ; complaints that appear to be wellfounded should be looked into with little delay. Again, the
investigation of an accident or cases of occupational disease
should be accorded a high priority.
It is difficult, on the other hand, to define a standard of
frequency for routine visits of inspection. This question
may be approached in either of two ways. The standard may
be expressed in chronological terms, requiring establishments
to be visited, say, once a year at least ; or it may be expressed
in terms of need, requiring workplaces to be inspected " as
often . . . as is necessary to ensure the effective application of
the relevant legal provisions ". The latter, in fact, is the
standard adopted in the Labour Inspection Convention, 1947,

20

GUIDE FOR LABOUR INSPECTORS

and appears to be the criterion most commonly employed in
inspection services with long experience and proved effectiveness.
The practical application of this standard depends in
large part on the judgment and initiative of the inspection
staff stationed at the local branches of the service. It means
that, once priority demands have been met (e.g., investigation of accidents and occupational diseases and of complaints),
a decision has to be taken on the relative needs for routine
investigation among the establishments coming under the supervision of the service. The most effective solution to this
problem appears to be to concentrate inspections in the first
place on establishments that carry on operations involving a
high degree of risk to safety or health, and on those with a
record of serious violations of the legal provisions.
COLLABORATION WITH EMPLOYERS AND WORKERS

There can be no question that the active assistance and
co-operation of employers and workers are of paramount
importance in the work of supervising the application of labour
law. It is certainly valuable for inspectors to profit by the
practical knowledge of those directly concerned in production,
and both management and labour will have greater confidence
in the work of the inspectorate if they feel that they share in
the work and are not merely regarded as passive objects of
inspection. It is therefore important that the parties concerned should be given an opportunity to express their opinions,
bring forward suggestions and even take an active part in the
work of inspection.
Some forms of co-operation have already been mentioned—
i.e., the notification of complaints alleging abuses, the maintenance of records and registers, the notification of accidents, etc.
There are, in addition, arrangements designed to encourage
active collaboration between employers and workers in improving conditions affecting health and safety conditions, and
between these parties and the inspectorate. There is a wellestablished and spreading tendency towards the formation of
safety committees or similar bodies within each undertaking
or establishment, comprising representatives of the employers
and workers concerned. In some cases the establishment of
such bodies may be required by law, in others they are set up

THE LABOUR INSPECTION SERVICE

21

voluntarily by the parties concerned. In either case their
functions generally include direct collaboration with labour
inspectors in their investigatory work and, more particularly,
in connection with inquiries into industrial accidents or occupational diseases.1
Another form of collaboration is to organise conferences
or joint committees where officials of the inspectorate discuss
questions concerning the enforcement of labour legislation
and the health and safety of workers with employers' and
workers' organisations, or their representatives. Still another
is to make arrangements for informing employers and workers,
by means of lectures, posters, pamphlets and films and through
special safety and health exhibitions, of the provisions of labour
legislation, methods of application and measures for preventing
industrial accidents and occupational diseases.
Enforcement Measures
As has been mentioned the inspection service aims in the
first instance at securing voluntary compliance with the law
by assisting employers and workers to understand the legal
requirements and by giving them useful and practical advice on
the best means of compliance. In spite of this primary consideration, however, the service must be capable of enforcing
compliance by applying legal penalties when efforts to secure
voluntary compliance fail—i.e., in the case of deliberate, repeated
or serious violations. Moreover, because of the wide range of
possible offences, a system of warnings and orders must be
interposed between these two extremes of persuasion and legal
sanctions.
A common practice in this regard is for the labour inspector
to issue a warning in all cases of minor offences (and exceptionally in the case of a serious offence) with a view to avoiding
unnecessary litigation. Related to this is the power of the
inspector to issue an order requiring remedy of a defect that
may constitute a threat to the health or safety of the workers ;
such orders prescribe a time limit for compliance or, in the
event of imminent danger to health or safety, may have immediate executory force.
1

See also pp. 98-101.

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GUIDE FOR LABOUR INSPECTORS

It will be readily apparent that recourse to such enforcement measures, i.e., warnings, orders and legal sanctions,
depends in large part on the personal judgment of the inspector
as to the seriousness of an offence, the intention of the offender
(e.g., the possibility of recurrence) and the risk to safety or
health involved. While the central administration of the service can lay down general principles to guide the inspector,
these would be recognised as applicable largely in respect of
extreme cases of serious or deliberate violation. More often
than not, however, the inspector would probably be confronted
with cases which fall short of being extreme and in which he
would have to apply his own judgment as to the action most
likely to yield maximum results. These results should be
measured not in terms of penalties but rather in the degree of
success achieved by the inspector in promoting willingness to
correct abuses and introduce improvements.
Labour Inspection Reports
There are two types of general report in use in well-established inspection services : the reports made periodically by
the labour inspectors on their supervisory work, their observations and results obtained, and annual reports published by
the service on the work of inspection as a whole.
INSPECTORS' REPORTS

To enable the central inspection authority to exercise
constant supervision over enforcement throughout the national
territory and thereby to ensure uniformity in the norms of
application, inspectors should keep their superiors regularly
informed of their activities and observations. The information to be given, the administrative procedures involved and
the prescribed periodicity for submitting reports will necessarily
vary from country to country. Nevertheless, it is possible
to sketch in broad outline some of the essential principles.
Whether inspectors' reports should be submitted daily,
weekly or monthly, or at some other convenient interval, is a
matter for decision by the central inspection authority, but in
any case it seems clear that reports should be submitted as
often as possible, though their quality should not be sacrificed
to their frequency. Moreover, inspectors should be required

THE LABOUR INSPECTION

SERVICE

23

to draw up their reports according to a prescribed plan—that is,
to use forms elaborated by the central authority for the purpose. This considerably simplifies the administrative work
of the inspectors themselves and facilitates supervision by the
central authority.
With regard to the particulars of inspectors' reports, it
seems essential in the first instance to prescribe a general form
for routine or regular visits of inspection. The information
to be recorded on such a form may be approximately as follows :
(a) identification of the establishment visited (including
name, address, ownership and nature of business), and the
number of workers employed (classified by sex and age—i.e.,
if above or below a prescribed age limit) ;
(b) a summary of the inspector's investigations, including
references to each of the matters within his competence (e.g.
hours of work, rest breaks, weekly rest, the various regulated
aspects of the conditions under which young persons and women
are employed, medical examination, health hazards, sanitation,
ventilation, lighting, guarding of machinery and moving apparatus, personal protective equipment, the posting of schedules
and notices, record keeping), together with indications of the
inspector's observations, any violations that may have been
noted, and warnings or orders issued to make needed corrections ;
(c) administrative details of the inspection visit (e.g.,
the inspector's name, the date and time of the visit, the names
of persons interviewed).
In addition to this basic general report, the record system
of an inspectorate usually comprises such special reports as
may be required by the particular circumstances of the service,
its organisation and its administrative practice. These may
include, for example, report forms dealing specifically with
the employment of children, hours of work, and wages, which
are generally used in cases of violation and are designed to
record the observations of the inspector in greater detail than
is possible on the general report form. Still other special
types of report may be prescribed in respect of accident and
occupational disease investigations, follow-up inspections (i.e.,
to check compliance with orders requiring correction of a situation observed on a previous visit) and the investigation of complaints.

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GUIDE FOR LABOUR INSPECTORS

Internal reporting procedures should be kept as simple
as possible consistent with the needs and circumstances of the
service, so that inspectors can devote the greater part of their
time to the actual work of inspection.
ANNUAL REPORTS OF THE INSPECTION SERVICE

The internal reporting system of the inspectorate is not
only important for the proper administrative functioning of
the service and for ensuring uniformity of supervision : it also
provides the material needed by the central authority to compile a general report on the activities of the service as a whole.
Such reports, usually published annually, have both national
and international significance. Nationally, they enable the
public (e.g., employers' and workers' organisations, social
welfare institutions) and the legislative authorities to judge
whether, and to what extent, the legislation for the protection
of workers is really being applied, what points are not adequately
covered by the existing legislation, and what legislative action
is needed to correct abuses. They also provide material for
the international comparison of real labour standards (as distinct
from the theoretical standard indicated by the provisions of the
laws), which can be revealed only by inspection, and permit
those concerned to compare experience, to draw useful conclusions with a view to improving their own methods of enforcement, and promote the adoption of effective preventive measures.
As regards the substance of annual reports, which depends
to a large extent on the scope and content of the laws enforceable
by the inspection service, article 21 of the Labour Inspection
Convention, 1947, provides that—
The anual report published by the central inspection authority
shall deal with the following and other relevant subjects in so far as
they are under the control of the said authority :
(a) laws and regulations relevant to the work of the inspection
service ;
(b) staff of the labour inspection service ;
(c) statistics of workplaces liable to inspection and the number of
workers employed therein ;
(d) statistics of inspection visits ;
(e) statistics of violations and penalties imposed ;
(f) statistics of industrial accidents ;
(g) statistics of occupational diseases.

THE LABOUR INSPECTION

SERVICE

25

Collaboration with Other Authorities and Bodies
Mention has already been made of the collaboration of
employers and workers with labour inspectors, at the level of
the workplace and in connection with the actual work of inspection. Full advantage should similarly be taken of every
opportunity to promote collaboration between the labour
inspection service and other authorities and bodies ; strictly
speaking such collaboration does not enter into the internal
organisation of the service, but it is nevertheless of valuable
assistance in the elaboration and application of labour standards
and in educating employers and workers, and the public in
general, on such matters.
Public authorities with responsibilities and functions related
to the work of the inspection service may include employment
exchange services, educational authorities, health authorities,
social insurance and workmen's compensation funds, various
types of social welfare services, etc. Collaboration between
such authorities and the inspectorate in the solution of problems
of mutual concern is a widely recognised asset of great value,
which should be promoted locally, regionally or nationally,
according to circumstances.
Any opportunity for useful collaboration with non-governmental bodies should likewise be seized. One outstanding
example of such collaboration is the work that the central
authority may do with national organisations of employers
and workers in elaborating and applying protective labour
standards—in particular, safety and health standards for
specific industries. There may also be voluntary or private
bodies such as national safety organisations, associations
interested in youth problems or social welfare, scientific and
technical associations, standards institutions and companies
issuing insurance against a variety of industrial risks : the
central administration should be active in promoting effective
co-operation with all such groups having research and educational interests in industrial and social problems.

PART II
INSPECTION RULES AND PROCEDURES
In order to carry out his duties the labour inspector must
himself be fully familiar with the purpose and content of the
legal provisions he is responsible for enforcing and with the
most effective means of complying with them. He should, so
far as possible, familiarise himself with the problems and
operations of the establishments he has to inspect, so that his
advice on measures needed to protect workers from industrial
hazards will be practical. He must be able to explain why
legislation has had to be enacted ; the benefits in lower costs of
production, higher productivity and improved relations to be
derived from the application of sound labour standards ; the
role of the labour authority in enforcing the law ; and how
management and workers can co-operate to make more secure
the safety, health and welfare of the workers.
Success in this work depends not only on the inspector's
technical skills and knowledge but on his personal judgment
and qualities of tact, impartiality and integrity. All these
factors bear directly and substantially on the inspector's success
in inspiring the full confidence of employers and workers in
his ability to help them achieve the purposes of protective
labour laws and regulations.
In accomplishing these purposes, the labour inspector
performs a social mission of the highest importance to the
interests of management, workers and the general community.
He is not a routine official carrying out a routine task : as an
enforcement officer and an expert and trusted adviser of labour
and management, the inspector has a substantial contribution
to make to the economic and social life of his community, both
local and national.

INSPECTION RULES AND PROCEDURES

27

General Rules
CONDUCT AND OBLIGATIONS OF LABOUR INSPECTORS

It is of paramount importance that the inspector should
at all times conduct his relations with employers and workers
in a courteous and tactful manner. At no time should he
express to employers or workers any disagreement with or
criticism of the legal provisions he has to enforce or the
administrative instructions prescribed by his supervisors. Any
suggestions concerning the legal standards or administrative
procedures should be made to the inspector's supervisors, who
will give them the fullest consideration.
Similarly, the inspector should at all times bear in mind
that the provisions of the law establish minimum requirements
that may not be abated through action taken by private persons,
either as individuals or in a body. He cannot accept as a possible
defence the excuse that an agreement, individual or collective,
exists providing for standards lower than those prescribed by
law.
The inspector's work demands the application of his full
time and interests. He cannot attempt to carry on another
occupation or business and at the same time give full attention
to his official duties. Moreover, his impartiality would be
seriously jeopardised if he had a personal interest in any workplace to which his responsibility extends. Inspectors are
accordingly prohibited from having any direct or indirect
interest in the undertakings under their supervision.
The inspector must strictly observe the rule of professional
secrecy. In the course of his duties, he enters workplaces,
examines wage and employment records and observes machinery,
appliances and processes of production. The individuals and
undertakings concerned are entitled to the fullest assurance
against the unwarranted disclosure of information obtained in
this way. Consequently, inspectors are bound not to reveal,
even after leaving the service, any manufacturing or commercial
secrets or working processes that may come to their knowledge
in the course of their duties.
Moreover, it is important that persons, and in particular
workers, who give information to labour inspectors, or who
bring complaints alleging that a defect exists or that a legal

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GUIDE FOR LABOUR INSPECTORS

provision is being violated, should not be exposed to retaliation
or disadvantages. The inspector must treat the source of such
information or complaint as absolutely confidential ; he should
not even give the employer any intimation that a visit of inspection was made in consequence of a complaint.
It is obvious that a labour inspector cannot accept gifts,
services or favours from either employers or workers. The
acceptance of objects of even small material value or of special
services (such as the purchase of an article at a discount not
extended to the general consuming public) may be construed
as evidence of an improper relationship and thus destroy the
reputation of the inspector for impartiality. Inspectors must
therefore firmly refuse any offer of gifts, services or special
favours from employers or workers.
INSPECTION VISITS

The inspector should at all times carry the official credentials
issued to him by the service, since they attest his rights and
powers of visit, inspection and investigation. In carrying out
visits of inspection he should, for general purposes, be equipped
with copies of the laws and regulations enforceable by the
inspection authority, explanatory pamphlets and similar publications, where such exist, the prescribed record and report forms
and forms of posted notices.
Regular and Special Visits
Inspection visits may be divided into two kinds : (1) visits
of routine inspection, and (2) special visits—i.e., check visits,
visits of reinspection, investigation of complaints and investigations of accidents and occupational diseases.
In a routine visit of inspection the inspector examines
employment records, registers or documents that the employer
is required by law to maintain, visits all the premises where
work is performed, and investigates the conditions under which
the legal provisions for the protection of workers are applied.
With this object in view he observes general working conditions,
the specific conditions of hygiene, safety and welfare prescribed
by law either generally or in certain types of industry or for
certain classes of workers, and compliance with provisions
regulating the employment of workers in occupations classified

INSPECTION RULES AND PROCEDURES

29

as dangerous or unhealthy, where such regulations exist. He
also sees that the notices required by law are duly posted up
for the information of the workers. He asks for such information as he considers necessary, from the employer or from
workers, on any matters concerning the observance of laws
and regulations.
In making a special visit the inspector has a particular
purpose in view, which may be to check compliance with certain
specific legal provisions ; to ascertain what action has been
taken to give effect to recommendations or orders made on a
previous visit ; to investigate the causes of an accident and
take measures to prevent the recurrence of similar cases ; or
to investigate a complaint. As regards complaints alleging violation of the law, two general rules apply : they should be treated
as confidential and they should be investigated. If there is a
dispute about the facts and the inspector feels it may be
necessary to disclose the name of the complainant, he should

first obtain the latter's permission to do so, if possible in writing.
If permission is refused the inspector should in no case disclose
the identity of the complainant. Every complaint should be
investigated unless the allegations made are clearly insufficient
to support a charge of violation of the law. This also applies
to anonymous complaints. The investigation of a complaint
should be carried out and reported in the same manner as a
regular inspection.
Timing of Visits
As a rule a routine visit of inspection should be carried out
during the ordinary working hours of an establishment. However, if the inspector has cause to suspect the existence of
violations at other times of the day or night—for example,
illegal overtime or night work, work performed illegally on the
weekly rest day, or the employment of children at proscribed
hours—the visit should be made at a time when the situation
can be investigated. If more than one shift is worked in the
establishment a visit should, if possible, be made during each shift.
In the case of industries or establishments that are
particularly busy at certain times of the year, the regular
inspection visit should normally be made at seasonal or peak
periods of employment, since violations are more likely to
occur at such times than during slack seasons.
3

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GUIDE FOR LABOUR

INSPECTORS

If new laws or regulations are adopted that apply to a
particular industry or type of establishment, inspection should
be concentrated on that industry or those establishments in
the period immediately following such adoption ; and the efforts
of the inspector should largely be devoted to instructing the
persons concerned on the requirements established by the new
legal provisions and how best to comply with them.
Notice of Visits
In normal circumstances the inspector should not inform
an employer in advance that an inspection visit will be made.
A previously announced visit may make it possible to conceal
violations of regulations relating, for example, to minimumage requirements, prohibition of night work, and hours of work.
In some cases notice to the employer that a visit will
be made may be unavoidable for practical reasons. In rural
districts, for example, an inspector who has no personal means
of quick transport may have to arrange for transport to be
provided by the management of an undertaking. Or, again,
the layout of premises m a y be such t h a t the inspector cannot

expect to make a surprise visit.
In either case, upon entering an establishment the
inspector's normal practice should be to address himself to
someone in authority—the employer or his representative—to
whom he should show his credentials and explain the purpose of
his visit. In exceptional circumstances (for example if the inspector has reason to believe that the normal procedure may result
in concealing an abuse) he may decide to examine the working
premises before addressing himself to a person in authority.
Order of Inspection
It is not possible to suggest an order of inspection adapted
to all situations. The inspector has to judge for himself
whether he should first examine conditions in the working
areas of an undertaking or inspect records and documents.
If he is not already familiar with the undertaking from his
previous visits, or if he considers it desirable to interview a
number of workers before examining the records, he may wish
to visit the working areas first. On the other hand he may
decide to inspect the records first if his previous experience

INSPECTION RULES AND PROCEDURES

31

with the undertaking indicates that they are complete and
accurate, or if he suspects that the employer may otherwise
be able to conceal evidence of violation.
In the course of the inspection visit to the working areas
of the undertaking the inspector may, should he think it
desirable, ask to be accompanied by the employer, manager
or other responsible person so that any necessary changes may
be explained to someone with sufficient authority to take action
in the matter ; and, in cases in which a joint works council
or safety committee or similar body exists, by one or more
workers' representatives on such bodies.
First Inspection Visit
If properly carried out the first visit by an inspector to
an establishment that has not previously been visited, or the
management of which is new, can greatly influence the attitude
of the employer towards the service.
The inspector should present himself to the employer at
the outset of the visit, show his credentials and explain the
purpose of the visit. He should, moreover, take the time to
outline the scope of his inspection activities, including the
examination of records, interviews with workers and examination of the working areas and processes, and be prepared, if
necessary, to give detailed information concerning the legal
requirements. He should try to make it clear that the purpose
of his mission is to ensure that the law is applied and that, to
this end, he is prepared to furnish the employer with all necessary
information and advice to assist him in complying with his
obligations.
After the inspector has made the initial visit, he should
discuss his findings with the employer, pointing out any shortcomings he may have observed, and offer advice on needed
improvements. It should be noted, however, that this suggested
procedure does not affect the inspector's obligation to make a
full report on the visit and to initiate administrative procedures
in case of serious or wilful violations.
The extra time and care with which the first visit of inspection is carried out will be amply repaid if it results in establishing
a firm basis of respect for the inspector's mission and confidence
in his personal capacity.

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GUIDE FOR LABOUR

INSPECTORS

Closing the Inspection Visit
As in the case of a first visit it is a useful practice for the
labour inspector to inform the employer or his representative of
his findings, explain what specific action may be needed to
eliminate any violations he may have observed, and furnish
any appropriate or pertinent informative material, such as
copies or extracts of the labour laws, interpretations, posters,
etc. However, at such discussions the inspector should not
undertake prolonged negotiations concerning future compliance,
nor should he, except in the case of minor offences, discuss
evidence of violations observed. Furthermore, such discussions
in no way affect the inspector's obligation to submit the prescribed reports on his inspection visit.
Inspectors' Reports
Every visit of inspection, whether routine or special, and
regardless of the outcome of the visit, must be reported by the
inspector to his supervisors. These reports enable the central
authority to exercise over-all direction and control of the
enforcement activities of inspectors, and thereby ensure uniformity in inspection standards and practices. They also form a
reliable statement of the inspector's observations in the event
that further action by a higher administrative authority is
necessary. And they provide a concrete basis for judging the
real standard of protection afforded by the inspection service
and progress made in the administration of the social policy
of the State.
In order to facilitate supervision by the central administration, ensure comparability and simplify the administrative work
of inspectors, standard forms are prescribed, together with
instructions on their use.
General Inspection Procedures
The inspection procedures indicated below are classified
for convenience under separate headings relating to hours of
work and related questions, wages, and the employment of young
persons and women. Although each is thus dealt with separately,

INSPECTION RULES AND PROCEDURES

33

the implication is not intended that a separation is to be
maintained in following these procedures. While reference to
the examination of various types of registers, records and other
documents and to the interviewing of workers is made under
more than one heading, the inspector in carrying out an
investigation may well examine records and interview workers
in respect of more than one subject at the same time (e.g.
hours of work and wages).
The thoroughness with which these procedures should be
applied rests in the last analysis on the judgment of the inspector
with regard to the situation in each undertaking. In a great
number of cases the inspector may be reasonably sure from
previous inspection visits that the legal provisions are faithfully applied and that it is therefore not necessary to follow
the procedures fully. In other circumstances, however, such
as a visit to an undertaking with a previous record of repeated
or intentional violations or to an undertaking which has not
previously been visited, the inspector should apply them.
It should be remembered that the inspector's primary aim
is to help employers and workers to understand and comply with
the legal requirements. The object of these inspection procedures
is largely to determine how well the law is being applied, and
thus to serve as a basis for further action by the inspection service. If the inspector should find, for example, that an employer,
through lack of knowledge of the legal requirements and the
means of applying them, commits a relatively minor violation of
record keeping, the inspector should undertake to explain what
the requirements are and how the situation may be improved.
The procedure for applying legal sanctions should be initiated
only if these efforts prove unsuccessful and the inspector reaches
the conclusion that failure in compliance is deliberate and is
likely to be repeated.
HOURS OF WORK AND RELATED QUESTIONS

The various aspects of this group of questions include
normal and maximum limits on hours of work, shift work,
night work, rest periods, meal breaks, weekly rest and annual
and public holidays, to the extent that there may exist legal
provisions on these matters enforceable by the labour
inspectorate.

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GUIDE FOR LABOUR INSPECTORS

The inspector can ascertain whether the legal provisions
in question are effectively applied mainly in two ways : (1) by
examining the records, registers or other documents required
by law to be maintained by the employer, and (2) by interviewing
a representative number of workers in the undertaking with a
view to checking the accuracy of the records. Where records
are not complete or are thought to be inaccurate, it is all the
more important to interview workers.
Examination of Records, Registers and Other Documents
The inspector's examination of records should start with
the current or most recent pay period, and work backward
from that point, preferably to the last pay period examined
in the last preceding visit. If the time available for the visit
does not permit him to check all the records concerned, he should
in any case examine those covering a sufficiently representative
number of pay periods. If the undertaking is one that has
fluctuating periods of activity, the inspector should be sure to
examine the records for peak or busy periods as it is at such
times that violations are more likely to occur.
The inspector's examination of hours records should, of
course, be guided by the relevant legal provisions. If, for
example, hours of work are regulated on a daily or weekly
basis, his interest lies in ascertaining the number of hours
worked per day or per week and in determining whether they
are in accordance with the law. Similarly, his examination
should be guided by the legal provisions in respect of such
related aspects as shift arrangements, general and particular
(e.g., for women workers), limitations on night work, rest
and meal breaks, etc.
If the employer is required to post schedules for the notice
of the workers, showing hours of work, rest and meal breaks,
shift arrangements, weekly rest days, etc., the inspector should
compare details of the records with those indicated on the posted
notices. If the time records are not complete a useful practice
is to compare them with the records of wages paid, as wage
payments in excess of normal amounts may indicate the working
of illegal overtime.
Where the examination of time records indicates the
existence of a violation, the inspector should make a full and

INSPECTION RULES AND

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35

accurate copy of the details for inclusion in his report of the
visit.
Finally, the inspector may have reason to believe that illegal
overtime or night work is being carried out and that he cannot
check the situation by examination of the time records alone.
In such a case, the inspector should make a check visit to the
undertaking before or after the regular working hours.
Interviewing Workers
One means of checking compliance with the legal requirements and the accuracy of time records is for the inspector
to interview a number of workers. Normally, these interviews
take place in the undertaking as part of the inspection visit,
but in special circumstances the inspector may hold them
outside the workplace, at his office or at a worker's home. If
the interviews take place in the undertaking, the inspector
should speak with a sufficient number of workers to make it
impossible for any individual giving information of a violation
to be indentified for reprisal. If the inspector decides to
interview workers outside normal working hours and outside
the undertaking, he may obtain names and addresses for this
purpose from the employment records of the undertaking ; but
here also he should take care not to identify to the employer
the workers selected for interview.
Such interviews are useful in connection with a wide range
of legal regulations concerning hours of work and related
subjects. For example, a record of the time allowed for meal
or rest breaks would not be in itself sufficient for inspection
purposes ; the inspector can confirm the actual practice followed
in the establishment only by speaking to a number of workers
employed there. This procedure is equally useful in connection
with night work limitations (both those of a general nature and
those applying particularly to special classes of workers—e.g.,
young persons and women), shift arrangements, weekly rest, etc.
Finally, it may be recalled that the interviewing of workers
assumes increased importance as a means of supervising application of the legal provisions if the employer is not required to
keep time records adequate for this purpose, or if the records
kept are not so detailed or complete as to satisfy the inspector
that the law is faithfully applied.

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Posting of Schedules, Notices, etc.
The principal object in requiring employers to post notices
or schedules of hours of work, rest breaks, meal times, shift
arrangements, etc., is to inform workers of their conditions of
work in these respects. The inspector should see that the
required notices are in fact posted in prominent places ; that the
posters are clear and legible and not defaced ; that the official
form, if one is prescribed, is followed ; and that all required
information is given in a readily intelligible manner.
If the schedule is not posted the inspector should see
that the omission is rectified before he leaves the undertaking
and should also mention it in his inspection report.
WAGES

Depending upon the legal provisions to be enforced by the
inspection service, the inspector's responsibilities in respect of
wages may include supervision of prescribed minimum
wage rates ; the time, place and method of wage payments ;
and deductions from wages.
The procedures indicated above for supervising hours of
work and related questions are applicable here, too, and the
inspector should therefore extend his examination of records
and his interviews with workers so as to make a simultaneous
check of wages. Starting with the most recent pay period,
he should check the records of daily or weekly earnings against
hours worked to see that wages are computed and paid in
accordance with the requirements prescribed by law. In the
case of an establishment known from previous visits to have a
good record of compliance, the inspector may be content with
examining only-a representative number of sample pay periods.
In other cases he may consider it justified to make a more complete examination and to interview a number of workers to
secure confirmation of the accuracy of the wage records.
If there is a legal provision requiring that the workers
be informed of the particulars of the wages paid to them (e.g.,
the method of wage calculation and deductions, if any, from
gross earnings), the inspector should examine the procedure
followed in the undertaking to see that it is in conformity
with the law.
Full and accurate details of any violations noted by the

INSPECTION RULES AND PROCEDURES

37

inspector should be taken down and included in his report. In
such cases as incorrectly computed wages or wage payments
lower than the legal minimum, it is important for purposes
of remedial administrative action to have a record of the number of hours worked, the amount of earnings due to the worker
and the amount actually paid.
Requirements for the posting of notices, for purposes
similar to those mentioned above, may cover such subjects as
minimum wage rates, the days on which wages are paid, the
place of payment, etc. It is the inspector's duty to see that
such requirements are properly carried out.
EMPLOYMENT OF YOUNG WORKERS AND WOMEN

The inspection procedures for enforcing the laws and
regulations dealing with the employment of women and young
workers will be similar to those concerned with other branches
of general labour legislation. Some mention must, however,
be made of particular aspects of this type of inspection.
The inspector should take particular care to inform and
advise the employers and employees concerned of their rights
and obligations as laid down by the special legislation governing these groups of workers. He should also be alert to the need
for co-ordinating his work with other agencies interested in the
protection of women and children and, wherever possible,
for referring women and young workers who stand in need of
assistance to the existing social services.
In order to discharge his duties effectively the labour
inspector who has to deal with the work of women and young
persons should have acquired, in addition to the general training
provided for inspection staff, a special knowledge of the problems involved in this particular field of work. He must, of
course, be thoroughly acquainted with the laws and regulations
concerning the work of women and young persons and allied
matters, such as regulations relating to compulsory education
for children and young persons, as well as with the problems
of their application. In addition, he should have a good knowledge of the organisation and operation of other agencies,
such as the employment services, school authorities and public
and private social welfare and health services with which he
will need to co-ordinate his work.

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It may often be of advantage to entrust the supervision
of the protection of women and young workers to a woman
inspector, not only because a woman may have from personal
experience a more intimate knowledge of the problems of women
and youth but also because she may be able to win the confidence of these groups of workers more easily than her male
colleagues.
Inspection Procedures as regards Young Workers
If effective supervision of the laws and regulations dealing
with admission to work and the protection in employment of
young persons is to be assured, the employer must be required
by law or regulations to keep reliable evidence of the young
persons in his employment (including apprentices) and to make
such evidence available for inspection purposes.
This evidence may take the form of a register in which
the employer enters such data as name, date of birth or age,
and sex of the young person, date of entry into employment,
occupation in the undertaking, and details of hours and wages
in accordance with the specific legal provisions that may exist
with regard to young workers.
In addition to the register the employer should be required
to keep on file documents, issued by the competent authorities,
the purpose of which is to prove the age of the child (for instance, birth certificates) and attest the fulfilment of other
requirements that may be prescribed by law, such as compliance with school obligations, consent of the parents or guardian to the employment of the young person, and certification
of physical fitness for the particular employment concerned.
Where apprenticeship regulations exist the apprenticeship
contracts should also be kept on file by the employer.
As regards determination of age, which constitutes a
vital factor in the application of labour legislation concerning
young persons, certain difficulties may arise where the system
of registering births is inadequate or non-existent. Pending
the full development of such registration it will be necessary
to make use of any other available means of determining age,
such as church and school records, medical certificates issued
by a certified physician, etc.
The documentary evidence that the legal requirements

INSPECTION RULES AND

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39

for admission to work (regarding age, schooling and physical
fitness) have been fulfilled may also take the form of a workbook
or employment certificate issued for each young person by the
appropriate authority (e.g., the labour department, the employment service or the school authority) upon initial employment ;
this should be lodged with the employer to keep on file and to
make available for inspection.
As regards the posting by the employer of the timetables
of young workers and of the text of laws and regulations governing their work, inspection procedures will be similar to those
explained above.
Age of Admission to Employ meni.
The abolition of child labour constitutes the primary
objective of all child labour legislation and the effective enforcement of the legal provisions regarding this question will therefore be one of the most important tasks of the inspector.
Where the laws and regulations provide that the employer
should keep the records discussed above, these records should
be carefully examined by the inspector to ascertain that they
are kept as prescribed. In particular, special attention should
be paid to the careful checking of the registers with the employment permits, work books or other documents kept on file
by the employer and attesting the ages of the young persons
employed.
Registers should also be checked directly with the young
employees concerned. For this purpose the inspector may
proceed in two ways. In undertakings which are known to
apply carefully the provisions on minimum ages and records,
the inspector may first examine the record and then check
them by interviewing a number of young workers ; in this
case it may facilitate the inspector's work if he can take
the register or list of young persons with him when going
through the workplace. If, however, the inspector has reason
to suspect violation, he should not waste time checking records
with the risk that evidence may in the meantime be concealed.
He should at once interview young persons at their workplaces,
make notes of the data so collected and then compare them
with the registers or other documents to see whether all juveniles
found working are duly recorded.
Where registers or documents attesting age do not exist,

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or are inadequate, the inspector will have to depend primarily
on information obtained by interviewing young workers. He
should pay special attention to those who seem to be below
the legal age of employment or who claim to be above the age
for which registration is prescribed. Care should also be
taken that no child uses an age certificate belonging to another
or one that has been illegally issued or is fraudulent.
If he suspects a violation the inspector should have power
to require the employer to furnish proof of age within a certain
time and, in serious cases, to dismiss young workers or suspend
their employment until such proof has been provided.
Should violations of the minimum age and recording provisions be revealed, the inspector should try to find out what
steps, if any, were taken to ascertain the age of the child on
his engagement ; and he should discuss with the employer
methods of avoiding such violations in the future. Full details
of contraventions concerning minimum age and recording
provisions should be given in the inspector's report on his
visit.
Moreover, the inspector's duties should not end with the
dismissal of a young person found to be illegally employed.
Measures should be taken to ensure the moral and physical
well-being of such a person by arrangements for his attendance
at school when he is of school age, or by bringing the case to
the attention of the public and private welfare institutions if
poverty was the reason for his premature employment.
Fitness for Employment.
If the national laws and regulations prescribe that young
persons cannot be admitted to work unless found physically fit
through medical examination, the inspector's procedures will
be similar to those used with regard to minimum-age provisions.
He should carefully check the medical certificates kept
on file by the employer and interview the young persons to
ascertain that no one covered by the provisions is working
without having obtained the certificate in question or without
having undergone medical re-examination if that is prescribed
by law.
Where the certificate is issued subject to specified conditions of employment, or is valid only for a particular job or

INSPECTION RULES AND

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41

occupation, the inspector should see to it that the prescribed
conditions are fulfilled and that the child is actually employed
at the specified work.
All violations of the provisions concerning the medical
certificate of fitness for employment should be brought to the
notice of the authority responsible for the issue of such certificates for further action.
If the inspector is of the opinion that the young worker
is, for physical reasons, generally unfit for employment, he
should refer the case to the services from which the young
person may get appropriate medical treatment and such schooling, vocational training and guidance as are needed.
Hazardous Occupations.
In the case of hazardous occupations, too, the inspection
procedures will be closely linked with the checking of the
minimum age for admission to work.
When visiting the working areas of an establishment the
inspector should observe the occupations at which young
persons are engaged to ascertain whether any of them is
employed at work prohibited for a person of his age. The
inspector should also compare the records indicating the occupations of the young persons with the work they are actually
doing.
As regards occupations to which the laws or regulations
admit young persons under a specified age only subject to
safeguarding conditions (such as medical examination, prohibition of employment in hazardous trades, special provisions
respecting hours of work and rest), the labour inspector should
ascertain that these conditions are actually fulfilled. He
should see to it that young persons occupied in hazardous work
that is nevertheless legally permissible for them have received
adequate training in their work and instruction in the danger
involved, and that they work under the supervision of an
experienced older worker.
It will be a great advantage if inspectors have legal authority to suspend employment, or to modify conditions of employment that might be injurious to young workers. Where social
welfare or health services exist in the undertaking itself, their
collaboration will be of great value in assuring that young persons are given suitable work.

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Hours of Work and Rest, Wages, etc.
As regards hours of work, night work, shifts, meal breaks,
holidays, etc., and wages, the inspector should proceed in the
case of young persons in the same way as indicated above for
the inspection of these matters for all workers, having due regard,
however, for the special legal provisions that may exist for
young workers in this connection.
Before inspecting hours and wage conditions, the inspector
should check the ages of the young persons employed in order
to identify those who may be covered by the child labour provisions. When a shorter working day is prescribed for young
workers than for adults, it might afford an additional control
if the inspector inquired what arrangements, such as shift
work of young persons or replacement by another worker, have
been made to carry on with the work performed by the young
person during the hours he himself is not allowed to work. A
similar procedure might be adopted as regards special provisions for young persons in respect of longer night rest, breaks,
annual leave, etc.
Where the law provides that the normal working hours of a
young person should include the time spent at continuation
classes for general or technical education that young persons
are required to attend, it is advisable for the inspector to find
out from the competent school authorities whether the young
persons have actually attended the courses in question during
the hours specified.
If the inspection service is empowered, on special application, to grant permission to employ young persons on overtime
or night work, the inspector should verify whether such exceptions are really necessary and should keep a close record of the
use made of this faculty by the different undertakings.
Apprenticeship.
If the supervision of apprenticeship comes within the
duties of the labour inspector he should examine carefully all
documents that the employer is required to keep with regard
to apprentices working in the undertaking (such as a register
of apprentices, apprenticeship contracts or wage records of
apprentices), and should ascertain that the apprentices have
reached the prescribed minimum age, receive proper train-

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43

ing and enjoy the special protection with regard to hours,
wages, health, etc., prescribed for them. He should also check
whether the proportion of the number of apprentices to the
total number of workers employed in an undertaking corresponds to that laid down by law or regulations.
Special Problems : Small Undertakings, Street Trading,
Public Entertainment.
Special problems of supervision may arise when the inspector has to deal with enforcement of child labour regulations in a great variety of small and scattered industrial and
non-industrial undertakings, including shops, workshops in
houses, etc.
Here it will prove particularly advantageous for effective
application of the child labour provisions if work permits or
workbooks are issued to the young persons and kept by the
employers at the disposal of inspectors, and if these documents
are reissued or officially stamped at each change of employment—a procedure that makes it easy to identify the young
worker, his age and conditions of work.
In the case of employment in street or itinerant trading
or in occupations carried on in public places (cabarets, cafés,
theatres, and the like), inspection will be greatly facilitated
if the young persons concerned are required to obtain from a
competent authority a licence or work permit certifying that
the legal requirements, such as age, education and physical
fitness, have been satisfied and, in addition, are obliged to
wear a badge as a means of showing conspicuously that the
work is exercised in conformity with the legal prescriptions.
It adds to the value of the permit and the badge as instruments of enforcement if both have to be reissued at reasonably
frequent intervals. However, the inspector will hardly be
able to exercise supervision over such scattered places of employment alone, but will have to rely on the extensive collaboration
of such other authorities as the local police, education authorities, public and private social workers and social welfare
organisations concerned with the protection of children.
It is also advisable for the inspector to pay special attention to the investigation of alleged violations of the law reported
by the public or by the teachers or parents of the child or young
person.

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Inspection Procedures as regards Women Workers
As in the case of young workers, inspection of the employment of women will be greatly facilitated if records of female
workers are kept by the employer and held at the disposal of
the inspector. It is most useful for adequate inspection if the
records include detailed information about such items as maternity leave and other legal provisions concerning women as
regards hours and shifts worked, wages, etc.
Materniiy Proteclion.
One of the principal duties of the inspector will be to ensure
the effective application of the legal provisions on maternity
protection.
He should direct his special attention to the rest periods
accorded to women before and after confinement, to the guarantee of reinstatement in employment after maternity leave,
to the payment of maternity benefits, to special arrangements
such as breaks for nursing and crèches, and to the protection
of the health of pregnant and nursing women at work.
From the records kept by the employer or, if they are lacking or inadequate, from information obtained from employers
and workers, the inspector should ascertain which of the women
workers are eligible to benefit by the maternity provisions.
If any of these women is absent, he should ask whether her
absence is due to confinement and, if so, inquire about the
expected date of confinement, the length of leave taken before
confinement, the benefits received by the woman during her
leave and the measures taken to ensure her reinstatement on
her return. It is sometimes advisable for the inspector to
obtain this information from the woman herself, at her home or
in hospital.
When an inspector finds a pregnant woman at work he
should ask her when she intends to take her maternity leave
before confinement where such leave is not compulsory, and
see to it that all legal requirements, such as the notification
of the employer by medical certificate, the visiting of the competent services for prenatal health care, etc., are fulfilled. He
should also check whether the work done by the woman is
prejudicial to her condition and ask for her transfer to lighter
work if necessary.

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45

If the records show that a woman has been dismissed
since the last inspection visit, the inspector should inquire
about the reasons for such dismissal and, if necessary, interview
the woman herself in order to ascertain that she has not been
dismissed for reasons relating to maternity in contravention
of legal provisions guaranteeing her maintenance in employment.
Having ascertained from the records kept by the employer
(or, in default of such records, from personal interviews) which
women have recently come back from maternity leave, the
inspector should investigate whether they are allowed, as
provided by law, to take time off and absent themselves from
work in order to nurse their children, to make use of crèches
existing in the undertaking or in its neighbourhood, etc. The
inspector should also ascertain from payrolls and records of
hours worked whether nursing breaks are counted as working
hours and paid accordingly, if so prescribed by law or regulations. Where employers are required to establish crèches in
their undertakings, the inspector should check the use made
by the women of this facility and, if they do not avail themselves of it as fully as might be expected, should find out the
reason. He should also see whether the crèches are kept in
good sanitary condition.
In general, the inspector should make sure that women
workers are well informed of their rights under maternity protection legislation and know how to benefit by them. Where
a social service exists in the plant, its collaboration in this
matter will be very useful.
In addition, supervision of maternity protection will need
close co-operation with the social insurance system or public
fund responsible for providing benefits. The collaboration of
any other social assistance and health services concerned with
the protection of working mothers and their children may also
prove helpful.
It is evident that a woman inspector would be more suitable
for the supervision of maternity protection.
Hazardous Occupations, Seats, etc.
The inspector should ensure that women are not employed
at occupations prohibited to them as hazardous, or are not
obliged to carry heavy loads exceeding weight limits fixed by
law or regulation. Where their employment in hazardous work
4

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GUIDE FOR LABOUR INSPECTORS

is subject to certain safeguarding conditions concerning health
and safety, such as covering of the hair, medical examination,
sanitary provisions, or special working hours, the inspector
should also see to it that these conditions are duly observed.
If seats must be provided for women workers, the inspector
should ascertain whether there are enough of them, whether
they are of satisfactory construction, and whether the women
can actually make use of them.
Hours of Work and Rest, Wages, etc.
As regards the supervision of women's hours of work, night
work and related questions as well as women's wages, the procedure will be the same as that indicated for all workers with
due regard, of course, to any special provisions that may apply
to women workers. Such special provisions may, for instance,
concern restrictions of overtime, longer or more frequent
breaks between periods of work, longer weekly rest hours and
prohibition of night work (with possible exceptions from it).
Special attention should be paid by the inspector to the
careful checking of records and to individual statements of
women workers in order to ascertain whether the wages paid to
them are in conformity with the provisions as laid down by
legally binding provisions. This will call for the checking of
the minimum rates of wages paid, and, where prescribed by
the existing provisions, of the application of the principle of
equality of remuneration as between men and women workers.
Special Problems : Small

Undertakings.

Special problems of supervision may arise when the
inspector has to visit a great variety of small and scattered
industrial and non-industrial undertakings, including shops,
workshops, etc. The difficulties in connection with supervision
of women workers in such conditions will arise mainly from the
scattered location of workplaces and the fact that the work
is often carried on in private homes. The inspector should
have the same authority to enter workplaces in homes where
persons other than the members of the family are employed,
as he has with regard to any workplaces subject to inspection.
It will greatly facilitate the work of the inspector if the employers
who give out home work are required to send to the inspection
service at regular intervals, for instance once a year, a list of

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47

the homeworkers employed by them during that period. Inspection can then be carried out in the workplaces concerned and
when conditions are found to be unsatisfactory, the inspector
should visit the employer or subcontractor in order to obtain
the necessary changes.
The principal problem with respect to work carried out
in homes is to see that the workers receive the minimum wages
fixed for them by laws and regulations, including, where such
regulations may exist, payment for travelling and waiting
time in calling for and delivering work. The inspector therefore
needs to have access to the wage books of the workers, and to
the registers of homeworkers and the records of payments
kept by the employers. He should interview a representative
sampling of homeworkers in order to determine that the records
are accurate. He should also inquire into such other problems
as illegal labour of children.
I n a d d i t i o n t o t h e s u p e r v i s i o n of w a g e s t h e

inspection

services may also be concerned with industrial hygiene and
safety of homeworkers, for instance, when the laws and regulations prohibit the employer from giving out home work involving
the use of poisonous or dangerous substances. In this field
it might prove useful for the service to have, where possible,
the assistance of the local health services.

Safety and Health Inspection in Industrial Establishments
The purpose of this section is to offer some brief general
advice on the detection of occupational risks in industrial
establishments (as distinct from mines, construction sites and
agricultural undertakings) and to indicate in more detail some
of the commonest specific risks that should be borne in mind
during inspections.1 It would not be practicable to deal with
every risk in every kind of industrial establishment, and no
attempt is made to give guidance as regards the risks of any
special processes, equipment, substances or working conditions.2
1
It is realised t h a t a highly developed labour inspectorate will
include medical, electrical, engineering, chemical and perhaps other
specialists, but it is not within the scope of this guide to discuss in
detail the functions of these specialists.
2
A bibliography of general works on occupational safety and health
is appended.

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This section does, however, deal with some equipment in wide
use and also with general classes of risk such as those from
fire and dangerous substances. It also indicates measures
that industrial establishments themselves can employ to promote
safety and health and so lighten the task of the inspector
(i.e., through the creation of a plant health and safety organisation).
Lastly, mention is made of measures designed to limit as
far as possible the seriousness of injuries caused by accidents,
namely medical aid, including first aid.

GENERAL REMARKS ON SAFETY AND HEALTH

The factory inspector who deals with safety and health in
industrial undertakings has to ensure the observance of regulations having the force of law, but he must keep in mind that
these regulations lay down only minimum requirements. To
fall below that minimum is to break the law. The best safety
and health conditions attainable sometimes represent a higher
standard, and when this is so the inspector should strive to
achieve more than is required by the legislation in the field of
safety and health. For this, the inspector must have sufficient
knowledge of the technology of the undertakings he inspects—
knowledge which he may acquire from his visits to undertakings,
and also from technical handbooks. 1
Experience has shown that health and safety inspection
has obtained better results where inspectors have concerned
themselves not only with enforcement of technical regulations,
but also with advisory and educational aspects of accident
prevention and health protection. The importance of these
aspects is now generally recognised, but the methods that make
a prevention programme successful are still often lacking in
industrial undertakings, and here the assistance, advice and
encouragement of experienced inspectors may contribute greatly
to the spread of health and safety consciousness throughout
industry. Hence the inspector should also be aware of the
1
In matters on which there are no national regulations, useful
guidance may in many cases be afforded by the Model Code of Safety
Regulations for Industrial Establishments for the Guidance of Governments and Industry, published by the International Labour Office in
1949 (see bibliography).

INSPECTION RULES AND PROCEDURES

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factors that make for the success of a prevention programme :
for instance, support from management, well designed premises,
well protected equipment, well trained workers, good working
conditions, and good industrial relations.
The inspector should, however, fully realise that only
someone who is constantly in the undertaking can know the
many small things that have often nearly caused an accident,
and may cause an accident when someone acts unsafely ; and
this is one of the reasons why the inspector can never take the
place of the safety engineer. But the safety engineer's
experience will be useful to the inspector, as the inspector's
will be to the safety engineer, and hence a sound basis will
exist for their co-operation in the interest of safety and health.
The inspector may find it necessary to give close attention
to those undertakings—they will include the majority of the
smaller undertakings—where there is no safety engineer, and
where in practice what is done in the interest of safety and health
often depends entirely on the inspector.
Need for Co-operation
It should be realised at the outset that it is not possible
for one inspector to develop suitable qualifications for the
complete inspection of all types of equipment, processes and
operations that he encounters. The inspector should, however,
endeavour to develop a working knowledge of the different
types of industrial installations and operations as well as make
himself familiar with the basic requirements and principles of
accident prevention and the protection of health. In addition, inspection services should, whenever necessary, have
recourse to the assistance and services of specialised national
agencies and international bodies. The inspection authorities
should also consider the practicability of setting up advisory
committees for the promotion of safety and health in a particular
branch of industry, for a particular task (such as the protection
of a certain type of machine) or for other purposes. Such
committees might be composed of representatives of management and labour of the industries concerned, and of experts
on the subjects to be studied (manufacturers of equipment,
representatives of research organisations, medical and engineering consultants, etc.).

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Inspections : Scope and Procedure
The inspector should try to acquire a good knowledge of
the safety and health conditions prevailing in all establishments
under his care. For this reason he should normally conduct
his visits during working hours, observe the complete cycle of
operations and discuss his findings with the management. His
visits should not be notified in advance to the establishment
concerned. He should make, within the provisions of national
laws and regulations, unannounced visits to obtain a fair view
of the prevailing conditions in the industry concerned. He
should, if necessary, ask for essential technical information—e.g., blueprints of installations, data on the particular equipment and processes of the industry, and analyses or samples
of materials used or manufactured. With this information in
hand he may study the causes of defective environmental
conditions and the specific hazards involved.
Although it is a function of the inspector to detect occupational risks it is not within his province to limit the right of
the plant manager to select his own equipment and methods of
work in so far as they are not prohibited by law. He should,
above all, avoid any undue interference with production and
refrain from taking any steps to relieve plant managers and
supervisors of their responsibility to provide a safe and healthy
working environment for their personnel.
However, the inspector should not try to make inherently
faulty or unsuitable processes safe ; for instance, if he finds
an abrasive wheel mounted on a spindle moulding machine
he should not try to devise a guard for the wheel, but should
condemn the use of the wheel.
Equipment with which the inspector is not familiar should
not be examined except when he can call in qualified experts
to assist him. The inspector should request the assistance of
the plant management for the testing, trial runs, etc., of
machinery or other equipment. He should not operate any
equipment himself without the consent of the management and,
generally speaking, he should ask plant personnel to start up
machinery and equipment, if this is necessary.
During the inspection of dangerous equipment such as
machinery, elevators and pressure vessels, and operations or
processes involving dangerous substances, special attention

INSPECTION RULES AND

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should be given to the prevention of injuries to the inspection
staff and to plant personnel. The appropriate equipment, tools
and clothing should be used and all necessary precautions
should be taken to ensure the protection of everyone concerned.
Recommendations with respect to hazards detected during
visits to plants should be worked out in close collaboration
with managements and, if necessary, with labour representatives,
in order to ensure that the protective measures devised are
practicable and are likely to be applied.
Inspection Records
The results of health and safety inspections should be
recorded in an orderly manner for two principal reasons. First,
the inspector should keep a clear account of his activities in the
undertakings under his care. Secondly, the records will serve
for reference at later dates, or may even be consulted to establish
certain facts in legal or other investigations. Where possible
the first inspection reports should give a clear account of the
conditions obtaining, and of the operations and processes
carried out. It is good practice to use standard inspection
forms on which the essential items may be grouped in such a
way that reference may easily be made to the various types of
occupation and equipment. Special forms are often used for
particular types of work or equipment. Forms provide a useful
means of obviating the risk that important matters will be overlooked and assembling data on the work or equipment examined ;
but it should be remembered that they serve only as a guide
and inspectors should not necessarily be confined to the points
listed on them. Forms cannot cover every contingency and
the inspector must use his intelligence and not rely on them
exclusively.
The inspector should be very careful what he includes in
his report : as far as possible, he should base his observations
on what he actually sees and not on unauthenticated statements,
and should refrain from giving opinions on matters on which
his knowledge is insufficient.
He should, however, include general observations on the
conditions in the plant visited (e.g., the state of the equipment,
safety consciousness of personnel and supervisory staff, and other

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conditions that may affect safety and health). He should
include the recommendations made to the management as a
result of his inspection.
The inspector should treat any information gathered in
the course of his visits to plants as confidential ; it should be
disclosed to public authorities only in the cases and to the
extent specified by law. An inspector suspected of disclosing
trade secrets would soon lose the confidence of plant managers.
Frequency of Inspections
It is not possible to establish any hard and fast rule with
regard to the frequency of safety and health inspections. The
inspection schedule should allow for repeated visits to be made
to plants where conditions are such as to require special attention. Because of the particularly hazardous nature of some
operations or of special circumstances it is sometimes necessary
to make inspections at short intervals. To ensure the incorporation of protective features in new factory premises, for instance,
it may be necessary to visit the site during construction.
Similarly, when factories are planning to introduce new processes or new raw materials, visits might be made for the purpose
of examining the plant changes involved or having analyses
made of the new substances, or surveys conducted of the new
environmental conditions.
When it has been found necessary to make changes in
existing structures, equipment or processes, reinspection may
become necessary to ensure compliance with requirements
previously laid down. In such cases previous inspection records
will be found a most valuable aid.
Equipment Required for Inspections
The equipment and tools required for the inspection vary
widely, depending on the nature of the industry and on the type
of operation being examined.
The inspector should carry with him, in so far as is
practicable, the tools and equipment he may need for the type
of examination or test he expects to perform during any particular inspection. Measurements are commonly made of the
dimensions of workrooms, guard clearances and distances,

INSPECTION RULES AND PROCEDURES

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lighting, temperature, humidity and airflow and dust concentrations among other things.
If the instruments are only used from time to time, they
can be kept in a central place where due attention can be given
to their maintenance, checking and, if necessary, repair.
Accident and Health Records
Where statutory provisions for the reporting of industrial
injuries and occupational diseases do not exist, or where the
existing provisions such as those laid down by compensation
boards or other bodies are not found adequate for prevention
purposes, the inspection authorities should take steps to promote a suitable voluntary system. Essential features of such
a system are the prompt reporting of injuries by the plant
management, a good investigation procedure and the adoption
of adequate measures to prevent recurrence.

Standard injury report forms, such as those used by many
inspection authorities and adapted to the particular conditions
of the industry, should be employed. Often it will be found
that reports lack essential information. To lessen the difficulties inherent in the accurate reporting of accidents and
injuries to health, the inspector may need to spend some time
showing the responsible persons in industry, either on the occasion of visits or in the course of health and safety training
programmes, the manner in which report forms should be completed. All the circumstances that may have some bearing
on the causation of an injury should be mentioned in the
report to ensure that all the facts required for taking the
appropriate corrective measures will be available.
Periodical analyses of records of accidents and cases of
occupational disease will reveal to the inspection authorities
the commonest types of risk and causes of injuries for a given
industrial undertaking or for a group of undertakings manufacturing similar products or operating similar machines and
equipment. These records will also give valuable assistance
to plant managers in several ways, but especially by keeping
them informed of the trends in injury experience and providing
necessary data for the determination of a suitable prevention
policy.
As a great number of industrial injuries are due to human

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failure, accurate and detailed statistics will also prove very
useful in campaigns to develop safety and health consciousness
among workers.
It is good practice to complete the records of injuries and
illnesses by analysis of their aggregate cost to the industry
concerned. Such analyses often help to convince managements
of the advantages of sound prevention policy.
In short, the inspection authorities should require a standard
procedure for the compilation of industrial injury statistics,
ensure that injuries are adequately reported and investigated,
and try to ensure that the information gathered as the result
of investigation is put to proper use.
Promotion of Safety and Health
As already suggested, great emphasis should be laid on
safety and health education as a most effective means of preventing employment injury. Substantial benefits may derive
from appropriate instruction courses for safety and health
officials, for plant managers and supervisors, for workers in
general, and for specialists.

The inspection authorities should

take a keen interest in the development of training programmes
and, if possible, participate actively in them.
Experience has shown that training courses in first aid
have done much to interest workers in accident and disease
prevention. There are other means (talks to trade union
meetings, showing of films in places of public assembly or on
plant premises, public address systems, etc., requiring in one
form or another the participation of workers and employers)
that are likely to further the safety and health movement,
especially in countries where the development of such activities is still in the preliminary stage. The inspector can usefully advise on the most appropriate methods by which safety
and health may be furthered.
But whatever his technical qualification and his personal
qualities of judgment, tact, firmness, integrity and energy,
success in the prevention of industrial injuries cannot be attained
by the inspector alone ; it depends to a great extent upon the
organised co-operation of employers and workers with inspection authorities.

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BUILDINGS AND OTHER WORKPLACES

Notification of the Commencement of Operations
When the notification of the commencement of factory
operation is required by law, the inspector should ascertain
that the employer has sent to the competent authority a written
notification containing the prescribed particulars, including
a description of the work to be carried on in the establishment.
This also applies to subsequent changes in the type of work and
to extensive alterations and extensions to the factory buildings.
It should be noted that it is generally very difficult and
costly to introduce alterations in existing buildings, in buildings
under construction or in plant layout once operations have
begun. It is therefore important that building plans and plant
installation drawings should be carefully examined immediately on receipt by the inspection authorities so that any alterations required for safety or health considerations may be suggested in due time.
General Provisions concerning Buildings and Other Workplaces
All buildings and workplaces should be so constructed
and maintained as not to constitute risks of accident or injury
to health.
The inspector should pay attention to the height of the
workrooms and the space available per person working in them,
and take measurements when the standards set by legislation
do not appear to be complied with.
Floors should be firm, level, clean and non-slippery, and there
should be sufficient space around the machines and adequate
unobstructed aisles, preferably clearly marked by painted lines.
As a general rule openings in floors should be protected
by railings and toeboards or by hinged covers or panels to
prevent the fall of persons and to protect persons underneath
against falling objects. If elevated walkways are made of
gratings, the openings in the gratings should be sufficiently
small to stop falling objects, or else screens should be installed
under them. Floor and wall openings should be inspected
with care to see whether they are guarded and if so whether
guards are suitable and effective.

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Stairways should be of sufficient strength and width to afford
safe passage to workers. Exposed sides should be protected
by railings. Winding stairways should be prohibited.
Though most regulations indicate that wall openings from
which there is a drop of a certain height must be guarded, it
should be kept in mind that there is not necessarily a direct
relation between the height of a drop and the seriousness of
an accident.
When inspecting a factory the inspector should also give
his attention to the factory yards, noting the condition of the
ground, storage arrangements îor material, movement of vehicles
and possible danger points, such as factory entrances and
exits and blind corners of buildings.
Lighting
To the greatest extent practicable, a workroom should
be lighted by natural light. The psychological effect of natural
light should be kept in mind.
Natural light should be augmented as required to ensure
adequate illumination of workplaces. Sufficient lighting should
also be provided for passages, stairs and yards. As a general
indication, from 100 to 300 lux (10 to 30 foot-candles) should
be provided for ordinary shop work where discrimination of
detail is not essential.
Glare should be avoided and the eyes of the workers should
not be exposed to strong contrasts. On the other hand it
must be remembered that the easy perception of objects is not
obtained in all cases by means of intense illumination ; moderate contrasts in colours are often very useful. The use of
eye-shields or of shading or diffusing devices should be encouraged where necessary, and walls and machines should be
painted in pale colours.
Where large numbers of workers are employed in a building, emergency lighting, independent of the general lighting
system, should be provided in all important stairways, exits
from workplaces and other passageways.
It is important to maintain all lighting equipment and
windows in a satisfactory state oí repair and cleanliness. The
best lamps will not provide good lighting unless the glass is kept
clean.
°

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General Ventilation
In workrooms where the atmosphere is not permeated by
dust, fumes, etc., suitable atmospheric conditions can usually
be maintained by natural ventilation, which should if possible
come from or near the ceiling to prevent harmful draughts.
Where artificial ventilation is used, the inspector should
see that the place from which the air for the workrooms is
taken is such as to guarantee a supply of pure fresh air. The
ventilation system «should be kept in effective operation during
working hours, in addition, the inspector should ascertain
that air in crowded rooms is renewed with sufficient frequency
during working hours.
The following figures are given as a guide for maintaining
suitable atmospheric conditions in workrooms : the minimum
distance between floor and ceiling should be 3 m (9 ft. 10 in.) ;
the minimum cubic space per worker in an enclosed room should
be 11.5 m 3 (400 cu. ft.) ; where the ceiling is high, heights above
4.5 m (14 ft. 9 in.) should not be taken into account in measuring this cubic space. The minimum rate of air supply should
be 30 m 3 (1,000 cu. ft.) an hour per worker. In any case the
ventilation system should be such as to avoid insufficient air
supply, vitiated air, harmful draughts, excessive heat or cold,
sudden variation in temperature and objectionable odours.
Temperature and Humidity
A temperature suitable for the type of work performed
should be maintained in enclosed workplaces. Heating of
workrooms in cold weather, and air movement and ventilation
in warm weather, should be so arranged as to provide reasonable comfort. Relative humidity under 20 per cent, or over
80 per cent, should be avoided. When use is made of local
heating, care should be taken to ensure regular elimination of
combustion gases.
Noise, Vibration and Shock
Noise, vibration and shock have a detrimental effect on
health and should, as far as possible, be suppressed by insulation
of flooring, walls and ceilings, and by other technical measures

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such as placing machines on bases constructed independently
of the flooring, or isolating them in separate chambers. Workers may to some extent be protected by personal protective
devices such as ear plugs. Those exposed to excessive noise
should be medically examined regularly.
Ladders and Platforms
Ladders are in very common use and should be carefully
inspected since they are the cause of a great number of accidents. They should be well constructed and maintained,
and the right type should be selected for a given job and used
with all necessary precautions. Workers should be instructed
in the proper use of ladders.
It is preferable to obtain ladders from specialised manufacturers who are in a position to furnish industrial establishments with a complete set of ladders and stepladders of the
correct size and strength for the types of work to be performed.
Ladders should be regularly examined by a plant official,
and only qualified workers should be permitted to repair
them.
Working platforms of temporary construction are often
found to be improperly constructed : the platform boards may
consist of damaged timber or be too thin or too short, and the
whole platform may be shaky or otherwise insecure. Platforms should be solidly constructed of good material and
provided with proper railings and toeboards on exposed sides.
Housekeeping
In the interests of a safe and healthful working environment, managements should take adequate measures to maintain
the cleanliness of premises, including floors, work benches,
windows and equipment, and the orderly arrangement of raw
materials, products, mobile equipment, tools, etc. It is important to keep all passageways and exits clear.
Where floors are washed with streams of water or are
continuously wetted in the industrial process, an adequate
drainage system should ensure that pools of water cannot form
and that the water is speedily removed from the floors, or suitable footwear should be provided.

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FIRE PREVENTION AND PROTECTION

General
In many countries fire precautions in industrial premises
are a matter partly within the jurisdiction of local authorities
and partly within that of the labour inspectorate. The present section does not attempt to apportion responsibility in
this field between the two authorities, but indicates matters
that will need to be covered by inspection.
Before starting out to inspect an industrial establishment,
the inspector should acquaint himself with the fire hazards of
the industry concerned. In this way he will know better what
particular matters to look into, and the inspection is more
likely to be efficient.
The matters to be covered by the inspection will include
exits and the organisation of evacuation arrangements in case
of fire ; alarm systems ; fire-fighting facilities (including any
automatic sprinkler system, water supply, hydrants, hoses,
and portable extinguishers) ; storage arrangements for flammable and explosive substances ; arrangements for disposal of
waste ; lightning protection ; and fire-fighting personnel.
Smoking
If there is a dangerous area where smoking is forbidden,
attention should be given to the possibility of providing the
workers with a place, e.g. a canteen, where smoking is allowed.
In factories where smoking does not offer a direct risk, smoking
is sometimes allowed till one hour before rest time or stopping
time. In this way the employer tries to minimise the risk that
a burning cigarette may be thrown away, shortly before the
workers leave, somewhere in a corner or other place where it might
be unobserved and cause fire, possibly after the workers have left.
Fire Brigades
In all industrial undertakings a sufficient number of men
should be trained in the use of the fire-fighting equipment
provided and in the procedure to be following in the event of
a fire. Large undertakings should have properly trained fire
brigades.

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Exits
It is of particular importance that adequate exits, such
as stairways and passageways, should be provided in order
to allow all persons to leave their places immediately and in
good order when a fire warning is given.
These exits should be so designed that congestion is avoided,
and the inspector should see that they are unobstructed by
piles of material, packing cases, etc., that doors open easily,
and that exits are clearly marked as such.
All stairway enclosures and fire exit partitions should have
fire doors of the self-closing type that can be easily opened
from either side. The inspector should see that there is ample
space between fire doors and goods piled on the floor.
Horizontally sliding doors are inadvisable since they can
be blocked by persons pressing against them. Where they
exist the inspector should carefully verify that they slide
easily.
Alarm Systems
The fire alarm system of an industrial establishment should
have signals that are audible over the whole building, and a
sufficient number of easily accessible signal-sending stations.
The system should be in good working order at all times.
Fire Drills
Exit drills should be held often enough to ensure orderly
exit in the event of fire.
Fire-Fighting

Facilities

Pumps and Hydrants.
Fire pumps, if any, should be so located or protected
that their operation will not be impaired by a fire in the establishment. The inspector should see that they are maintained in
good working order. Hydrants should be free of sediment and
should be protected against freezing in cold weather.
Hoses.
Fire hoses should be kept clean and dry, with the nozzle
attached, either connected to the water piping or on suitable

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and readily accessible racks, so as to be immediately available
for use. It is important that all hose couplings for use outside
and all hydrants or stand-pipe nipples are of the same types
as those used by the local public fire department which may
be called upon for aid.
Use of Water.
The inspector should verify that an adequate water supply
at the necessary pressure is maintained at all times. In some
fires, however, water should not be used and it is very important
for the safety of workers to have notices posted, when appropriate, at the entrance and inside the building stating that
water should not be used in such fires, e.g. fires involving
aluminium or magnesium powder, calcium carbide or, as a
general rule, live electrical equipment.
Sprinklers.
Where automatic sprinkler systems are used, the watercontrol valves on such systems should be kept open and water
supplied at all times. Sprinklers should be checked to see that
effective spray action is ensured, and that the sprinklers are not
painted, whitewashed, corroded, damaged or heated in such a
way as to endanger their normal functioning.
The distribution of water discharged from sprinklers
should not be obstructed by stock or partitions. The inspector
should see that a clearance of at least 60 cm (24 in.) in all
directions is maintained around automatic sprinkler nozzles.
Extinguishers.
Industrial establishments, including those with approved
automatic-sprinkler protection, should be equipped with portable
fire extinguishers suitable for the types of fire liable to occur,
having regard to the nature of the processes or the contents of
the establishment.
The inspector should verify whether fire extinguishers are
conveniently and conspicuously located and maintained in
good working order. He should note the date of the last
charge, which should be recorded on a label, and see that all
fire extinguishers have a plate giving the instructions of the
manufacturer for filling, maintenance and use.
5

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Special attention should be drawn to the fact that the
charge in portable extinguishers may itself cause a hazard under
certain circumstances ; for example, carbon tetrachloride and
methyl bromide form dangerous gases if used in a confined
atmosphere.
Flammable and Explosive Substances
Minimum requirements for the storage of flammable and
explosive substances are set out below. The inspector should
bear in mind that these requirements are meant to apply to
industry in general and are not confined to specially dangerous
establishments.
In the first place explosives, flammable liquids, compressed
gases, coal and other flammable materials should be stored in
accordance with any special regulations issued by the competent
authority. Where flammable liquids are used it should be
considered whether these liquids are really necessary for the
work, and cannot be replaced by liquids causing less or no
risk of fire, e.g. for cleaning purposes benzene (benzol) could
be replaced by trichloroethylene or another non-flammable
product. In some cases (e.g. garages) the replacement of petrol
(gasoline) for cleaning machine parts by paraffin (kerosene) has
been a considerable improvement. The inspector should see
that flammable liquids are not stored in workrooms, where
only a small quantity for immediate use should be kept.
Even small quantities of flammable liquids, e.g. quantities
used for cleaning purposes, should not be stored in glass containers, for if they break the liquid may perhaps spread on the
clothes of the worker and catch fire. Fatal accidents have
resulted from the breakage of such containers.
Above-ground tanks for storing flammable liquids
should be—
(a) placed on firm foundations of non-combustible
material at a safe distance from any building ;
(b) surrounded with pits, catch basins or depressions of
sufficient size to hold the contents of the tanks in the event of
rupture ;
(c)

provided witli adequate fire-extinguishing equipment ;

(d)

equipped with effective protection against lightning.

and

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If cylinders containing flammable or explosive compressed
gases are stored inside the establishment, the storage place
should be isolated by fire-resisting and heat-resisting partitions
or walls. They should be so stored that they do not fall over
and yet can be easily removed in case of fire.
It is also important to see that combustible dry materials
should be stored in fire-resistant bins provided with lids.
The inspector should see that quantities of packing material
of a flammable nature are stored in separate buildings or in
non-combustible or metal-lined rooms. If small quantities of
such material are to be stored, metal or metal-lined bins with
self-closing covers can be used.
Special attention should be given to the prohibition of
smoking in the neighbourhood of flammable substances.
Processes involving explosive or flammable substances, for
example the manufacture of acetylene and the charging of
acetylene cylinders, should be reported by the inspector to a
specialist inspector competent to deal with them.
Waste
Waste material of a flammable nature should not be permitted to accumulate on the floors. It should be removed as
often as possible, and the inspector should see that it is placed
in suitably covered metal containers. It is important in the
interest of fire prevention that all oil-soaked waste, rags or
other material subject to spontaneous combustion should be
placed in self-closing metal receptacles, the contents of which
should be removed at suitable intervals.
Lightning
All industrial buildings, storage tanks containing flammable liquids, and tall chimneys or stacks should be protected
against lightning.
ELEVATORS AND HOISTS

General
The inspection of elevators calls for special knowledge,
and in some countries is only undertaken by special elevator
inspectors or by specialist engineers. The following recom-

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mendations should not be taken as complete, but they may
be of use where specialist inspectors are not available.
The principal parts of elevator installations to which attention should be given during inspections are the hoistways,
landing doors, car or cage, guides, buffers and counterweights,
ropes and machinery. The inspector should also see that the
signs and notices required by law are in place. The inspector
should post a notice on every floor or landing indicating that
an inspection is taking place.
Hoistways
The hoistway should be enclosed by a continuous wall or
a substantial grill work, metal bars, or wood slats, with no
interior projections and no large openings except for the
necessary doors, windows or skylights. An inspection should
be made outside the hoistway, at all floors, in order to verify
that the enclosure complies with these requirements and is of
sufficient strength.
The inspector should see that there are ample top and
bottom clearances for the car.
Landing Doors
Landing openings in power-elevator hoistway enclosures
should be protected by doors or gates, which should be provided
with interlocks to hold the elevator car immovable while the
doors are open and to make it impossible to open any landing
door when the car is more than 7.5 cm (3 in.) from thatl anding.
The inspector should ascertain, at each floor, whether these
devices are in good working order.
Cars
The inspector should see that the elevator car is enclosed
at sides and top, except for the necessary door openings.
Power-elevator cars, except those of direct lift plunger
elevators, should have safety gear capable of stopping and
holding the car with full load in cases of overspeed, free fall
or slacking of cables. The inspector should verify whether
this gear is in good operating condition by calling the necessary
technical assistance.

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Guides, Buffers and Counterweights
The inspector should see that appropriate material is used
for the guides and should verify their alignment over the whole
length of the hoistway. He should also examine the joints
and fastenings and see that the rails are clean and adequately
lubricated where necessary.
Ropes
Car and counterweight ropes should be examined very
carefully, as they are vital to the safe operation of elevators.
The inspector should look for worn or flattened strands and
broken wires. The proper lubrication of ropes is very important since it will retard deterioration and corrosion.
A careful examination should also be made of rope fastenings. The inspector should see whether bolts are tight and
clamps are properly attached. He should examine the sheaves
for wear and make a hammer-test of the rim and spokes to
detect cracks.
Machinery
The hoisting machine should be examined thoroughly to
see that it is safely installed and is in good working order. In
the case of a winding-drum machine the inspector should
examine the rope fastenings on the drum and see that there are
at least two turns of rope when the car and counterweights
are at the bottom of their travel. All gears should be properly
guarded and lubricated.
In the case of hydraulic elevator machines, the inspector
should examine the elevator pumps, automatic by-passes,
valves and pressure tanks. He should look for leaks in valves
and pressure tanks, and see that all parts of the machine are
properly lubricated in order to avoid corrosion.
Notices
The inspector should see that notices indicating the
maximum permissible load to be carried are conspicuously
posted in all elevator cars, and that all power elevators that do
not conform to the regulations for passenger elevators have
notices posted at every landing and in every car, prohibiting
all persons except the operator from riding in them.

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MACHINE GUARDING

General
Machine guarding is a large and complex subject and it
will not be possible to deal here with methods of guarding
all the types of machine now in use. However, transmission
machinery is in universal use and is moreover responsible for
large numbers of accidents ; consequently considerable space
has been devoted to it.
All dangerous parts of prime movers (engines, motors, etc.),
of transmission equipment (shafting, gears, belts, etc.) and of
power-driven machines should be effectively guarded unless
they are so situated that it is quite impossible for the workers
to reach them. Special attention should be given to revolving
and other moving parts such as belts and shafts which, by
reason of a worker's duties, may become accessible.
A highly dangerous condition exists where setscrews, keys,
bolts, grease cups, etc., protrude on moving parts. Setscrews,
if practicable, should be countersunk and other protruding
elements should be covered by sleeves or other devices.
Maintenance of Machinery
In the course of his visit to a factory the inspector should
verify whether there is a safe system of performing machine
maintenance work, such as repairs, adjustments and oiling.
As a rule these operations should not be carried out while the
machinery is in motion.
A system that has gained universal favour is the one under
which a worker who is about to perform maintenance or repair
work on or near machinery has the machinery stopped by
disengaging the power transmission equipment or by bringing
the prime mover to rest, and then puts the starting mechanism
under his own lock and key. Specially designed switch boxes
or other arrangements on clutches and drives should then be
provided, to facilitate the attachment of the maintenance
worker's lock.
It is not always possible or practicable to stop machinery
for oiling and greasing purposes. If such is the case the grease
cups and oil pipes should be extended to a length well out of

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the danger zone, or a self-lubricating or central oiling system
should be installed.
Oilers, cleaners and maintenance workers who carry out
their work from ladders, scaffolds or platforms are particularly
exposed to danger. The safety of men on such supports should
be ensured by means of portable screens, or by railings, or else
the moving parts to which a worker may be exposed should
be stopped before he begins work.
Clothing
A common source of injury to workers around machinery
is loose-fitting clothes. Revolving parts of machinery easily
pick up loose parts such as sleeves, ties, collar ends, gloves,
coats and even the hair, especially the long hair of female
workers. All clothing should be tight-fitting ; gloves and rings
should not be worn and women's hair should be well tucked
in under suitable caps or scarves.
Power Control
There should be means of effectively controlling the speed
of prime movers under varying conditions of load. Speedlimiting devices and safety stops when not operated automatically should be provided with remote controls so that they
can be brought into action from a safe place.
Where machines are not driven by an individual motor
they should be equipped with a clutch, a loose pulley or any
other adequate device for controlling the movement of the
machine from the position of the operator at work. On large
machines where two or more operators may be endangered
by the motion of the machine there should only be one starting
device (e.g., push-button) but there should be readily accessible
means by which the machine can be stopped by each operator.
The inspector should see that these controls are in such a position and so designed that they cannot be operated inadvertently
by persons or objects around the machine. It is also good
practice to adopt a system of identification of the controls in
order to avoid mistakes.
A case in point is where several operators are engaged
in operating a large press ; here push-button controls accessible
to all the operators can be provided. Another system requires

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all operators to actuate simultaneously an individual control
device to keep the machine in action. On equipment such as
rolls and calenders, there should be a safety trip control placed
in the immediate vicinity of the operator and easily actuated
by a slight movement of any part of his body to bring the
machine to a quick stop.
Guards
The point of operation on machines can be protected in
many ways—by interlocking or fixed guards, by automatic
feeds, etc. Two-hand controls are not recommended if they
can be put out of action by the machine operator.
Interlocking devices that disengage the driving mechanism
while the dangerous parts of a machine are exposed are used,
for example, on presses, and on agitating and mixing machines
in which the blades come to rest when the cover of the machine
is lifted.
To be effective, guards should fulfil a number of requirements in addition to that of merely covering a dangerous moving
p a r t of a machine.

The protection provided by the guard

should be positive, i.e. not depend upon some other mechanism
being brought into action, and should prevent all access to the
danger zone during operation. The design and construction of
guards in general should be such that they will not hamper
production or constitute a hazard in themselves. They should
operate automatically where possible, and in any case should
not require special effort or attention on the part of the operator.
Guards that cause discomfort or inconvenience to the operator
will sooner or later be discarded.
They should be strong enough to fulfil their purpose,
e.g. afford protection against the breakage of an abrasive
wheel or of a saw band.
The inspector should bear in mind the advantages of
machinery having built-in safety features, since it is much
easier to achieve safety with such machines.
It is sometimes necessary to fence off the approach to
machinery instead of providing individual guards for all its
moving parts. This is often the case with machines having
large flywheels, cranks, rods, etc. Suitable railings and toeboards should then be provided so as to prevent persons from

INSPECTION RULES AND PROCEDURES

69

coming into contact with dangerous parts. Special attention
should also be given to the provision of safe passageways over
or around such machines.
Transmission

Machinery

The risks caused by different parts of mechanical power
transmission equipment are so serious that from the point of
view of accident prevention the use of mechanical power
transmission should be limited as far as possible. Individual
electric drive is preferable. Moreover, this type of drive has
other advantages : better and simpler lighting of the workroom can be achieved ; it requires less room ; there is a considerable saving in mechanical power ; there is less restriction on
the positioning of machines ; machine maintenance is simpler ;
and machine speeds can be changed more simply.
If mechanical power transmission has to be employed
sufficient care must be devoted to construction and installation.
Special attention must be given to the situation of the
bearings and pulleys. No pulley should have a broken rim,
for this might damage the belt or even break it ; moreover, the
belt or the metal lacing might hook into the pulley and lead to
breakage of parts of the mechanical transmission equipment.
Dirty or improperly aligned bearings may become heated and
cause trouble. Someone may then be tempted to expose himself to danger by approaching pulley drives and revolving shafts
for inspection purposes.
As a rule it should be possible to stop every machine
individually without affecting other machines. In this way the
necessity of performing maintenance and repair work on or near
a machine in motion will be reduced. If, for the individual
stopping of machines, fast and loose pulleys are used the
machine should be provided with a permanent belt shifter and
mechanical means of preventing the belt from creeping from
the loose to the fast pulley. Then the machine cannot be started
unexpectedly. A clear warning signal should always be given
before transmission equipment is set in motion.
Accidental movement of the machinery may also occur
when the fast pulley is set in motion by the loose pulley as a
result of friction due to bad alignment or insufficient oiling.
The best solution is to place the loose pulley on a separate

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shaft ; this solution is the only correct one in the case of a shaft
running at over 800 revolutions per minute.
With a well-designed oiling system the oiling devices do
not move when the belt is on the loose pulley and do not
constitute dangerous protruding parts when the belt is on the
fast pulley.
It must be possible to stop different sections of mechanical
power transmission equipment separately. For this reason
suitable couplings that can be handled from the floor should be
built in. To stop a shaft quickly it will sometimes be necessary
to have a brake, especially when the machines driven by the
shaft have accumulated a great amount of energy.
Stopping the different sections separately is necessary not
only in the case of an accident, but also during repair work
in the neighbourhood of the shaft. Unshipped belts can only
be replaced safely while the transmission is at rest. If the shaft
must turn during the replacement of a belt, it should be turned
very slowly. If a belt pole is used by a worker standing on
the floor for unshipping a belt while the shaft revolves, the
pole must be of such a length that it extends from the top of
the pulley to within about 60 cm (24 in.) of the floor. This
means that the bottom of the pole is not higher than the
worker's knee. In this way, if the top of the pole is caught
by moving parts, the bottom will not strike the worker's body.
Belts should be unshipped from revolving shafts only
when stopping the shaft would create serious practical difficulties, e.g, by stopping mechanical agitation in vessels and
thus causing loss or danger. In any case belts should be
unshipped only by men experienced in this kind of work.
Transferring belts by hand on cone pulleys is more dangerous
than is usually realised. A simple and safe system of unshipping
belts on normally rotating shafts is unknown.
Belts that are temporarily not in use must be taken away
from the transmission. If this is impossible the belts must be
suspended on fixed posts. In some cases a bearing can be used
for this purpose ; in other cases it will be necessary to make a
special belt support. These supports, whether hangers or
perches, must be sufficiently rigid and 15 mm to 20 mm (0.6 in.
to 0.8 in.) larger than the belt to prevent contact between belt
and pulley. The support must reach a few centimetres under
the rim of the pulley to prevent nipping of the belt between

INSPECTION RULES AND PROCEDURES

71

support and pulley and to prevent the belt falling on the shaft.
When unshipping the belt is an exception, the disadvantage
of this system is that it requires a permanent construction for
an operation which seldom occurs. In such a case a semicircular screen connected to a long pole can be placed on the
shaft temporarily.
It is not sufficient to protect only the parts of the transmission that are dangerous if touched during normal operations, but
it is also necessary to protect those that are dangerous if touched
during cleaning or oiling the machines and the transmission.
Protection by complete enclosure is required for all those
moving parts of a transmission near which people pass with
loose yarns, steel wire, fibres or other articles that can easily
be caught by rotating parts.
The guards must be suitably constructed. The following
materials can be used : angle iron 25 X 25 x 3 mm (1 x 1 x
0.125 in.) to 40 x 40 X 4 mm (1.6 X 1.6 x 0.16 in.), pipe
19 mm to 38 mm (3/4 in. to 1 % in.), perforated plate, or woven
wire 2 mm (0.08 in.) in diameter. If wood is used, it must be
sound ; the guards must be of robust construction.
The guards should not be placed at a distance of more than
about 30 cm (12 in.) from the dangerous parts, so as to prevent
persons from standing between the latter and the guard. The
meshes of woven wire used for screen should not be more than
5 cm (2 in.), but if the guard is less than 10 cm (4 in.) from
the dangerous part, the openings in the screen should not be
more than 12 mm (0.5 in.).
In general, belts 5 cm (2 in.) or more wide and running at
a speed of 5 m/sec. (16.5 ft./sec.) or more must be guarded
by enclosures 1.80 m (6 ft.) high. In most cases it will be
sufficient to protect only those parts of the transmission that
are at a height of less than 1.80 m (6 ft.) above floor, staircases, platforms, etc. However, if goods are stored in the neighbourhood of parts of the transmission, protection is necessary
(unless the dangerous parts are situated more than 1.80 m
(6 ft.) above the top of the pile of goods) because workers may
stand on the pile to handle the goods.
If the breaking or falling of a belt would endanger persons,
suitable protection under the belt is necessary. For instance,
a trough-type guard can be installed over places where persons
pass or work.

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Guards and oiling and greasing cups must be placed in
such a way that it is unnecessary to go or to reach behind the
guards during normal work and during oiling.
Guards that must be removed and replaced frequently for
repair and maintenance purposes must be so designed that they
can be replaced quickly and easily. If the guards can be made
in such a way that when opened they obstruct an aisle, their
replacement at the completion of repairs or examination
becomes almost automatic.
The safest belt joint or fastening is glue or rawhide or
leather lacing. If the belt is glued, the seam must be made in
such a way that it cannot be damaged when running on the pulley.
The protruding parts of the transmission are not the only
dangerous ones : smooth shafts may also cause accidents by
wrapping of a belt, of clothes, of threads, steel wire, fibres, etc.
Smooth shafting is particularly dangerous because it looks
safe and is so widely believed to be safe. Such shafting not
more than 1.80 m (6 ft.) above the floor or near places where
goods are stored should be guarded by complete enclosure.
All parts of the transmission should be easily accessible
for maintenance and oiling. Where necessary a safe passageway
should be provided. Ladders should be fitted with hooks to
prevent slipping, and if necessary have non-slip bases. For work
near rotating shafts, ladders should be provided near the top
with movable screens giving temporary protection from the
shaft on both sides of the ladder.
Work on transmission equipment should only be done by
experienced men familiar with the work. Work that must be
done when the transmission is running should only be done on a
special order and under the direct responsibility of a competent
person.
The dressing of a belt should be done at the place where the
belt leaves the pulley and during this work the belt must run
slowly.
Painting, cleaning and similar work should, if possible,
be done with the transmission stopped.
ELECTRICITY

The inspection of electrical installations requires special
knowledge and measuring equipment, and for this reason

INSPECTION RULES AND PROCEDURES

73

specialised technical inspectors are often appointed for the purpose. An examination of some parts of electrical installations
by an inspector making a general inspection of industrial
establishments may be a means of detecting dangerous conditions before the occurrence of an accident, but only a specialist
can make a proper examination.
Installation of Electrical Equipment
Electrical equipment must be suitable for the work it has
to do and for the premises in which it is used. It should be
protected against mechanical damage, capable of resistance to
environmental heat, humidity, etc., as well as to chemical
agents to which it may be exposed, and should not be liable
to ignite flammable dusts, gases or vapours. There is electrical
equipment specially designed for safe use in dangerous atmospheres, for example dust-, water-, explosion- and flame-proof
equipment.
The inspector should ascertain whether electrical equipment accessible to workers presents any danger of shock. He
should, for instance, draw the attention of responsible persons
to the danger involved in the use of unprotected lampholders,
defective portable lamps and makeshift fuses and to the importance of checking electrical hand tools when delivered by
the tool store.
Temporary electrical installations, such as those used
during ship construction and on building or civil engineering
construction sites, need particularly careful inspection.
Portable electric tools and lamps used in boilers, tanks or
other vessels should be supplied only with current of a very
low voltage through an isolating transformer.
Electrical Equipment in Use
The inspector should ascertain the condition of electrical
equipment. The inspection should be concerned principally
with the external examination of the sheathing of cables and
flexible conductors, outlets, plugs, connections to appliances,
switches and other control equipment, etc.
The insulation of electrical systems should be controlled
with the help of appropriate measuring devices.

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Permanent enclosures, covers or other suitable guards
should be provided, where practicable, for all current-carrying
parts operating at 50 volts A.C. or more to earth.
Portable electric tools and lamps should be carefully
examined, especially with regard to the integrity of the earth
(ground) connections of the frame of the tools (control of the
earth wire included in the supply cable and of the earth pin
which forms a part of the plug).
Protective Devices
The inspection of automatic protective devices of electrical
installations should be concerned primarily with the rating of
fuses and circuit breakers for protection against overload, and
with the testing of protective devices having mobile parts
(thermal and magnetic switches, etc.).
The continuous integrity of the earthing (grounding)
system should be verified as well as the earth connections of
equipment frames, enclosures, sheathing and other metal noncurrent-carrying parts receiving current from a supply system
with the neutral to earth. It is important to examine the
position and area of earth plates, and the nature of the surrounding earth. A more complete control of earth connections and
their resistance should, however, be made with appropriate
measuring devices.
Fire-Fighting

Equipment

Fires involving electrical installations or originating in
buildings containing much live electrical equipment, such as
power stations and substations, should be fought with extinguishers containing non-conducting and non-toxic substances,
such as carbon dioxide or dry chemicals. These extinguishers
should be readily available close to the installations.
Work on Electrical Installations
The inspector should ascertain whether suitable precautions are taken to protect men working on electrical equipment
and conductors. As a rule work should not be done on live
equipment or conductors where the pressure exceeds 250 volts
A.C. or D.C. to earth.

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75

Static Electricity
Appropriate measures should be taken in places where
there is a risk of explosion or ignition to guard against sparks
resulting from static electricity. The accumulation of static
charges can be avoided, for instance, by maintaining an appropriate relative humidity (not less than 50 per cent.), by earthing
all metal parts, by installing metallic collectors (combs) on
belts, and textiles, paper, etc., in course of manufacture, or
by using radio-active eliminators.
BOILERS AND PRESSURE VESSELS

The inspection of boilers and pressure vessels, like that
of elevators, calls for special knowledge and cannot be thoroughly
carried out by the ordinary inspector.
However, the inspector, if suitably qualified, may carry
out an external examination of the boiler or pressure vessel
as suggested below, and if he suspects that anything is wrong
he should call in a specialist. Internal examinations must be
left to specialists.
Safety features should be incorporated in boilers and
pressure vessels in the design and construction stages. It is
therefore important for the inspector to verify that the user
has not removed any safety devices or rendered any of them
inoperative.
Sleam Boilers
Boiler Booms.
The design and construction of boiler rooms should be
such as to reduce to a minimum the risk of fire spreading to the
building in which the boiler is housed or to adjacent buildings
or workrooms.
There should be at least two exits from all boiler rooms,
placed so as to permit easy and rapid evacuation of the room
in the event of an explosion or a rupture of steam lines.
Means such as stairs or platforms should be provided to
ensure safe access to equipment that is out of reach, or else
remote control devices should be provided.
A careful examination should be made of the foundations
and supporting structures of boilers to ensure that they are of

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adequate strength. Measures should be taken to prevent the
furnace heat from impairing the strength of the boiler supports.
External

Examination.

A careful external examination will reveal any surface
cracks, broken attachments, defective fittings, structural defects,
leaks, etc. All defects noted should be recorded by the inspector. The examination will also afford an opportunity to
compare the setting of valves, the markings the boiler should
bear, etc., with the manufacturer's specifications. All these
matters should be verified in accordance with the requirements of national regulations, where these exist, or with the
provisions of recognised standards.
During the external inspection of a boiler in service
examinations and tests should be made of safety and other
valves, water and steam gauges, fittings, openings, piping
blow-off and water-column pipes, connections and cocks, in
order to ascertain that these parts meet the requirements of
official regulations or recognised standards. The inspector
should ascertain whether the boiler has the openings necessary
to allow complete cleaning of the boiler for examination purposes. Manhole openings should be of sufficient size to allow
easy ingress and egress.
Safety Valves.
The inspector should ascertain that all steam boilers as
well as economisers and superheaters have at least one safety
valve of suitable capacity, which is kept in good operating
condition at all times. Safety valves should be kept free of
obstruction of any kind, and should be placed as close as possible to the boiler or other equipment concerned and independently of any other steam connection valve or fitting. No stop
valve should be inserted between the boiler and the safety valve.
Safety valves should be tested to ensure that they will function
rapidly at the pressure for which they are set, and that any
fittings attached to them such as mufflers or discharge pipes
will not interfere with their discharge capacity.
Water-Column Pipes and Water-Gauge Glasses.
The steam and water pipes leading to the water column
and gauge glass should be of ample diameter (at least 25 mm

INSPECTION RULES AND PROCEDURES

77

or 1 in.) and be mounted in such a way as to ensure proper
functioning. The try-cock and gauge cocks (which should be
placed within reach of the boiler attendant or be equipped with
extension rods or other devices permitting operation from the
floor) should be tested, and the water-column and gauge glasses
should be blown down when the boiler is under pressure to
check the performance of the blow-off piping and of the water
gauge.
Steam Gauges.
All boilers should be equipped with a steam gauge, the
performance of which should be periodically checked against
that of a standard testing gauge to be mounted on the same
steam gauge connection. Steam gauges should be so designed
and placed as to afford easy reading by boiler attendants,
and have the maximum permissible working pressure indicated
in red on the dial.
Other Devices and Equipment.
All gauge cocks, stop, check and pressure-relief valves,
fusible plugs, blow-off pipes, vent pipes, pressure gauges and
other fittings on steam or hot water boilers should be examined
to ascertain their working condition and to enable the inspector
to form a general opinion of the maintenance and operation
of the equipment by the user. Adequate means should be
provided to permit easy identification of all control valves
and equipment by the operators.
Hydrostatic Tests.
In some cases when there is doubt as to the extent of a
defect found in a boiler, the boiler may have to undergo a
hydrostatic test by a competent person or firm.
Boiler Records.
The boiler records should include the manufacturer's
certificate showing (1) all the technical specifications of design
and construction ; (2) the results of tests carried out on the
materials of construction and on the various parts of the boiler
in the construction stage before being placed in service or after
installation, reconstruction or repairs ; and (3) the results of
all tests, periodical examinations, cleanings, repairs, altera6

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tions, etc., that have been made on the boiler since the date
of installation.
It is important that all the findings reached on the occasion
of an inspection, as well as all the recommendations made and
the repairs ordered, should be carefully noted in the records
of the boiler, or on special inspection forms, to ensure that a
complete history of the life of the boiler is available for future
inspections.
Operation and Maintenance.
Safety in the operation of boilers is dependent to a large
extent on the manner in which they are operated and maintained. The inspector should therefore ascertain that there is
adequate supervision and that the workers in charge of operation and maintenance of boilers possess proper qualifications
to meet standards established by national laws and regulations,
where these exist, or other recognised standards.
Pressure Vessels
General.
As with boilers, the general purpose of an inspection of
pressure vessels is to ascertain that they have been designed,
constructed and installed, and are operated, in accordance with
statutory requirements, where these exist, or with recognised
standards.
The pressure vessel records should be studied systematically.
The use to which the vessel is put often plays an important
part in its actual condition, irrespective of its age. Vessels
used for corrosive substances, for instance, or in corrosive
atmospheres will deteriorate rapidly, especially if not protected by suitable coatings and linings. Even in the case of
protected vessels the coverings or linings may have to be removed
in order to determine the condition of the walls, especially,
when there is doubt as to effect on the safety of the vessel of
corrosion, erosion or electrolysis.
External

Examination.

The pressure vessel and its parts, fittings and attachments
should be thoroughly cleaned before the inspection takes
place.

INSPECTION RULES AND PROCEDURES

79

The inspector should satisfy himself that the materials of
construction of the vessel and its equipment are adequate for
the use to which the vessel is put. For instance, a pressure
vessel suitable for use as an air receiver might be quite unsuitable for use with acids, which would attack the material of
which it was made.
Safety Valves.
The safety valve should be of an approved type and be
free to operate at the pressure for which it is set.
It should he ascertained whether precautions are taken
against possible clogging of the connection leading to the safety
valve by the material contained in the vessel or where the
surrounding temperature is likely to freeze the valve. In
some cases, e.g. when there is danger of clogging, freezing or
sticking, rupture discs of suitable material are used.
Other Precautions.
Some means should be provided to protect operators in
workrooms where hazardous substances are being processed
against possible loss of control of the processes under way.
This may be done by providing facilities for drowning any
charge, or dumping it in a pit or trough to prevent the spread
of the material to the workroom.
The inspector should satisfy himself that vessels cannot
be opened while they are under pressure. In the case of revolving
vessels or vessels with agitating or mixing mechanisms, interlocks or other positive devices should be provided to ensure that
operators will not be injured by driving or stirring mechanisms
or any steam, hot water or chemical.
Where steam-heated pressure vessels are operated at a
pressure less than that of the steam supply line, an effective
reducing valve, followed by a safety valve, should be installed
in the line leading from the main line to the vessel. These
two valves should be tested by the inspector and reset if
necessary.
The inspector should satisfy himself that necessary protection is provided against hazards from exposed moving parts
of machinery or hot surfaces of the vessels or pipes leading
to them.
Where there is danger of spontaneous combustion, splashes

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or sprays of hot water, acids, steam or other substances during
operations, adequate means, including personal protective
equipment, should be provided for the protection of the operators
in the workrooms. Stop valves and other control equipment
should be so located that they can be safely operated.
Hydrostatic Tests.
It may be necessary to submit the vessel to a pressure test
if there is doubt about the safe working pressure in view of
internal erosion or corrosion, or after major repairs.
Inspection Records.
The findings made on the occasion of an inspection of
pressure vessels should be recorded in accordance with provisions similar to those laid down for boilers.
Additional Requirements for Other Types
of Pressure Equipment
Compressors.
Compressors are submitted to considerable vibrations which
may easily damage the foundations on which they are installed.
The inspector should see whether the foundations, supporting
structures and anchorages are of adequate strength. Cracks
may develop in parts of the machine that are bolted or otherwise attached to the flooring, and particularly in machine
supports.
Means should be provided to ensure that the discharge
pressure of the compressors will not exceed the allowable
maximum pressure of the system. Where a stop valve is
installed in the air discharge piping of the compressor, a safety
valve should be installed between the stop valve and the
compressor. These valves should be carefully examined.
The inspector should ensure that the air intake for air
compressors is at a place where the air is as pure and clean as
possible and free from any flammable or toxic gases or fumes.
At the discharge end of the compressor, an oil separator or trap
should be installed to avoid carry-over of cylinder lubricant to
receivers and other parts of the system.
As special hazards exist when dangerous gases are being
compressed, the inspector should verify whether adequate pro-

INSPECTION RULES AND

PROCEDURES

81

tective measures have been taken and, in particular, whether a
safe escape has been provided for dangerous gases from safety
valves, blow-down valves, traps, etc.
Air Receivers.
When inspecting air tanks, special attention should be
given to the supports or hangers of tanks as these are often
subject to a considerable amount of vibration, which may cause
the supports to fail. Safety valves and stop valves should be
checked and, if necessary, reset.
A particular hazard exists with compressed air tanks in
that explosions may result from a mixture of the air with oil
which may be drawn into the supply piping during the compression cycle. All receivers should be equipped with a drain
trap at their lowest point. The drain trap, which may be an
automatic device or a simple valve, should be checked to ensure
that it has not become clogged by dirt or otherwise been rendered
inoperative.
Refrigeration

Tanks.

Factory rooms in which refrigeration tanks and other parts
of refrigerating systems are permanently installed and operated
should be completely enclosed to ensure that in the event of
severe leaks the refrigerants will not pass into other parts of
the factory building. These rooms should be well ventilated ;
they should not be used as a passageway.
Careful examination of the tanks and equipment is necessary
to detect leaks and consequent respiratory hazards.
Gas Cylinders.
The control of the construction and the testing of cylinders
for compressed, liquefied and dissolved gases should be left to
inspectors with special experience in this field. However, the
requirement that cylinders should be suitably handled should
be enforced by every inspector.
The design and construction of cylinders used for compressed gases should meet the requirements of national regulations, where such exist, or of recognised standards. All cylinder specifications should be made available to the inspector.
It is important for the inspector to examine the records of the
cylinders to verify the purpose for which the cylinders were

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made and that for which they are used in an industrial establishment. The markings on the cylinder applied by official
testing authorities or by the manufacturer should indicate the
maximum charging pressure of the cylinder, the name of the gas
for which it was made and the dates of manufacture and of the
last test the cylinder has undergone.
Cylinders that are severely dented or scored or that show
a marked degree of corrosion, scaling or lamination or doubtful
welded seams should be immediately taken out of service and
returned to the manufacturer for repair. The user should not
be permitted to perform any repairs on gas cylinders, because
they are precision-built appliances that require expert workmanship and must be submitted to exhaustive tests before
they are filled and shipped to any industrial establishment.
The inspector should see that all gas cylinders are provided with pressure gauges and suitable reducing valves, and
with ventilated valve-protecting caps when not in use. He
should also examine all fittings and gas lines for possible leaks
and damage.
The inspector should ascertain that suitable handling
equipment and methods are employed in establishments that
use gas cylinders. Precautions should be taken to guard
against knocking, dropping or rolling cylinders, and properly
designed trucks, cradles and tools should be available to transport cylinders from one workplace to another.
In storage, oxygen and other oxydising-gas cylinders
should be separated from other cylinders, especially from those
containing flammable gases, and should be stored away from oil,
grease and volatile liquids. Storage rooms should be well
ventilated, protected against heat and plainly marked on the
outside with appropriate and clearly visible danger signs.
Suitable clamps, chains or hooks should, be used to fix
vertically placed cylinders to a wall to prevent dropping. The
connection to the wall must be made in such a way that the
cylinder can easily be removed if necessary, e.g. in case of
fire. Cylinders should not be used for a purpose for which they
were not made, e.g. as rollers to transport heavy objects.
When stored in the open air cylinders should be adequately
protected against excessive variations of temperature, direct
rays of the sun, accumulation of snow and ice and continuous
dampness.

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83

Water Tanks.
Devices should be installed on hot water pressure tanks
to prevent the generation of steam in the water space of the
tank. Considerable pressure could develop in tanks which are
not equipped with automatic temperature regulators or other
devices to prevent a possible rise in pressure due to high temperatures. A pressure gauge should be mounted between the
reducing valve and the relief or safety valve in such a way as
to afford easy reading, and should be examined and tested by
the inspector at the same time as the reducing and safety valves.

FURNACES, KILNS AND OVENS

The following points, common to furnaces, kilns and ovens,
should receive attention in the course of inspections.
Floors
Floors around furnaces, kilns and ovens should be of noncombustible material and kept free of obstructions to ensure
safe working conditions at all times.
Protection against Atmospheric Hazards
The inspector should ensure that the atmosphere of adjacent workrooms is not contaminated by fumes, gases and smoke
that may be emitted by heating equipment. He should have
available suitable means of carrying out simple air analysis
as occasion arises. Natural or mechanical ventilation should
be such as to eliminate the possibility that workers will be
inconvenienced by such emanations or prevent the formation of
explosive mixtures in the equipment and in the workrooms.
Suitable respiratory equipment should be made available for
workers who must enter hazardous atmospheres to perform
their duties. A person with adequate first-aid training should
be readily available.
Protection against Heat
Devices should be provided to protect workers against
radiant energy and hot substances and equipment, special
attention being given to the protection of the eyes.

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Fuel Control
Means should be provided on gas and oil-fired heating
equipment by which, in the event of failure of the heating
equipment or of any of its parts to maintain proper combustion
of fuel, the feed lines can be immediately cut off. Where
automatic cut-off valves are used for this purpose they should
be examined by the inspector to ensure that they have not been
rendered inoperative.
Fire Protection
The inspector should ascertain that a safe clearance is kept
between all heat sources and any flammable substance or
unprotected combustible material, and that fire-extinguishing
equipment, suitable for the class of fire to which the process
is exposed, is available and kept in serviceable condition.
HANDLING, TRANSPORTATION AND
STORAGE OF MATERIALS

General
A very large proportion of all industrial accidents occur
in the handling and transportation of materials, and it is therefore desirable that the inspector should pay close attention
to these matters. The application of certain basic principles
to handling and transportation will greatly help to reduce the
frequency of the most severe types of accidents in these operations. Generally, the inspector should favour the replacement
of manual by mechanical handling where practicable.
The inspector should ascertain whether transport and hoisting equipment operators have been properly instructed in their
work because the safety of other people in the vicinity of the
workplace often depends on these operators. Workers should
also be properly instructed in safe methods of lifting and handling heavy objects. The inspector should take into account
the weight and nature of the objects to be lifted, the distances
they are to be carried, and the frequency of lifting and carrying. Special attention is needed in the case of women and
young workers.
Suitable personal protective equipment should be supplied
to workers handling objects with sharp edges, fins, slivers,

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85

splinters or similar projections, or handling hot, caustic or
corrosive materials. This equipment includes gauntlets, aprons,
leggings, goggles, hard hats, and safety belts for workers handling bulk materials in storage bins, or on exposed heights such
as roofs.
The inspector should examine the equipment and appliances
used for handling and transporting materials to ascertain that
they are adequate for the work required of them, and are maintained in good working order. The equipment most commonly
used for handling and transportation of materials in industry
includes cranes, hoists, crabs, winches, blocks and tackle,
conveyors, power tractors and power or hand trucks.
The inspector should ascertain that the following basic
provisions are adhered to.
(a) All hoisting and transporting appliances should be
plainly marked with the maximum safe loads that can be lifted
or carried by them.
(b) Moving parts of machinery should be adequately
guarded by machine guards, by barriers or by position.
(c) Electrical, steam or pressure equipment used in
connection with hoisting or transportation equipment should
conform to the requirements laid down in the sections above
concerning electricity, and boilers and pressure vessels.1
(d) There should be adequate means to stop and hold in
position any equipment under load, and the controls should
be arranged and marked in such a way as to reduce the risk of
inadvertent or erroneous operation.
(e) There should be a uniform code of signals throughout
the establishment for the operation of equipment. The inspector should ascertain that the code adopted is understood
and used by all concerned.
Measures should be taken to ensure the safety of workers
having to perform their duties in the vicinity of or in the path
travelled by lifting and transport equipment.
Hoisting Appliances
The framework, working gear and accessories of hoisting
appliances should be of good mechanical construction, sound
1

See above, pp. 72 and 75.

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material and adequate strength. Electrically operated hoisting appliances should be equipped with limit switches or other
devices limiting the travel of the load. All hoisting appliances
should be thoroughly inspected and tested by competent persons before being first taken into service and at suitable intervals during use. A certificate should be drawn up for such
inspection and test and kept available for the labour inspector
at the industrial establishment.
Strain-bearing structural members of cranes, if subject
to shock, should be constructed of steel or equivalent metal.
Crane cabs or cages should be so situated that the operator
always has a good view of the operations.
Travelling cranes should be so designed and installed
that there is always adequate clearance between the crane and
roof trusses, walls, columns and other structures. The hooks,
gear, shafting, ropes and structural members of travelling cranes
should have adequate factors of safety as laid down in national
regulations or in recognised standards.
The runways of travelling cranes should be provided at
both ends with adequate rail stops or bumpers.
Safe access to overhead cranes by means of suitable ladders,
stairways, platforms, etc., should be provided for operators and
maintenance or repair workers.
Plant Railways
When inspecting plant railways the inspector should
observe matters such as the general soundness and strength
of construction ; clearances between buildings, structures and
piles of material on the one hand and the tracks on the other ;
the protection of level crossings ; the construction and equipment of the locomotives and other rolling stock ; and the
standard of maintenance. He should also see that the operating rules are satisfactory and are enforced.
Constructional matters needing attention include the type
and condition of the rails, guard rails on curves, the safety of
overhead tracks, the guarding of frogs and points, the protection of exits opening directly on to the tracks, the provision
of stout buffers at the end of tracks, and the provision of
warning signs, gates and barriers where required to prevent
danger.

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Piling and Storage of Materials
The foundations and floors of storerooms, warehouses and
buildings generally should be strong enough to eliminate any
risk of collapse under the weight of the materials they will
have to carry. Systematic control of the weight of all materials
resting on the floors of a building should be maintained to ensure
that not more than the maximum safe load (static and dynamic)
is carried. Materials should not be piled against partitions,
walls or structural columns unless these parts of the building
have been designed to withstand such pressure as may be
applied to them by the materials.
It is important to verify that piles of materials do not
interfere with the lighting, impede the operation of machines
and equipment, obstruct passageways and exits, impair the
efficient functioning of sprinkler systems or constitute an
obstruction to the ready use of other fire-fighting equipment.
Special precautions should be taken to avoid building
unstable piles of certain types of articles, such as bags, collapsible boxes and cartons, pipes, drums, bar stock and round
objects. Tie pieces, specially designed racks, wood strips
and stop blocks should be used for such articles where necessary.
When necessary to ensure safety, precautions should be
taken in storage to protect materials against atmospheric
conditions ; calcium carbide, for instance, is particularly sensitive to damp ; and other substances, such as explosives, compressed gases and flammable liquids, should be protected against
the heat of the sun or of heating appliances. Closed drums
or vessels may, under the influence of temperature, develop
appreciable internal pressure.
Where no official regulations exist on the storage of hazardous substances the inspector should endeavour to ascertain
that the storage conditions provided for substances with a
special fire or explosion risk are such as to eliminate the risk.
The storerooms and warehouses for them should be remote
from any workplace, and properly protected by signs, barriers,
fences, etc. Access to such buildings and rooms should only
be permitted to experienced workers who have been trained to
cope with the special hazards that may develop as the result
of any accidental occurrences.

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As regards the special precautions which should be taken
against fire, reference should be made to the section on fire
prevention and protection. 1
DANGEROUS SUBSTANCES AND RADIATIONS

Dangerous Substances
The inspectorate should gather adequate information on
the properties of all harmful substances used in the industrial
processes within its jurisdiction. A careful examination should
be made of all processes and operations in which flammable,
infectious, irritating, offensive or toxic dusts, fibres, fumes,
gases, mists or vapours are generated or released in dangerous
quantities.
Attention should be paid to new processes or substances
introduced into industry, and some means should be devised
to determine the hazards of the new processes or substances
before operations are started. Where the substances to be used
appear to be harmful, or where means are not available to
determine the characteristics of the substances, protective
measures should be taken in accordance with recognised safety
and health standards.
Health Risks.
Toxic substances occur in the form of solids, liquids, dust,
gas, fumes or radio-active emanations. They have a triple
path of entry into the system : by inhalation, by ingestion,
or by skin absorption, of which the first is by far the most
important.
A high percentage of all cases of industrial poisoning is
attributable to the inhalation of dust, fumes and gases. Ingestion of toxic substances, due in large measure to eating with
dirty hands or to consuming food in the workroom, can be almost
entirely avoided by education of workers in personal cleanliness,
hygiene and provision of a canteen.
Certain poisons can be absorbed through the skin, for
example aniline, tetraethyl lead and nicotine. Some toxic
substances cause ulceration of the skin, for example compounds
of chromium or arsenic.
1

See above, p . 59.

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89

The risk of dermatitis is present in a large variety of
processes involving the handling of irritants such as dyestuffs,
cements, mineral oils, turpentine and its substitutes, organic
solvents, alkalis and acids and poisonous woods, to mention
but a few of the processes. Dusts, sprays or splashes of various
substances can also cause dermatitis if in contact with the
bare skin for long enough.
Health risks are also present in the handling of animal
hides, wool, hair or hooves, which may contain anthrax spores,
and of grain containing mycotic organisms.
Work in compressed air may cause illness if not properly
organised and supervised. The physical fitness of men to be
employed on such work should be examined.
Cleaning.
When inspecting workrooms where dangerous substances
are handled or processed, the inspector should note whether the
maintenance of the rooms is such as to avoid unnecessary exposure of the workers to the substances. The floor and walls
should be kept clean. Places where dust can accumulate should
be eliminated and, when this is impossible, the places systematically cleaned at suitable intervals. The methods used in cleaning
up dangerous dusts or liquids must also be inspected, as these
may be dangerous to the cleaners.
Isolation from Exposure.
Processes involving hazards due to the nature of the
substances used should, as far as practicable, be carried on
in separate rooms, with a minimum number of workers and
with special precautions. Where there is dust or fumes, precautions include the use of airtight apparatus, fume chambers,
suction hoods connected to exhaust systems, or wet methods.
In all operations where it is not practicable to use such equipment, suitable personal protective equipment such as masks
and goggles should be available and used. Short exposure
on isolated and infrequent occasions may sometimes be the
only remedy. In some cases it may be sufficient if the operation can be performed in the open air.
Identification.
There should be means of identifying containers, pipelines, apparatus and other equipment in which dangerous

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substances are placed or processed. This may be done by
using suitable labels, possibly combined with a colour scheme.
The inspector should ensure that all workers engaged in operations involving dangerous substances are thoroughly instructed
in the handling and use of these substances and in the requisite
safety, fire-protection and first-aid measures. Identification
by colour should not be accepted as a substitute for proper
instruction and supervision of workers, particularly in plants
with a high risk of explosion or fire.
Air

Sampling.

Atmospheric samples should be taken in workrooms where
harmful dusts, fumes, gases or vapours arise to ensure that
the concentration is kept within permissible limits. Ventilation and exhaust equipment should be examined, and tested if
necessary, to ensure that harmful substances do not leak through
into the atmosphere of the workrooms, or that contaminated
air is not recirculated into workrooms.
Fire and Explosion

Risks.

Operations involving an explosion risk should be carried
on in separate buildings situated at such distances from other
buildings as may be specified by the competent authority or
recognised standards, or in rooms separated from one another
and from other rooms by adequate fire-resisting walls. Buildings or premises containing flammable or explosive liquids
should be so constructed or so surrounded by a wall that no
liquid can spread outside the building. In every room there
should be adequate means of escape from every point at which
a person is employed. The buildings should be provided with
suitable explosion vents, and precautions should be taken to
ensure that ignition or explosion is not caused by electrical
equipment, smoking, open lights, heating equipment, static
electricity, etc. Automatic fire alarms should be installed.
Numerous precautions are required in connection with the
manufacture of acetylene, spray painting with volatile flammable
liquids, the manufacture of explosives, the working of magnesium, manufacturing processes liberating organic dusts (flour,
starch, pulverised coal, etc.), and other processes with explosion
risks. In the absence of national regulations the inspector

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will find the essential precautions set out in manuals of recognised standards.
Substitutes for Harmful Substances.
If workers' health is endangered by the use of harmful
substances, an attempt should be made to substitute harmless
or less harmful substances. This is particularly important
where solvents are used : some solvents, in addition to creating
high explosion and fire risks, are also very toxic. There are
available in industry several types of low-hazard solvent, which
can replace high-hazard ones with advantage. Another example
is the replacement of sand in sand-blasting by steel shot or grit.
Dangerous Radiations
Infra-Red

Radiations.

All workers frequently exposed to sources of intense heat
need protection of the skin and especially the eyes, owing to
the presence of infra-red rays. They should wear goggles or
shields having appropriate absorption standards. The inspector should ascertain that such eye-protection equipment is
available and used where required.
All sources of intense infra-red radiation should, as far
as practicable, be shielded near the source by heat-absorbing
screens, water screens or other suitable devices to prevent such
radiation striking the eyes of workers not wearing suitable eye
protection. It may be advisable to provide salt tablets for
workers engaged in work involving exposure to intense heat.
Ultra-Violet Radiations.
In industrial establishments where operations such as arc
welding are carried on entailing a dangerous emission of ultraviolet radiation, the inspector should ascertain that precautions
are taken to prevent the diffusion of such radiations, especially
of radiation liable to reach the eyes of the workers. Protective
measures include placing suitable cabinets or screens around
the sources of emission, interposing a screen—absorbent glass
or other material—between the source of radiation and nearby
workers, and limiting the area of irradiation to the minimum.
When these methods are inapplicable, goggles conforming to
suitable absorption standards should be worn by all exposed

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workers, who should also be required to protect their hands and
forearms with gauntlets or suitable barrier creams.
Ionising

Radiations.

For all industrial establishments where ionising radiations
are used or generated or where radio-active substances are manufactured, stored or handled, the inspector should call for the
necessary technical assistance to determine whether the workers are adequately protected against the effects of ionising radiations. Such protection requires special protective materials and
expert knowledge of the operation of detection and measuring
devices.
HEALTH AND WELFARE

Some aspects of the working environment that have a
bearing on health and safety (lighting, ventilation, temperature and humidity) as well as dangerous substances and radiations have already been dealt with. This section therefore
deals only with general measures for protecting the workers'
health and for promoting their welfare.
Medical

Examinations

One of the inspector's main tasks is to ensure that all
medical examinations required by law have been carried out.
These usually include—
(a) Pre-placement examinations. All young workers
entering industry for the first time should have procured a
medical certificate of fitness.
(b) Periodic re-examinations. All young workers below
a certain age, and all workers of any age in certain dangerous
or unhealthy occupations, must be re-examined from time to
time. The time between re-examinations depends on the
type of trade. It may be fixed by regulations, or the factory
medical officer may decide how often such re-examination is
necessary.
(c) Special examinations. Other categories of workers
who should be medically certified fit for their work are those
resuming work after an illness, and physically handicapped
workers.

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There should also be a record of those who have requested
a special examination.
The inspector should see that all statutory obligations
with regard to medical examination are complied with. He
should therefore ask to see the examination records showing—
(1) names of workers examined; (2) their age; (3) dates of
examinations ; (4) whether special examinations have been
made as required by law, e.g. X-rays, laboratory tests, etc. ;
(5) doctor's decision concerning fitness for employment in each
case.
Medical data such as details of the doctor's findings are
confidential and may be seen only by a medically qualified
inspector.
Where the law does not require compulsory medical examination the management may be persuaded, in their own interest,
to institute a voluntary system.
Exclusion of Workers from Dangerous, Unhealthy and
Unsuitable Work
The inspector should know the industries in which dangerous
or unhealthy processes are carried on, and give them special
attention, visiting them more frequently or at special times.
Where regulations prohibit the employment of certain persons
on dangerous, unhealthy or physically unsuitable work, the
inspector should see that these are complied with.
Notification of Occupational Diseases
The inspector should, by examining the records or other
sources, find out whether any occupational diseases have
occurred, and whether they have been reported to the proper
authority if this is required by law.
Medical Aid
Where the law requires that medical aid should be available, the inspector should see that it complies with the standards
laid down, be it a complete medical service with a doctor in
charge, or a sickroom in the charge of a nurse or other competent
person. The inspector has not, however, to judge the standard of medical work performed.
7

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Where no arrangements for the care of the sick or injured
are required by law, the inspector should endeavour to persuade
the management to make suitable arrangements, bearing in
mind the size of the factory and the type of work done. Where
there are several small neighbouring establishments, or where
there are difficulties in establishing a medical service, he may, for
example, take the initiative in organising inter-works co-operation in this matter. He may also suggest how suitable arrangements can be made with a nearby hospital, clinic or health
centre.
In any medical service accurate records on proper forms
are essential. The inspector should see that such records are
being kept, as they will enable him and the authorities to make
a fair appraisal of the general health situation, and to detect
possible sources of injury.
Even where there is no organised medical service, every
undertaking should have readily available adequate supplies of
first-aid equipment. Ordinarily, small undertakings (e.g., with
less than 25 workers) keep a box containing the medicaments,
dressings and instruments needed to treat minor injuries, cuts,
abrasions, burns, etc. One person, trained in first aid, should
be in charge of this equipment ; he should have at least one
deputy, in particular since a number of workers may be injured
at the same time.
In larger undertakings a suitably equipped first-aid or
ambulance room should always be available, and there should be
a sufficient number of workers trained in first aid. Where
there is a risk of asphyxiation, electrocution or other special
hazard, suitable rescue and resuscitation apparatus must be
available and in working order, and the first-aid workers must
be trained in their use. A doctor or nurse, or trained attendant,
should be on call at short notice.
The inspector should make sure that all the workers
know that first-aid treatment is available and that they understand the importance of reporting even apparently trivial
injuries.
The inspector should satisfy himself that the first-aid and
rescue equipment prescribed by regulation is duly provided,
properly stocked, in working order and kept in a suitable place.
He should make sure that personnel have been designated to
take charge of it and are properly trained or qualified.

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Drinking Water
The inspector should see that an adequate supply of safe
drinking water is readily accessible. The public health
authority may be consulted with regard to its purity. Taps
or sources of water unsafe to drink must be conspicuously
labelled, and workers warned against their use.
Wherever possible the water should be supplied by
fountains, such as the jet or bubble type. If cups have to be
used, workers should either provide their own, or disposable
paper cups should be provided by the management. Sharing
of cups should be forbidden.
For men (e.g., furnacemen) working in hot and humid
conditions, where perspiration is rapid, salt tablets, preferably
coated ones, should be supplied to prevent heat exhaustion
and cramps.
Cleanliness
Cleanliness plays a considerable part in keeping any workplace in a healthy condition, and is especially important where
harmful, noxious, offensive or putrifying materials are used. In
such cases special methods of cleaning may be necessary.1
Attention should be drawn to the risks that may be involved
in the cleaning operation itself, e.g. in the cleaning of toxic
dusts. The cleaning devices and exhaust systems must be
inspected regularly.
Clean and tidy floors and clean, tidily arranged tools help
in reducing accidents. Good " housekeeping " has a favourable
psychological effect, which helps in the same way.
Windows, skylights and lamps must be kept clean so that
lighting is adequate.
Workbenches and Seating
Much fatigue and ill-health and some accidents can be
prevented if workbenches are of such a height and so placed
in relation to the worker's eyes and arms as to enable him to
work with the maximum efficiency. Where the work can be
performed in a sitting position, seats, with back and arm rests
if possible, should be provided.
1

See above, p. 89.

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GUIDE FOR LABOUR INSPECTORS

On an average, work should be 107 cm (42 in.) above the
floor for men, and 100 cm (39 in.) for women. Seats should
be of such a height that the elbows are level with the work.
Sanitation
A sufficient number of latrines should be available for the
workers. For male workers one latrine for every 25 persons
or less, employed at any one time, is usually sufficient, provided
there is also one urinal for every 15 men. There must always
be separate latrine accommodation for women, however few
are employed ; at least one latrine should be provided for every
15 women or less. A small closed disposal bin should be provided in every closet used by women workers (or a small gas or
electric incinerator may be installed in their changing-room
for this purpose).
Latrines should be readily accessible in all weathers, and
be well lighted at all times. They should have impervious
floors and walls of a finish that can easily be cleaned. Each
unit should be screened from view, have a door with a latch for
privacy and be supplied wiih toilet paper. Closets should
never open directly on to the place of work, but on to a room or
screened passage. There should be a wash-basin and soap
available near at hand for use after going to the latrine, especially
in factories where food is processed or manufactured. Separate
washing facilities should be provided for women workers.
The type of latrine most suited to the locality will depend
on the finances available, the availability of water, the drainage
system, the religious scruples of the workers, and other factors.
Generally speaking those of the water flush type are the most
hygienic, provided the workers know how to use them. A public
health expert should advise on this matter.
It is in the small factories, with only one or two latrines,
that the greatest nuisance is often found.
Washing Facilities
Washing facilities should be conveniently situated. Their
type and number may be regulated by law. If there are separate
basins, which is desirable, there should be one for every seven
workers. If there is a sink or trough used in common, there
should be 60 cm (24 in.) to every seven workers. Where there

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97

are no regulations the inspector should estimate the type and
number required, depending on the kind of work, danger of
poisoning, etc.
Running water should always be available. In cold
climates warm water should also be provided.
The wash-place drainage should be trapped and should
discharge outside the premises into an open gully before entering
the main drainage system ; the public health officer will advise
on this.
The walls and floors should be of impervious material,
easily washable, and the floors should be non-slippery.
In some industries shower baths are necessary. There
should be hot and cold water—the hot tap being valved to
prevent scalding. Each shower should be screened.
Soap and, if necessary, nailbrushes, should be provided.
Soap or detergent from a dispenser, rather than individual
cakes, is preferable to avoid loss and misuse. Towels should
preferably be individual or disposable ; otherwise towels must
be frequently changed.
Changing-Rooms
Workers should not have to change into their working
clothes, and hang their private things, in the actual workroom.
There should be changing-rooms adjoining the washrooms,
and preferably near the factory entrance, provided with wellventilated lockers or boxes for each worker or pair of workers.
There should be artificial heating for cold, wet weather.
The women's changing-rooms should always be entirely
separate from the men's.
A person should be specially designated to look after the
washing and changing facilities, and latrines ; he should be
responsible for cleaning, keeping the floors dry, disinfecting,
and replenishing soap and towels.
Women's Restrooms
Where more than ten women are employed, there should
be a restroom adjacent to their toilet accommodation. A couch,
screen and blanket should be provided. If there is a medical
aid station the restroom is usually combined with it and placed
under the supervision of the nurse.

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Canteens and Messrooms
Workers should always be discouraged from taking meals
in the actual workplace and, where dangerous or toxic processes
are carried on, they should be forbidden to do so. Instead
the management should provide separate accommodation where
the workers can eat their own food in comfort and cleanliness.
In sunny climates, in addition, outdoor accommodation may
well be provided.
Canteens and messrooms should be well ventilated and
lighted and large enough to avoid overcrowding. The furnishings,
walls and floor should at all times be kept clean.
Where meals are provided the hygiene of the kitchen and
food storage facilities should be inspected, unless this is done
by the public health authority.
General Hygiene
The inspector should see that the workers do not contravene
the ordinary rules of hygienic behaviour. There should be no
spitting, latrines should be properly used and ventilation
maintained, and there should be no smoking where smoking
is forbidden. The inspector should watch when the workers come
off shift to note the use made of wash-basins, changing rooms, etc.
It may be necessary to suggest that a meeting of workers
be called to explain points of this sort, which are not always
readily appreciated. It is difficult to enforce compliance with
rules that are not understood by the workers.
SAFETY AND HEALTH ORGANISATION AND TRAINING

Organisation
While the elimination or correction oí unsafe and unhealthy
conditions and practices is a normal function of management,
long experience has shown that the standard of industrial
safety and health in undertakings can be raised considerably
by some kind of specific safety and health organisation. This
organisation may consist of delegates appointed by the workers,
special committees, a responsible officer appointed by the
management, or combinations of these.
In small undertakings employing not more than, say,

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99

25 workers the workers should appoint one of their number
to be their delegate. In larger undertakings there should be
a general safety and health committee, and it has been found
that such committees usually give better results when they are
joint bodies composed of representatives of both management
and workers. In certain countries, such committees are a
statutory requirement.
In all industrial establishments, there should be an official
specially appointed to deal with matters relating to industrial
safety and health. In large or dangerous undertakings this
official should devote all his time to safety and health problems :
he should, in fact, be the safety and health officer. If an undertaking comprises a number of separate departments, there
should be a separate organisation for each department in which
a considerable number of workers are employed, and a central
safety and health organisation for the whole undertaking.
The inspector should be provided with such information as
he may require on the appointment of safety and health
delegates, committees and officials.
Whatever form of safety and health organisation exists
in a particular undertaking, its duties should include the
following :
(a) To participate in drawing up rules for each occupation
represented in the undertaking. These rules should include
appropriate extracts of all official safety and health regulations
relating to the occupation in question.
(b) To keep itself well-informed of safety and health
conditions in the undertaking, and endeavour to promote all
improvements that it considers necessary.
(c) To endeavour to secure the co-operation of all workers
in the promotion of safety and health.
(d) To report unsatisfactory safety and health conditions
to the employer or his authorised representative, and endeavour
to have them remedied.
(e) To participate in the investigation of all accidents
in the undertaking and make recommendations for preventing
recurrences.
(f) To make periodical inspections of the undertaking
and all its equipment, in the interest of safety and health.

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(g) To watch over compliance with official regulations,
instructions, etc., relating to safety and health in the undertaking.
(h) To study the statistics of accidents and diseases
occurring in the undertaking.
(i) To see that all new workers receive adequate safety
and health training, instruction and guidance.
(j) To see that all official regulations, instructions,
notices and pictorial material, relating to safety and health
in the undertaking are brought to the notice of all the workers
concerned.
It is only at intervals that the labour inspector visits
each of the undertakings placed under his supervision to observe
whether the workers are adequately protected against occupational hazards. Matters relating to safety and health should,
however, be under constant supervision in every undertaking,
and the inspector should be at particular pains to encourage
and help management and workers to establish and maintain
such supervision. Safety and health committees will greatly
contribute to this end.
All undertakings should keep records of all lost-time
accidents, cases of occupational diseases, minor accidents and
dangerous occurrences, and compile statistics that will show
the accident record of every department, occupation and
individual, and the distribution of accidents by causes so that
attention is drawn to matters demanding action from the
standpoint of safety and health.
In undertakings where no organisation of the kind described
above exists, the inspector should, unless he thinks that such
a course is inadvisable for any reason, draw the employer's
attention to the advantages attaching to the creation of such
an organisation and, if appropriate, offer to give such assistance
as may be proper in setting one up.
In undertakings where a safety and health organisation
does exist, the inspector should acquaint himself with its
composition and functions, obtain copies of the undertaking's
safety and health rules, inspect the accident statistics and more
generally display an interest and give encouragement and, if
appropriate, tactful advice.

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Training
It should be fully realised that accident prevention is one
of the most important subjects in training courses and that it
cannot be separated from production.
It is a well established fact that by far the greatest number
of employment injuries can be attributed to human failure
—wrong attitude of the employer, the foreman or the worker,
lack of knowledge or skill, unsafe or unhealthy practices,
etc.—and can only be corrected by the adequate training of
management, supervisors and workers.
Where plant training programmes exist the inspector
should ensure that safety and health matters are adequately
dealt with in the general training programme. Where such
programmes do not exist the inspector should endeavour to
institute within the general safety and health organisation of
the establishment an adequate system by which new workers
will be given proper instructions before being assigned to work,
and particularly to work involving special hazards.
This system of training new workers could, with advantage,
be extended, through works safety and health committees or
otherwise, so as to cover all workers.
There is no doubt that a good training programme in an
undertaking will not only make the undertaking safer and
healthier but will also lighten the task of the inspector.

APPENDIX
SELECTED BIBLIOGRAPHY

The purpose of this bibliography is to furnish a short list of
works of a general character dealing with questions of occupational
safety and health. Accordingly, the list does not comprise specialised
publications on matters such as boilers, electrical installations, ionising radiations, and toxicology, of which the general labour inspector
is not usually expected to have expert knowledge. A detailed
bibliography covering the whole field of occupational safety and
health would be much too long to be included in this guide, but the
references included, many of which themselves have bibliographies,
will doubtless provide much useful information on the commonest
problems faced by labour inspectors.
Particular mention may be made of the following three I.L.O.
publications :
The Model Code of Safety Regulations for Industrial Establishments for the Guidance of Governments and Industry (Geneva, 1949),
on which Part II of the guide is largely based, contains over 240 sets
of regulations grouped in 16 chapters.
The Law and Practice Relating to Safety in Factories (Montreal,
1949) includes a detailed analysis of the safety regulations of 14 industrialised countries grouped in 43 chapters, together with much
information on agencies and methods for promoting safety in the
countries concerned.
Occupational Safety and Health, published quarterly, provides
current information on legislation, inspection activities, and safety
and health activities generally all over the world, together with numerous abstracts of literature and should be of assistance to inspectors
who are seeking up-to-date information on particular problems.
General
Roland P. (editor). Industrial Safety. 2nd edition. New
York, Prentice Hall, Inc., 1953.
BRANDT, Allen D. Industrial Health Engineering. New York, John
Wiley and Sons, Inc. ; London, Chapman and Hall, Ltd., 1947.
GAUTRELET, Maurice. Manuel de
médecine du travail et d'hygiène industrielle. Paris, G. Doin & Cle., 1949.
BLAKE,

104

GUIDE FOR LABOUR

INSPECTORS

HEINRICH, H . W . Industrial Accident Prevention.
A Scientific Approach. 3rd edition. New York, Toronto and London, McGrawHill Book Company, Inc., 1950.
K L E M , Margaret C. (editor). Industrial Health and Medical Programs.
Washington, D.C., Federal Security Agency, Public Health Service, Division of Industrial Hygiene, Publication No. 15, 1950.
K L E M , Margaret C , and M C K I E V E R , Margaret F . Small Plant Health
and Medical Programs. Washington, D.C., Federal Security Agency,
Public Health Service, Division of Occupational Health, 1952.
LANGELEZ, Albert. Traité des maladies professionnelles.
Liège, Ed.
Desoer, undated.
MARCHAND, M. Hygiène et sécurité du travail. Lille, Caisse régionale de
sécurité sociale, P a r t s I and II, 1949 ; P a r t I I I , 1952.
M I N I S T R Y OF LABOUR AND NATIONAL S E R V I C E .

Chief Inspector of Factories for the Year. . ..
tionery Office.
NATIONAL SAFETY COUNCIL.

Annual

Report

of the

London, H.M. Sta-

Accident Prevention

Manual

for

Indus-

trial Operations.
2nd edition. Chicago, 1951.
PANCHERI, Giovanni. Manuale di Igiene del Lavoro. Milan, La Cultura, Editrice Libraria, 1950.
PATTY, F . A. (editor). Industrial Hygiene and Toxicology.
New York,
Interscience Publishers, Inc., Vol. I, 1948 ; Vol. I I , 1949.
PLUMBE, C. Conway. Factory Health, Safely and Welfare Encyclopaedia.
London, t h e National Trade Press, 1953.
SIMONIN, C. Médecine du travail. Paris, Librairie Maloire, 1949.
STANDARDS ASSOCIATION OF AUSTRALIA.

General Principles
Sydney, 1952.

for Safe Working

Australian

in Industry.

Standard

Code of

AS. CZ.5-1952.

Industrial Premises
Ventilation, Heating, Air Conditioning.
AMERICAN C O N F E R E N C E OF GOVERNMENTAL INDUSTRIAL H Y G I E N I S T S .

Industrial
Ventilation.
A Manual of Recommended Practice.
Ann Arbor, Michigan, 1951.
BEDFORD, Thomas. Basic Principles
of Ventilation
and Heating.
London, H . K. Lewis and Co., 1948.
M I N I S T R Y OF LABOUR AND NATIONAL SERVICE, F a c t o r y

Department.

Heating and Ventilation in Factories. Welfare Pamphlet No. 5.
London, H.M. Stationery Office, 1952.
Lighting and Colour.
COMMONWEALTH OF AUSTRALIA, Department of Labour and National
Service, Industrial Welfare Division. Industrial Lighting.
Bulletin No. 1, Sydney, 1945.
— Colour in Factory and Office. Industrial Data Sheets, Series C.I.
Sydney, 1953.
HOME OFFICE. Lighting in Factories and Workshops.
Welfare Pamphlet No. 7, 5th edition. London, H.M. Stationery Office, 1937.
ILLUMINATING

ENGINEERING

2nd edition.

SOCIETY.

New York, 1952.

I.E.S.

Lighting

Handbook.

105

APPENDIX

SPIESER, Robert. Handbuch für Beleuchtung.
Zentrale für Lichtwirtschaft in Zürich. 3rd edition. Basle, Wepf and Co. Verlag,
1950.
Floors, Stairs.
AMERICAN STANDARDS ASSOCIATION.

Openings,
1932.
NATIONAL

Railings

SAFETY

Safely Code for Floor and Wall

and Toe Boards.

COUNCIL.

Floors

ASA A12-1932.
and Flooring.

New York,

Safe

Practices

Pamphlet, No. 11, revised. Chicago, 1939.
— Stairs and Ramps.
Safe Practices Pamphlet, No. 2.
1942.

Chicago,

Sanitation.
HUNTINGTON
1951.

LABORATORIES,

I N C . Sanitation

INDUSTRIAL W E L F A R E SOCIETY, I N C . Works

Handbook.
Lavatories.

Indiana,
A Guide to

the Design, Layout, Improvement a n d Management of Cloakrooms, Washrooms, and Lavatories in Industry. London, 1949.
K I R K , J . Balfour. A Manual of Practical Sanitation.
London, Tindall
and Cox, 1949.
Industrial Processes
Handling and Transport of Materials.
Industrial Materials Handling.
Institute, Inc., 1950.

Cleveland, Ohio, Lincoln Extension

Welding.
AMERICAN W E L D I N G SOCIETY.

Cutting Operations.

Safety in Electric and Gas Welding and

ASA Z49.1-1950.

New York, 1950.

M I N I S T R Y O F LABOUR AND NATIONAL SERVICE, F a c t o r y

Department.

Memorandum on Safely Measures Required in the Use of Acetylene
Gas and in Oxy-acelylene Processes in Factories.* London, H.M.
Stationery Office, 1944.
Industrial Equipment
Electrical Installations.
Memorandum by the Senior Electrical Inspector of Factories on the Electricity Regulations.
4 t h edition. London, H.M. Stationery Office,
1951.
Elevators, Lifting Appliances.
AMERICAN STANDARDS ASSOCIATION.

Safely Code for Elevators,

Dumb-

waiters and Escalators.
ASA A17.1-1937. New York, 1937.
— Safety Code for Cranes, Derricks and Hoists.
ASA B30.2-1943.
New York, 1943.

106

GUIDE FOR LABOUR

— American Recommended
(Inspectors' Manual).

Practice for the Inspection
of Elevators
ASA A17.2-1945. New York, 1945.

INTERNATIONAL LABOUR O F F I C E .

of Lifts.

INSPECTORS

Safety

in the Construction

and

Use

Studies and Reports, Series F, 2nd section, No. 8. Geneva,

MINISTRY O F LABOUR AND NATIONAL SERVICE, F a c t o r y

Department.

The Use of Derrick Cranes. Safety Pamphlet No. 15. London,
H.M. Stationery Office, 1949.
— The Use of Chains and Other Lifting Gear. Safety Pamphlet No. 3,
7th edition, revised 1949. London, H.M. Stationery Office,
1950.
Ladders.
AMERICAN STANDARDS ASSOCIATION.

Ladders.

ASA A14.1-1952.

ASSOCIATION

Safety

Code for Portable

DES INDUSTRIELS D E B E L G I Q U E .

usagers des échelles.

Wood

New York, 1952.
Code de sécurité

aux

Code 06. CSC. E 1. Brussels, undated.

STANDARDS ASSOCIATION OF AUSTRALIA.

Gangways, Stairs, and Ladders.

S.A.A.

Code for

CA 10-1938.

Platforms,

Sydney, 1938.

Machinery.
AMERICAN

STANDARDS

Power-Transmission
1953.
INSTITUT

ASSOCIATION.

Apparatus.

NATIONAL D E SÉCURITÉ.

aux transmissions.

La

2nd edition.

INTERNATIONAL LABOUR O F F I C E .

Safely

Code

for

ASA B15.1-1953.
prévention

Mechanical

New York,

des accidents

dus

Paris, 1953.

The

Safe

Installation

and

Use of

Abrasive Wheels. Studies a n d Reports, Series F , 2nd section,
No. 9. Montreal, 1944.
Fire and Explosion Risks—Harmful
Substances—Radiations
Fire and Explosion Risks.
BIRCHALL, J . D .
The Classification of Fire Hazards and Extinction
Methods.
London, Ernest Benn, Ltd., 1952.
BLANDIN A. Les éléments des risques d'incendie et d'explosion et de
leur prévention. Paris, André Martel, 1952.
NATIONAL

FIRE

PROTECTION

ASSOCIATION.

National

Fire

Codes.

Boston, Mass. : I. Flammable
Liquids,
Gases, Chemicals and
Explosives, 1951 ; I L The Prevention of Dust Explosions, 1950 ;
I I I . Building
Construction and Equipment,
1951 ; IV. Extinguishing and Alarm Equipment, 1951.
Harmful Substances.
COMMONWEALTH OF AUSTRALIA, Department of Labour a n d National
Service, Industrial Welfare Division. The Safe Use of Harmful
Substances.
Sydney, 1953.
SAX, N . Irving. Handbook of Dangerous Materials.
New York,
Reinhold Publishing Corporation, 1951.

107

APPENDIX

Head and Eye Protection
CANADIAN STANDARDS ASSOCIATION : Code for Head and Eye

tion.

CSA Z.94-1948.

R O Y A L SOCIETY FOR T H E P R E V E N T I O N OF ACCIDENTS.

tion for Industrial
1951.

Protec-

Ottawa, 1948.

Workers.

Eye

Technical Pamphlet No. 2.

Protec-

London,

Compilation of Accident Statistics
AMERICAN STANDARDS ASSOCIATION.

Injury

Rales.

ASA Z16.1-1945.

Method of Compiling

Industrial

New York, 1945.

STANDARDS ASSOCIATION O F AUSTRALIA.

Australian

Standard

of Recommended Practice for the Recording of Industrial
AS CZ.6-1952. Sydney, 1953.

Code

Accidents.

Publications of the International Labour Office

Model Code of Safety Regulations
for Industrial Establishments
for the Guidance of
Governments and Industry
Standards applying to construction, equipment and working
conditions in industrial establishments, brought together as a
contribution towards eliminating danger to life and securing the
safety and health of workers. The Code was approved by a
Tripartite Technical Conference which met at Geneva in
September-October 1948 ; in June 1949 the Governing Body of
the Office authorised the Director-General to distribute it to
governments. In order to facilitate keeping the collection up
to date it has been published in loose leaf form with a clothcovered binder. An index is included.
SUMMARY OF THE TABLE OF CONTENTS

^

Chapter

I.
II.
III.
IV.
Y.
VI.
VII.
VIII.
IX.
X.
XI.
XII.
XIII.
XIV.
XV.
XVI.

General Provisions.
Premises of Industrial Establishments.
Fire Prevention and Protection.
Machine Guarding.
Electrical Equipment.
Hand Tools and Portable Power-Driven Tools.
Boilers and Pressure Vessels.
Furnaces, Kilns and Ovens.
Handling and Transportation of Materials.
Dangerous and Obnoxious Substances.
Dangerous Radiations.
Maintenance and Repairs.
Health Protection.
Personal Protective Equipment.
Selection of Workers, Medical Service, Medical Aid.
Safety Organisation.

Appendix

I.
II.
III.
IV.

Minimum Spindle Diameters and Recommended Speeds
for Abrasive Wheels.
Protection of Presses.
Maximum Allowable Concentrations of Harmfu.
Substances.
Dangerous Radiations.

Geneva, 1949. XXXV -f- 524 pp.

Price: $4 ; £1 ; 16 Swiss francs