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Occupational Health and Safety Act, 1993 (Act No. 85 of 1993)


Health and Safety of Children at Work Regulations

Schedule 1: Guidelines on risk assessments and plans of safe work procedures regarding permitted work by child workers

5. Increased risks of children at work



1) Regulation 3(2) provides that the risk assessment should take into account, to the extent that they are relevant to any work by child workers, a range of factors.


2) These factors, together with examples of how they could become relevant at work, are:
a) the increased biological sensitivity of children to chemicals, biological agents, carcinogens and hormone disrupters For example chemicals may metabolize faster and have greater impact at smaller doses.
b) the increased vulnerability of children to sleep disruption, for example children require more sleep than adults and children's body clock is more vulnerable under conditions of shift work;
c) the vulnerability of children to direct and indirect coercion or abuse from any person, particularly when working alone, for example-

•   children working alone in retail outlets are easier targets for criminals

•   children in domestic service are isolated in private homes and may be subjected to sexual abuse by others in the homes;

d) the relative lack of experience and maturity of children in making safety judgments, for example children may not have sufficient insight to know that a mechanical tool is faulty, or that a ladder is not sufficiently stable, so may continue using the device in a situation where an adult would know to stop;
e) the reduced ability of children to adapt to inflexible work routines, for example children may not be able to maintain concentration when working for long periods without a break, increasing the likelihood of injury due to fatigue or stress related to prolonged work without rest;
f) the reduced ability of children to perceive dangers correctly, for example -

•   children, especially teenagers, typically explore, experiment, and take risks, but lack a sense of vulnerability;

•   sometimes they try to do "a little more" to prove themselves;

•   they desire acceptance from adults and peers, and are susceptible to peer pressure, yet want to assert their independence;

•   children may be inexperienced in work practices or lack role models for responsibilities associated with the world of work;

g) the reduced capacity of children to understand safety messages, for example some safety messages require cognitive processes that children may not have acquired;
h) whether the design of any machinery, tools, equipment and protective equipment is appropriate for children's stature, for example whether the handle of a power tool is too big for the size of that child's hands, thereby reducing the child's ability to control the power tool;
i) the implications of children working at the period when their skeletal structures and bones are still developing, for example children's growth and development may be adversely affected by having to carry heavy loads or do repetitive work;
j) from an ergonomic perspective, children's physical development is not typically suited to the design of machinery, tools, equipment and protective equipment that is appropriate for children's stature; these must be assessed whether the mismatch jeopardizes a healthy and safe working environment. For example most equipment, including safety equipment, is designed for adults, so will not fit most children's body build; as a result, children may be forced into awkward postures to use a device, or may not be able to benefit from the use of gloves to protect themselves from hazards to the skin, because of poor fit of a glove;
k) the physiological, hormonal and other vulnerabilities of children at puberty, for example -

•   working children may be more susceptible to sexual exploitation by adults who take advantage of children;

•   chemicals that cause endocrine disruption may have serious effects on children's hormonal function.