X A study on labour

inspectors’ careers
Arsenio Fernández Rodríguez
A study on labour inspectors’
careers

Arsenio Fernández Rodríguez

LABADMIN/OSH, GOVERNANCE and TRIPARTISM

International Labour Office

Geneva
Copyright © International Labour Organization 2020
First published 2020

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A Study on Labour Inspectors’ Careers

International Labour Office – Geneva: ILO, 2020

ISBN: 9789220313763 (web PDF)

Also available in Spanish: Estudio sobre la carrera profesional de los inspectores de trabajo, ISBN
9789220313800 (web pdf); and French: Étude sur la carrière professionnelle des inspecteurs du
travail, ISBN 9789220313787 (web pdf)

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Contents

Abstract 4

Abbreviations 6

Introduction 7

Chapter 1. The labour inspector’s powers, limitations and status 12

Chapter 2. Threats and challenges faced by labour inspectors 19

Chapter 3. Recruitment and selection of labour inspectors 30

Chapter 4. Training of labour inspectors 39

Chapter 5. Other factors influencing the retention of labour inspectors and their
performance 48

Appendix I 58

A) Justification 58

B) The example of four countries 58

Appendix II Selected bibliography 88

3
Abstract

This paper is addressed to managers of labour inspection systems who have to

develop or improve upon a human resources (HR) policy for labour inspectors. It
provides them with: a basis for developing policies specifically for labour
inspectors; an overview of today’s current approaches to HR with respect to
labour inspectors; and a number of good practices in recruitment, training,
remuneration, promotion, mobility and work-life balance.

When designing policies that are consistent with the status of labour inspectors
and liable to attract a larger number of well-qualified and highly-performing
staff, account must be taken of both their status and duties – as well as the
threats they are likely to face in the course of their duty, which may result in them
performing poorly. The information on the status and duties of the labour
inspector given in this paper comes from the relevant ILO Conventions and
Recommendations, as well as from reports of the Committee of Experts on the
Application of Conventions and Recommendations (CEACR). As regards the
threats they might encounter, the sources consist of comments made by the
CEACR and a number of reports and studies on specific countries.

In order to provide an overview of existing HR policies for labour inspectors, a

desktop review was undertaken that drew upon the ILO’s labour inspection
country profiles, the websites of a number of National Labour Inspectorates, and
several reports and studies.

When selecting good practices for this paper, the criteria have been the extent
to which they appear to enhance quality of performance, retention and
productivity among serving labour inspectors. Studies on the effects of specific
good practices on labour inspectors’ performance or motivation, but also general
HR literature, have helped to identify such practices.

The information, clarifications and comments on the labour inspector’s status

and duties found in this paper are comprehensive enough to fill any knowledge
gaps in this area. However, the paucity of analytical studies of Labour
Inspectorates makes it difficult to draw any firm conclusions about the impact of
specific HR practices and trends on labour inspectors’ work. Even if future
research might contribute towards gauging the effectiveness of the “good”
practices described in this document, it must be borne in mind that they must

4
correspond to the civil service’s general policy and its legal framework – both of
which may vary from country to country. Therefore, as regards recommended
HR practices, this paper must be regarded as a source of inspiration rather than
providing authoritative advice or off-the-shelf practices.

5
Abbreviations

CEACR Committee of Experts on the Application of Conventions and

Recommendations

CPD Continuing Professional Development

DWEA Danish Work Environment Agency

EPZs Export processing zones

EU European Union

GDP Gross domestic product

HICs High-income countries

HR Human resources

IALI International Association of Labour Inspection

ICT Information, Communication & Technology

ILO International Labour Organization/Office, depending on the context

MICs Middle-income countries

NLI National Labour Inspectorate

OECD Organization for Economic Co-operation and Development

OSH Occupational safety and health

SLIC European Senior Labour Inspectors’ Committee

WLB Work-life balance

6
Introduction

It goes without saying that management of the workforce is key to maximizing

the performance levels and competence of the staff of any organization. This is
particularly relevant in the case of the labour inspection service, with its complex
administrative system.

The labour inspection system requires a modern and sound human resources
(HR) management for a number of reasons:

 A national labour inspection service employs many individual labour

inspectors. A coherent HR policy helps to harmonize their performance
standards, thus favouring a more homogeneous inspection activity
across all individual inspectors.
 A Labour Inspectorate (LI) must respond to many needs with limited
resources. However, even if it has abundant funds, these are of little
use if they are not sensibly managed. HR policy should therefore strive
to optimize the key agent of the LI public service: the labour inspector.
 Labour inspection is a nationwide service that affects thousands of
companies and millions of workers: a uniform HR policy reduces
disparities in the performance of labour inspectors throughout the
country and rectifies any other geographical imbalances that might
exist.
 The inspection activity is a permanent public service, for which a long-
term HR policy is needed.

The ILO has long been aware of the specific features of the labour inspection
service, and of the need to provide labour inspectors with a status and conditions
of service in keeping with the social importance of their mission, which safeguard
their impartiality, personal authority and independence.

7
As early as 1923 the Labour Inspection Recommendation, 1923 (No. 20),1 stated
that:

… the inspectorate should be on a permanent basis and should be independent

of changes of Government; the inspectors should be given such a status and
standard of remuneration as to secure their freedom from any improper
external influences and that they should be prohibited from having any interest
in any establishment which is placed under their inspection.

Article 6 of the Labour Inspection Convention, 1947 (No. 81),2 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.

Purpose of this study

With this paper, the Office is attempting to respond to the increasing number of
requests for guidance on HR policy for Labour Inspectorates. Our aim is to
provide a source of information and inspiration for countries wanting to better
their labour inspection service through an improved HR policy.

Let us clarify from the start that this is not a guide to all existing HR policies for
labour inspectors; neither is it a detailed description of the policies of a few
National Labour Inspectorates. Either of these options would have required a
considerable amount of background information about the “source” countries
(their legal framework and civil service traditions and regulations and more) in
order to be of use to those countries wanting to improve their HR policies for their
labour inspectors. More importantly, such a document would have failed to

1
International Labour Organization (ILO): Labour Inspection Recommendation, 1923 (No. 20), adopted at the
5th Session of the International Labour Conference (1923). Status: Instrument with interim status; available at:
http://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO::P12100_ILO_CODE:R020
2
ILO: Labour Inspection Convention, 1947 (No. 81), adopted at the 30th Session of the International Labour
Conference (ILC) (Geneva, 1947). Status: Up-to-date instrument (Governance (Priority) Convention, available
at: http://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO::P12100_ILO_CODE:C081
8
provide an overview of today’s HR approaches and practices, or contained a
selection of effective practices – and we believe that this is the kind of content of
interest to HR managers, which might prompt them to look for further
information.

We therefore opted to examine a broad range of HR policies for labour inspectors

from a pool of 35 countries across six regions and subsequently summarized the
main HR approaches in the following areas: recruitment, training, promotion, pay
and mobility. For each of these areas, we have identified good practices.

By “good practices” in this context we mean HR practices that are likely to help
Labour Inspectorates attract and recruit the people most suited to being labour
inspectors; retain them; and keep their productivity levels high while they remain
in service.

It goes without saying that the good practices identified are not meant to be
replicated, since LI human resources policy has to be devised in line with the
individual country’s public service’s wider policy, legal framework, administrative
practices and culture.

Method
The HR policies which may increase the number of well-performing labour
inspectors differ somewhat from country to country. This may be attributed to
two main reasons: first, wide differences exist in the economic level of
development, the mandate of the Labour Inspectorates and the civil service legal
framework between countries; second, the duties and necessary competences
and knowledge of generalist labour inspectors are clearly not the same as those
of specialized labour inspectors. Nevertheless, there is a basic set of powers
common to all labour inspectors, with which HR managers should be familiar.

These powers, as well as the human, organizational and material resources

required to ensure that labour inspectors may exercise them fully and effectively,
may be found in: the Labour Inspection Convention, No. 81 (1947); the Labour

9
Inspection (Agriculture) Convention, 1969 (No. 129); 3 the Labour Inspection
Recommendation, 1947 (No. 81); 4
the Labour Inspection (Agriculture)
Recommendation, 1969 (No. 133);5 the Protocol of 1995 to the Labour Inspection
Convention, 1947;6 and reports of the Committee of Experts on the Application
of Conventions and Recommendations (CEACR). 7 It is against this common
framework that good HR policies have been identified. That being said, to help
with this identification, data and findings from studies and papers dealing with
HR policies have also been used on occasion.

Having dealt with the criteria for identifying good practices, a few lines must be
devoted to the pool of HR policies from which these good practices have been
selected.

As mentioned above, one of the aims of this paper is to serve as a source of

information on HR policies applying to labour inspectors. We therefore set out to
gather information on these HR practices from as many countries as possible and
from different regions in the world, thereby providing HR managers with as
comprehensive a catalogue of HR policies as possible. A desk study, which
involved examining all the information available to the general public (usually
online) or in-house documents about HR policies for labour inspectors in 35
countries, constituted the raw material for this study.

Structure and content of the paper

3 ILO: The Labour Inspection (Agriculture) Convention, 1969 (No. 129), adopted at the 53rd Session of the ILC (1969),
available at: https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO::P12100_INSTRUMENT_ID:312274
4 ILO: Labour Inspection Recommendation, 1947 (No. 81), adopted at the 30th Session of the ILC (1947). Status: Up-to-date

instrument, available at: http://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO::P12100_ILO_CODE:R081

5 ILO: Labour Inspection (Agriculture) Recommendation, 1969 (No. 133), adopted at the 53rd Session of the ILC (1969).

Status: Up-to-date instrument, available at:

https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:::NO:12100:P12100_ILO_CODE:R133
6 Protocol of 1995 to the Labour Inspection Convention, 1947 (PO81), adopted at the 82nd Session of the ILC (entry into

force: 9 June 1998). Status: Up-to-date instrument, available at:

http://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO::P12100_ILO_CODE:P081
7 ILO: Committee of Experts on the Application of Conventions and Recommendations (CEACR), Reports of the Committee of

Experts since 1932 – Links to pdf documents, available at: http://www.ilo.org/global/standards/applying-and-promoting-

international-labour-standards/committee-of-experts-on-the-application-of-conventions-and-recommendations/lang--
en/index.htm

10
This paper is primarily addressed to HR managers who are not necessarily
familiar with the role of the Labour Inspectorate or the duties of labour
inspectors.

Chapter 1 deals with the powers and employment status of labour inspectors.

Chapter 2 considers some major obstacles to putting in place optimal HR policies,

that is, policies that are likely to increase the productivity and quality of labour
inspectors’ performance and/or encourage them to stay in the job long enough
to reach their full potential.

Chapters 3, 4 and 5 cover the recruitment and selection, training, pay, promotion,
mobility, and work-life balance of labour inspectors – six areas where HR policies
have a powerful influence on how well they are likely to perform and how long
they will stay in the job.

11
Chapter 1. The labour inspector’s powers,
limitations and status

The main functions of labour inspectors are to enforce labour legislation and
provide information and advice on ways in which to comply with it. In order to
discharge these duties, labour inspectors are entrusted with a number of powers.
However, they can only exercise these powers if they are granted a status
guaranteeing that their decisions, and their activity as a whole, are independent
of external influences – such as an abrupt change in middle management on
account of political reasons.

It is hard to understand the need for a status that protects the independence of
labour inspectors without being familiar with their main functions and powers,
as well as the obligations with which they have to comply. These two areas are
examined in sections 1.1 and 1.2; a description of their status is contained in
section 1.3 of this chapter.

1.1 Powers of labour inspectors

Labour inspectors’ functions are to secure the enforcement of legal provisions
relating to conditions of work and the protection of workers; supply technical
information on ways to comply with these provisions; and to bring to the
competent authority’s notice any defects or abuses not specifically covered by
the existing law. Labour inspectors therefore play a key role in the compliance
process of labour legislation. It goes without saying that they cannot fulfil such a
mission without being given unique powers – powers that no other public
officials have.

These faculties or powers are set out in Articles 12, 13 and 17 (2) of Convention
No. 81:

Article 12

1. Labour inspectors provided with proper credentials shall be empowered:

12
 (a) to enter freely and without previous notice at any hour of the day or
night any workplace liable to inspection;

(b) to enter by day any premises which they may have reasonable cause
to believe to be liable to inspection; and

(c) to carry out any examination, test or enquiry which they may consider
necessary in order to satisfy themselves that the legal provisions are
being strictly observed, and in particular --

(i) to interrogate, alone or in the presence of witnesses, the

employer or the staff of the undertaking on any matters
concerning the application of the legal provisions;

(ii) to require the production of any books, registers or other

documents, the keeping of which is prescribed by national laws or
regulations relating to conditions of work, in order to see that they
are in conformity with the legal provisions, and to copy such
documents or make extracts from them;

(iii) to enforce the posting of notices required by the legal

provisions;

(iv) to take or remove for purposes of analysis samples of

materials and substances used or handled, subject to the
employer or his representative being notified of any samples or
substances taken or removed for such purpose.

2. On the occasion of an inspection visit, inspectors shall notify the employer or

his representative of their presence, unless they consider that such a
notification may be prejudicial to the performance of their duties.

Article 13

1. Labour inspectors shall be empowered to take steps with a view to remedying

defects observed in plant, layout or working methods which they may have
reasonable cause to believe constitute a threat to the health or safety of the
workers.

13
 2. In order to enable inspectors to take such steps they shall be empowered,
subject to any right of appeal to a judicial or administrative authority which
may be provided by law, to make or to have made orders requiring--

(a) such alterations to the installation or plant, to be carried out within

a specified time limit, as may be necessary to secure compliance with the
legal provisions relating to the health or safety of the workers; or

(b) measures with immediate executory force in the event of imminent

danger to the health or safety of the workers.

3. Where the procedure prescribed in paragraph 2 is not compatible with the

administrative or judicial practice of the Member, inspectors shall have the
right to apply to the competent authority for the issue of orders or for the
initiation of measures with immediate executory force.

Article 17

2. It shall be left to the discretion of labour inspectors to give warning and

advice instead of instituting or recommending proceedings.

It is clear that some of the powers listed above, such as the issuing of orders
requiring alterations to the installation or plant, can cause major disruptions to
businesses. This is one of the reasons why labour inspectors’ actions must not be
politically biased, and why they should not have a direct economic interest in the
companies they inspect or their competitors; neither should they serve a group’s
or an individual person’s interests.

The prohibitions that labour inspectors must observe, which are to be found in
ILO Conventions Nos. 81 and 129, are a means of counterbalancing the powers
with which they are entrusted. In addition, labour inspectors are bound by the
general obligations of civil servants. The State should seek to prevent labour
inspectors’ misuse or abuse of their powers by fostering observance of these
specific and general obligations, and by prosecuting and penalizing any
violations.

However, using legislative or de facto measures to curb labour inspectors’

powers, allegedly with a view to preventing their misuse, may deprive them of
their means to carry out their functions. Making previous notice to the employer

14
mandatory before a visit to the workplace is an example of this: if the enterprise
concerned has any employees without a work contract, they will probably be
asked not to turn up on the day of the labour inspector’s visit.

That being said, it is a prerequisite for labour inspectors to have a status that
guarantees them employment stability so that that they can carry out their duties
with professionalism. If it were possible to remove labour inspectors for arbitrary
or political reasons, the labour inspection service would not be able to fulfil its
role – and compliance with labour legislation would most probably suffer as a
result.

A sound HR policy for Labour Inspectorates should therefore endeavour to

ensure the professional conduct and accountability of labour inspectors, while in
no way weakening their employment status or curtailing their powers.

1.2 Prohibitions that labour inspectors must observe

Article 15 of ILO Convention No. 81 succinctly identifies the three main
prohibitions that labour inspectors must observe.

Article 15

Subject to such exceptions as may be made by national laws or regulations,

labour inspectors--

(a) shall be prohibited from having any direct or indirect interest in the
undertakings under their supervision;

(b) shall be bound on pain of appropriate penalties or disciplinary

measures not to reveal, even after leaving the service, any
manufacturing or commercial secrets or working processes which may
come to their knowledge in the course of their duties; and

(c) shall treat as absolutely confidential the source of any complaint

bringing to their notice a defect or breach of legal provisions and shall
give no intimation to the employer or his representative that a visit of
inspection was made in consequence of the receipt of such a complaint.

15
With regard to the provision that labour inspectors may not have “any direct or
indirect interest in the enterprises under their supervision”, the CEACR has
pointed out that the concept of direct and indirect interest must be defined with
precision in national legislation so as to assess the exact scope of the prohibition.
But even when the concept is clearly defined, the CEACR regrets that it is often
not broad enough. For instance, there are countries where the concept of
“interest” is confined to the material or financial interest in the enterprise being
inspected.

By contrast, the Committee recommends that the concept of direct and indirect
interest embraces not only material or financial advantages but also personal
interests of a psychological, emotional or political nature that are likely to exert
an undue influence on the discharge of the inspector’s duties.

With regard to the duty of confidentiality, it must be noted that the scope of this
obligation differs in various countries. Nonetheless, it is not this disparity that
most concerns the CEACR but the fact that not all Members have set out in law
that this obligation should be maintained after inspectors have left the service.
The Committee has thus on occasion drawn the attention of certain governments
to the need to amend the legislation in this respect.

The third obligation incumbent upon labour inspectors, “treating as absolutely

confidential the source of any complaint bringing to their notice a defect or
breach of legal provisions”, is intended to protect the complainant from reprisals.
Since the complainant is usually an employee, he/she might be harassed at work
or dismissed if their identity is revealed. Fortunately, according to the
information available to the CEACR, compliance with this obligation has not
raised any particular difficulties.

1.3 The labour inspector’s status

To enable labour inspectors to fulfil their duties and mission, their impartiality
and independence must be safeguarded at all times. These concepts may be
guaranteed in different ways; however it is a prerequisite that the continued
employment of inspectors in the service should not depend upon political
considerations.

16
Consequently, Article 6 of Convention No. 81 states that the inspection staff shall
be composed of public officials whose status and conditions are such that they
are assured of stability of employment: A public official is anyone in a position of
official authority that is conferred by a state, whether appointed or elected;8 Article 6
of Convention No. 81 adds the requirement of stability of employment to this
definition.

The CEACR understands that stability of employment is best secured if labour

inspectors are civil servants appointed on a permanent basis rather than simply
state employees. This is the case in many Member States, where labour
inspectors are permanent civil servants. For instance they are funcionarios de
carrera (in Spanish) or fonctionnaires (in French) – where labour inspectors are
among the permanent staff (le personnel statutaire, and they are agents titulaires
de leur statut). But this does not hold true everywhere.

For instance, there are countries where all labour inspectors are appointed for a
limited period of time and their contract is renewed if their performance is
deemed satisfactory. In other Member States, some of the inspection staff are
offered permanent employment once their probation period is over – while other
labour inspectors with the same duties and roles are employed on a fixed-term
basis.

However, even if the status of permanent civil servants is coupled with a national
legislation in which labour inspectors’ powers and duties comply fully with ILO
standards, this is not nearly enough to foster the integrity and commitment of
labour inspectors.

At this point, it is worth examining what other factors are needed. First, there is
the issue of resources, which we shall examine in some detail in the next
chapters; second, it is vital that Labour Inspectorates engage with their
communities and governments, and in particular with the stakeholders at the

8
Compliance: Bribery and fraud: Guidance for academic, administrative and support staff, including
anti-bribery and anti-fraud policies (Oxford), available at:
https://compliance.admin.ox.ac.uk/oxdrupal_website/ To find the quote: bribery& fraud>definitions
and interpretations

17
workplace, such as the employers’ and workers’ representatives; and third, the
Labour Inspectorate should attempt to create a work environment that allows
and encourages individuals to conduct themselves in an ethical and professional
manner.

The International Association of Labour Inspection (IALI) is well aware of the role
played by these factors. In its Global Code of Integrity for Labour Inspection
(adopted in 2008), it states that the guide is intended to assist people employed in
Labour Inspectorates to understand their obligations as public officials 9 and to
provide guidance on mechanisms for all employees to distance themselves from
unethical practices and to out such practices whenever they are noticed.10

The Code provides an ethical framework of six broad values:

 knowledge and competence;

 honesty and integrity;
 courtesy and respect;
 objectivity, neutrality and fairness;
 commitment and responsiveness; and
 consistency between personal and professional behaviour.

Each of these six values is expressed in terms of Standards of Conduct for both
individuals and the Labour Inspectorate. The implementation of these values and
standards requires commitment at both the individual and organizational level.
But it must be remembered, as the IALI points out, that this Code of Integrity is
only a framework and should stimulate each country to discuss and adopt its own
Code reflecting these common principles and suited to local conditions.11

9
IALI: Global Code of Integrity for Labour Inspection, (endorsed in 2008), p. 4, available at:
http://www.ilo.org/labadmin/info/WCMS_117608/lang--en/index.htm

10
ibid., p. 5.
11
ibid., p. 2.
18
Chapter 2. Threats and challenges faced by
labour inspectors

This chapter considers the major obstacles to developing a labour inspection

service that fulfils its main functions. As mentioned in chapter 1, the main
functions of the Labour Inspectorate are to enforce labour legislation and to
provide advice and information on ways to comply with this legislation. Both
functions are entrusted to labour inspectors. It therefore goes without saying
that anything that prevents labour inspectors from discharging their duties or
undermines their powers is an obstacle to having a labour inspection service that
fulfils its role.

It must be stressed at the outset, that ill-suited HR policies will not be among the
obstacles examined here. This chapter will focus on those obstacles that are
prejudicial both to labour inspectors in the execution of their duties, and to HR
departments when they are trying to establish policies that encourage high-
performance standards and accountability among labour inspectors.

These obstacles will include:

 Restricted mandate of the Labour Inspectorate and curtailed powers of the

labour inspection system.
 Entrusting labour inspectors with tasks that are unrelated to their primary
functions.
 Challenges specific to lower middle-income and low-income economies.
 Challenges specific to Labour Inspectorates in high-income countries (HICs)
and middle-income countries (MICs).
 Socially prevailing gender prejudices and prejudices against certain groups.
 Violence against labour inspectors.
 Lack of material resources.

Restricted mandate of the Labour Inspectorate/Curtailed

powers of the labour inspection system

19
The full mandate of the labour inspection system is defined in Article 3 of ILO
Convention No. 81:

1. The functions of the system of labour inspection shall be:

 (a) to secure the enforcement of the legal provisions relating to conditions

of work and the protection of workers while engaged in their work, such as
provisions relating to hours, wages, safety, health and welfare, the
employment of children and young persons, and other connected matters,
in so far as such provisions are enforceable by labour inspectors;

 (b) to supply technical information and advice to employers and workers

concerning the most effective means of complying with the legal provisions;

 (c) to bring to the notice of the competent authority defects or abuses not
specifically covered by existing legal provisions.

2. 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.

As noted by the CEACR (2006), many different issues are covered by conditions of
work. For example, in addition to the factors listed in Convention No. 81, Article 6
(1) (a) of Convention No. 129 lists weekly rest, holidays and the employment of
women.

Likewise, the Committee points out that the phrase protection of workers while
engaged in their work, as used in Convention No. 81, has to be understood in a
broader manner in the light of subsequent Conventions and Recommendations.
Thus, social security and conditions of termination of employment, as well as the
fundamental rights of workers – such as the right to organize and engage in
collective bargaining – could all be considered as being included in the concept
of the protection of workers.

ILO standards do not therefore impose a broad or a narrow interpretation of

either working conditions or protection of workers. Consequently, there is some
ambiguity, or rather flexibility, as to what the remit of the labour inspection
system might be. This flexibility has translated into two types of National Labour
Inspectorates: the generalist and the specialist. The former has a broad mandate

20
and addresses elements of employment and industrial relations (including
working conditions, health, safety and welfare of workers), while the latter is
usually restricted to occupational safety and health (OSH). It must be noted that
although there are some National Labour Inspectorates that are purely
generalist or purely specialist, there are countries in which the labour inspection
system is somewhat mixed.

It has been argued that generalist Labour Inspectorates may be better equipped
to respond to the consequences of economic and labour market change, such as
an increase in the number of migrant workers and the growth of the informal
economy, because they already deal with social and employment matters.12 In
addition, it has been noted that if one single authority, instead of more than one,
monitors compliance with most labour provisions, the chances are that violations
of a different nature – e.g. a breach of legislation in both OSH and social security
– affecting the same worker/s will be identified and resolved with less hassle for
the employees concerned. That being said, the ILO does not favour the generalist
model over the specialist one; neither can any preference be inferred from the
CEACR’s observations over the years.

The Office’s main areas of concern with respect to restrictions on the mandate of
the labour inspection services and labour inspectors’ powers are the following:

 Areas that are exempt from the application of national labour laws, and
thus, outside the scope of action of the Labour Inspectorate. In some
countries, export processing zones (EPZs) are partially or totally exempt
from supervision. Other areas outside the coverage of labour laws are new
kinds of informal working practices (e.g. zero hours contracts,
homeworking), which previously may have been considered part of the so-
called “informal economy”. Finally, domestic work very often lies outside
the remit of the National Labour Inspectorates. These exemptions mean
that in a given country not all people at work have the same level of
protection under the law.

12
P. Teague: “Reforming the Anglo-Saxon model of labour inspection: The case of the Republic of Ireland”, in
European Journal of Industrial Relations (2009), available at:
http://journals.sagepub.com/doi/abs/10.1177/0959680109103603
21
  Member States in which the inspection and monitoring of occupational
safety and health (OSH) are managed by employers’ associations. The ILO
has always maintained that monitoring, alerts, health expertise and the
provision of health-related advice must be the responsibility of a public
body.

 Restrictions on labour inspectors’ powers. There are a number of Member

States where labour inspectors have to give notice to the employer before
visiting the workplace. This is a very serious restriction on labour
inspectors’ powers, since it may result in breaches of law such as child
labour or undeclared workers going undetected.

Entrusting labour inspectors with tasks that are unrelated

to their primary functions
The above-mentioned restrictions are not the only cause for concern. Indeed,
entrusting labour inspectors with tasks that are not directly related to the
discharge of their duties is often inadvisable. Although some of these tasks (e.g.
calculation of severance pay, drafting of resignation letters at the worker’s
request, issuance of work permits) are not in conflict with labour inspectors’ main
functions, they take up time and divert the labour inspectors’ attention from their
primary duties. More worryingly, other tasks entrusted to labour inspectors in
some Member States are regarded as incompatible with their labour inspectors’
main functions.

Having dealt with the obstacles related to the legal framework that defines the
remit of the Labour Inspectorate, let us now turn to other kinds of challenges –
over which labour inspectors have no control. These include: the socio-economic
level of development of the country; the strength of racial and gender prejudices;
and the mistrust of – or even contempt for – civil servants. These factors must be
taken into account to ensure that labour inspectors’ performance is as effective
as possible. Equally important, a well-conceived HR policy for labour inspection
can mitigate the negative effects of those factors.

22
Challenges specific to lower middle-income and low-
income economies
A country’s socio-economic level of development is usually reflected in the level
of its skilled workforce, the sectors employing the most people, and the
employment rate. In countries with agricultural-based economies, the
percentage of people at work and of skilled workers is low, with many people
working in the informal economy. In these countries, labour inspectors must deal
with many instances of bogus self-employment, undeclared work, and high
under-reporting rates of work-related accidents. This latter feature, the high
under-reporting of occupational accidents, is also found in countries which have
experienced rapid economic growth and industrialization over the past 20–40
years; however, in these countries, the labour inspector’s job is somewhat easier
in that the workplaces are generally larger and the percentage of workers with
no fixed place of work is lower.

In both these categories of countries, only a small share of the gross domestic
product (GDP) is earmarked for the prevention of work-related accidents and
diseases, and as a result the percentage of preventable deaths, injuries and
diseases among workers is high. It is not only the lack of funds that explains why
independent low-skilled workers do not invest in preventive measures: they are
often poorly educated and trust in traditional practices and remedies – and in
addition, they do not have easy access to reliable information on prevention. In
the case of countries that have only been industrialized fairly recently, the safety
and health management in factories is still inadequate, and in some cases
virtually non-existent.

There is another difficulty that often goes hand in hand with weak economies:
the fact that there are comparatively few highly educated people who, as a rule,
are not attracted to the civil servant sector; they often choose to move abroad
or work in the private sector.

Challenges specific to labour inspectorates in HICs and

MICs

23
Two relatively new phenomena are affecting many HICs, and less acutely MICs:
the increase in non-standard forms of employment and the rise in the number of
immigrant workers.

Among the non-standard forms of employment that are new or have become
increasingly important over the past 20 years, digital platform work is the most
innovative and has grown appreciably in recent years. Digital platform work is in
many respects very heterogeneous. It includes relatively high-skilled IT tasks
(matched and delivered online), lower-skilled repetitive online work, and work
that is matched on the platform, but which involves services that require physical
delivery, as is the case with large companies in the sectors of food delivery and
the transport of passengers.

When it comes to enforcing labour law, the status of platform workers is a key
issue for Labour Inspectorates whether they are self-employed or employees.
Labour inspectors require a sound knowledge of regulations on labour
employment relationships, and they also need to understand how digital
platforms work. Meeting these needs involves training in those two areas – but
many Labour Inspectorates still fall short in this respect.

The main reason why the status of platform workers is not yet part of the training
content in many HICs and MICs is that there is no broad consensus that the
current labour legislation can embrace the employment relationship between
platform workers and the platform. Indeed, it is still a matter of controversy
whether or not platform workers meet the legal criteria to be regarded as
employees.

Despite the difficulty in classifying digital platform workers as employees or self-

employed persons, a number of OECD countries have taken measures to provide
them with social protection.13

The second challenge is the growth of “undeclared work”, which has grown in
parallel with the increase in immigrant workers. The ways in which undeclared

13
OECD: The future of social protection. What works for non-standard workers? (2018), available at:
https://doi.org/10.1787/9789264306943-en
24
work is a challenge to Labour Inspectorates is well summarized in an ILO working
document: Labour inspection in Europe: undeclared work, migration, trafficking:

In many cases, migrant workers – particularly migrants with an irregular or

unauthorized status – are recruited into undeclared work. They thus become
vulnerable and subject to lower level standards. Demands that labour
inspectorates cooperate in enforcing immigration law may, however,
compromise the core function of labour inspectors (which is the application of
labour legislation for all workers). At the same time, migration issues have to be
taken into account when considering how labour inspectorates can contribute to
preventing and regularizing undeclared work.

Labour inspectorates face practical obstacles in planning and carrying out visits
since undeclared work is by its nature hidden and not easily detected. Even when
inspectors uncover situations of undeclared work, a delicate balance must be
considered taking due regard of the interests of workers, legitimate enterprises
and, in certain cases, the applicable law on unauthorized immigration.14

Nine years later, in 2019, undeclared work is still a challenge to Labour

Inspectorates across Europe. The need for inspectors to acquire specific skills
(being able to speak foreign languages) and specific knowledge (understanding
other countries’ labour law and social security requirements) is advised especially
in the context of “cross-border” workers.15 A common complaint among senior
officials in European Union Labour Inspectorates (EU LIs) is the difficulty they
experience in establishing: cooperation with tax authorities, for instance on the
level of data exchange and data sharing, and/or on the level of operation. They
also find it difficult to take the lead in establishing greater cross-government
cooperation on the level of strategy. It has often been mentioned that there is a

14
ILO: Labour inspection in Europe: undeclared work, migration, trafficking, Working Document No. 7,
LAB/ADMIN (Geneva, 2010), p. vii, available at: https://www.ilo.org/wcmsp5/groups/public/---ed_dialogue/---
lab_admin/documents/publication/wcms_120319.pdf

15
C. Williams, P. Vanden Broeck, A. Scharle: Future role and competence profile of Labour Inspectorates
(Lithuania, 2019).
25
need to develop much better relationships between inspectorates and social
partners as well as other stakeholders.16

Socially prevailing gender prejudices and prejudices

against certain groups
Gender prejudices and prejudices against certain ethnic groups (e.g. Roma, lower
castes) are never reflected in the explicit criteria for recruiting or promoting
labour inspectors. In Member States where the interview is part of the selection
process and/or where performance appraisal is used, these prejudices may play
a part, especially when there is only one interviewer or evaluator with no
guidelines as to how to proceed. There are, however, a number of countries in
which the labour inspection services lawfully discriminate against older
applicants or applicants with disabilities. Examples of such types of
discrimination are: age limits to civil servants wishing to take exams for
promotion to administrative posts; and countries where being able-bodied is a
requisite for anyone wanting to be a labour inspector.

Unfortunately, prejudices prevalent in a society, even when they do not exist in

the Labour Inspectorate’s decision-making processes, will affect labour
inspectors in their dealings with employers and workers – especially if they are
members of a marginalized group or gender themselves. This is one of the
reasons why labour inspectors’ advice and even warning orders may go
unheeded, thus forcing the Labour Inspectorate to resort to sanctions that are
often contested by employers. As a result of this, workers’ occupational hazards
are not removed promptly after detection, and other statutory infringements
take a long time to be resolved. Another effect of such prejudices is that the
percentage of female labour inspectors and labour inspectors from marginalized
groups is rather small in a number of countries, often because individuals from
such groups have difficult access to higher education or because they are
susceptible to violent or disrespectful treatment from colleagues, employers or
employees.

16
ibid., p. 5.
26
Violence against labour inspectors
Unlike all the obstacles examined above, violence against labour inspectors in its
least extreme forms, such as offensive language, is – and has always been – fairly
common all over the world. This is not surprising as labour inspectors have to
enforce the law and are often met with hostility.

While physical attacks are rare, verbal ones during inspection visits are not
uncommon, even in regions of the world with very low levels of violence.
However, after the murder of two French labour inspectors during a farm
inspection in 2004, the European Senior Labour Inspectors’ Committee (SLIC)
drew up a guide: Violence towards inspectors: Good practice guide. The SLIC guide
gives advice on how to prevent violent incidents and to support labour inspectors
who have been victims of violence. Although most of the measures in the guide
are not particularly costly, they may constitute a financial burden for a number
of National Labour Inspectorates that are seriously underfunded.

Lack of resources
Inadequate funding for Labour Inspectorates translates into insufficient
resources, which in turn limits the Inspectorate’s capacity to carry out its main
duties. There are four areas in which underfunding has the greatest negative
impact: insufficient number of labour inspectors; insufficient use of new
technologies; absence of means of transportation; poorly equipped local offices.

According to Article 10 of Convention No. 81, the number of labour inspectors

must be determined taking into account the following factors:

 (a) the importance of the duties which inspectors have to perform, in

particular--

(i) the number, nature, size and situation of the workplaces liable to
inspection;

(ii) the number and classes of workers employed in such workplaces;

and

(iii) the number and complexity of the legal provisions to be enforced;

27
  (b) the material means placed at the disposal of the inspectors; and

 (c) the practical conditions under which visits of inspection must be carried
out in order to be effective.

The Committee on Employment and Social Policy (ESP Committee) of the

Governing Body of the ILO suggested, in 2006,17 ratios of labour inspectors to
workers; but it used the level of the individual country’s economic development
as the only criterion for determining such ratios. The reality is that the number
of labour inspectors relative to workers is low – and not only low but insufficient
in low-income and medium-income countries. Nonetheless, even in relatively
wealthy regions of the world, the number of labour inspectors is often regarded
as insufficient. This was the view taken by the European Parliament in its
resolution of 14 January 2014, where it voiced its concern at the understaffing of
Member States’ inspection authorities.18 One of the measures suggested to relieve
overworked labour inspectors is to hire support staff who could do some of the
administrative tasks which labour inspectors do presently, thus allowing
inspectors to concentrate on their primary duties.

Information systems are a precious tool for the collection and analysis of data,
without which it is hard to develop sound planning and an effective coordination
of inspections. Such systems can also improve administrative transparency and
accountability, since they make it possible to record the findings, follow up and
sanctions of each inspection visit. However, as remarked by the Governing Body
ESP Committee in 2010: the initial set-up and maintenance of new technological
systems can be costly, (….) in the long term these investments can contribute to a more
cost-effective use of staff and reduced communication expenses. There can be no
denying that information systems are extremely useful for HR decisions and the

17
ILO: Governing Body Committee on Employment and Social Policy of the Governing Body (GB.297/ESP/3),
297th Session (Geneva, November 2006), further to the Discussion of the General Survey on labour inspection
at the 95th Session (2006) of the International Labour Conference. The ESP stated that: the ILO has taken as
reasonable benchmarks that the number of labour inspectors in relation to workers should approach: 1/10,000
in industrial market economies; 1/15,000 in industrializing economies; 1/20,000 in transition economies; and
1/40,000 in less developed countries.
18
European Parliament: European Parliament resolution of 14 January 2014 on effective labour
inspections as a strategy to improve working conditions in Europe (2013/2112(INI)) (Strasbourg, 2004),
available at: http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+TA+P7-TA-2014-
0012+0+DOC+XML+V0//EN

28
recruitment of new labour inspection staff, as well as for the promotion and
granting of other incentives to individual labour inspectors. Unfortunately, not
only low- but also middle-income countries lack such systems.

As regards the practical conditions under which inspections are carried out, a lack
of resources restricts the transportation of labour inspectors to workplaces – and
this has an adverse effect on their performance. The CEACR is well aware that a
major obstacle preventing labour inspectors from discharging their duties is the
inadequacy or absence of means of transport. In many low-income countries, the
vehicles provided by the Labour Inspectorate are so few that labour inspectors
often have to cancel or reschedule visits, or else replace them with visits to
workplaces they can reach on foot. In these same countries public transport is
scarce and unreliable, and if labour inspectors use their own cars the costs
involved are not usually reimbursed.

The fourth and final area in which underfunding has the greatest impact on
labour inspectors’ performance is poorly equipped or inadequate offices. As
stated in Article 11 of Convention No. 81:

1. The competent authority shall make the necessary arrangements to furnish

labour inspectors with--

(a) local offices, suitably equipped in accordance with the

requirements of the service, and accessible to all persons concerned;

(b) the transport facilities necessary for the performance of their

duties in cases where suitable public facilities do not exist.

2. The competent authority shall make the necessary arrangements to

reimburse to labour inspectors any travelling and incidental expenses which
may be necessary for the performance of their duties.

As reported to the CEACR, not only are there too few offices in many countries,
but those that do exist are not suitably equipped. Problems range from not
enough computers or a lack of writing materials to the absence of electricity or
water. Some of these shortages clearly prevent labour inspectors from carrying
out their duties and may cause low morale.

29
Chapter 3. Recruitment and selection of
labour inspectors

Conventions Nos. 81 and 129 make the same two comments on the issue of
recruitment:

Article 7, Convention No. 81

1. Subject to any conditions for recruitment to the public service which may be
prescribed by national laws or regulations, labour inspectors shall be
recruited with sole regard to their qualifications for the performance of
their duties.

2. The means of ascertaining such qualifications shall be determined by the

competent authority.

3. Labour inspectors shall be adequately trained for the performance of their

duties.

Article 8, Convention No. 81

Both men and women shall be eligible for appointment to the inspection staff;
where necessary, special duties may be assigned to men and women
inspectors.

Article 9, Convention No. 129

1. Subject to any conditions for recruitment to the public service which may be
prescribed by national laws or regulations, labour inspectors in agriculture
shall be recruited with sole regard to their qualifications for the performance
of their duties.

2. The means of ascertaining such qualifications shall be determined by the

competent authority.

3. Labour inspectors in agriculture shall be adequately trained for the

performance of their duties and measures shall be taken to give them
appropriate further training in the course of their employment.

Article 10, Convention No. 129

30
 Both men and women shall be eligible for appointment to the labour inspection
staff in agriculture; where necessary, special duties may be assigned to men
and women inspectors.

For its part, the Labour Inspection Recommendation, 1923 (No. 20), gives some
indication as to the sort of people who should work as labour inspectors:

… it is essential that the inspectors should in general possess a high standard

of technical training and experience, should be persons of good general
education, and by their character and abilities be capable of acquiring the
confidence of all parties.

The CEACR’s recommendations are more specific. First, the “qualifications for the
performance of their duties” should include not only technical skills and
qualifications, but also personal and psychological abilities. Second, discretion,
integrity and impartiality should be among those personal qualities. Third, in the
Committee’s opinion, appropriate in-depth interviews conducted in a fair and
objective manner are the best way for the competent authority to select the most
suitable candidates.

After having examined the information on the recruitment process of the 35

countries listed in Appendix II, we observed the following: what individual
countries believe to be the right qualifications for a prospective labour inspector
depends to a great extent upon whether the inspection system is a generalist or
specialist one; and upon the importance given to the psychological profile of the
candidate.

Generalist labour inspection systems (e.g. the Spanish model) look for candidates
already familiar with legal provisions on working conditions, while specialist
labour systems (e.g. the United Kingdom model) do not, since their Labour
Inspectorates only deal with health and safety issues. As a general rule, there is
at least one knowledge-based exam on labour legislation in the selection process
of generalist labour inspections; by contrast, in specialist labour inspection
systems, candidates are not expected to have knowledge of OSH legislation when
applying for the post of labour inspector.

As for the importance given to soft skills, they tend to play a central role in
specialist labour inspection systems: candidates without the required soft skills
will not be recruited. In the case of generalist labour inspections, the importance
31
of soft skills varies widely: in some countries they are not assessed at all, while in
others they are – either by means of an interview (e.g. France) or through an
assessment conducted by a professional (e.g. Argentina). The soft skills most
widely assessed are: the ability to relate to and work with people; the ability to
work well under pressure and without supervision; initiative; and the ability to
communicate effectively.

We shall now turn our attention to the similarities among these 35 countries as
regards their recruitment and selection process, starting with requirements
other than the ones discussed above:

1. A certain level of education, which applicants must have attained by the

time they apply to the open competition for entry into the service. This
requirement is extremely common. However, the minimum educational
level may range from a secondary education certificate (Armenia requires
only the completion of secondary education for junior positions) to an
advanced academic degree, such a master’s degree (e.g. the Czech
Republic). Very few countries (e.g. Finland and Denmark) require no
minimum level of education.

2. A clean criminal record, as is the case with all other public service posts.

3. Being a national of the country that recruits. There are a number of

exceptions: vacancies at the Health and Safety Executive (HSE) in the
United Kingdom, for instance, are open to UK nationals, Commonwealth
and European Economic Area (EEA) nationals, as well as certain non-EEA
nationals; in Brazil, not only Brazil nationals but Portuguese nationals who
are covered by the Equality Statute between Brazil and Portugal may be
appointed as labour inspectors.

4. Written tests. At some stage in the selection process, candidates must sit
a/several written test/s that assess, as mentioned above, soft skills or
relevant legal knowledge – or both. There are, however, a number of
countries where the selection process does not involve any kind of written
examination. This is the case of Honduras, where applicants are selected
for appointment as labour inspectors following an evaluation of their CVs.
Other countries, like Tunisia, hold two types of competitions: those that

32
 include examinations, and others where candidates with the most suitable
CVs are appointed.

5. Age limits. The general trend is to abolish age limits, in compliance with
equality obligations; but some Member States have yet to repeal them. In
general, the minimum recruitment age is 18 years.

Having considered the main similarities among the 35 countries, we shall now
examine the differences between them:

1. In some countries, there may be only external competitions for the vacant
posts of labour inspector; in others, there are both internal and open
competitions. The latter case is fairly common: competitions open only to
civil servants – so-called “internal” competitions; and those open to anyone
meeting the minimum criteria for the post – so-called “external”
competitions. There are however a number of countries where
competitions are always external. This does not necessarily imply that the
vacant posts are always filled by the people who obtain the highest scores
on the competition; there are, for instance, cases in which vacancies are
filled from among the ranks of civil servants without any kind of
competition (e.g. Kazakhstan).

2. Work experience may be a requirement, or considered an asset, in some

countries; in others, it is irrelevant to the recruitment process. When work
experience is a requirement (e.g. Slovenia – five years either as an
employer or an employee – Argentina, Pakistan, Peru), the number of
years of prior work experience usually depends on the level of the position:
the more senior the position, the longer the work experience required. It
is also worth noting that, as a general rule, the candidate’s work
experience must be related to the duties that the labour inspector is
expected to perform (e.g. Finland).

3. An interview may, or may not, be part of the selection process. A number

of countries do not include an interview when they are recruiting labour
inspectors, although they may conduct an oral examination – or more than
one (e.g. Spain). When this interview is part of the selection process, it is

33
 usually designed to assess the candidates’ personal qualities and a
number of soft skills.

4. Training may be included in the selection process, or only carried out after
the candidate’s appointment. When training is an integral component of
recruitment, it usually takes place at the end of the selection process; i.e.
it is only provided to candidates who have successfully completed all the
other stages (e.g. Venezuela). As a general rule, candidates who succeed
in reaching the training stage are subsequently tested on the content of
the training they have received.

5. The policy towards disabled applicants varies considerably from country to

country. In a number of Member States, the candidate must be in good
health or without disability (e.g. Peru, Kazakhstan). In others, the candidate
must be able to drive a car (New Zealand), and have a number of soft skills
– some of which might make it difficult for disabled persons to apply. In
another group of countries, the health status requirement is phrased in
terms vague enough to encourage people with certain types of disability
to apply (e.g. Brazil). Among HICs, positive discrimination towards disabled
applicants is common, but takes different forms. For instance, the United
Kingdom has the guaranteed interview scheme (GIS), thanks to which all
disabled people applying under this scheme are invited to an interview if
they meet the minimum criteria.

Good practices
When assessing the suitability of a particular recruitment/selection practice, it is
important to bear in mind two factors: the resources available for the recruitment
process and to the Labour Inspectorate; and what the job of labour inspector
actually involves in the country concerned. A number of policy questions follow
here below – and the answers to these questions often depends on either or both
these factors.

34
Should priority be given to soft skills and practical knowledge
over academic qualifications and knowledge of labour legislation
– or the other way around?
As mentioned earlier in the text, labour inspectors in some countries deal with
issues of occupational safety and health alone; in others they must monitor
compliance with all labour legislation relating to working conditions. But there
are other ways in which the tasks of labour inspectors differ; for instance, in some
Member States, labour inspectors inspect only one type of work (e.g. Finland). In
general, a narrower scope of action justifies less emphasis on a knowledge of
labour legislation – i.e. the fewer the types of work labour inspectors must inspect
and the fewer the working conditions they must monitor, the greater the
importance of so-called soft skills when selecting applicants.

Notwithstanding these differences, there is no denying that there are a number

of soft skills that all labour inspectors must have. But although there seems to be
enough evidence that they can be boosted through training interventions,19 it is
also true that when it comes to deliberate attempts to enhance people's soft skills,
the glass is at least half full [...] soft skills coaching, training, and development are
more likely to work on those who need it the least. 20 The safest solution would
therefore seem to be to recruit people who already have at least some of the key
soft skills, such as an ability to communicate well, to take the initiative, to take
decisions without constant supervision, and discretion.

Should candidates be appointed by direct selection or on the

basis of their CV?
If the resources available for the recruitment process are scarce and labour
inspectors do not require an extensive and up-to-date knowledge of labour
legislation for carrying out their routine tasks, selecting the candidates with the
most suitable CVs may well be a reasonable option.

19
T. Chamorro-Premuzic: “Can you really train soft skills? Some answers from the science of talent”, in Forbes,
available at: https://www.forbes.com/sites/tomaspremuzic/2018/06/14/can-you-really-train-soft-skills-some-
answers-from-the-science-of-talent/#54f4e45dc460
20
ibid.
35
Nonetheless, if a country has enough resources to design appropriate written
tests and assess the applicants’ performance, CVs should not be used as the only
or main basis for recruitment for the following reasons. First, if candidates take
the same examination, under the same conditions and are assessed using the
same criteria, this helps create a level playing field. Second, examinations
specifically designed for the recruitment of labour inspectors are a means of
checking whether or not the knowledge previously acquired by the candidates is
still up-to-date and relevant to the post for which they are applying.

Should previous work experience be a requirement?

Given the duties of labour inspectors, it seems advisable for applicants to have at
least one or two years’ work experience before applying for the post rather than
doing so upon completion of their studies. Another advantage of considering
work experience – if not as a requirement but at least an asset – is that Labour
Inspectorates are more likely to end up with new appointees who are not so
young. Older recruits are less likely to quit their jobs, and a number of National
Labour Inspectorates sorely need a stable workforce. It also makes more sense
for countries to allocate resources to training new appointees who are likely to
stay in their job long enough to build the necessary skills and knowledge for a
career, rather than to applicants seeking short-term opportunities.

Should a technical interview be part of the selection process?

An interview is generally considered to be one of the best means to assess
whether or not a candidate has the soft skills required to do a job well.

Ideally, there should be a selection committee to ensure that applicants short-

listed for an interview are evaluated by more than one individual, thus
minimizing the potential for personal bias. At least some of the members of the
committee should be senior labour inspectors; under-represented groups must
have equal opportunity to serve on these committees.

The candidates should be asked questions that are relevant to the vacant position
and to the specific skills and ability required to perform the job. These questions
should also be based on a number of predetermined behavioural requirements.
For example, rather than merely considering "good communication skills", there

36
should be a list of specific behavioural patterns that might reveal whether the
candidate has this attribute. By way of example, one of these behavioural traits
could be “can use different registers to communicate the same idea”.

There are other rules that are worth observing. All candidates should be asked
the same questions, and these should include open-ended questions, i.e.
questions requiring more than a “yes”- or “no”-style answer, such as
behavioural/hypothetical questions relating to situations the candidate is likely
to face on the job. An example of this could be: “What would you do if you were
called names by the manager of the factory you were inspecting?”

Should a training course be included as part of the selection

process?
A fair number of countries do include a training course as part of the selection
process, but the duration and type of training varies from country to country. In
some recruitment processes the training component lasts for a few days (Peru),
but in others it covers several months (e.g. Spain); another major difference is
that the training may or may not include a practicum component.

Even when the training component lasts only a few days, it may – if the content
relates to the specific tasks of the labour inspector – be a deciding factor for some
applicants. They may realize that they are not, after all, attracted to the job, or
that they lack the skills to do it well. These applicants are likely to abandon the
recruitment process at this stage, and those that are left will be strongly
motivated and thus more likely to become well-performing labour inspectors if
they are appointed.

As a rule, countries that do not provide this training stage as part of the selection
process offer initial training to newly-recruited labour inspectors during their
probationary period. This training can last either several months or years and is
therefore a lot more thorough. However, it would be more cost-effective to offer
some sort of training during the selection process and provide further training
only to those applicants who have been selected.

Should there be positive discrimination for disabled applicants?

37
The absence of any type of disability is not a requirement in many countries. But
should positive action for disabled candidates be adopted when recruiting labour
inspectors?

First, positive discrimination in recruitment must be legal in the country, as is the

case with the United Kingdom, where the Equality Act 2010 (EA ’10) makes
provision for this. Second, the chosen form of positive discrimination should
ensure a level playing field – rather than giving some sort of privilege to disabled
candidates.

There are two considerations that should be taken into account when removing
barriers for disabled candidates:

 candidates should be given enough information about each stage in the

recruitment process, and in particular about the tests they will have to
take. This information, in countries where the examination board is
allowed to make adjustments for disabled applicants, will help candidates
with an impairment to decide whether they need to disclose it or not.

 written examinations help to protect physically impaired people from any

prejudices against their disability for there is no visual contact between the
applicant and examiner. However, disclosure is necessary when the
candidate might be at a disadvantage if necessary adjustments are not
made to the written examination. For example, candidates with dyslexia
might be allowed to use a spell checker when completing the written
examination.

38
Chapter 4. Training of labour inspectors

References to training are found in Recommendations Nos. 20 and 133 and

Conventions Nos. 81 and 129. Recommendations Nos. 20 and 133 focus on the
training of newly recruited inspectors. Recommendation No. 133 advises that
persons appointed as labour inspectors […] should be given adequate training on the
job as rapidly as possible (Article 7), 21 and Recommendation No. 20 links the
probation period to the training of the newly recruited labour inspectors:

… Inspectors on appointment should undergo a period of probation for the

purpose of testing their qualifications and training them in their duties … their
appointment should only be confirmed at the end of that period if they have
shown themselves fully qualified for the duties of an inspector.

With regard to Convention No. 81 (Article 7) and Convention No. 129 (Article 9),
they both stipulate that inspectors must be adequately trained for the
performance of their duties; but Convention No. 129 adds that measures shall be
taken to give them further training in the course of their employment (Article 9 (3)).

Indeed, as pointed out by the CEACR, the need for further training became
apparent between the adoption of the 1947 and the 1969 instruments:

Initial basic training, even when consolidated through additional training

during the probationary period, was not sufficient to maintain the skills
required by the labour inspectors to perform their increasingly complex duties.

It is clear from these sources that both initial training for newly appointed
inspectors and further training for more experienced labour inspectors are
necessary. No country has ever questioned this need; the fact that labour
inspectors receive little or no training may usually be attributed to a lack of funds.

This holds true in many low-income and lower middle-income countries, where
the only training that labour inspectors receive is provided by international
organizations – the ILO among others. But the effectiveness of such initiatives is

21
https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO::P12100_ILO_CODE:R133
39
limited, since they can only reach a small number of inspectors and give training
in one or a few areas, and they are usually one-off events.

In the case of middle- and some high-income countries, initial training is provided
but often there is no, or not sufficient, training for senior inspectors. This
realization led the European Parliament to voice its concern at the lack of further
training in the European Union in its resolution of 14 January 2014 on effective
labour inspections as a strategy to improve working conditions in Europe.

Countries that do provide sufficient initial and ongoing training are among the
worlds´ wealthiest. Let us consider the various ways in which they offer this
provision.

Before going into any detail on this matter, it must be noted that differences in
the provision of training for labour inspectors do not seem to be contingent upon
the type of labour inspection system – either generalist or specialist. It goes
without saying that inspectors at Labour Inspectorates only dealing with OSH
matters do not receive training in labour law beyond OSH legislation. But other
differences or similarities in the training content may be attributed to a variety of
reasons, among them: whether the inspectors specialize in an industrial sector
rather than a geographical area (Finland); and whether they come from similar
or very different backgrounds.

Leaving aside the content, differences may be found in the following aspects of
training for newly recruited inspectors:

 The number of hours devoted to training and the length of the period
during which this training is dispensed may vary;
 The initial training may be part of the recruitment process or be provided
during the probationary period;
 The training may be either theoretical and practical, or both;
 The way in which trainee inspectors are assessed – and who assesses them
– may differ.

The duration of the training varies widely from country to country. Some devote
as little time as a few weeks (Finland), while in other countries the training period
may last for several years (the United Kingdom). Reasons for the exact duration
of the initial training in each country are difficult to identify – but as a general

40
rule, a training period that extends beyond a year is a sign that labour inspectors
are regarded as elite civil servants, which is why so much time and funds go into
making them fully operational.

In most HICs, initial training takes place during the first year or years of
employment rather than during the recruitment process. Spain is the only
country among the HICs where the theoretical part of the initial training (lasting
up to 480 hours) is part of the selection process, and participants are assessed
by means of an examination at the end of it. Practical training, lasting for five
weeks, takes place at one of the provincial Inspectorates once the selection
process is over.

In most HICs initial training has both a theoretical and a practical component.
The theoretical component includes classroom-based instruction and/or online
courses, and usually ends with an examination. The practical component nearly
always includes joint visits to workplaces with a more experienced labour
inspector.

This “more experienced colleague” (the line manager in some countries) does not
have the same importance and role in the training of newly recruited inspectors
everywhere. In some HICs, their role is very limited in scope and duration, while
in others the “mentor” is responsible for structuring the training and for the
continuous and final assessment of the newly recruited labour inspector (e.g.
Belgium).

With regard to further training, leaving aside content, differences may be found
in the following areas:

 Frequency and reach;

 The way in which it is provided;
 The mandatory or optional nature of the training;
 Feedback on the content and delivery of the training.

In the majority of HICs and MICs, most Continuing Professional Development

(CPD) training is undertaken on a voluntary basis – and there are a myriad of
factors upon which its reach depends, such as the usefulness of the topics from
the perspective of the senior labour inspectors (their intended target).

41
In many countries, training for senior inspectors is only mandatory when there
are major changes in the legislation affecting labour inspectors’ duties, or when
new systems of information are put in place involving new ways of recording data
collected from inspection visits and their follow-ups. Therefore, throughout most
of the world, the training frequency of labour inspectors varies considerably and
depends on the nature of the changes that occur during a labour inspector’s
years of service. Only in a few countries is training for senior labour inspectors
compulsory (e.g. Kazakhstan and Venezuela).

Formal mid-career training is provided both online and on-site. The extent to
which either type is used varies from country to country, but both face-to-face
and online training are offered in most instances. In order to save costs, on-site
courses are often attended by a limited number of inspectors or cascade training
is used, whereby representatives from district Labour Inspectorates attend
centralized training courses, and the knowledge is then cascaded down by means
of training sessions within the district. In some countries these courses and
seminars are run, or at least organized, by a national training centre; in others
the responsibility for the continuing professional development of inspectors lies
with district Inspectorates or line managers.

With regard to formal training, one of the most significant differences is between
countries that provide training on a tailored basis (e.g. the Netherlands) and
those that decide on the training content mainly on the basis of factors affecting
all the labour inspectors (e.g. changes in the national labour legislation) or
specific ranks of labour inspectors (e.g. those with managerial responsibilities).
Among the latter group of countries, another relevant difference is whether or
not, and to what extent, a needs analysis is taken into account when deciding
upon the training content.

An area for improvement in most countries is feedback on the training, which is

often insufficiently developed and organized. The most widely used feedback
method is questionnaires completed by attendees at the end of the course; but
some countries also use feedback forms completed by the trainers, while others
rely mostly upon on-site visits to courses and training sites set up by the national
training centre or some other government department with supervisory powers.

42
Apart from these training courses, seminars and workshops, all HICs and MICs
offer opportunities for knowledge sharing. In many of these countries, the
Labour Inspectorate intranet makes training materials available to all inspectors,
and it also provides access to all relevant legislation and documents. Other
systems of informal knowledge and experience sharing are also common: online
forums, but also regular meetings to discuss specific files upon which labour
inspectors have worked or are still working (e.g. Belgium). The latter has brought
an unexpected bonus for labour inspectors working in Labour Inspectorates
where most of their work is carried out “solo” and outside the office. Knowledge
sharing therefore creates an opportunity for social and professional contact
between colleagues.

As regards the topics of the training courses themselves, let us consider

separately the training provided for newly recruited inspectors and senior ones.
In the vast majority of HICs and MICs, newly recruited labour inspectors, with no
previous experience in any of the tasks undertaken by a labour inspector and
irrespective of the remit of their labour inspection duties, receive training on:

– Powers and duties of inspectors;

– Relevant legislation;

– Investigation of breaches of workplace legislation.

An increasing number of HICs are including psychosocial risks and

communication skills as areas of training for newly appointed inspectors, rather
than leaving these subjects to experienced inspectors. Other components of the
initial training depend upon: the remit of the Labour Inspectorate; the
characteristics of the productive sector in each country; and the background of
the newly recruited inspectors.

Inspectors with greater experience attend training courses on any area in which
changes have been significant enough to affect their day-to-day work (e.g.
changes to the labour legislation). However, many HICs are now offering them
some training in areas related to the so-called “new and emerging risks”.

In theory, “new and emerging risks” are mostly present in green jobs,
crowdsourcing, nanotechnology, robotics and 3D printing. In practice, most of

43
the risks related to these categories of work are not new, but have existed for a
long time: what is new is the service offered or the products made, and more
importantly the form of employment involved. Labour Inspectorates in HICs are
starting to focus their training precisely on these non-standard forms of
employment, whose workers are hard to reach and to protect.

The only risks that are “new” – not because they emerged a short time ago but
because they have fairly recently become a major concern and an area for
training – are “psychosocial risks” and “violence against labour inspectors”. It
must be noted that while training on the former is quite common in HICs, training
on the latter is fairly new and confined to a few countries.

Good practices

A training programme on OSH

The European Union Senior Labour Inspectors´ Committee (SLIC) Common
standards for OSH inspector training programme may be used for guidance by any
country wanting to develop a training programme for new recruits in the area of
OSH, since it is consistent with ILO standards and is not specific to a particular
country or region – with the exception of the chapter devoted to EU directives.

The SLIC programme specifies the basic content of the training and how it may
be structured. The seven areas dealt with are as follows:

 Training on risks mentioned in the framework directive and in the daughter

directives;
 Training the inspectors on risk assessment;
 Training on the preparation for an inspection;
 Training on the investigation of occupational accidents and diseases;
 Training on inspector duties and rights;
 Training on communication skills;
 Training on management of conflict and pressure.

It must be noted that the SLIC‘s publication does not include guidelines on how
the training must be delivered; i.e. there are no suggestions as to whether the
training should be online or classroom-based, who qualifies as a trainer, or how
44
long the training should last. Failing to provide guidelines concerning the delivery
of training is no flaw in itself, but it reflects an awareness of the differences in
budget and in approaches to training in general, as well as in the civil service
across the EU. There is but one recommendation regarding delivery: the use of
mentoring in the preparation of inspection visits and while conducting them, as
well as in the investigation of accidents and diseases.

Mentoring
Mentoring, rather than simply job shadowing, is used as a training tool for new
recruits in a number of countries. As a general rule, the mentor is a more
experienced colleague who undertakes joint inspections with the mentee and
generally supports the new inspector during the mentoring period. Countries
such as Canada and Denmark, which use mentoring for a substantial length of
time (six months in Canada and 12 in Denmark) in combination with other forms
of training, manage to shorten the time needed for the newly appointed
inspector to gain confidence and know-how.

Not only that, research since the 1980s has shown that employees who
experience mentoring are more likely to be retained and promoted. A recent
study22 of 829 midsize and large United States’ firms, which examined the way
in which mentoring improves diversity within a single company, is relevant to
countries wishing to increase the representation of women and minority groups
among labour inspectors:

Mentoring has been proven to be more successful at promoting workplace

diversity than diversity training programs alone. One key challenge is structuring
the program so that it benefits all diverse groups. Mentorship programs are most
likely to improve promotion and retention of diverse groups if senior level
executives act as mentors, if potential mentors and mentees are assessed and

22
K. Conboy and C. Kelly: What evidence is there that mentoring works to retain and promote employees,
especially diverse employees, within a single company (Cornell University, 2016), available at:
https://digitalcommons.ilr.cornell.edu/cgi/viewcontent.cgi?referer=https://www.google.com/&httpsredir=1&
article=1120&context=student

45
matched on Big Five personality traits, and if direct managers of mentees are
engaged and involved with the mentorship program.

In particular, the data from the 829 US firms above indicates that: Mentorship
programs can boost the representation of black, Hispanic, and Asian-American
women, and Hispanic and Asian-American men at manager levels by 9% to 24%,
as compared to the other initiatives which have lower results ranging from 2% to
18%.23

A development initiative: Law Hour

Although, as noted earlier, the provision of ongoing training in low-income
countries, and even in lower middle-income countries, is at best insufficient, it is
worth mentioning initiatives for knowledge sharing such as the Law Hour
developed by DIFE (Department of Inspection for Factories and Establishments)
in Bangladesh:

… an initiative that takes place in every District Office once a week whereby
inspectors take it in turns to propose a ‘grey’ area of the law for discussion and
the Deputy Inspector General then leads that discussion, everyone takes part and
conclusions are reached on good practice. If consensus cannot be reached, the
DIG would raise the issue for a view to the next level in DIFE. This enables a
consistent approach to be taken in regards to the aspect of labour law discussed.

Training as part of the recruitment process

As discussed in chapter 3, including a training component in the selection
process helps applicants find out more about the knowledge and skills that a
labour inspector is expected to have. Those applicants who are put off by the
information they receive during this initial training period are given the chance
to withdraw their candidature before the appointment process. The resources
used and time spent on this initial training stage should obviously be limited so

23
ibid.
46
that the Labour Inspectorate can concentrate its efforts on the most motivated
candidates who complete the whole recruitment process successfully.

47
Chapter 5. Other factors influencing the
retention of labour inspectors and their
performance

Chapters 3 and 4 have already examined the influence that recruitment methods
and criteria have in attracting the right candidates for the job of labour inspector
and the role played by training in equipping labour inspectors with the necessary
knowledge and skills to carry out their duties. In addition, it has been noted that
both recruitment criteria and training have a bearing on staff retention.

Chapter 2 listed a number of difficulties that makes the job of labour inspector
less attractive, such as a lack of transport facilities, prejudices and violence. Yet
there are a few other factors likely to affect the retention of labour inspectors
and their performance, which HR managers should take into account:
reimbursement of expenses necessary for the performance of duties;
remuneration; promotion opportunities; mobility; and work-life balance.

ILO Conventions Nos. 81 and 129 remind Member States of the need to
reimburse labour inspectors for any travelling and incidental expenses which may
be necessary for the performance of their duties.24 One of the consequences of not
doing so is that workplaces are not frequently visited and some hardly ever,
which for a Labour Inspectorate amounts to not being able to fulfil its main
duties.

Underpaying labour inspectors can have serious consequences.

Recommendation No. 20 draws attention to labour inspectors’ “remuneration”,
but it only links it to freedom from any improper external influences, 25 i.e. a fair
salary as a means to avoid the temptation of treating certain employers leniently in
exchange of favours.26 The CEACR also warns that insufficient remuneration for
the Labour Inspectorate may result in a higher turnover among labour inspectors

24
ILO Labour Inspection Convention, 1947 (No. 81), Article 11 (2).
25
ILO Labour Inspection Recommendation, 1923 (No.20), Article B (13).
26
International Labour Conference 95th Session, 2006 Report III (Part 1B), p. 70
https://www.ilo.org/empent/Publications/WCMS_108572/lang--en/index.htm

48
and make it more difficult to attract highly qualified individuals. The Committee
also remarks that individual labour inspectors may be treated with disrespect on
account of their low salaries.

The CEACR stresses that labour inspectors’ remuneration should be

commensurate with their responsibilities, and at least as good as that of other civil
servants at comparable levels in the same country. It also links performance-
related incentives, granted to teams and individuals, as being a recognition,
reinforcement and rational use of employees’ skills.

At this point, it seems relevant to examine to what extent Member States comply
with the recommendations of the CEACR. Levels of remuneration in low-income
countries are low – and often low in comparison with that of other civil servants
with duties of a similar complexity; this also applies to many middle-income
countries. Among high-income countries, there are huge differences in salary
levels, and even between countries with roughly the same GDP. We may take the
example of Spain and the United Kingdom: a newly recruited labour inspector
earns approximately twice the minimum wage in the United Kingdom, and 4.5
times the minimum wage in Spain. The main reason why the Spanish new recruit
is better paid in relative terms (even though the minimum wage in the United
Kingdom is closer to the average pay in the country) is that new recruits in Spain
have basically the same responsibilities as senior labour inspectors, while this is
not the case in the United Kingdom – where initial training takes two to four
years.

As regards the variations in a labour inspector’s remuneration package between

countries, the main difference lies in whether there is performance-related pay
or not.

No examples of performance-related pay were found among the low-income

countries in this study, where remuneration appears to be determined by grade,
specific post and seniority. Among middle- and high-income countries, incentive
pay is not uncommon, but its share in the total remuneration varies considerably
and there is more than one way of assessing performance. Assessment is
contingent upon the appraisal of the line manager (e.g. Ukraine), or upon how
close the individual inspector and/or district Inspectorate have been in reaching
the targets set for the year or trimester (e.g. Spain).

49
When the appraisal is the sole responsibility of the line manager, guidance is
often given as to what aspects of performance to consider; however, the
evidence used as the basis for scores or comments may vary substantially from
evaluator to evaluator. When individual and team performance are measured
against predetermined outcomes, differences between countries may depend
upon how many types of outcome are taken into consideration. These may
include the number of inspection visits, the amount of unpaid taxes collected,
and the number of undeclared workers registered with the Social Security.
Setting precise and quantitative objectives requires a sound national action plan
based on reliable data on the state of labour legislation compliance in the
country.

Promotion opportunities, together with salary, have an undisputed effect on

turnover rates. As pointed out by Mendeloff et al.:

Low base pay, insufficient salary growth over time and the lack of opportunities
for advancement within the inspectorate can lead to high attrition.27

According to ILO reports on low-income countries, the lack of good career

prospects is one of the major causes for labour inspectors’ high turnover, and
the same appears to be true of middle-income countries. Two recent reports28 on
the Department of Inspection of Factories and Establishments in Bangladesh
identify the insufficient number of cadre posts as a deterrent to anyone aspiring
to a career and as one of the reasons why inspectors leave the Labour
Inspectorate. The ILO and others have reported evidence that good pay and long-
term career opportunities have helped build successful Labour Inspectorates in
Brazil and the Dominican Republic.29

27
Mendeloff et al.: Human resource practices for labor inspectorates in developing countries (Cornell
University, 2014), p. 7, available at:
https://digitalcommons.ilr.cornell.edu/cgi/viewcontent.cgi?article=2814&context=key_workplace

28
J. D. Martín Gonzalez: Study on Department of Inspection of Factories and Establishments (DIFE). High level
staff retention and motivation (Geneva, ILO, 2017); S. Ashcroft and S. Williams: Strategic review of the labour
inspection system delivered by the Department for Inspection of Factories in Bangladesh.

29
R.R.C. Pires: “Flexible bureaucracies: Discretion, creativity, and accountability in labor market regulation and
public sector management”, in Humanities and Social Sciences, Vol. 71, No. 1-A, (2010), p. 327.

50
As regards the criteria for promotion, progressing from the initial category of
trainee inspector to first-level inspector usually requires passing an examination
or completing a training course or diploma. After that first promotion, the
remaining ones, except the top positions, may be granted automatically (after
completing a number of years at the previous level), or else they are awarded on
the combined basis of seniority and merit. This second system may take different
forms depending on how merit is measured; some countries use performance
appraisal (e.g. Portugal and Belgium), but in others inspectors must acquire new
qualifications or skills (e.g. Kazakhstan).

A further factor that has been claimed to have an effect on motivation, retention
rates and performance quality is mobility. We have already discussed vertical
mobility (promotion), but horizontal mobility, which involves doing a different job
for the same authority or being seconded to another government department or
body or to an international organization, may have a positive effect on inspectors’
performance once they return to their previous post. A number of studies
suggest that transfers to functionally similar units enable employees to acquire
multiple skills and enhance promotion probability,30 which means that both the
Labour Inspectorate and the labour inspector may benefit from horizontal
mobility.

Recommendation No. 20 advises labour mobility: … more particularly during the

early years of their service, [labour inspectors] should be transferred from district to
district at appropriate intervals in order to obtain a full experience of the work of
inspection. Von Richthofen31 suggests that inspectors should not be kept in the
same industry sector for long periods because they tend to have an insufficiently
critical and questioning attitude to long-established practices. There is some
empirical evidence to bear out this claim. In 1982, a number of authors found
that surface mining inspectors in the United States with lengthy assignments to
single mines were less likely to demand stringent enforcement. Similarly, a study

30
K. Ariga: Horizontal transfer, vertical promotion, and evolution of firm organization (Elsevier, 2004), available
at: http://www.computer-services.e.u-tokyo.ac.jp/p/seido/output/Ariga/ariga004.pdf

31
W. von Richthofen: Labour inspection: A guide to the profession (Geneva, ILO, 2002), available as of 5
November 2014 at: http://www.ilo.org/safework/info/publications/WCMS_108665/lang--en/index.htm

51
of offshore oil platforms in the Gulf of Mexico32 found that length of time at an
assignment was linked to laxer enforcement.

An additional factor that has an impact on retention is work-life balance (WLB)

practices. Research 33 supporting the benefits of WLB for organizations is
substantial, some of which includes: employee satisfaction and well-being;
reduced absenteeism and turnover; successful recruitment and retention;
increased productivity; and customer satisfaction. A Roffey Park Institute study34
found that 38 per cent of a sample of employees would consider leaving their
current employer to gain a better WLB, even if it meant reduced pay. Another
study also states that organizations that invest heavily in WLB report lower
employee turnover.35

A few National Labour Inspectorates have had work organization practices that
favour work-life balance for many years. A case in point is Spain, where, since the
early 1990s, labour inspectors are allowed and given the technological means to
work from home. They are only required to show up at the office for very specific
tasks (such as meetings with employers or employees’ representatives).

In most EU countries WLB improvements for labour inspectors began during the
2007–14 period; this was not intentional but a by-product of efforts to offset the
effects of budget cuts. Such cuts had led to a reduction in senior management

32
L. Muehlenbachs, S. Staubli and M. Cohen: The effect of inspector group size and familiarity on enforcement
and deterrence: Evidence from oil platforms, Vanderbilt Law and Economics Research Paper Nos. 13-35,
Vanderbilt Owen Graduate School of Management Research Paper No. 2350923 (2013), available at:
https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2350923

33
P. Mayberry: “Work-life balance policies and practices in the UK: Views of an HR practitioner”, in Journal of
Management, 23 (2) (2006), pp. 167-188; L. Morgan: The impact of work-life balance and family-friendly
human resource policies on employees’ job satisfaction (London, Oxford University Press, 2009); M. White et
al.: “High Performance” management practices, working house and work-life balance”, in British Journal of
Industrial Relations, 41 (2) (2003) pp. 175-195.

34
Roffey Park Institute (2004), available at: http: //www.roffeypark.com/research/wbl.html

35
Mayberry, op. cit.

52
and support staff in many EU countries, and changes were needed so as to avoid
excessive workloads for serving labour inspectors.

A SLIC study presented at the 60th SLIC Meeting in 2011 praised a number of ICT
tools and gadgets which had been shown: “to have a significant impact on planning
and efficiencies, both in terms of time spent out and in the office”.36 These included:
a fully integrated work scheduling planning system (Danish Work Environment
Agency (DWEA)); work recording databases; and i-Pads and other tablet style
personal computers for use in the field. The same study lists a number of
measures to reduce unnecessary travelling to the office such as holding
meetings on allocated office days, and an increase in the use of
videoconferencing for internal meetings. A second SLIC study, drafted in 2016,37
summarized levels of regulatory activity between 2008 and 2014 across the EU.
It noted that:

Most National Labour Inspectorates (NLIs) do not appear to have significantly

changed their approach to enforcement decisions after inspections and
investigations. Where reduced activity is apparent, this may be linked to
resources and to targeting approaches or it may reflect the changing risk
profile of industries and business through 2008–2014. The links with economic
activity must be relevant, at some level, and reduced construction industry
activity alone could explain some of the fluctuations in NLI activity reported.

Several countries have maintained very similar activity profiles and even where
NLIs have reduced their inspection activity, the approach to investigating
incidents was largely consistent.

… Levels of regulatory activity fluctuated 2008–2014, but there were no

significant trends and activity has largely returned to levels similar to those of
2008.

As regards the effects of the reduction in financial resources, the 2016 study
concludes that most Member States did not have to resort to salary cuts or

36
SLIC: Labour Inspectorate resource reductions in the European Union, Senior Labour Inspectors‘ Committee,
Document 756, 60th SLC Meeting (May 2011).

37
SLIC: Study about the impact of the economic crisis on the European labour inspection systems from 2007 to
2014.
53
increase labour inspectors’ working time. This is an indication that the time-
saving tools and practices introduced during the 2008–14 period have not only
given labour inspectors more family and private time than they would otherwise
have had, but that productivity levels have not suffered.

As a general rule, understaffing is a serious problem in low- and middle-income

countries. This, coupled with insufficient vehicles to travel to workplaces and no
ICT tools or gadgets that might help save time, tends to result in long working
hours and low productivity – thus making it impossible for most labour inspectors
to achieve an acceptable work-life balance.

Good practices

Reducing travel-related expenses

The reimbursement of expenses incurred by labour inspectors if they have to
travel can be a challenge for underfunded Labour Inspectorates. That being said,
the costs arising from their meal and accommodation expenses may be
somewhat reduced by the following steps: cascade training for training
purposes, so that only one individual per district Inspectorate incurs travel-
related expenses; video-conferencing for meetings of senior management from
different district Inspectorates; work scheduling and route planning software to
help schedule visits to workplaces, thus making it possible to opt for the most
economical solutions. This software might require additional funds – at least in
its initial stages – but future savings would justify such an investment.

In 2009 the Danish Working Environment Agency (DWEA) introduced Transvision,

a visit-scheduling and route planner software programme, after it noted that the
previous system resulted in excess mileage and a duplication of routes.
Transvision:

– Links directly into existing work recording and management systems;

– Registers inspectors’ locations (home) and “conditions” (industry
expertise, etc.);

54
 – Lists workplaces to be visited in the next quarter and their “conditions”
(industry type, size, etc.) – with investigations being added as and when
necessary;
– Matches the appropriate inspector to a company and schedules visits in
diaries;
– Plans visits on an appropriate route;
– “Fixes” visits a week in advance, giving inspectors time to prepare; and
– Allows inspectors to reject or request additional visits.

Performance incentive systems

It has been observed in various countries that the quality of labour inspectors’
work, their productivity and their likelihood of leaving the Labour Inspectorate
are contingent upon the extent to which their remuneration is linked to their
performance.

Including a performance-related component in total pay seems to boost morale

and to encourage inspectors to remain in the service. Workers appear to consider
that measuring performance by means of objective indicators is the fairest
assessment method.

A number of experiences (e.g. Brazil before 2008) suggest that basing

compensation merely on the number of inspections performed, or on the
amount of unpaid taxes collected, results in inspectors focusing narrowly on their
performance measures and neglecting those aspects of their work that go
unrewarded. Incentive pay based exclusively on individual productivity has also
been criticized, as it discourages cooperation between colleagues.

It would therefore seem advisable to introduce a system that: first, rewards merit
by assessing performance on the basis of objective criteria; second, takes into
account both individual and team performance; and third, incorporates some
quality control checks. As regards the objective criteria, they should include as
many relevant quantifiable indicators as possible: number of inspections – but
also types of inspections; and a variety of outcomes resulting from these
inspections rather than simply unpaid taxes collected. The word “team” might
imply the district Inspectorate, but it might also refer to specialized teams of
labour inspectors. In either case, the goals to be achieved must be set

55
beforehand and depend on a national action plan devised on the basis of up-to-
date data on aspects relevant to the remit of the labour inspection service (e.g.
occupational accidents and diseases). Quality controls may consist of the line
manager reviewing reports, improvement notices, and other relevant
documents produced by labour inspectors with greater or lesser frequency –
which is one way of helping them raise their working standards.

One country where the Labour Inspectorate has long had a compensation
system that meets the above-mentioned three conditions is Spain. With minor
changes, any country could easily adopt the Spanish model – provided that its
Labour Inspectorate has access to data relevant both to infringements of the
labour legislation and to OSH issues in the national territory. This data should be
used as the basis for a national plan specifying the Labour Inspectorate’s
programmes and activities, and the outputs expected within a given timeframe.
In this way, the objective criteria determining the inspector’s remuneration are
given a sound basis. The performance-incentive amount that each Spanish
labour inspector receives depends upon the extent to which the district
Inspectorate and the individual inspector achieve their share of the expected
outputs.

Attractive career paths

An attractive career path appears to increase the chances of inspectors staying
with the Labour Inspectorate. For it to be attractive, there should be enough
management posts so that any ambitious, productive and well-qualified
inspector can reasonably expect to be given the opportunity to play a managerial
role at some point in his or her working life. The most reliable way of promoting
the best inspectors appears to be internal competitions involving either the
acquisition of new qualifications or examinations. This avoids the risk of highly
subjective criteria when appraising candidates – or suspicions of favouritism.

No studies have been undertaken to ascertain to what extent the above-

mentioned practices have been effective in retaining labour inspectors and
improving their productivity. This comes as no surprise as evidence on the effect
of workplace rewards to employees in the public sector is seldom conclusive and

56
cannot be easily extrapolated from one country to another. 38 However, a
number of surveys and interviews with labour inspectors about their reasons for
dissatisfaction suggests that an insufficient number of administrative posts and
promotions based on opaque or too subjective criteria may well play a part in
keeping retention and productivity low. In a number of Latin American countries
– including Argentina, Brazil, Chile, El Salvador, Nicaragua and Uruguay –
substantial reforms were made to establish a more explicit career path for
inspectors, which appear to have reduced turnover.39

Facilitating the return of labour inspectors to the Labour

Inspectorate
In a number of countries, labour inspectors seconded to another host
organization – whether international or national – have the right to return to the
Labour Inspectorate at the level or rank they had before their secondment.
Nonetheless, according to our desk research, only a few countries in the world,
e.g. France, Spain and Portugal, grant labour inspectors this right when they
return after being employed – rather than simply being seconded – by an
organization in the private or public sector.

There is no denying that the organization to which labour inspectors move

becomes their new employer. However, the reason for giving these returning
inspectors the same return rights as seconded staff is that the benefits for the
Labour Inspectorate are thought to be roughly the same. For the Labour
Inspectorate, it is one of the ways that inspectors may increase their knowledge,
abilities and skills, which in turn may result in improved employee motivation and
reduced turnover.

38
Economic Insight: Valuing different workplace rewards (October 2017), available at:
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/655988/
Valuing_Different_Workplace_Rewards.pdf

39
M. L. V. Ruiz: Labour administration: To ensure good governance through legal compliance in Latin America.
The central role of Labour Inspection, Labour Administration and Inspection Programme, Working Document 1
(Geneva, ILO, 2009). As of 5 November 2014, available
at: http://www.ilo.org/labadmin/info/pubs/WCMS_116044/lang--en/index.htm
57
Appendix I

A) Justification
This Appendix contains a description of the HR policy for labour inspectors in
four countries: one in Latin America and three in Europe. The three European
countries have not only been chosen because their labour inspection systems
are fully-fledged and long-established, but – more importantly – because they
have greatly influenced the systems of other countries that have similar legal
framework and civil service models.

By providing these specific examples of coherent and fully developed HR

policies for labour inspectors, the Appendix sets out to bring together all the
various aspects covered separately in this report. This will help illustrate the
interdependence of these various aspects.

It must be noted that the information provided on each of these three HR

policies is not a detailed description of their legal framework, or the labour
inspector’s status or career in each of these four countries; it includes only
the main features of the respective HR policy. Webpage links are given for
those readers wanting further information or details.

B) The example of four countries

 Spain
 United Kingdom
 Peru
 France

Spain40

40
For more detailed information see: http://www.mitramiss.gob.es/itss/web/index.html

58
 Status of the labour and social security inspector

The Labour and Social Security Inspectorate (ITSS) in Spain is the public service
responsible for monitoring compliance with labour and social security standards,
enforcing accountability and providing guidance and, where appropriate,
conciliation, mediation and arbitration on such matters.

Labour and social security inspectors are authorized to discharge all the powers
that are legally attributed to the ITSS and are recognized in the exercise of their
duties as a public authority.

Labour and social security inspectors are career civil servants and, as such, are
subject to the legal framework for civil servants as regards their rights,
responsibilities and restrictions.

In order to understand what the status of a labour and social security inspector
entails within the Spanish civil service, it is important to note that the
classification of career civil servants reflects:

– The body to which they belong. The body groups together the shared
powers, capacities and knowledge they have acquired in the selective
admission process.

– The group under which that body is classified. There are three groups,
based on the minimum qualification required to belong to each one. The
highest group, group A, requires a university degree.

– Certain groups, such as group A, are divided into sub-groups, according

to the level of responsibility of the functions the civil servant is to perform
and the nature of the tests for admission to the sub-group. Sub-group A1
is the upper sub-group of group A.

– Level of job position. Each body, according to the group under which they
are classified, is divided into levels according to job position. Group A has
a minimum level of 20 and a maximum level of 30. A civil servant’s level

59
 corresponds to the functions that they discharge or, where appropriate,
that they have previously discharged.

In short, the status of labour and social security inspectors within the civil service
in Spain entails: belonging to an upper body of the administration (the Upper
Body of Labour and Social Security Inspectors); belonging to an A1 body, which
is part of the highest category of civil servants; and being in the job position levels
26 and 27 – the highest levels that exist.

Selection process for labour and social security inspectors

To join the Upper Body of Labour and Social Security Inspectors, it is necessary
to be a Spanish national, an adult, and in possession of a degree (PhD, graduate,
engineer, or architect) and pass the relevant selection process – which, like all
selection processes for the civil service in Spain, is governed by the constitutional
principles of equality, merit and ability.

Once a job vacancy in the civil service is published, the Under-Secretariat of the
Ministry of Labour, Migrations and Social Security (the department by means of
which the Government Agency of Labour and Social Security Inspection (OEITSS)
is attached to the Ministry) announces the selection process to fill the position.
The announcement, which is published in the Official State Gazette, sets out: the
number of positions available; the list of topics, exercises, assessment and scores
of the tests involved in the selection process; and the composition of the selection
panel.

Both external and internal candidates can participate in the selection process;
but internal applicants (mostly labour sub-inspectors) can obtain additional
points by submitting proof of relevant qualifications, skills or work experience.

During the competition stage, applicants must pass a series of tests to

demonstrate their knowledge of regulations related to the inspection role
(through oral and written presentations); their ability to issue a ruling on
inspection cases (i.e. to apply regulations in a practical situation); and their
command of a foreign language.

The preparation time required to pass the competition varies widely. It must be
borne in mind that the syllabus is made up of some 270 topics, and experience

60
shows that preparation can last between a minimum of one year (very rarely) up
to three or even four years – the most common being around three years full-
time.

After passing the competition, the applicant becomes a “probationer” and must
undergo the second stage of the process, which consists of a highly practical
selection course. The course is made up of two parts: the first is organized by the
ITSS School (the specialized training unit of the OEITSS), where trainees are
taught the analytical skills of the various areas of inspection work and have to sit
specific tests to test the knowledge they have acquired; the second consists of
probationers addressing a specific case, which is then graded by the selection
panel.

The duration of this selection course has varied in the past. More recent courses
tend to be around 400 teaching hours, spread over a maximum of five months.

The sum of the marks an applicant has achieved in the competition stage and the
selection course (where the marks achieved in both parts are added together) is
the external candidate’s final mark. Internal candidates can add to this sum the
points they were awarded for “merits” (relevant qualifications and/or work
experience).

After successfully passing the selection process, probationers start a placement

in the autonomous communities and provinces, where they accompany
experienced inspectors posted there. This enables them to learn about the
practical side of an inspector’s work. Upon completion of the placement,
probationers become career civil servants and are assigned a location
(contingent upon the marks they achieved in the selection process) where they
finally obtain a post. A probationer’s placement period length also varies,
normally lasting from five to eight weeks.

Training policy for labour and social security inspectors

In addition to the initial training they undergo to obtain their post, labour and
social security inspectors receive continuous training throughout their
professional lives. The ITSS envisages this training as:

61
 i) A right. It is recognized that inspectors have the right to continuous
training and a continuous updating of their professional knowledge and
capacities throughout their working lives. In this respect, the ITSS School
is responsible for: organizing, leading and assessing training courses,
programmes and activities for continuous training; and developing
programmes and activities for the updating of professional knowledge,
specialization and professional development. Every year, a programme
provides training activities on various aspects of an inspector’s work
(mainly, although not exclusively, on social security and employment,
prevention of occupational hazards, work relations, new technologies and
information technology, international relations and languages, relational
skills and data protection). It consists of: face-to-face training, dispensed
at a centralized level (delivered in Madrid in the school itself) and at
regional level (delivered at the autonomous and provincial community
level); and an online training course. To encourage their participation,
inspectors’ attendance of the programme is considered an activity that
counts towards their productivity targets.

ii) An obligation. The inspector is obliged to participate in assigned training

and specialization activities. Although participation in courses is generally
voluntary, attendance of certain courses, such as those aimed at providing
inspectors with adequate training to handle specific requirements
inherent in the role, such as taking part in an inspection campaign, is
mandatory.

Career development of labour and social security inspectors in Spain

The career and promotion opportunities of labour and social security inspectors
are governed by the same principles that apply to admission into the body
(equality, merit and ability). As indicated at the beginning of this report, the
position of inspector is assigned levels 26 and 27. After passing the selection
process, inspectors are admitted into the system at level 26, which increases after
two years of service.

Moving up from level 26 to the higher levels assigned to group A (which, as

indicated, reaches a maximum level of 30) involves the following steps – both of
which require a public announcement:

62
  A competition. This is the usual way to fill a position. Announcements for a
competition must set out the rules and, inter alia, the requirements to be
assessed (years of service, level of education and ability to reconcile
personal and family life, etc.); the grading scale; and the composition of
the assessment committee. The position is awarded to the candidate who
achieves the highest marks. By participating in the competition, inspectors
can reach: level 27, by competing for vacant positions advertised at that
level; or level 28, by competing for vacant leadership roles in provincial
inspectorates that are advertised.
 A free appointment for filling positions of special responsibility and trust.
The announcement for this position must indicate the necessary
requirements for the post and the body that will assess, at its discretion,
the suitability of candidates applying for it. Once appointed, the applicants
may be dismissed at that body’s discretion.

Within the administrative structure of the OEITSS, certain positions are

customarily filled by labour and social security inspectors, thus allowing
inspectors to occupy positions of levels 28, 29 and 30. This happens in:

 The central administrative structure, specifically in the Sub-Directorate of

the Anti-Fraud Office; the Sub-Directorate General for the Coordination of
the Inspection of the Labour Relations System; and the Sub-Directorate
General of Institutional Relations and Technical Assistance.
 The territorial administrative structure of the OEITSS, in the case of the
Special Directorate, Territorial Directorates, heads of Provincial
Inspectorates and, within the latter organization, heads of Specialized
Units.

Remuneration policy for labour and social security inspectors

Remuneration for labour and social security inspectors is divided into: basic
remuneration, which is paid to the inspector in line with the group or sub-group
to which their professional body belongs; and supplementary remuneration,
commensurate with the specific characteristics of their position, professional
career and performance targets.

It should be noted that most civil servants’ pay consists of basic remuneration.
Civil servants who belong to bodies in lower sub-groups, and whose work is less

63
complex, receive less supplementary pay – while civil servants in higher bodies,
such as inspectors, receive a larger share of supplementary remuneration.

Basic remuneration consists of:

– A salary, which is the amount allocated to inspectors for carrying out their
work within sub-group A1;

– Three-year increments, i.e. a payment for every three years of service.

These categories of basic remuneration are paid in 12-monthly installments, with
two extra payments in June and December of each year.

Supplementary remuneration consists of:

– Payments for special posts, which involve certain technical requirements,

commitments and responsibility. This is one of the most important forms
of remuneration for posts of special responsibility.

– Post payment: the higher the complexity and responsibility of the post,
the higher the post payment. When inspectors are admitted into the
system, their post payment level is 26. As they progress in their career,
their post payment increases.

– Productivity payment: this remuneration varies according to the

inspectors’ individual performance. This payment is awarded for high
performance and the amount of work and dedication that inspectors put
into performing their duties. An integrated plan of action for the ITSS
system is drawn up each year. It sets performance targets for inspectors
in accordance with their level of responsibility to ensure that their
performance is in line with the social and economic situation. In Spain, the
lower level of the productivity payment of the ITSS remuneration system is
ten per cent of total remuneration, while the higher level allowed for by
the system is 21 per cent of total pay.

– Payments for extra services performed outside of normal working hours:

remuneration for on-call services to investigate work accidents (fatal or of
particular seriousness or significance) on weekends or public holidays.
These payments take into account the location, the inspector’s availability
and travel to the location of the accident within the time limits set. In such

64
 cases, payments cover local services, on-call services and expenses for the
extra services provided.

– Allowances for performance of duties: these include payments for

expenses incurred by inspectors when they have to use their private
vehicles for carrying out inspection visits. The allowances cover the
number of kilometres travelled, tolls and, where appropriate, vehicle
maintenance.

Mobility of labour and social security inspectors

The mobility of labour and social security inspectors within the territorial
organization of the OEITSS may occur in various ways.

The usual way for an inspector wishing to move from one place to another is to
participate in an announced transfer competition. Open calls list the places that
are vacant in different provinces, as well as the terms that govern the process.
The post is given to the applicant who receives the highest marks in the
competition.

Another way, although less common, is for two inspectors who occupy the same
post in different provinces to exchange places.

There are also ways to move or temporarily cover posts, such as secondments or
temporary assignments. In both cases, the post occupied is not “transferred” and
the situation is temporary.

Inspectors may also move for reasons of health or rehabilitation, or if they have
been a victim of gender-based violence (to guarantee their protection and their
right to comprehensive social security).

United Kingdom41

41
For more details see: https://www.hse.gov.uk/

65
 The Health and Safety Executive (HSE)

 Employment status of labour inspectors

Permanent

 Recruitment of labour inspectors

Paid external media campaign:

o Google
o Target jobs
o Jobs the Word
o Total jobs
o Guardian jobs

Free media:

o LinkedIn
o Disability jobs board
o HSE website

Attendance at graduate recruitment fairs.

Assessment process:

Stage 1: Short form application (SFA).

Online tests – verbal reasoning test and the online Civil Service
Judgement Test.

Stage 2: Assessment Centre – including E-Tray exercise, presentation

followed by Q&A, written test, role play exercise.

 Training. The regulators' training programme (RTP) dovetails fieldwork

with blended learning. Trainee inspectors study for and successfully
obtain the National Examination Board in Occupational Safety and Health
(NEBOSH) Diploma (level 7) in Regulatory Occupational Health and Safety,
which is unique to HSE.

66
 The first two years focus predominantly on giving the successful
candidate the legal knowledge – whilst working supported in the field –
so that they can inspect, investigate and enforce the law. This is
integrated with the foundation of core technical training to identify
health and safety problems, analyse situations, judge legal compliance
and any corrective action needed. Development and performance are
assessed against key developmental milestones, and successful and
timely achievement against these milestones is an essential element in
remaining employed by HSE. It is a condition of continued employment
with HSE that the diploma is successfully completed.

HSE provides comprehensive support to the trainee inspectors by

training through their manager, a dedicated coach and development
managers. They also gain support through their fellow trainees.
The third year of the training programme follows the same experiential
learning process as the first two, and is called Continuing Professional
Development (CPD). It expands on the technical knowledge of
occupational health and safety issues so that the trainees can
competently deal with the multitude of business that HSE regulates.

 Promotion. Achievement of the development milestones, including a

pass in the required assessments, makes the trainee eligible for
promotion to main grade inspector and further elements of the training
programme. As a main grade inspector, the salary increases to £37,292 –
and recruits should acquire this within two years of starting the
programme.

 Remuneration. This amounts to £29,472, rising to £37,292 after two

years following successful completion of the RTP course. Candidates in
London receive an additional £4,260 London weighting allowance.

 Mobility. This involves moving to other district Inspectorates or

Headquarters, or secondments to other departments/organizations. As a
civil servant, inspectors are required to be mobile across government
departments within the parameters of reasonableness. The issue of what

67
 is reasonable relates to individual circumstances at the time of any
proposed changes to the place of work. Movement across divisions may
be required depending on business need.

Peru42
Human resources policies for SUNAFIL labour inspectors

This section sets out to examine how human resources are managed in the
National Superintendency of Labour Inspection (SUNAFIL) by: analysing the
relationship between the financial and non-financial compensation policies in
place, and the working conditions, recruitment procedure, training and internal
promotion of labour inspectors; and identifying best practices and opportunities
for improvement in inspectors’ performance.

It will also outline the profiles of inspection staff, their age range and other
characteristics of civil servants. Labour relations between labour inspectors and
SUNAFIL, including the current remuneration policy, will also be considered.

SUNAFIL

SUNAFIL is a specialized technical agency attached to the Ministry of Labour and

Employment Promotion and is responsible for: promoting, overseeing and
monitoring compliance with social and labour legislation and occupational safety
and health legislation; and providing technical advice, conducting investigations
and promoting standard setting on such matters. SUNAFIL’s vision is to make
Peruvian citizens highly employable and ensure that they are protected by labour
rights and are able to work in roles that contribute to the sustainable and
inclusive development of Peru, thereby guaranteeing decent and productive
work.

SUNAFIL is an independent administrative agency with a high level of autonomy

in performing its functions under the legal mandate issued by the same law that

42
For more details see: https://www.sunafil.gob.pe/

68
established the agency, dated 15 January 2013. SUNAFIL began operating in April
2014 and incorporates three levels of inspection staff positions: assistant
inspectors; labour inspectors; and supervisor inspectors, who until then had
performed their functions in a directorate-general of the Ministry of Labour and
Employment Promotion.

Establishment of SUNAFIL

Upon its establishment in 2013, the functional competencies and inspection staff
of the Ministry of Labour and Employment Promotion were transferred to
SUNAFIL. It was specified that workers belonging to the inspection agency would
be employed under private sector labour regulations, providing better job
security and worker benefits than public sector labour regulations in Peru.

Before SUNAFIL was established, labour inspectors performed their functions

under the labour regulations of the civil service, with salaries lower than 40 per
cent of their current remuneration and working conditions that inevitably did not
meet the demands of the inspection role. SUNAFIL, acting on its own initiative or
through various collective bargaining mechanisms, has since been progressively
securing benefits for the inspection staff.

Remuneration of labour inspectors

At present, the inspection staff provide services under labour regulations

pertaining to the private sector and are remunerated according to the position
they hold. Inspection staff also receive: legal benefits; an annual inspection staff
bonus; an allowance to cover transport and light refreshments while working; a
work uniform; work clothes; 30 days of holiday for each year worked; paid leave
for a number of considerations; and non-financial compensation. Table A.1
details the annual income of labour inspectors.

69
Table A.1: Annual income of labour inspection staff.

Payment Supervisor Inspector Assistant

Remuneration 102 000 90 000 78 000

Training 400 400 400

Bonuses 17 000 15 000 13 000

Compensation for time 9 917 8 751 7 584

worked

Inspection staff bonus 8 370 8 370 8 370

Transport and 6 534 6 534 6 534

refreshments

Annual income (soles) 144 221 129 055 113 888

Working conditions of labour inspectors

Benefits granted to labour inspectors meet the specific financial and non-
financial compensation requirements of inspection staff. In addition,
compensation granted has been designed to meet particular non-financial
demands, is individual-specific, and meets the short-term and legal demands of
inspectors’ work.

In the last two years, there has been an effort to promote aspects of work such
as teamwork, dedication, self-management, enterprise and innovation – all of
which are necessary for SUNAFIL to make its culture more holistic and carry out
its work more effectively.

In addition, SUNAFIL has optimized the working conditions of inspection staff,

who annually receive, among other things: work clothes appropriate to the
functions they exercise; personal protective equipment; insurance against
70
occupational accidents and diseases; and Complementary Insurance for
Hazardous Work. It has also established specific working groups, made up of
staff from all levels, which focus on specific issues such as labour-related issues,
child labour, safety and health at work, rural work and informal urban work.

Inspectors also have at their disposal a fleet of vans and minibuses to travel from
their offices to inspection sites.

It is worth noting that since they began managing the agency, the current senior
management of SUNAFIL has established the conditions necessary to provide the
annual inspection staff bonus (achieved through a process of collective
bargaining when inspection staff worked under the Ministry of Labour and
Employment Promotion before SUNAFIL was established). It has continued to
grant the bonus since 2017, having granted payments accrued from previous
years. In addition, it is currently considering whether there are funds available to
provide a payment for transport (equivalent to 15 soles a day) and refreshments
(equivalent to 12 soles a day) while working; this has been a subject of collective
bargaining.

Recruitment of labour inspectors

All inspection staff entered the Labour Inspectorate in two clearly differentiated
ways:

By being transferred from the Ministry of Labour and Employment Promotion to

the recently established SUNAFIL in 2014; or

By passing one of the two public competitions held in 2018.

The first group, who were transferred from the Ministry of Labour and
Employment Promotion, entered the Labour Inspectorate through a public
competition. Their working and financial conditions under the Ministry were
much lower than they are today.

Inspectors in the first group today account for at least 66 per cent of all labour
inspectors, are between 40 and 60 years of age, are lawyers by profession, and
are trained to carry out inspection fieldwork.

71
The second group are relatively new inspectors, who entered the Inspectorate by
means of one of the two public competitions. Inspectors from this group account
for approximately 34 per cent of all labour inspectors; they are between 25 and
35 years of age and from multidisciplinary professions – including geologists,
engineers of various specializations, accountants, physicians and nurses. There
are significantly fewer lawyers in the second group than in the first group.

As mentioned above, two selection processes were held at the national level in
2018. In the first one approximately 12,000 applicants competed for 160
vacancies, while in the second competition approximately 10,000 applicants
competed for 80 vacancies. Two prestigious universities, namely the Universidad
Nacional de Ingeniería (UNI) (National University of Engineering) and the
Universidad Nacional Mayor de San Marcos (UNMSM) (National University of San
Marcos), participated in the public competitions.

Training of labour inspectors

SUNAFIL’s management documents set out six strategic objectives:

(1) contribute to the training of workers;

(2) ensure compliance with social and labour legislation for workers in the formal
economy;

(3) ensure compliance with occupational safety and health legislation in the
employed population;

(4) ensure the exercise of social and labour rights of children and the use of the
Employee Assistance Programme (EAP);

(5) strengthen institutional management; and

(6) implement disaster risk management for SUNAFIL.

To achieve those objectives, SUNAFIL has developed two continuous

improvement strategies for its inspectors:

Staff induction programme upon entering the Inspectorate; and

72
Staff training.

A staff induction programme has been developed for new recruits, which
includes five key areas of an inspector’s role. It incorporates fieldwork, which
gives the assistant inspector first-hand experience of inspection work, including
issuing inspection orders, carrying out the inspection itself, producing the
records and reports needed during the inspection process and using the Labour
Inspection Information System (SIIT). In this way, assistant inspectors are able to
put into practice the knowledge and skills learnt in the theory stage of the
induction programme.

In regard to staff training, SUNAFIL has a team dedicated to training all

inspection staff. The SUNAFIL Training Centre (CFC) is responsible for “carrying
out annual induction training programmes, periodical training and development
on various matters relating to safety and health at work, and required technical
assistance for users of the Labour Inspection Information System (SIIT)
(inspectors, mediators and trainers). SUNAFIL staff in both the SUNAFIL offices
and regional governments are able to carry out their work more effectively
thanks to the organization’s annual labour inspection system training
programme. The aim of all staff training is to improve management of the labour
inspection system – and thus to ensure compliance with the social and labour
legislation and occupational safety and health”.

Career development of labour inspectors

In addition, three internal promotion competitions were developed between

2017 and 2018 (for promotion to labour inspector or supervisor inspector). These
were similar to the public competition in their assessment of academic,
administrative and aptitudinal skills. Approximately 60 per cent of the inspection
staff were promoted through these competitions, which were the first large-scale
promotion competitions to take place since SUNAFIL was established.

Both the public entrance competitions and the internal promotion competitions
evaluated candidates with respect to their: specific technical knowledge of the
role; logical-mathematical thinking; verbal reasoning; documentary evidence of
specialization courses or programmes related to the role; and previous

73
professional experience. SUNAFIL staff also conducted in-depth interviews with
candidates. The assessment was highly competitive and ensured that those
entering the Inspectorate, or being promoted within it, were qualified – within
the framework of merit-based selection processes in the Government of Peru.

Unionization of labour inspectors

At present, 95 per cent of inspectors belong to a trade union (there are two
inspectors’ trade unions, neither of which have an overall majority). Both trade
unions, in accordance with current legislation, submit collective bargaining
documents twice a year, the content of which is largely financial demands; this is
despite the fact that public bodies are prohibited by national law from
negotiating financial matters, which are the main source of conflict between the
two trade unions and SUNAFIL. However, to ensure direct and smooth
communications, to anticipate any source of conflict and to deal with non-
financial issues labour relations, committees have been formed and meet once a
month. Both representatives of SUNAFIL and the trade unions sit on them.

It should be noted that this large-scale unionization of inspection staff is usually

viewed with suspicion and mistrust by the companies inspected, because they
suspect this unionization endangers the impartiality of SUNAFIL inspectors
working on cases concerning fundamental rights related to trade union
freedoms.

France43
A word of caution

43
Useful links (in French):
https://travail-emploi.gouv.fr/metiers-et-concours/devenir-inspecteur-du-travail/
https://travail-emploi.gouv.fr/droit-du-travail/le-reglement-des-conflits-individuels-et-collectifs/article/l-
inspection-du-travail
https://travail-emploi.gouv.fr/IMG/pdf/l_inspection_du_travail_en_france_en_2017.pdf
http://www.intefp.travail-emploi.gouv.fr/activites-de-formation/formation-statutaire/iet

74
Pursuant to the 2016 recommendations of the General Inspectorate of Social
Affairs on the recruitment, training and professional careers of members of the
Labour Inspectorate, steps were taken to:

– reform the competitive recruitment process (tests, recruitment board,

percentage for each recruitment track) in order to be more responsive in terms
of attractiveness, openness and professional experience;
– overhaul the initial training, the conditions for taking up labour inspection
positions, and service training, in particular preparation for managerial
functions;
– improve the professional career paths of labour inspectors (hierarchical
pyramid, mobility, attractiveness, etc.);
– improve the governance and management of human resources and the
Institut National du Travail de l’Emploi et de la Formation Professionnelle
(National Labour, Employment and Vocational Training Institute, or INTEFP),
which trains labour inspectors.
On the last three points, the information communicated below is valid as
at October 2019 but is expected to change, in particular with regard to
training.

Professional status of labour inspectors

Inspection duties are performed by civil servants governed by the law on the civil
service and by texts meeting the requirements of ILO Conventions Nos. 81 and
129 and of the 2006 Maritime Convention.

- Members of the labour inspectorate, which is a specialized unit of civil

servants managed by the Ministry of Labour and belonging to the highest
civil service category (management, design and general studies
professions). Members are recruited at the licence level (three years of
post-secondary studies).

- Labour controllers, who have the same inspection prerogatives and

means of action as labour inspectors, but who do not have authority to
make administrative decisions (authorizations to break the contracts of
wage-earners protected by their status as worker representatives, working
hour derogations, etc.). They belong to the intermediate category of civil
servants (applications-related professions, comparable to intermediate
75
 professionals). The controllers can supervise teams, workshops and
services. They are recruited at the Bac +2 level (two years of post-secondary
studies).

As part of the labour inspection reform process launched in 2013, the

position of labour controller is gradually being eliminated and
recruitment has stopped. At the same time, a plan is being implemented
to transform labour controllers into labour inspectors by means of a
limited competitive recruitment process. Approximately 400 controllers
were still performing labour inspection duties at the end of 2018.

Consequently, the following developments concern only labour

inspectors.

Recruitment of labour inspectors

Labour inspectors are recruited:

– on the basis of a competitive recruitment process;

– by selection from among labour controllers able to prove that they have
15 years of public service (up to one-fifth of the posts opened to the
competitive process);

– on the basis of a professional test among labour controllers able to prove

that they have eight years of seniority in the inspectorate (up to one-fifth
of the posts opened to the competitive process or of the number of labour
inspectors).

Labour inspectors have to take three competitive tests:

1. The external exam (target: 50 to 60 per cent of posts open to the recruitment
process) is intended mainly for students. It is open to candidates with a level
II (Bac +3) qualification or equivalent (an application for recognition of
equivalency can be sent to the recruitment service).

76
The test has two stages: eligibility tests to select the applicants authorized to take
the subsequent tests and admission tests to determine the successful
candidates.

Eligibility:

- a composition on a modern subject of general interest relating to the role

of the public authorities and their function within major public service
fields (a file can be made available to the applicant);
- a test comprising four or five short-answer questions or practical case
studies in the field of labour law and European social law;
- a composition on one or several topics in one of the subjects chosen by the
applicant (public law, private law, business economics, employment and
social policies, labour health and safety, ergonomics and organization of
work, material or life sciences). A file is made available to applicants.

Admission:

- an individual role play based on a subject drawn by lots, followed by an

individual interview aimed at gauging the applicant’s aptitude to solve a
practical case, to find solutions, to reason in a specific situation;
- an interview with the recruitment board, to assess the applicant’s
capacities, motivation and interpersonal skills to be a labour inspector;
- a conversation test in a foreign language of the applicant’s choice.

2. The internal competitive recruitment process is for civil servants providing

evidence that they have four years of public service (target: 15 to 25 per cent
of posts).

The process comprises three mandatory eligibility tests:

- drafting of a document based on a file relating to labour or employment

and vocational training issues;
- the other two tests are the same as those in the external competitive
process.

It also comprises three admission tests:

- the first is identical to that in the external competitive process;

77
 - an interview with the recruitment board, to assess the applicant’s
capabilities, motivation and interpersonal skills to be a labour inspector
and the knowledge acquired from his/her professional experience;
- an optional foreign-language test that takes the same form as in the
external competitive process.

The third competitive process is chiefly intended for people who have worked
in the private sector (target: 25 to 30 per cent of posts). It is open to applicants
with a total of eight years of experience, either in one or several positions as a
member of staff or other representative, or in one or several professions; in office
as a member of the elected assembly of a territorial authority; or in the discharge
of one or several activities as a leader, including on a volunteer basis, of an
association. The period of professional experience is calculated taking into
account, for wage-earning activities, any activity carried out as a wage earner
under private law or as a self-employed worker.

The process comprises two mandatory eligibility tests:

- drafting of a document based on a file relating to labour or employment

and vocational training issues;
- a test comprising four or five short-answer questions or practical case
studies in the field of labour law and European social law.

It also comprises three admission tests:

- a group role play based on a subject drawn by lots followed by an

individual interview aimed at gauging the applicant’s aptitude for
teamwork and communication;
- an interview with the recruitment board, to assess the applicant’s
capacities, motivation and interpersonal skills to be a labour inspector and
the knowledge acquired from his/her professional experience;
- an optional foreign-language test that takes the same form as in the
external competitive process.

Training

The occupations open to members of the labour inspectorate are overseeing

application of labour law, implementation of employment and vocational training

78
policies, and development and support for social dialogue and collective
bargaining in enterprises.

After the competitive recruitment process, trainee labour inspectors undergo 18

months of paid training preparing them to discharge the duties of labour
inspector.

The training is dispensed by the INTEFP, a public administrative establishment

reporting to the Labour Minister that provides initial and service training for
labour inspectors, labour controllers and all Labour Ministry agents.

The training is broken down into two periods:

– a 15-month professional training period during which trainees acquire the

professional knowledge and capacities common to the various labour inspection
functions, after which the trainee inspectors are assigned to their posts following
evaluation tests;

– an additional three-month training period during which the trainees acquire

the competencies needed for their first assignment. The instruction is dispensed
over the subsequent 12 months in blocks of around one week per month.

The training alternates between spells of class work at the INTEFP and practical
training outside its walls. The teaching method used combines knowledge
acquisition with practical exercises and professional role play scenarios.

The practical training comprises several in-service blocks, a work placement, a

court placement and a European internship with another Labour Inspectorate, a
labour, employment or vocational training administration, or a European
institution.

Note:

The initial training for labour inspectors and the procedures used to assess
competencies are currently undergoing reform, the aims of which are to adapt
the training to what are rapidly changing professions; provide training over 18
consecutive months, with the final six months centred on on-the-job training;
organize genuine rotation and promote greater responsibility among services in
respect of training; adapt the training to the variety of profiles recruited; and
adapt the teaching method to professional training for adults. The reform will be

79
operational for candidates having successfully completed the 2020 competitive
recruitment process, who will start their training in January 2021.

Promotion

The Labour Inspectorate has four grades: labour inspector, deputy labour director,
labour director and labour director (ungraded).

Labour inspectors may, over the course of their careers, occupy technical or support
posts, managerial posts (head of a labour inspection control unit or sector head in the
Labour Department) and executive positions in the decentralized services or in the
central administration.

Promotion within each grade is by step and is triggered by seniority (whereas

promotion to a higher grade is on the basis of selection by the hierarchical authority,
subsequent to registration on a promotion table).

It takes about eight years to attain grade 2 and accede to labour inspector managerial
functions; 13 years to attain grade 3 and occupy an executive position; 18 years to
attain the highest grade; and 20 years to attain the highest step at the highest grade.

See the table on the next page.

LABOUR INSPECTORATE
2017

GRADES Cumulative
Duration
AND career
at step
STEPS duration

Labour director (ungraded)

1 year 29.75 years

Special
step
1 year 28.75 years

80
 1 year 27.75 years

Step 4 1 year 26.75 years

1 year 25.75 years

Step 3 3 years 22.75 years

Step 2 2.5 years 20.25 years

Step 1 2.5 years 17.75 years

Labour director

Step 6 HEA HEA

Step 5 3 years

Step 4 3 years

Step 3 3 years

Step 2 2 years 15.75 years

Step 1 2 years 13.75 years

Deputy labour director

Step 8 -

Step 7 3 years

Step 6 3 years

Step 5 2 years

81
Step 4 2 years

Step 3 2 years 12.75 years

Step 2 2 years 10.75 years

Step 1 2 years 8.75 years

Labour inspector

Step 10

Step 9 4 years

Step 8 3 years

Step 7 3 years

Step 6 3 years

Step 5 2 years

Step 4 2 years 6.75 years

Step 3 2 years 4.75 years

Step 2 2 years 2.75 years

Step 1 1.5 years 1.25 years

Trainee
1.25 years
inspector

Remuneration

82
Post-training, labour inspectors at the start of their careers earn a gross monthly
salary of 2,085 euros.

That amount goes up to around 3,330 euros when they reach the final step in the
inspector grade and, near the end of their careers, to nearly 4,555 euros at the
last step in the labour director grade.

See detailed table.

The salary is supplemented by the following:

– a residence allowance (depending on the place of assignment);

– a family supplement depending on the number of children;

– a system of compensation, the amount of which is on average 7,000

euros for the year at the start of the career.

See table below, in force October 2019:

LABOUR INSPECTOR

Grades and steps Gross indices Augmented indices Step duration Remuneration by step

Labour director (ungraded)

1 067 -
€ 4999.96
Special step Ungraded B

1 013 1 year
€ 4746.92

972 1 year
€ 4554.79
Step 4 Ungraded A

925 1 year
€ 4334.55

83
 890 1 year
€ 4170.54

Step 3 1 027 830 3 years

€ 3889.38

Step 2 995 806 2.5 years

€ 3776.92

Step 1 930 756 2.5 years

€ 3542.62

Labour director

972 - € 4554.79

Step 6 Ungraded A 925 1 year

€ 4334.55

890 1 year
€ 4170.54

Step 5 1 027 830 3 years

€ 3889.38

Step 4 995 806 3 years

€ 3776.92

Step 3 930 756 3 years

€ 3542.62

Step 2 871 711 2 years

€ 3331.75

84
Step 1 830 680 2 years
€ 3186.48

Deputy labour director

Step 8 995 806 - € 3776.92

Step 7 945 767 3 years € 3594.16

Step 6 906 738 3 years € 3458.27

Step 5 858 701 2 years € 3284.89

Step 4 826 677 2 years € 3172.42

Step 3 785 646 2 years € 3027.16

Step 2 740 611 2 years € 2863.15

Step 1 678 564 2 years € 2642.90

Labour inspector

Step 10 871 711 - € 3331.75

85
 Step 9 827 678 4 years € 3177.11

Step 8 786 647 3 years € 3031.84

Step 7 740 611 3 years € 2863.15

Step 6 678 564 3 years € 2642.90

Step 5 622 522 2 years € 2446.09

Step 4 595 501 2 years € 2347.69

Step 3 558 473 2 years € 2216.48

Step 2 518 445 2 years € 2085.27

Step 1 480 416 1.5 years € 1949.38

Trainee inspector 390 357 1.25 years € 1672.90

Mobility (to other district inspection services or headquarters or detachment to

other departments or organizations)

Most labour inspectors work in the decentralized services of the Labour Ministry,
for the most part in labour inspection services, but also in services overseeing
employment policies, providing guidance for economic change and inspecting
vocational training.

86
The occupations exercised by labour inspectors are essentially divided into four
families: “regulation and control”; “design, promotion and implementation of
policies and implementing mechanisms”; “expertise and support for operational
services”; and “guidance and organization of services and major projects”.

Within the Labour Inspectorate, they occupy the following positions:

 factory inspector;
 legal expertise and dispute settlement officer;
 labour inspection legal and methodological support officer;
 social dialogue support officer;
 labour law information officer.

They may also be assigned:

- to the central administration (in particular as legal expertise and dispute

settlement officers; labour inspection legal and methodological support
officers; policy design, promotion and follow-up officers);
- to the INTEFP, which trains labour inspectors (as project leaders, internal
trainers or training engineering officers).

Roughly one hundred labour inspectors work outside the ministry (Central Office
to Combat Illegal Employment, International Labour Office, National Agency to
Improve Working Conditions and its regional offices, the Employment
Department, ministries in charge of agriculture, transport and justice).

87
Appendix II

Selected bibliography
The main sources used in this paper have been: International labour standards
on labour inspection; ILO General surveys on labour inspection; opinions issued
by the Committee of Experts on the Application of Conventions and
Recommendations; and reports submitted by Member States on their
implementation of the provisions of ILO Convention No. 81.

a) Internal ILO desk-research on labour inspection careers:

Americas:

Argentina

Brazil

Canada: Québec

Chile

Honduras

Peru

Venezuela

Asia:

Armenia

Bangladesh

Kazakhstan

Vietnam

New Zealand
88
Europe:

Belgium

Czech Republic

Denmark

Estonia

Finland

France

Luxembourg

Moldova

Portugal

Romania

Slovakia

Spain

Sweden

Ukraine

United Kingdom

Africa:

Burkina Faso

Cote D’Ivoire

Madagascar

Mali

Morocco

Mauritania

Tunisia

Algeria

89
b) Additional sources of information:
K. Ariga: Horizontal transfer, vertical promotion, and evolution of firm
organization (Elsevier, 2004), available at:
http://www.computer-services.e.u-
okyo.ac.jp/p/seido/output/Ariga/ariga004.pdf

Cardiff University: Potential impact of emerging trends and risks on labour

inspection methodologies in the domain of occupational health and safety
(Environment Research Centre).

T. Chamorro-Premuzic: “Can you really train soft skills? Some answers from
the science of talent”, in Forbes, available at:

https://www.forbes.com/sites/tomaspremuzic/2018/06/14/can-you-really-
train-soft-skills-some-answers-from-the-science-of-talent/#54f4e45dc460

K. Conboy and C. Kelly: What evidence is there that mentoring works to retain
and promote employees, especially diverse employees, within a single company
(Cornell University, 2016), available at:

https://digitalcommons.ilr.cornell.edu/cgi/viewcontent.cgi?referer=https:/
/www.google.com/&httpsredir=1&article=1120&context=student

S. Ashcroft and S. Williams: Strategic Review of the Labour Inspection System,

delivered by the Department for Inspection of Factories in Bangladesh.

Economic Insight: Valuing different workplace rewards: A report for the Office
of Manpower Economics (2017), available at:
https://assets.publishing.service.gov.uk/government/uploads/system/upl
oads/attachment_data/file/655988/Valuing_Different_Workplace_Reward
s.pdf

European Parliament: European Parliament resolution of 14 January 2014 on

effective labour inspections as a strategy to improve working conditions in
Europe (Strasbourg, 2014), available at:

90
http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-
//EP//TEXT+TA+P7-TA-2014-0012+0+DOC+XML+V0//EN

E. Harbour and A. Ellis: “Benchmarking the recruitment and training of

labour inspectors” (February 2004).

Health and Safety Executive (HSE): Strategic review of the labour inspection
system delivered by the Department for Inspection of Factories in Bangladesh.

International Association of Labour Inspection (IALI): Global Code of

Integrity for Labour Inspection (SafeWork, South Australia, 2008), available
at: https://www.ilo.org/labadmin/info/WCMS_117608/lang--en/index.htm

International Labour Organization (ILO): Labour inspection in Europe:

undeclared work, migration, trafficking, Working Document No. 7,
LAB/ADMIN (Geneva, 2010), p. vii, available at:
https://www.ilo.org/wcmsp5/groups/public/---ed_dialogue/---
lab_admin/documents/publication/wcms_120319.pdf

J. D. Martín Gonzalez: Study on Department of Inspection of Factories and

Establishments (DIFE). High-level staff retention and motivation (Geneva, ILO,
2017).

P. Mayberry: “Work-life balance policies and practices in the UK: Views of

an HR practitioner”, in Journal of Management, 23 (2) (2006), pp. 167-188.

J. Mendeloff et al: Human resource practices for labor inspectorates in

developing countries (Cornell University, 2014), p. 7, available at:
https://digitalcommons.ilr.cornell.edu/cgi/viewcontent.cgi?article=2814&c
ontext=key_workplace

S. Montoya and J. Graham: Modernizing the Federal Government. Paying

for performance (Santa Monica, CA, Rand, 2007).

91
L. Morgan: The impact of work-life balance and family-friendly
human resource policies on employees’ job satisfaction (London, Oxford
University Press, 2009).

L. Muehlenbachs, S. Staubli and M. Cohen: The effect of inspector group

size and familiarity on enforcement and deterrence: Evidence from oil
platforms, Vanderbilt Law and Economics Research Paper Nos. 13-35,
Vanderbilt Owen Graduate School of Management Research Paper No.
2350923 (2013), available at:
https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2350923

OECD: Performance-related pay policies for government employees (Paris,

2005), available at: https://doi.org/10.1787/9789264007550-en

Regulatory enforcement and inspections, OECD Best Practice Principles for

Regulatory Policy (Paris, 2014), available at:
http://www.oecd.org/gov/regulatory-enforcement-and-inspections-
9789264208117-en.htm

The future of social protection. What works for non-standard workers? (Paris,
2018), available at: https://doi.org/10.1787/9789264306943-en

R. R. C. Pires: “Flexible bureaucracies: Discretion, creativity, and

accountability in labor market regulation and public sector management”,
in Humanities and Social Sciences, Vol. 71, No. 1-A, (2010), p. 327.

Government of Spain: Proceso selectivo para acceso a la Inspección de

Trabajo y Seguridad Social, Ministry of Labour, Migrations and Social Security,
Escuela de Inspección de Trabajo y Seguridad Social (EITSS), available at:
http://www.mitramiss.gob.es/itss/web/index.html

P. Teague: “Reforming the Anglo-Saxon model of labour inspection: The

case of the Republic of Ireland”, in European Journal of Industrial Relations
(2009), available at:
http://journals.sagepub.com/doi/abs/10.1177/0959680109103603

92
“Study about Labour Inspectorate resource reductions in the European
Union”, Senior Labour Inspectors’ Committee. Doc. Circa 756, May 2011.

“Study about the impact of the economic crisis on the European labour
inspection systems from 2007 to 2014”, SLIC.

“Analytical overview SLS career development of labour inspectors” and

“Recommendations to the State Labour Service human resources policies
on labour inspectors”, available at:
https://www.ilo.org/budapest/what-we-do/projects/WCMS_488014/lang--
en/index.htm

“Common standards for OSH Inspector Training Programme”, SLIC.

“Training and recruitment of labour inspectors: Initiative on an EU level

action”, SLIC Thematic Day-Luxembourg 2015.

Senior Labour Inspectors' Committee (SLIC): Violence towards inspectors:

Good Practice Guide (2007).

M. White et al.: ““High Performance” management practices, working

house and work-life balance”, in British Journal of Industrial Relations, 41
(2) (2003) pp. 175-195.

C. Williams, P. Vanden Broeck, A. Scharle: Future role and competence

profile of Labour Inspectorates (Lithuania, 2019).

W. von Richthofen: Labour inspection: A guide to the profession (Geneva,

ILO, 2002), available as of 5 November 2014 at:

http://www.ilo.org/safework/info/publications/WCMS_108665/lang--
en/index.htm

93
Roffey Park Institute (2004), available at:

http://www.roffeypark.com/research/wbl.html

M. L. V. Ruiz: Labour administration: To ensure good governance through

legal compliance in Latin America. The central role of labour inspection,
labour administration and inspection programme, Working Document 1
(Geneva, ILO, 2009). As of 5 November 2014, available at:

http://www.ilo.org/labadmin/info/pubs/WCMS_116044/lang--
en/index.htm

94
 International Labour Organization
Labour Administration, Labour Inspection and
Occupational Safety and Health Branch
(LABADMIN/OSH)
Route des Morillons 4
1211 Geneva 22
Switzerland
T: +41 22 799 6715
E: labadmin-osh@ilo.org
www.ilo.org/labadmin-osh