Young Workers on Site: Extra Duties and Considerations

Who Counts as a Young Worker?

In law, a young worker is anyone who hasn't yet reached 18. That's the definition used across the Management of Health and Safety at Work Regulations 1999 (MHSWR), and it doesn't matter whether they're on your payroll, on a work experience placement, or an apprentice attending college one day a week. If they're under 18 and doing work for you, the extra duties apply.

This catches more people than a lot of contractors expect. A 17 year old apprentice joiner, a 16 year old on a two week school work experience placement, a college student on day release, and a young labourer straight out of school are all young workers in the eyes of the law. There's a separate, narrower definition of "child" for those still of compulsory school age, but for most site purposes, the key line to remember is 18.

It's worth saying clearly: young workers are not a problem to be managed around. Construction needs new people coming through, and apprenticeships are one of the best routes into the trade. The law isn't there to stop you taking on young workers, it's there to make sure you've thought about what makes them different from an experienced tradesperson before you hand them a task.

What the Law Says

The core duty sits in Regulation 19 of the Management of Health and Safety at Work Regulations 1999. It requires you to protect young persons from risks arising from their lack of experience, their absence of awareness of existing or potential risks, and the fact that they haven't yet fully matured, physically or mentally.

This sits on top of your general duties under the Health and Safety at Work etc. Act 1974, which already require you to ensure, so far as is reasonably practicable, the health and safety of everyone affected by your work. Regulation 19 doesn't replace that, it sharpens it for a specific group who are statistically more likely to be hurt at work because they haven't yet built up the instinct for spotting danger that comes with time on the tools.

There's also a practical restriction from the Working Time Regulations 1998: young workers under 18 generally can't be required to work at night, with night defined as the period between 10pm and 6am (or 11pm and 7am where their contract sets those hours). There are limited exceptions, but for most site work, plan young workers into daytime shifts and don't roster them for night working or shutdown jobs without checking the rules properly first.

The Young Worker Risk Assessment

A generic site risk assessment written for experienced adult tradespeople isn't good enough on its own once a young worker is added to the crew. You need to go back through it, or write a specific supplement, that looks at the same tasks through the lens of someone doing them for the first time.

In practice, that means asking different questions. Not just "what's the hazard and how do we control it," but "would someone with no experience recognise this hazard at all," and "what happens if they freeze, panic, or make the wrong call under pressure." A trailing cable is an obvious trip hazard to a tradesperson who's worked around plant for years. To a 16 year old on their first week, it might just be part of the scenery.

Your assessment should cover the specific tasks the young worker will actually do, their level of physical development for anything involving manual handling or strength, their emotional maturity for anything involving working at height or lone working, and how quickly they can be reached by a supervisor if something goes wrong. Where the standard assessment already covers a control adequately for everyone on site, you don't need to reinvent it, but you do need to record that you've thought about the young person specifically, not just assumed the general controls will do.

Prohibited Tasks

The law doesn't hand you a neat list of banned jobs for young workers. Instead, Regulation 19 sets out categories of risk that young workers must be protected from, and in practice this rules certain tasks out unless very specific conditions are met.

Young workers must not be given work that's beyond their physical or psychological capacity, work involving harmful exposure to toxic or carcinogenic agents, work involving harmful exposure to radiation, work in extreme cold, heat, noise, or vibration, or any work where the risk is one they couldn't reasonably be expected to recognise or avoid because they're young and inexperienced.

There's an important exception built into the regulations for training. A young worker can be involved in these higher risk activities where it's necessary for their training, provided they're supervised by a competent person and the risk has been reduced to the lowest level reasonably practicable. This is exactly why apprenticeships work: a competent tradesperson can teach a 17 year old to use a cutting tool or work near live services, but only with proper supervision and a risk assessment that shows you've actually reduced the danger, not just hoped for the best.

What this means day to day is that a young worker shouldn't be sent up a scaffold alone, left to operate plant they haven't been trained on, put in a confined space, or asked to work with hazardous substances without the right controls and someone competent keeping an eye on them. If in doubt, ask whether an experienced tradesperson would recognise the risk instantly. If a young worker wouldn't, they need training and supervision before they go near it.

Supervision Requirements

There's no fixed ratio in law like one supervisor to every three young workers. What the regulations actually require is supervision that's appropriate to the level of risk. That means low risk, well understood tasks might need periodic checking in, while anything higher risk, like work at height, lifting operations, or use of power tools, needs closer, more direct supervision, at least until the young worker has shown they can do it safely and consistently.

HSE expects to see supervision that scales with risk and experience, not supervision that's set once and forgotten. A young worker in their first week on a task should be supervised more closely than the same young worker three months in, once they've demonstrated they understand the hazards and follow the controls without prompting. This progressive approach, sometimes called progressive independence, is good for the business too: it builds competent tradespeople instead of workers who can only follow instructions when someone's watching.

The person doing the supervising needs to be competent in the task itself, not just present. Sticking a young worker next to any available adult isn't supervision if that adult doesn't know the job well enough to spot when something's going wrong. Name the supervisor for each task in your paperwork, and make sure it's someone who actually knows what good practice looks like for that specific job.

Information, Instruction, and Training

Every young worker needs a site induction before they set foot on the working area, and it needs to go further than the standard version for experienced hires. Walk them through the site layout, welfare facilities, who to go to with a question or a concern, and what to do in an emergency, and check they've actually understood it rather than just nodded along.

Beyond the induction, each new task needs its own task specific briefing before the young worker starts it, covering the hazards, the controls, and what "stop and ask" looks like in practice. Young workers are less likely to speak up if they're unsure, often because they don't want to look inexperienced or slow the job down, so build regular check ins into the day rather than waiting for them to come to you.

A quick five minute chat at the start of a task, a check midway through, and a debrief at the end costs you almost nothing and catches problems before they become incidents. Document that these check ins happened. If something does go wrong, being able to show a pattern of ongoing instruction and supervision, not just a one off induction months ago, is what demonstrates you took the duty seriously.

Apprentices and College Placements

Apprentices have exactly the same legal protections as any other young employee. The fact that they're working towards a qualification doesn't reduce your duties as their employer, and it doesn't shift responsibility for their day to day safety onto the college or training provider.

There's a split of responsibility worth understanding clearly. The training provider or college is generally responsible for the quality and structure of the off the job training and qualification itself. You, as the employer, remain responsible for health and safety on your site, on your projects, for every hour the apprentice is working under your direction. That includes the risk assessment, the supervision, the task training, and the induction, exactly as it would for any other young worker.

The same principle applies to work experience placements and college site visits, even short ones. A two week placement doesn't get a watered down version of your duties, it gets the same Regulation 19 protections as an apprentice three years into their training, scaled to the tasks they're actually being asked to do.

Monitoring and Review

Young worker arrangements aren't a set and forget job. Review the risk assessment and the supervision plan more often than you would for an experienced adult worker, particularly in the first few weeks of any new task, and again whenever the young worker moves to a different job, a different site, or a different piece of kit.

Build in a short, regular check in as standard practice, not just when something's gone wrong. Ask how they're finding the work, whether anything has confused them, and whether they've seen anything on site that worried them. Young workers often won't raise concerns unprompted, so the responsibility for creating that opening sits with you.

If a young worker's role, tasks, or site changes, treat it as a trigger to revisit the assessment rather than assuming the original one still covers it. A young worker who's competent and well supervised on groundworks isn't automatically ready for work at height without the same process starting again.

Common Mistakes

Most young worker problems on site come down to a handful of avoidable gaps. Here's what HSE expects to see fixed first.