Groups at risk
Jennifer Webster, Health & Safety Laboratory, UK
In 1989, the Council Directive 89/391/EEC  (also known as the ‘Framework Directive’) introduced measures to improve the safety and health of workers. It established the minimum occupational safety and health (OSH) requirements within the European Union (EU). In Article 15 of the 1989 Framework Directive, it states that ‘particularly sensitive risk groups must be protected against the dangers that specifically affect them.’ In 1996, the European Commission (EC) produced its ‘Guidance on Risk Assessment at Work’  which identified the ‘sensitive risk groups’  as workers with disabilities, young and old workers, pregnant and nursing mothers, and untrained or inexperienced workers including seasonal, temporary or migrant workers. This article provides an overview of the occupational safety and health (OSH) risks faced by the ‘sensitive risk groups’ who in this article are referred to as vulnerable workers.
Background to groups at risk
Recently, the European Commission in response to demographic changes in Europe has sought to increase workforce participation to ensure sustainable growth which in turn will inevitably result in more workers from these groups being encouraged to join the labour market. The EU2020 Strategystates that:
‘...the employment rate of the population aged 20-64 should increase from the current 69% to at least 75%, including the greater involvement of women, older workers, and the better integration of migrants in the workforce.’
Recognising that if these groups are to be actively encouraged to participate within the labour market and not put their health and safety at risk as a result, additional protection would need to be put in place. Within employment guidelines for 2010, which were adopted by the Council in October 2010 and then confirmed in 2011, Guideline 7 calls for better integration in the labour market of young people, the disabled, legal migrants and other vulnerable groups and the promotion of occupational health and safety.
Over the past few years, more workers could be considered as vulnerable workers due to the changing nature of work with an increasingly mobile workforce; an increase in short term work contracts, contracts and with more women entering the workforce. Young workers are especially vulnerable because of their lack of experience and less knowledge of the work environment. However, older workers entering new jobs can also be vulnerable. The OSH requirements of all groups should be addressed to meet the aims and objectives of EU2020. This article will focus on some of the key OSH issues associated with each group.
Young workers are defined by the International Labour Organisation (ILO) and EU regulations  as those within the age group 15 to 24 years. Within this group are full and part-time workers, young workers supplementing their full-time studies, apprentices contracted to an employer and trainees between the age of 15 to 24 years in a non-contractual work situation. The common denominator is their lack of experience and maturity which may make them less aware of OSH policies and procedures or afraid to ask for help and advice from their supervisors or more experienced colleagues.
Under the terms of Council Directive 94/33/EC  the OSH of young workers is protected as it states that all children and adolescents should be considered a specific risk group and as such employers must guarantee that the working conditions of young workers are appropriate for their age. There are rules that must be applied to all young workers under the age of 18 years, namely that they should not be allowed to do work which:
- Exceeds their physical or mental capacities
- Exposes them to substances that are toxic or cause cancer
- Exposes them to radiation
- Involves extreme heat, noise or vibration
- Involves risks that they are unlikely to recognise or avoid because of their lack of experience or training or their insufficient attention to safety.
The six types of problems that young workers are more likely to be vulnerable to when at work are:
- Musculoskeletal symptoms
- Respiratory problems
- Allergy and toxicological problems
- Impaired mental health and well-being
- Alcohol and drug use
Young workers are also at greater risk of having an occupational accident although accident rates and causes of accidents vary greatly between different sectors and occupations. Due to their lack of experience, young workers are particularly vulnerable in industries that are already considered as hazardous e.g. construction, agriculture, and shipping.
There are a range of preventative measures that can be taken to reduce OSH risks to young workers  including:
- Communicating occupational safety and health risks to young workers.
- Providing young workers with training in OSH and prevention targeted specifically to that group.
- Including awareness of OSH in vocational training and education.
- Taking steps to make young people better prepared for the world for their working lives.
The European Council aims to increase women’s participation in the labour market to 75% as part of the EU’s 2020 Strategy. However, whilst improvements have been made to improve women’s OSH, there is more to be done. Women working in ‘women’s jobs’ in health and social services, retail and the hospitality sector have seen an increase in accidents and fatalities. They are more exposed to multiple musculoskeletal (MSD) risk factors and have more MSDs. They are also more exposed to sources of stress, especially as women are also more likely to be bullied and harassed, including sexual harassment, and exposed to multiple discrimination. They also have to cope with often poorly fitting personal protective equipment (PPE) that is often designed for men or larger body shapes. Women are increasingly moving into jobs that have in the past been seen as traditionally male such as construction and civil engineering . Female workers tend to work more on part-time contracts where they may not get as much training and may be left out of risk assessment.
Although immigration varies from country to country, some migrant workers will be women seeking employment opportunities. Those working in the service sector, particularly workers who work at client’s premises (home care, cleaners, personal services)  are less likely to speak the same language as their employer, may be asked to do work without the right equipment, and may be subject to harassment, violence and bullying.
Young female workers should also be aware of any reprotoxic risks associated with any chemicals they may be exposed to in the workplace as this may have an impact on their future health, their fertility and the health of any children they may have in the future. This applies equally to any potential fathers, as chemical exposure may result in heritable genetic damage and may also impair fertility. As OSH prevention policies have traditionally focused on high-risk sectors for men, such as construction and agriculture, they have had little effect on the occupational health and safety of women. 
New and expectant mothers
This section provides a brief overview of the main workplace reproductive hazards faced by new and expectant mothers. For more detailed information please refer to New and expectant mothers article. New and expectant mothers are considered to be an at risk group, i.e. they are more susceptible to work-related injuries and ill health than the average worker. They are also susceptible to reprotoxic risks from exposure to chemicals which can harm not only their health, but also the health of their unborn child, sometimes well into adulthood. New and expectant mothers are defined as workers who are pregnant or who have given birth within the previous six months, or are breastfeeding. Employers need to recognise that there could be different risks depending on whether a woman is pregnant, has recently given birth or is breastfeeding. The main reproductive hazards include:
- Chemical Agents, which once they enter the mother’s body may then enter the foetus and at the early stages of its development may cause birth defects or miscarriage.
- Physical Agents, which may include excessive noise, vibration, extremes of temperature, ionising and non-ionising radiation, and could impact on materials handling, movement and posture, travelling, mental and physical fatigue and other physical demands such as prolonged standing and sitting.
- Biological Agents such as viruses, fungi, spores and bacteria may impair the fertility of both men and women or cause birth defects.
Employers should identify the hazards associated with their business, evaluate the risks they pose and implement the appropriate control measures. However, employers should be mindful that exposure to reproductive hazards can affect the foetus. Furthermore, a woman may be particularly cautious about any potential risks to her unborn child and the anxiety that this might cause can in itself be harmful to both mother and child. Psychosocial factors such as stress during pregnancy generally can have an adverse impact on both mother and child
The safety and health of pregnant workers or new mothers is covered by Directive 92/85/EEC which requires the assessment of any ‘chemical, physical and biological agents and industrial processes considered hazardous.’ The guidelines were extended in 2000 to cover ‘movements and postures, mental and physical fatigue and other types of physical and mental stress.’ In 2008 the rights of pregnant workers were extended through an amendment which increased maternity leave from 14 to 18 weeks. This also permits mothers to breastfeed for longer if they choose to do so without the risk of contaminants from the workplace being passed to their baby through their breast milk. There have been improvements made to the protection of the health and safety at work of self-employed pregnant women and Directive 2010/41 gives self-employed pregnant women at least 14 weeks maternity allowance. 
Ageing and older workers
Within some Member States, the State Retirement Age has been increased to support changes in pension systems and to enable and encourage people to continue working until the retirement age. In order to extend working lives and to continue to get the best out of workers for longer; working conditions in relation to health and safety, including flexible working arrangements amongst others, have to be improved. It is estimated that by 2025 the proportion of 50-64 year old workers will double in size compared to workers under the age of 25 . Older workers are protected under the EU’s ‘Framework Directive’ (89/391/EEC) and when considering the ability of an older worker to carry out a job of work, age should not be a barrier as older workers will vary in how they respond to the ageing process and the majority of older workers will continue to have good mental and physical health that permits them to work well up to the age of 65-70 years of age . Age-related decline affects mainly physical and sensory capacities, which are most relevant to heavy physical work. There is evidence that job performance is the same across all age groups and in some studies older workers may perform better in terms of accuracy and the consistency of output than their younger colleagues. In addition, cognitive skills such as intelligence, knowledge, language and complex problem solving are resistant to age-related declines and are likely to increase with age until 60 years of age.Older workers are generally less likely to have accidents than their younger counterparts. However, workplace accidents involving older workers tend to result in more serious injuries (i.e., permanent disability, dismemberment, or death). Particular causes of stress for older workers can be lack of opportunities for career development and training, and difficulties in adapting to changing technologies.  Age-sensitive risk assessment means taking into account age-related aspects of different age groups when assessing risk, including potential changes in functional capacity and health status in the case of older workers. More consideration must be given to the physical demands of the work, hazards related to shift work, work in hot conditions, noise, etc., in the case of older workers. However, as inter-individual differences increase with age, assumptions should not be made purely on the basis of age. The risk assessment should consider work demands in relation to the individual’s functional capacities and health status. 
Where a worker becomes ill, particular attention may be necessary to their needs for rehabilitation and return to work. However, this need is not limited to older workers. For example; with increases in cancer survival rates, there is growing recognition of a need to actively manage the return to work after cancer, whatever the age of the worker.
The European Agency for Occupational Safety and Health at Work (EU-OSHA) defines disability as a state that covers both physical and mental impairments and covers all employees who might be hampered in work performance, including people with long term or progressive conditions. It is estimated that 23.5% of the working population in the EU-27 has a chronic illness and 19% have a long-standing health condition. Some musculoskeletal disorders can need careful management to avoid long-term disability or to minimise the impact of chronic problems.
Member States are required to adopt regulations ensuring the OSH of employees whilst at the same time ensuring equal treatment for people with disabilities. The EU Directive 89/654/EEC covers the minimum OSH requirements for the workplace and directs that workplaces must be adjusted to take account, where required, of the needs of workers with disabilities. This provision applies to the doors, passageways, staircases, showers, washbasins, lavatories and workstations used or occupied directly by workers with disabilities. Directive 89/391/EEC requires employers to carry out risk assessments, eliminate risks and adapt work and the workplace to the workers, including workers with disabilities. Risk assessment should also apply to work equipment, organisation, working alone, dangerous substances etc., so all Directives apply and are relevant. Further information on the legislative obligations on employers can be found in Workers with disabilities article
It should be recognised that workers with disabilities are part of a widely diverse group and some workers may not exhibit any obvious signs of disability. Those suffering from mental health problems may not have any outwardly visible signs, but nevertheless may need suitable provisions to be made.
OSH issues that they face may be similarly varied. Each worker should be treated on an individual basis. Establishing a disability management policy and procedures may be beneficial.
Disability sensitive risk assessments should:
- Take into account the capabilities of the disabled individual;
- Take into account the nature and extent of the individual’s disability;
- Take into account the specific requirements of the job;
- Avoid making stereotypical assumptions about risks associated with a particular type of impairment;
- Consult with the individual concerned at all stages;
- Seek advice from Occupational Safety and Health professionals, Medical professionals, disability employment groups or organisations;
- Coordinate between safety personnel and equality personnel;
- Consider reasonable accommodations to prevent or reduce the assessed risks;
- Consult with the individual to check that the accommodations suggested are suitable and appropriate before and after implementation.
Although not every disabled worker may require a workplace accommodation, some typical types of accommodation include:
- Adjustments to work organisation, duties and working hours
- Adjustments to the physical features of the workplace
- Adjustments to work equipment
- Installing appropriate signs, signposting and emergency procedures
- Consider how communications and auxiliary services can be best deployed
- Training and supervision.
Further detailed information about the types of accommodations and adjustments can be found on Workers with disabilities article.
Migrants can be found in many jobs, including high-skilled jobs in information technology and professional jobs and what is referred to as ‘three D-jobs’, dirty, dangerous and demanding, the most common sectors being in agriculture and horticulture, construction, health care, working in domestic households, transport and food sectors. The three main OSH issues relating to migrant workers are:
- The high employment rates of migrant workers in high risk sectors;
- Language and cultural barriers to communication and training in OSH;
- They are more likely to sustain occupational injuries and diseases because they often work more overtime and can be in poor health.
Foreign citizens are twice as likely to be overqualified as nationals. This gap indicates a potential misuse of migrants’ skills and qualifications. 
To support migrants in the workplace, the EU Framework Directive 89/391/EEC) sets out the requirement to carry out an inclusive risk assessment. Best practice for employers in managing the OSH of migrant workers includes the following recommendations:
- Manage discrimination at work rather than ignore it. Listen to workers concerns but also understand that attitudes to work can be influenced by cultural differences.
- Take into account the verbal and written language skills of migrant workers before conducting a risk assessment.
- Check that any risk assessment processes can be understood by migrant workers and if necessary have them translated.
- If the language skills of the migrant worker are poor then safety training should be ideally delivered in their first language.
- Employers should adopt a policy of integrating migrant workers into the workforce to create a truly intercultural workplace
- Creating an inclusive, supportive and open workplace should impact on work-related accidents, occupational diseases and work stress and improve the working conditions of migrant workers.
The definition of self-employed varies across the Member States but it can be divided into five categories: 
- Entrepreneurs, who run their business with the help of employees;
- Traditional ‘free professionals’, who, in order to work in their occupation, must meet specific requirements, abide by regulations and duty-bound codes and often pass examinations to be listed in public registers. They generally carry out their activities alone or in association with other professionals and with the help of a limited number of employees, if any;
- Craft-workers, traders and farmers, who represent the traditional forms of self-employment. They usually work with family members and a small number of employees;
- Self-employed workers in skilled but unregulated occupations sometimes referred to as ‘new professionals.’
- Self-employed workers in unskilled occupations, who run their business without the help of employees but who may sometimes be assisted by family members.
According to figures produced in 2009, self-employed workers account for ten per cent of the workforce in Europe, ranging from 21% in Greece to 4% in Estonia. There is a significant proportion of self-employed workers in agriculture (47%) and construction (17%). Council Recommendation 2003/134/EC of 18 February 2003 concerns the improvement of the protection of the health and safety at work of self-employed workers . They often work long and irregular hours and are mostly low paid so they tend to neither have the time or the money to pay for appropriate OSH training and safety equipment. Self-employed workers should assess the risks not only to their own health and safety at work but also that of the people they work with and members of the public. Directive 2010/41/EU makes reference to pregnancy rights, family workers and to harassment.
Temporary agency workers
The changing labour market has resulted in the number of permanent jobs declining and many employers are choosing different forms of employment contract that gives them greater flexibility. This means there are a variety of different types of temporary worker but for the purposes of this article a temporary worker is defined as ‘…a person with a contract of employment or an employment relationship with a temporary agency with a view to being posted to a user undertaking to work temporarily under its supervision’. A temporary agency worker is defined under Directive 2008/104/EC as ‘…any natural or legal person who, in compliance with national law, concludes contracts of employment or employment relationships with temporary agency workers in order to assign them to user undertakings to work there temporarily under their supervision and direction.’ 
The experience of temporary workers will vary, often depending on how long they are going to be at the workplace. For instance, maintenance workers are a group particularly at risk as maintenance becomes increasingly sub-contracted. As a result, employers should ensure that temporary workers have the same OSH protection as other employers and ensure that appropriate risk assessments are undertaken so that temporary workers know what steps have been taken to protect them. Employers should ensure that:
- Temporary workers understand the information and instructions they need to work safely, and receive any necessary training.
- The language needs of temporary workers are taken into account if they come from another country.
- Temporary workers have the qualifications and skills to do the job.
- The arrangements for the provision and maintenance of any personal protective equipment, display screen equipment, as well as any necessary health surveillance, are agreed.
- Arrangements for reporting relevant accidents are agreed in line with the appropriate legislation for that country.
What employers should consider
- Avoid stereotyping people and making assumptions about what the hazards are and who is at risk.
- Adapt work and preventative measures to workers. Matching work to workers is a key principle of EU legislation.
- When designing or planning work, consider the needs of a diverse workforce rather than waiting for a young/ pregnant/disabled/older/migrant worker to be employed and then having to make changes.
- Link occupational safety and health into any workplace equality actions, including equality plans and non-discrimination policies.
- Provide relevant training and information regarding safety and health risks to risk assessors, managers, supervisors, safety representatives as well as the workers.
- Ensure that occupational safety and health training is tailored to the workers’ needs and circumstances.
- Ensure that temporary and shift workers, subcontracted and maintenance workers as well as part-time workers are included in risk assessment, workplace training and education, and prevention.
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- Council Directive 94/33/EC of 22 June 1994 on the protection of young people at work, OJ L 216/12, 20.8.94. Available at: 
- EU-OSHA – European Agency for Safety and Health at Work, Facts 69, Young Workers – Facts and Figures, 2007 Available at: 
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- Eurostat – European Commission. Migrants in Europe: A statistical portrait of the first and second generation, 2011 Edition, pp.1-155. Available at: 
- Eng, A., & Kelly, M. New and Expectant Mothers at Work – Guidelines for Health and Safety, Occupational Safety and Health Service, Department of Labour, 1998, Wellington, New Zealand.
- Council Directive 92/85/EEC of 19 October 1992 on the introduction of measures to encourage improvements in the safety and health at work of pregnant workers and workers who have recently given birth or are breastfeeding (tenth individual Directive within the meaning of Article 16 (10 of Directive 89/39/EEC)).Available at: 
- Council Directive 92/85/EEC, Communication on the Guidelines on the assessment of the chemical, physical and biological agents and industrial processes considered hazardous for the safety or health of pregnant works and works who have recently given birth or are breastfeeding, (COM(2000) 466 final/2, Brussels, 20.11.2000. Available at: 
- Council Directive 92/85EEC on the introduction of measures to encourage improvements in the safety and health at work of pregnant workers and workers who have recently given birth or who are breastfeeding, COM(2008) 637 final.  OJL 348. Available at:
- Council Recommendation 2003/134/EC of 18 February 2003 concerning the improvement of the protection of the health and safety at work of self-employed workers. Available at: 
- EU-European Union, Council Directive 2010/41/EU of the European Parliament and of the Council of 7 July 2010 on the application of the principle of equal treatment between men and women engaged in an activity in a self-employed capacity and repealing Council Directive 86/613/EEC.  OJL 359. Available at: 
- Griffiths, A., Knight, A., & nor Mohr Maudlin, D., Ageing, work-related stress and health – Reviewing the evidence, Report for Age Concern and Help the Aged and TAEN, 2009, pp.1-33. Available at: 
- Council Directive 89/391/EEC of 12 June 1989 on the introduction of measures to encourage improvements in the safety and health of workers at work.  OJL 183. Available at: 
- Directorate-General for Employment, Social Affairs and Inclusion, Eurobarometer, Special Eurobarometer 378, Active Ageing. 2012, pp.1 – 261. Available at: 
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- Return to work after cancer Available at: http://www.iosh.co.uk/returntowork
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- Knoche, K., Sochert, R., Houston, K.. Promoting healthy work for workers with chronic illness: A guide to good practice,’ European Network for Workplace Health Promotion (ENWHP), 2012 . Available at 
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- Council Directive 89/654/EEC of 30 November 1989 concerning the minimum safety and health requirements for the workplace.  OJL 393. Available at: 
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- Council Recommendation 2003/134/EC of 18 February 2003. concerning the improvement of the protection of the health and safety at work of self-employed workers. Available at: 
- Directive of the European Parliament and the Council on the working conditions for temporary workers. COM(2002) 701 final. Brussels, 28.11.2002. Available at: 
- Directive 2008/104/EC of the European Parliament and of the Council of 19 November 2008 on temporary agency work, [2008[ OJL 327/9.. Available at: 
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- Directorate-General for Internal Policies, employment and Social Affairs, ‘Occupational health and safety risks for the most vulnerable workers.- Executive Summary, 2011, pp. 1-135. Available at: 
Links to Further reading
EU-OSHA – European Agency for Safety and Health at Work. Gender issues in safety and health at work, Facts 42, 2003 Available at: 
EU-OSHA – European Agency for Safety and Health at Work, Including gender issues in risk assessment, Facts 43, 2003 Available at: 
EU-OSHA – European Agency for Safety and Health at Work, Health Promotion among young workers: A summary of good practice cases, Facts 101, 2011. Available at: 
EU-OSHA – European Agency for Safety and Health at Work, Promoting health and safety in European Small and Medium-sized Enterprises (SMEs), 2005, pp.1-100. Available at: 
Grandjean, P., Bellinger, D., Bergman, A., Cordier, S., Davey-Smith, G., Eskenazi, B., Gee, D., Gray, K., Hanson, M., van den Hazel, P., Heindel, J. J., Heinzow, B., Hertz-Picciotto, I. H., Hu, H., T-K Huang, T., Kold Jensen, T., Landrigan, P. J., McMillen, I. C., Murata, K., Ritz, B., Schoeters, G., Skakkebaek, N. E., Skerfving, S., & Weihe, P. ‘The Faroes Statement, Human Health Effects of Developmental Exposure to Chemicals in Our Environment.’ Basic & Clincal Pharmacology & Toxicology, 2007,pp.1742-7843. Available at: 
EU-OSHA – European Agency for Safety and Health at Work, – Ensuring the health and safety of workers with disabilities, Facts 53, 2004. Available at 
EU-OSHA – European Agency for Safety and Health at Work, – Young Workers – Facts and figures, Exposure to risks and health effects, Facts 70 (no date) . Available at:
EU-OSHA – European Agency for Safety and Health at Work, ‘Occupational safety and health and education: a whole-school approach.’ 2013, pp.1-102. Available at: