Labour Inspection Convention, 1947 (No. 81) - Iceland (Ratification: 2009)

Direct Request (CEACR) - adopted 2021, published 110th ILC session (2022)

In order to provide a comprehensive view of the issues relating to the application of the ratified Conventions on labour inspection, the Committee considers it appropriate to examine Conventions Nos 81 (labour inspection) and 129 (labour inspection in agriculture) together.

Article 5 of Convention No. 81 and Article 12 of Convention No. 129. Effective cooperation between the inspection services and other Government services. The Committee notes the Government’s indication in its report that on 15 November 2019 the Administration of Occupational Safety and Health (AOSH) signed a cooperation agreement with the tax authorities, the Directorate of Labour and the Reykjavík Metropolitan Police to address undeclared work and social dumping. The Government also indicates that cooperation with the social partners on the matter is planned under a special agreement that is in the pipeline. The Committee requests the Government to provide information on the progress made in the implementation of the cooperation agreement between the AOSH and the public bodies to address undeclared work and social dumping.

Article 6 of Convention No. 81 and Article 8 of Convention No. 129. Status of labour inspectors. In its previous comments, the Committee noted the Government's statement that the level of wages of the AOSH, in comparison with other Government institutions, may influence the recruitment and retention of high-quality staff. The Committee notes the Government's indications in response to its previous request for information on the measures taken or envisaged to retain skilled and experienced staff that the AOSH has improved its human resources policy and has placed emphasis on improving the conditions of service of inspection staff. The Committee requests the Government to provide specific information on the measures taken to improve the status and conditions of service of labour inspectors. Furthermore, in order to ensure the stability of employment of labour inspectors, the Committee requests the Government to adopt the necessary measures to guarantee that the remuneration of labour inspectors is similar to that of other public officials with responsibilities of a similar category and complexity, and to provide details on these measures and illustrative figures in this respect, including comparative figures for categories of public officials identified as having similar responsibilities.

Article 7(3) of Convention No. 81 and Article 9(3) of Convention No. 129. Training of labour inspectors. With reference to its previous comments, the Committee notes the information provided by the Government on training provided to new labour inspectors at the AOSH. The Government indicates that the basic training programme takes place in the inspectors’ first and second year of service and covers topics such as occupational health and safety measures, inspection and inspection reports, chemical and biological hazards, indoor air quality, noise, vibration and lighting, and personal protective equipment. With regard to the training provided to new labour inspectors, the Government indicates that a new training programme was adopted in 2016, in which trainees are instructed on the role of the AOSH, its structure and activities, occupational safety and health aspects, legislation and procedural rules. The Government further indicates that inspection visits are made to enterprises where the new inspectors are guided and taught by specialists and experienced inspectors. Subsequent to the initial round of training sessions, the Government indicates that planning days, workshops, and meetings are held with some regularity and these include training on additional aspects of the job. The Committee notes, however, that the Government does not indicate whether the introductory training or the basic training held by the AOSH contain content relevant to inspections in agriculture. The Committee therefore requests the Government to take the necessary measures to ensure that labour inspectors in agriculture receive adequate training for the performance of their duties (such as on risks in livestock farming or the handling of chemicals and pesticides) and to provide information on the results obtained in this respect, including the number of labour inspectors trained, the subjects covered and the impact of the training.

Articles 10 and 16 of Convention No. 81 and Articles 14 and 21 of Convention No. 129. Number of labour inspectors and inspection visits. In its previous comments, the Committee requested the Government to provide information on the measures taken to ensure that the number of labour inspectors is sufficient to secure the effective performance of inspections functions. The Committee notes the Government's indication that there are 13 labour inspectors in the country, mainly in the capital area, and that there is one vacant position that will be filled in autumn 2021. The Government also reports that there are 0.6 labour inspectors per 10,000 employees, and that it is aware of the need to increase the number of labour inspectors. The Committee requests the Government to pursue its efforts to ensure that the number of labour inspectors, including in agriculture, is sufficient to secure the effective discharge of the duties of the inspectorate and that workplaces are inspected as often and as thoroughly as necessary. It also requests the Government to provide detailed information on the measures taken and the results achieved, including the number of labour inspectors and their distribution by region, as well as the number of inspections visits carried out.

Article 12 of Convention No. 81 and Article 16 of Convention No. 129. Right of inspectors to enter freely and without previous notice and notification of the inspector’s presence when carrying out an inspection. Further to its previous comments, the Committee notes the Government's reference to the amendment of section 82, paragraph 1 of the Act on Working Environment, Health and Safety in Workplaces No. 46/1980 by Act No. 80/2015. The Committee notes that this amendment establishes that AOSH staff shall make inspection visits to enterprises to carry out their inspection functions, and that they shall be granted access to the enterprises’ workplaces for this purpose. This section further provides that, in their inspection visits, AOSH staff shall contact the employer or his representative and the parties involved in work safety in enterprises. The Committee notes, however, that while section 82 provides for the obligation to grant access to AOSH personnel to workplaces, it does not provide for their entrance without previous notice at any hour of the day or night. In addition, it notes that section 82 establishes the obligation of AOSH personnel to contact the employer or his/her representative during their inspection visits. In this respect, in its 2006 General Survey, Labour inspection, paragraph 78, the Committee indicates that unannounced visits enable the inspector to enter the inspected premises without warning the employer or his representative in advance, especially in cases where the employer may be expected to attempt to conceal a violation, by changing the usual conditions of work, preventing a witness from being present or making it impossible to carry out an inspection. The Committee requests the Government to continue its efforts to ensure that inspectors can carry out unannounced visits in accordance with Article 12(1)(a) of the Convention, including through appropriate legislative change if necessary. It further requests the Government to ensure that, pursuant to current law or a modification thereof, inspectors notify the employer or his representative on the occasion of an inspection visit, unless they consider that such notification may be prejudicial to the performance of their duties, as required by Article 12(2) of the Convention. The Committee requests the Government to provide information on progress made in these respects.

Article 13 of Convention No. 81 and Article 18 of Convention No. 129. Measures with immediate executory force in the event of imminent danger to the health or safety of the workers. The Committee notes the information provided by the Government, in response to its previous request for statistical information on preventive action taken by labour inspectors, that coercive measures including the prohibition of work and the use of equipment were used in 132 cases in 2015. The Government indicates that this was twice as many cases as in 2014 and explains that the increase was mainly due to the adoption of stricter inspection methods in the construction industry and the monitoring of machinery and equipment. The Committee further notes that, according to the information provided by the Government, the sectors in which the most coercive measures were applied in 2015 include construction and building repairs with 68 measures, schools with 14 measures, fishing industry, freezing plants and processing factories with 12 measures, metallurgy, machinery production, shipbuilding and ship repairs with 6 measures and wood industries with 5 measures. The Committee requests the Government to continue to provide information on the preventive measures taken by labour inspectors per year with a view to remedying defects observed in plant, layout or working methods, including the number of orders issued with immediate executory force in the event of imminent danger to the health or safety of the workers and the sectors in which such orders were issued.

Article 14 of Convention No. 81 and Article 19 of Convention No.129. Recording and notification of industrial accidents and cases of occupational disease. Further to its previous comments, the Committee notes that the Government indicates that section 79 of the Act on Working Environment, Health and Safety in Workplaces provides that the employer shall report to the AOSH: (i) without undue delay, all accidents in which a worker dies or becomes incapable to work for one day or more in addition to the day on which the accident occurred, (ii) within 24 hours an accident in which it is likely that a worker has incurred long-term or permanent damage to his health. This section also provides that a physician who finds out, or suspects, that a worker or a group of workers have an occupational disease, a work-related disease, or have been exposed to harmful influences as a result of their jobs, shall report this to the AOSH without undue delay. Taking due note of the indications provided by the Government, the Committee requests the Government to provide information on the number of industrial accidents and cases of occupational disease duly notified to the labour inspectorate per year and the causes related to these events.

Article 19 of Convention No. 81 and Article 25 of Convention No. 129. Periodical reports. With reference to its previous comments, the Committee notes the Government's indication that, according to the changes in the organisational chart for the AOSH that took effect on 1 January 2017, district and regions were abolished, which means that labour inspection is now fully centralised. The Committee takes note of this information, which addresses its previous request.

Articles 20 and 21 of Convention No. 81 and Articles 26 and 27 of Convention No. 129. Publication and content of the annual report. The Committee notes that the 2020 AOSH annual report, published on the AOSH website, contains information on labour inspection service staff, inspections visits and industrial accidents. However, it notes that this report does not contain information on a number of subjects required under Article 21 of Convention No. 81 and Article 27 of Convention No. 129, including laws and regulations relevant to the work of the inspection service, statistics of workplaces liable to inspection and the number of workers employed therein, statistics of violations and penalties imposed and statistics of occupational diseases. The Committee requests the Government to take the measures necessary to ensure that annual reports on the activities of the labour inspection services contain information on each of the subjects set out in Article 21 of Convention No. 81 and Article 27 of Convention No. 129, including with reference to statistics on violations and penalties imposed pursuant to Articles 17 and 18 of Convention No. 81 and Articles 22, 23 and 24 of Convention No. 129, and that the annual reports be transmitted to the ILO in accordance with Article 20(3) of Convention No. 81 and Article 26(3) of Convention No. 129.

Matters specifically relating to labour inspection in agriculture

Article 15 of Convention No. 129. Transport facilities and reimbursement of professional travel expenses. The Committee notes the information provided by the Government on the adoption of Government Advertisement No. 3/2015 on driving charges for government employees (applicable when government employees drive their own vehicles in the performance of their duties) and Government Advertisement No. 2/2016 on domestic travel allowances for government employees, following the repeal of Decree No. 1/2013 and Decree No. 3/2013. In this regard, it notes that Government Advertisement No. 3/2015 determines a travel fee in travel agreements between government employees and government agencies. It also notes that the Government Advertisement No. 2/2016 establishes per diem allowances for the payment of accommodation and subsistence for government employees on domestic travel on behalf of the State. It also notes that Rule No. 1/2009 on payment of travel expenses for travel on behalf of the Government includes the reimbursement of travel, food and accommodations expenses (sections 2 and 3). The Committee takes note of this information, which addresses its previous request.

Article 17 of Convention No. 129. Preventive control. With reference to its previous comments on the role of labour inspectors in the preventive control of protective chemical substances, rodent poisons and insecticides, the Committee notes that the Government indicates that prior to licensing and when renewed, pesticide storage facilities are inspected by the AOSH, and that machinery used to disperse the pesticides is inspected annually by the AOSH. The Committee requests the Government to provide information on the preventive measures taken by the labour inspection services to control protective chemical substances, rodent poisons and insecticides, including the number of inspections of pesticide storage facilities and of machinery used to disperse pesticides, and the results of such inspections.

Direct Request (CEACR) - adopted 2014, published 104th ILC session (2015)

Article 6 of the Convention. Status of labour inspectors. The Committee previously noted that inspection staff members are government employees that enjoy the rights stipulated under the Government Employees Act No. 70/1996. The Committee notes the Government’s statement that, with regard to career prospects, labour inspectors have the prospect of rising through the ranks within the Administration of Occupational Safety and Health (AOSH) as, for example, managers either within the regions or in the specialized departments of the institution. It also notes that both labour inspectors who hold a university degree and those with technical or vocational education have, on average, lower rates of pay than other comparable government employees. The Government also indicates that a survey conducted by the Union of Public Servants indicated that the employees of AOSH scored the lowest of all government institutions regarding satisfaction with their wages. The Government states that the wages at AOSH in comparison with other government institutions may influence the recruitment and retention of high-quality staff. The Committee accordingly requests the Government to provide information on any measures taken or envisaged to retain skilled and experienced staff, including measures to guarantee labour inspectors with conditions of service at least equivalent to those of other public officials with comparable duties and responsibilities.

Article 7(3). Training for labour inspectors. The Committee previously noted that newly engaged labour inspectors at the AOSH attend a six-week training programme and that a mandatory regular training programme is held annually. The Committee notes the reference in the Government’s report to a copy of the training programme for new labour inspectors and the agenda for the last regular training programmes, but observes that these are not attached to the Government’s report. The Committee therefore requests that the Government provide detailed information on the regular training provided, as well as the training provided to new labour inspectors at the AOSH, including the subjects, attendance and impact of these training activities.

Articles 10 and 16. Number of labour inspectors and inspection visits. The Committee notes from the information in the Government’s report that there are 11 labour inspector positions, which represents a 25 per cent reduction in capacity compared with the years prior to the economic crisis in 2008. The Government indicates that there are now four inspection regions, which are large geographically, and that the capacity in these regions is low. The Government further indicates that there is approximately one labour inspector per 15,900 employees, and that there is a need to increase the number of labour inspectors. In this regard the Committee notes that the number of inspections undertaken in 2013 was 1,973, a significant decrease from the 2,936 inspections undertaken in 2008. The Committee accordingly requests the Government to provide information on the measures taken to ensure that the number of labour inspectors is sufficient to secure the effective discharge of the duties of the inspectorate, including that workplaces are inspected as often and as thoroughly as necessary. It requests the Government to continue to provide information on the number of labour inspectors and distribution by region.

Article 12. Right of inspectors to enter workplaces freely and without previous notice and notification of the inspector’s presence when carrying out an inspection. With reference to its previous comments, the Committee notes the Government’s statement that section 82 of the Act on Working Environment, Health and Safety in Workplaces is not in conformity with Article 12(1)(a) and (2) of the Convention. The Government indicates that the Minister of Social Affairs and Housing has appointed a committee assigned with the task of formulating proposals for employment and occupational health policy, and that the comments of this Committee with respect to Article 12 will be forwarded to that committee for consideration. The Committee urges the Government to pursue its efforts to ensure that labour inspectors are authorized to enter without previous notice all workplaces liable to inspection and to carry out inspections without notifying the employer of their presence, in conformity with Article 12 of the Convention. It requests the Government to continue to provide information on progress made in this regard.

Article 13. Measures with immediate executory force in the event of imminent danger to the health or safety of the workers. The Committee notes the Government’s statement that section 85 of the Act on Working Environment, Health and Safety in Workplaces empowers labour inspectors, in situations where they consider that there is considerable danger to the life or health of employees or others, to demand immediate action be taken by the employer to improve the lack of security in the workplace, and they can stop the part of the operations in question. The Committee requests that the Government provide statistical information on the preventive action taken by labour inspectors with a view to remedying defects observed in plant, layout or working methods in line with Article 13 of the Convention, including the number of demands made with immediate executory force in the event of imminent danger to the health or safety of the workers.

Article 14. Recording and notification of industrial accidents and cases of occupational disease. The Committee previously noted that, according to section 79 of the Act on Working Environment, Health and Safety in Workplaces, employers must notify the AOSH of accidents within one week of their occurrence. The Committee reminded the Government that employers should record industrial accidents and occupational diseases by the quickest practicable means so that labour inspectors or the competent authority can carry out investigations and take the necessary action to prevent a recurrence. The Committee notes the Government’s statement that it has decided to undertake a comprehensive revision of the Act on Working Environment, Health and Safety in Workplaces. The Government indicates that, in this work, it will take into account the Committee’s comments concerning section 79 of the Act. The Committee requests that the Government pursue its efforts so that employers notify of occupational accidents, by the quickest practicable means so as to enable labour inspectors or the competent authority to conduct investigations and take action to prevent a recurrence if necessary. In this regard, it encourages the Government to take into account the guidance provided in paragraphs 6.1.4, 10.1.6 and 10.2.8 of the ILO code of practice on the recording and notification of occupational accidents and diseases.

Article 15(b). Compliance by labour inspectors with the obligation of maintaining manufacturing or commercial secrets. The Committee notes the Government’s statement that section 18 of the Government Employees Act, No. 70/1996, covers the requirements of Article 15(b) of the Convention concerning the obligation of labour inspectors to maintain manufacturing or commercial secrets. It notes that section 18 of the Act states that each employee (anyone who is hired into service of the government for a period exceeding one month) is obliged to observe confidentiality in regard to matters of which he/she gains knowledge in his/her work and that is regarded as confidential according to law, the instructions of superiors or by the nature of the matter. Section 18 further states that the obligation of confidentiality remains even if the employee concerned leaves his/her employment.

Article 19. Periodical reports. The Committee notes the Government’s statement that local inspection offices in the districts submit annual reports prescribed by the central authority. The Government indicates that these reports describe all main activities during the past year and the results of inspections for every district. In addition, the districts continuously register inspection activities in the AOSH’s database. The Committee requests that the Government provide examples, with its next report, of the periodical reports submitted to the central inspection authority by local inspection offices in the districts.

Articles 20 and 21. Publication and content of the annual report. The Committee notes the annual report of the AOSH of 2013, published on the AOSH website, which includes information on the laws and regulations relevant to the work of the inspection service, the number of staff, statistics of inspection visits and penalties imposed as well as data on occupational accidents and diseases. The Committee encourages the Government to ensure that the annual report of the AOSH is communicated to the ILO, in conformity with Article 20(3) of the Convention. It also requests that the Government take the necessary measures to ensure that, in future, this report contains information on the number of workplaces liable to inspection and the number of workers employed therein, in conformity with Article 21(c) of the Convention.

Direct Request (CEACR) - adopted 2012, published 102nd ILC session (2013)

The Committee notes the Government’s first report under the Convention.

Article 5(a) of the Convention. Cooperation between the inspection services and other government services. The Committee notes from the Government’s first report that, pursuant to Article 51 (a) of the Act on Working Environment, Health and Safety in Workplaces, No. 46/1980, the Administration of Occupational Safety and Health (AOSH) participates in the consultative committee on preventive measures against major industrial accidents. The Committee would be grateful if the Government would keep the ILO informed on the activities of the consultative committee and their impact on the labour inspection system. Please indicate any other areas of cooperation between the AOSH and public or private institutions engaged in similar activities as well as the justice system.

Article 5(b). Collaboration of the labour inspection with employers and workers and their organizations in the area of OSH. The Committee notes from the Government’s first report that the AOSH cooperates with organizations of employers and workers through the Icelandic Rehabilitation Fund and the Focal Group on OSH. The Committee also notes that, according to Articles 4, 5 and 6 of the Act on Working Environment, Health and Safety in Workplaces, No. 46/1980, trade union and safety representatives should collaborate with employers to promote health and safety at the workplace. The Committee would be grateful if the Government would provide more detailed information on the cooperation between the AOSH and organizations of employers and workers, as well as on any other collaboration of trade unions and safety representatives with labour inspectors at the enterprise level.

Article 6. Status of labour inspectors. The Committee notes that, according to the Government’s first report, inspection staff members are government employees that enjoy the rights stipulated under the Government Employees Act No. 70/1996. There are no provisions established for them specifically. With reference to paragraph 204 of the 2006 General Survey on labour inspection, the Committee wishes to emphasize that it is vital that the status, levels of remuneration and career prospects of inspectors be such that they reflect the complexity and socio-economic importance of their duties so that high quality staff are attracted, retained, and protected from any improper influence. The Committee requests the Government to specify the conditions of service of labour inspectors and in particular, wages and career prospects in relation to other types of public officials performing similar duties (e.g. social security and tax inspectors).

Article 7(3). Training for labour inspectors. The Committee notes that, according to the Government’s first report, all newly engaged labour inspectors at the AOSH attend a six-week training programme that includes law and regulations on labour inspection, introduction of working procedures, practical lessons and inspection visits with experienced supervisors. The Government also reports that a regular training programme is held every year and participation is mandatory for all labour inspectors. The Committee would be grateful if the Government would provide detailed information on the subjects, attendance, frequency and impact of training activities provided to labour inspectors upon their entry into service and in the course of employment to enable them to acquire the technical knowledge required for the performance of their duties.

Articles 10 and 16. Number of labour inspectors and inspection visits. The Committee notes that, according to the Government’s report, there are around ten labour inspectors, and that in the last 2–3 years, there has been a reduction of 33 per cent of the capacity of the labour inspection system. The Committee also notes that the inspection districts are seven, quite large and distant geographically, and that there is less than one full-time post of labour inspector per district outside the capital. Furthermore, the Government reports that inspectors in the capital area have more expertise in specific areas and assist with inspections in some of the rural districts. The Committee recalls that according to Article 10 of the Convention, the number of labour inspectors should be sufficient to secure the effective discharge of the duties of the inspectorate in light of the number of workplaces liable to inspection, the number of workers employed therein, the number and complexity of the legal provisions to be enforced as well as the material means placed at the disposal of the inspectors and the practical conditions under which visits of inspection must be carried out in order to be effective. The Committee would be grateful if the Government would provide an evaluation of the needs of the labour inspectorate in human resources in light of the criteria provided in Article 10 of the Convention and indicate the measures taken or envisaged to ensure that workplaces are inspected as often and as thoroughly as necessary as established under Article 16 of the Convention. The Committee also requests the Government to provide more information on the distribution of labour inspectors by region, category and level of qualification.

Article 12. Right of inspectors to enter workplaces freely and without previous notice and notification of the inspector’s presence when carrying out an inspection. The Committee notes that, pursuant to Article 82 of the Act on Working Environment, Health and Safety in Workplaces, No. 46/1980, staff of the AOSH shall contact the employer or his representative and the parties involved in safety at work within the enterprises during inspections, and they shall provide all necessary information concerning the inspection. The Government also reports that the method of inspection, which has been in use since 2007 in enterprises with 30 employees or more, provides that the workplace is always informed of an upcoming visit from the inspectors. The Committee reminds the Government that, according to Article 12(1)(a) of the Convention, labour inspectors should be empowered to enter freely and without previous notice at any hour of the day or night any workplace liable to inspection. Furthermore, Article 12(2) of the Convention provides that 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. The Committee requests the Government to take the necessary measures in order to bring the law and practice into conformity with the requirements of the Convention in this regard, so that labour inspectors are authorized to enter without previous notice all workplaces liable to inspection and carry out inspections without notifying their presence. The Committee requests the Government to inform the Office of all developments in this regard.

Articles 13, 17 and 18. Enforcement measures. The Committee notes that, pursuant to Article 84 of the Act on Working Environment, Health and Safety in Workplaces, No. 46/1980, if the AOSH has claimed with due notice that improvements should be carried out on defective conditions and which can be classified as infringement of this Act or the regulations and announcements which have been issued in accordance with this Act, and these improvements have not been carried out when that time limit has passed, the AOSH can have the operations stopped and close the enterprise or the part thereof at which the claim is aimed.

With reference to paragraphs 106 and 107 of the 2006 General Survey, the Committee wishes to emphasize that the intention of Article 13 of the Convention is to empower labour inspectors to take preventive measures with a view to remedying defects observed in plant, layout or working methods which they have reasonable cause to believe constitute a threat to the health and safety of the workers. The provisions of this Article are not intended to punish employers responsible for violations, but to ensure the elimination of the causes of risks with a view to minimizing risks. In case where an infringement of the Act is observed or where an employer fails to comply with measures ordered on the occasion of an inspection, in accordance with Article 13, the labour inspector should be empowered to make use of Article 17, which involves such measures as prompt legal proceedings without previous warning or, where appropriate, warnings and advice. The Committee emphasizes in this regard that routine inspections are indispensable to give full effect to Article 13, which would avoid or reduce the need to make use of the powers provided for in Article 17. The Committee would be grateful if the Government would provide information and data on the preventive action taken by the labour inspectorate with a view to remedying defects observed in plant, layout or working methods in the area of OSH in line with Article 13 of the Convention including the number of measures with immediate executory force taken during the reporting period in the event of imminent danger to the health or safety of the workers. The Committee also requests the Government to specify the number of legal proceedings instituted against persons who violated legal provisions enforceable by labour inspectors, as well as the penalties applicable for labour law violations and to provide relevant information on their actual enforcement (Articles 17 and 18 of the Convention).

Article 14. Recording and notification of industrial accidents and cases of occupational disease. The Committee notes that, according to Article 79 of the Act on Working Environment, Health and Safety in Workplaces, No. 46/1980, the employer must notify the AOSH of accidents within one week. With reference to paragraphs 6.1.4, 10.1.6 and 10.2.8 of the ILO code of practice on the recording and notification of occupational accidents and diseases, the Committee reminds the Government that for inspection purposes employers should record industrial accidents and occupational diseases by the quickest practicable means so that labour inspectors or the competent authority can carry out investigations and take the necessary action to prevent a recurrence. Therefore, the Committee would be grateful if the Government would take the necessary measures to reduce the timing of notification established under Article 79 of the Act on Working Environment, Health and Safety in Workplaces, No. 46/1980, to the quickest practicable means to enable labour inspectors or the competent authority to conduct investigations and take action to prevent a recurrence if necessary.

Article 15. Compliance by labour inspectors with the obligations of maintaining manufacturing or commercial secrets. The Committee notes that Article 83 of the the Act on Working Environment, Health and Safety in Workplaces, No. 46/1980 does not cover the requirements of Article 15(a) and (b) of the Convention concerning the obligation of labour inspectors not to have any direct or indirect interest in the undertakings under their supervision and to maintain manufacturing or commercial secrets. The Committee requests the Government to take the necessary measures to bring the law and practice into conformity with the requirements of the Convention in this respect.

Articles 19, 20 and 21. Periodical reports and publication and communication of an annual report on the work of the inspection services. The Committee notes from the Government’s report that local inspection offices in the districts submit annual reports prescribed by the central authority. The Government specifies that these reports describe all main activities during the past year and results of inspections for every district. Apart from this, the districts make continuous registration of inspection activities in the administration’s corporate database. The Committee recalls that the obligation of labour inspectors or local inspection offices to submit to the central inspection authority periodical reports is provided in Article 19 of the Convention. Furthermore, under Article 20 of the Convention, the central authority has the obligation to publish and send to the ILO a consolidated annual general report containing the information required in each clause of Article 21(a)–(g). Referring to its 2010 General Observation on Articles 20 and 21 of the Convention, the Committee recalls the interest of publishing all the information required by Article 21 of the Convention in an annual inspection report so that it may reflect as faithfully as possible the scope, coverage and effectiveness of the labour inspectorate, and allow for the elaboration of accurate impact analyses and needs assessments in relation to human and material resources, with a view to the progressive improvement of the functioning of the labour inspection system. The Committee would be grateful if the Government would provide sample copies of the reports of local inspection offices, which were not attached to the report, and to indicate the measures taken or envisaged so that the central authority can publish and communicate to the ILO a consolidated annual report in line with Article 20 of the Convention containing all the information required in each clause of Article 21(a)–(g).

Article 26. Role of competent authority in identifying undertakings liable to inspection. The Committee notes from the Government’s report that no decisions have been made in relation to this Article. The Committee requests the Government to inform the Office of any developments in this regard.