Direct Request (CEACR) - adopted 2024, published 113rd ILC session (2025)

Promotional Framework for Occupational Safety and Health Convention, 2006 (No. 187) - Greece (Ratification: 2021)

The Committee notes the Government’s first report.

The Committee notes the observations of the Greek General Confederation of Labour (GSEE), received on 1 September 2023 and 27 August 2024.

Article 2(1) of the Convention. Promoting the continuous improvement of OSH by developing a national policy, national system and national programme. The Committee notes that Greece has a national policy on occupational safety and health (OSH) in the form of the National Strategy for OSH 2022–27 adopted in 2022 following consultations with the social partners, and a national OSH programme for 2024 as an annex to the Strategy. The Committee also notes that the Government has a national OSH system comprised of Act No. 3850/2010 on the ratification of the Code of laws on workers’ health and safety (Act No. 3850/2010) and a series of relevant Ministerial Decisions. The Committee notes that the National Strategy for OSH 2022–27 focuses on the continuous upgrading of working conditions and aims at meeting the new and inter-related challenges in the world of work. In its observations, the GSEE points to a lack of an integrated national OSH policy, functional infrastructure, and accountability within the national OSH policy and annual programmes. In this respect, it highlights a lack of prioritization of OSH issues by the Ministry of Labour and Social Security, inadequate functioning of the Ministry's tripartite bodies, insufficient staffing and infrastructure of the Labour Inspectorate with regards to OSH, as well as a dysfunctional and ineffective OSH system that prioritizes formal compliance over effective implementation. It indicates that these factors have contributed to OSH deficits involving endangerment of human life, especially affecting migrant workers in Greece, and it refers to a dramatic rise in accidents, as indicated by data received by its member Federation of Associations of Employees of Technical Enterprises of Greece (OSETEE). GSEE also indicates that the data underscores the need for stronger OSH policies, coordination, and preventive measures, including the prioritization of OSH in light of climate change and extreme weather conditions, to ensure the safety and well-being of workers in Greece. The Committee requests the Government to provide its comments in this respect.It requests the Government to provide information on the measures taken to address insufficient staffing of the Labour Inspectorate with regards to OSH. It requests the Government to continue to provide information on the measures taken to promote continuous improvement of OSH, in consultation with the most representative organizations of employers and workers.

Article 2(3). Measures that could be taken, in consultation with social partners, to ratify relevant OSH Conventions. The Committee notes the Government’s indication in its report that the Division on the Promotion of the Application of International Labour Standards of the Supreme Labour Council is responsible for discussing the possible ratification of ILO Conventions. The Committee requests the Government to indicate whether specific consideration has been given to measures that could be taken with respect to the OSH Conventions of the ILO and to provide information on the outcome of the consultations held with the social partners in this respect.

Article 4(1). Periodical review of a national OSH system in consultation with the social partners. The Committee notes the periodic amendments to Act No. 3850/2010, most recently in 2023. The Government indicates that during the period covered by the previous National OSH Policy 2016–20, the legislative framework was strengthened both by transposing European Union directives and by establishing specific national legislation, for example on individual protection measures for employees of local self-government agencies, and safety and health in the distribution and transport of goods. The Committee requests the Government to continue to provide information on the measures taken to periodically review the national OSH system, including institutional arrangements for this review, and on the outcome of the consultations held with the social partners in this regard.

Article 4(2)(c). Mechanisms for ensuring compliance with national laws and regulations relating to OSH, including systems of inspections. The Government indicates that the monitoring of application of legislation on OSH and the investigation of occupational accidents lies within the remit of OSH Inspectors of the new independent administrative authority, the Labour Inspectorate, established under Law 4808/2021. In its observations, the GSEE indicates that the implementation of the Convention is closely linked to the effectiveness and accountability of the Labour Inspectorate. In this respect it reiterates its observations previously submitted under the Labour Inspection Convention, 1947 (No. 81) indicating that the creation of an independent Labour Inspectorate separated from the Ministry of Labour and Social Security has led to disconnection in coordinating OSH policies, and the non-functioning of the tripartite social dialogue body, the Social Control Council of Labour Inspectorate (SKEEE). According to the GSEE, this situation impacts the implementation of the National Strategy for OSH 2022–27, many of whose actions remain unimplemented. With regards to other mechanisms for ensuring compliance with national laws, the GSEE states that the Government should indicate whether the Register of Delinquent Companies Providing Cleaning and/or Security Services is operative and advocates for the publication of its methodology and data and its extension to all types of contractual assignments. The Committee requests the Government to provide its comments in this respect. With regard to the operation of the new Labour Inspectorate, the Committee refers to its comments that it adopted in 2022 concerning the application of Convention No. 81, specifically with respect to Articles 3 and 4 (restructuring of the labour inspection system, organization and effective functioning of the system of labour inspection, supervision and control by a central authority) and Article 5(a) and (b) (cooperation between the inspection services and public institutions, collaboration with representatives of employers and workers).

Article 4(3)(b), (c) and (e). Information and advisory services on OSH, provision of OSH training and OSH research. The Government indicates that, as provided in Act No. 3850/2010, the Ministry of Labour and Social Security and the Labour Inspectorate, individually or jointly, may conclude programme agreements with the Hellenic Institute for OSH (ELINYAE) for the preparation of studies, field research, training programmes in enterprises, consultancy services to employers or other actions and programmes for the promotion of OSH. According to Act No. 3850/2010, ELINYAE also provides training of safety technicians, occupational doctors and workers' representatives. In its observations, the GSEE indicates that although ELINYAE has the primary responsibility for collecting and disseminating OSH knowledge in the country, it is underutilized, and its financial stability is affected by the absence of a signed programme agreement and the transformation of the Greek Employment Office (OAED) into the Public Employment Service (DYPA). The Committee requests the Government to provide its comments in this respect.It requests the Government to provide further information on the measures taken to ensure the provision of information and advisory services, OSH training and the undertaking of research on OSH.

Article 4(3)(f) and (g). Collection and analysis of data on occupational injuries and diseases. Collaboration with relevant insurance and social security schemes. The Government indicates that statistical data are collected by the Labour Inspectorate. The Committee recalls that under its comments on Convention No. 81, it noted that no information was available on the number of occupational diseases and industrial accidents. In this respect, the Government indicates that in order to facilitate the collection and processing of reliable statistical data, it envisages the development of an integrated mechanism for the notification and registration of occupational accidents and diseases, the upgrading of the Labour Inspectorate’s Integrated Information System, and the creation of the new Integrated Information System for OSH (HERIDANOS). In this context, it also foresees the creation of an Occupational Risk Insurance Agency, following GSEE’s proposal. In its observations, the GSEE highlights the need for a comprehensive system to report and record occupational health issues, pointing to a lack of a central structure charged with this function, underreporting, delays in accident reporting and investigations, and the exclusion of undeclared and migrant workers from official statistics. With regard to the Tempi train accident in February 2023, which resulted in at least 57 deaths and numerous injuries, the GSEE points to significant discrepancies between the official data from the Labour Inspectorate and the actual conditions observed. With regards to collaboration, the GSEE points to the absence of a coordinated data system connecting public authorities, indicating that labour and social security databases, the National Statistical Authority (ELSTAT) and the judiciary are not synchronised. The GSEE highlights the need to enhance the capacity of the Hellenic Statistical Authority to develop national statistics from a human rights perspective, including on incidents of sexual harassment and abuse. It also advocates for a National Research and Reporting Centre to identify harmful factors. The Committee requests the Government to provide its comments in this respect. In addition, referring to its comments under Convention No. 81, the Committee requests the Government to indicate the measures taken to enable the collection and analysis of data on occupational diseases, and to ensure the production and publication of annual statistics on both occupational accidents and diseases. The Committee requests the Government to continue to provide information on the measures taken to reinforce the application of procedures for the notification of occupational accidents and diseases by employers. In this respect, it requests the Government to provide information on the progress achieved in the development of the new integrated mechanism for the notification and registration of occupational accidents and diseases, the upgrading of the Labour Inspectorate’s Integrated Information System, the creation of the new Integrated Information System for OSH (HERIDANOS), as well as the creation of an Occupational Risk Insurance Agency. It requests the Government to provide information on measures taken or envisaged to enhance collaboration between the Labour Inspectorate and relevant insurance and social security schemes.

Article 5(1) and (2)(e). National OSH Programme. Complementary national programmes. The Committee notes that the annual National Programme for OSH 2022–23 is annexed to the National OSH Strategy 2022–27 and forms an integral part of it. It also notes that a new National Programme for OSH 2024, was added in a new Annex in 2023 and it notes the information provided regarding tripartite consultations on the preparation of the National Programmes. The Committee requests the Government to provide information on the implementation of the National Programme for OSH 2022–23 and the National Programme for OSH 2024, including the activities carried out and the results achieved within their frameworks. It also requests the Government to provide information on the consultations undertaken with the most representative organizations of employers and workers in the programmes’ implementation, monitoring and evaluation.

Article 5(3). Publicizing the national programme. The National Programme for OSH 2022–23 and the National Programme for OSH 2024 are available online, as integral parts of the National Strategy for OSH 2022–27 on the website of the Ministry of Labour and Social Security and the website of ΕLΙΝΥΑΕ. The Committee requests the Government to provide information regarding the manner in which the Government ensures that its national programmes are widely publicized, in accordance with Article 5(3) of the Convention.