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

Lebanon

Radiation Protection Convention, 1960 (No. 115) (Ratification: 1977)
Occupational Cancer Convention, 1974 (No. 139) (Ratification: 2000)
Chemicals Convention, 1990 (No. 170) (Ratification: 2006)
Prevention of Major Industrial Accidents Convention, 1993 (No. 174) (Ratification: 2005)

In order to provide a comprehensive view of the issues relating to the application of ratified Conventions on occupational safety and health (OSH), the Committee considers it appropriate to examine Conventions Nos 115 (radiation protection), 139 (occupational cancer), 170 (chemicals) and 174 (prevention of major industrial accidents) together.

Impact of conflict on the safety and health of workers. The Committee notes the statement in the Government’s report that ongoing military aggression by Israel has seriously undermined the fundamental principle and right of a safe and healthy working environment, and that this has had grave repercussions for workers, employers and the labour market. The Government refers in this respect to the impact of attacks on civilians and workplaces, including hospitals and medical facilities, the destruction of socio-economic infrastructure, and the use of phosphorus and incendiary bombs on agricultural land. The Government indicates that as a result, thousands of workers and employers have been adversely affected, with a particularly negative impact on migrant workers. The Government also refers to the detonation of pagers and walkie-talkies in September 2024, stating that this impacted thousands of Lebanese civilians working in the vicinity of the explosions. The Government states that these explosions resulted in 32 deaths and injuries to 3,250 persons, including critical injuries to their faces, eyes, hands and bodies.

The Committee recalls that all workers have a right to a safe and healthy working environment. Noting with deep concern the impact on the safety and health of workers of the complex situation in the country, it urges that all necessary measures, as are possible, be taken to protect the safety and health of workers.

Protection against specific risks

Radiation Protection Convention, 1960 (No. 115)

Articles 3(1) and 6 of the Convention. All appropriate steps to ensure the effective protection of workers, in the light of available knowledge and maximum permissible doses of ionizing radiation. 1. Lens of the eye. Following its previous comments on this matter, the Committee notes that the Government did not indicate in its report whether it has revised table 2 of Decree No. 11802 of 2004, regarding the organization of prevention, safety and professional hygiene, which sets the dose limit to the lens of the eye as 150 mSv per year. With reference to paragraph 32 of its 2015 general observation on the application of Convention No. 115, the Committee once again requests the Government to take measures to ensure that the dose limits to the lens of the eye are set at 20 mSv per year, averaged over defined periods of five years, with no single year exceeding 50 mSv per year.

2. Protection for pregnant and breastfeeding workers. In the absence of information on any developments in this regard, the Committee refers to paragraph 33 of its 2015 general observation on the application of Convention No. 115 and urges the Government to take measures to establish the maximum permissible dose for workers who are pregnant or breastfeeding.

Articles 6(1), 7(1) and (2), and 8. Dose limits for persons between 16 and 18 years. Following its previous comments on this issue, the Committee notes that the Government has not provided information on any legislative developments fixing specific dose limits for workers engaged in radiation work between the ages of 16 and 18, which is allowed pursuant to Annex 2 of Decree No. 8987 of 2012. The Committee once again refers to its 2015 general observation on the application of Convention No. 115, recalling that, for occupational exposure of apprentices aged 16 to 18 years of age who are being trained for employment involving radiation and for exposure of students aged 16 to 18 who use sources in the course of their studies, the dose limits are: (i) an effective dose of 6 mSv in a year; (ii) an equivalent dose to the lens of the eye of 20 mSv in a year; and (iii) an equivalent dose to the extremities (hands and feet) or to the skin of 150 mSv in a year. The Committee urges the Government to take the necessary measures to ensure that specific dose levels are fixed for workers between the ages of 16 and 18 engaged in radiation work. The Committee requests the Government to provide information on the progress made in this regard.

Occupational Cancer Convention, 1974 (No. 139)

Article 2 of the Convention. Replacement of carcinogenic substances and agents by non-carcinogenic substances and agents. Limiting the number of workers exposed to carcinogenic substances. Following its previous comments on this matter, the Committee notes the Government’s indication that the Ministry of Public Health has launched the National Cancer Control Plan 2023–28, which includes awareness-raising about occupational hazards and cancer, and the drafting or amendment of regulations to limit exposure for individuals at risk. The Committee requests the Government to provide information on any legislative developments in this regard, including on any legislation requiring carcinogenic substances and agents to which workers may be exposed in the course of their work to be replaced by non-carcinogenic substances or agents or by less harmful substances or agents.Taking note of the Government’s indication that no additional measures have been taken in this regard, the Committee also requests the Government to take measures to ensure that the number of workers exposed to carcinogenic substances or agents and the duration and degree of such exposure shall be reduced to the minimum compatible with safety.

Article 5. Medical examinations. The Committee notes the Government’s indication that, in the absence of a national OSH Committee, no measures have been considered for identifying hazardous substances that cause occupational cancer. Therefore, the Committee once again urges the Government to take the necessary measures to ensure that workers are provided with medical examinations during the period of employment and thereafter as necessary, in order to evaluate their exposure and supervise their state of health in relation to the occupational hazards.

Chemicals Convention, 1990 (No. 170)

Articles 3 and 4 of the Convention. Consultations with the most representative organizations of employers and workers on the application of the Convention and the formulation, implementation and periodical review of a coherent policy on safety in the use of chemicals at work. Following its previous comments, the Committee notes with concern the Government’s statement that it has not formulated a policy on safety and health in the use of chemicals. The Committee recalls that, in accordance with Article 4, in the light of national conditions and practice and in consultation with the most representative organizations of employers and workers, each Member shall formulate, implement and periodically review a coherent policy on safety in the use of chemicals at work. The Committee requests the Government to take the necessary measures toformulate, implement and periodically review a coherent policy on safety in the use of chemicals at work, in consultation with the most representative organizations of employers and workers. The Committee recalls that the Government may avail itself of ILO technical assistance in this regard.

Prevention of Major Industrial Accidents Convention, 1993 (No. 174)

Article 4 of the Convention. Coherent national policy concerning the protection of workers, the public and the environment against the risk of major accidents. Following its previous comments requesting the Government to take measures to give effect to this Convention in consultation with the most representative organizations of employers and workers, the Committee recalls with deep concern that on 4 August 2020, a stockpile of ammonium nitrate stored in a port warehouse in Beirut exploded, killing more than 200 people and wounding more than 7,000 according to statistics from the Office of the United Nations High Commissioner for Human Rights. The Committee recalls that, in accordance with Article 3 of the Convention, a major hazard installation covers installations that store hazardous substances or categories of substances in quantities which exceed the threshold quantity. In this respect, the Committee notes with regret that the Government has, once again, not provided information on any specific measures taken to formulate, implement and periodically review a coherent national policy concerning the protection of workers, the public and the environment against the risk of major accidents, in accordance with Article 4 of the Convention. The Committee notes that in the context of the joint ILO–UNITAR project “Implementation of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), preventing chemical accidents and strengthening occupational safety and health”, implemented in 2021–22, a national OSH profile and draft national OSH policy have been prepared for Lebanon. The Committee urges the Government to take the necessary measures as a matter of urgency, in consultation with the most representative organizations of employers and workers, to formulate, implement and periodically review a coherent national policy concerning the protection of workers, the public and the environment against the risk of major accidents and to ensure a full application of the Convention in the near future. The Committee requests the Government to provide detailed information on the measures taken and the progress made in this regard.

The Committee is raising other matters in a request addressed directly to the Government.