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

Labour Inspection Convention, 1947 (No. 81) - Lebanon (Ratification: 1962)

The Committee acknowledges the complexity of the situation prevailing on the ground, which impacts the effective functioning of institutions in the country.

Article 3(1) and (2) of the Convention. Primary functions and additional duties of labour inspectors. 1. Supervision of union matters. The Committee previously noted that, in accordance with section 2(c) of Decree No. 3273 of 26 June 2000, the labour inspectorate is vested with the authority to monitor vocational organizations and confederations at all levels in order to verify whether the latter, in their operations, are exceeding the limits prescribed by law and by their rules of procedure and statutes. The Committee takes note of the Government’s indication that the role of labour inspectors under Decree No. 3273/2000 is primarily focused on counselling and guidance. In this context, the Committee recalls its long-standing requests for the Government to take measures to limit the intervention of labour inspectors in the internal affairs of trade unions and confederations. It reiterates that, pursuant to Article 3(1) and (2) of the Convention, the primary functions of the labour inspection system shall be to monitor and secure the conditions of work and the protection of workers, and that any further duties which may be entrusted to labour inspectors shall not be such as to interfere with the effective discharge of their primary duties or to prejudice in any way the authority and impartiality which are necessary to inspectors in their relations with employers and workers. The Committee urges the Government to take the necessary measures in law and practice to ensure that additional functions entrusted to labour inspectors do not interfere with their primary duties, in accordance with Article 3(1) and (2) of the Convention. The Committee requests the Government to provide information on measures taken in this respect and further urges that any supervision of trade union activities by labour inspectors be strictly limited to protecting the rights of trade unions and their members, avoiding any interference in their legitimate activities and internal affairs.

2. Work permits for migrant workers. The Committee previously noted statistics indicating that a significant portion of the labour inspectorate’s activities focused on the issuance and renewal of work permits, as well as inspections related to such permits, as reported by the Government. The Committee also noted information provided by the ILO Decent Work Technical Support Team indicating that the system for monitoring work permits through the labour inspectorate has remained unchanged in its essence. The Committee urges the Government to take measures to ensure that the functions assigned to labour inspectors concerning work permits do not interfere with or compromise their primary mandate under the Convention. It requests the Government to provide information on the proportion of time spent by labour inspectors on activities related to the issuance, renewal, and inspection of work permits compared to the time spent on performing their primary duties, in accordance with Article 3(1) of Convention No. 81.

Article 12(1) and (2). Right of inspectors to enter freely any workplace liable to inspection. In its previous comments, the Committee noted that the Memorandum No. 68/2 of 2009 mandates written authorization for unscheduled inspection visits, although according to section 6 of Decree No. 3273 of 2000 on Labour Inspection, labour inspectors shall have the authority to enter freely and without prior notice all enterprises under their supervision during hours of work at the enterprise.

The Committee notes the Government’s indication that Memorandum No. 68/2 is intended to ensure oversight by providing information on inspectors’ whereabouts to the Central Inspection Body. While noting this information and in the interest of legal certainty, the Committee requests that the Governmentamend Memorandum No. 68/2 of 2009 or to take other necessary measures to ensure that labour inspectors, with proper credentials, are fully empowered to enter workplaces without prior authorization, in line with Article 12(1) of the Convention. The Committee requests the Government to provide information on the steps taken or envisaged to address this issue and to supply copies of relevant legislative or administrative texts reflecting progress.

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