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

Labour Inspection Convention, 1947 (No. 81) - Pakistan (Ratification: 1953)

Labour law review. The Committee notes that an effort is currently underway to consolidate laws related to labour issues in the provinces of the Islamabad Capital Territory (ICT), Punjab and Sindh. In this respect, it notes that draft Labour Codes have been developed for Punjab and Sindh through the support of the ILO in close collaboration with the provincial Departments of Labour and in consultation with the social partners and are in the process of tripartite consultation. The Committee requests the Government to continue to provide information on the progress made in the review of the national labour legislation, and to supply a copy of the relevant legislative texts, once they have been adopted and indicate how they give effect to the articles of the Convention.

Article 3(1)(a) and (b) of the Convention. 1. Labour inspection and occupational safety and health (OSH). The Committee notes the Government’s indication in its report that the Department of Labour of ICT has requested the assistance of the ILO in developing industry-specific OSH protocols. Regarding Punjab, the Committee notes that the process of establishing an OSH council under the Punjab OSH Act 2019 is currently underway. According to the Government, the council will play a pivotal role in formulating rules that will govern safety audits, risk assessments, and other crucial OSH measures. Regarding Khyber Pakhtunkhwa (KPK), the Committee previously noted that the Department of Labour in KPK envisages the establishment of an OSH centre to carry out OSH inspections. The Government indicates that, while the development of implementing rules under the KPK OSH Act is ongoing, the province is currently relying on the KPK Factories Act 2023 for OSH inspections. The Committee notes that in 2022 there were no OSH inspectors under the Departments of Labour in Punjab, Sindh and ICT. The Committee requests the Government to continue to provide information on the progress made in establishing the OSH legislative framework under which OSH inspections are carried out. It requests the Government to provide copies of relevant OSH protocols in the ICT and of the implementing rules for KPK once they have been adopted.Noting the low number of OSH inspectors in the country, the Committee requests the Government to indicate the measures taken to increase the number of inspectors responsible for overseeing the application of OSH legislation and to provide information on the number of OSH inspections carried out.

2. Private auditing firms. The Committee notes the Government’s indication that currently no private auditing firms are engaged in conducting OSH audits in ICT. The Committee takes note of this information which addresses its previous request.

Article 7. Qualifications and training. In its previous comments the Committee noted that in Punjab, discussions are ongoing to establish rules specifying the qualifications for labour inspectors. The Department of Labour in Balochistan, with technical support from the ILO, has undertaken and will continue to conduct various training programs for labour inspectors which focus inter alia on specific legislation, OSH, child labour and forced labour. The Government indicates that, in Sindh, there are frequent training sessions for inspectors, while in the ICT, a critical need for improving officials’ knowledge on OSH has been identified and the Government has requested the ILO’s assistance in organizing trainings. The Government points to a general need for strengthening OSH capacity building for inspectors nationwide and for increasing collaboration between the federal and provincial governments to share best practices and resources. The Committee requests the Government to continue to pursue its efforts to ensure that inspectors receive adequate training for the performance of their duties and to provide more specific information on the content, frequency and duration of the training given to inspectors, as well as the number of participants. Noting the absence of information in this respect, the Committee requests once again the Government to indicate whether the Government of Punjab continues admitting officers into the Department of Labour from other departments of the district administration and the district police, to work as labour inspectors and if so, to provide information on the manner in which it is ensured that the new officials assigned to the Department of Labour performing the function of labour inspectors have adequate qualifications to perform effectively their inspection duties, in accordance with Article 7 of the Convention. In this regard, the Committee also requests the Government to provide information on the progress made in establishing rules specifying the qualifications of labour inspectors in Punjab.

Article 8. Eligibility of men and women for appointment to the inspection staff. The Committee notes that, according to the information provided in the 2022 annual labour inspection report regarding the number of female labour inspectors in the Departments of Labour and Departments of Mines across all provinces, women continue to make up a very small percentage of the labour inspectors. In 2022, the Departments of Labour had 14 female inspectors in Punjab, six in KPK, and four in Balochistan, while the Department of Mines in KPK employed three female inspectors. Furthermore, the Government indicates that currently, four female inspectors are working in the Department of Labour in Sindh. The Government acknowledges that, despite efforts made by the Departments of Labour in Punjab and KPK to recruit female labour inspectors and staff for other positions, the absence of female staff in the Department of Labour of the ICT remains a concerning issue. The Committee requests that the Government continue to pursue its efforts to increase the number of female inspection staff, and that it provides information in this respect, including any additional measures taken or planned and their outcomes. In particular, it requests the Government to indicate the measures taken to prioritize the recruitment of female labour inspectors in ICT.

Article 11. Financial and material means, including transport facilities. The Committee notes the detailed information provided on initiatives aimed at improving transport facilities in Punjab, Balochistan, KPK, and Sindh. However, it observes that transport facilities across these provinces remain inadequate. The Government acknowledges that a comprehensive assessment of transportation needs would be beneficial for the four provinces to ensure sufficient resources are allocated, enabling labour inspectors to carry out effective on-site inspections. Regarding KPK, the Committee notes that nine vehicles have been allocated to officers of the Directorate of Labour while requests for vehicles for 26 additional officers have not been fulfilled due to financial constraints. The Government also indicates that most transportations related to inspections in KPK are currently being conducted at the inspectors' personal expense. Regarding Sindh, the Government indicates that it has approved several schemes, including the procurement of durable goods for the Department of Labour, the digitalization of labour inspections, and the provision of transport for labour inspectors. Noting that the available transport facilities remain scarce, the Committee requests the Government to continue to provide information on any measures envisaged or adopted to ensure that sufficient budgetary resources are allocated for the labour inspectorate and specifically to strengthen the transport facilities available to inspectors in all provinces and ICT. It requests the Government to provide further detailed information on the transport facilities available to labour inspectors in each province, and the total amount spent on travel allowances each year.

Articles 17 and 18. Effective enforcement. Sufficiently dissuasive penalties for labour law violations. The Committee notes the information provided in the annual labour inspection report of 2022 regarding the number and types of infringements detected, the number and types of penalties imposed under various laws, the number of cases reported to the police for further investigation and prosecution, the judicial outcomes and the number and amounts of fines imposed by the Departments of Labour and Departments of Mines of the four provinces. The Committee notes that in its report the Government provides relevant information also for KPK and Balochistan for 2023 and ICT for both 2022 and 2023. Concerning the Committee’s previous request regarding measures taken to increase penalties, the Committee notes with interest the Government’s reference to the 2021 amendment of the Sindh Factories Act, 2015, which raised the applicable penalties for failing to give notice of commencement of work or of change of manager and for failing to get the factory registered. The Committee requests the Government to continue to provide information in relation to each of the provinces on the number of violations detected, the number of infringement reports issued, the number of cases brought to the courts, and subsequent convictions, and both the number and amount of the fines imposed, and to provide information on the proportion of imposed fines that are paid in practice for each province. The Committee requests the Government to continue to provide information on the measures taken or envisaged to ensure that the level of fines and other penalties for labour law violations and the obstruction of labour inspectors in their duties in each of the provinces are sufficiently dissuasive.

Articles 20 and 21. Publication of an annual inspection report. The Committee notes that the Government has communicated the labour inspection report for 2022, in accordance with Article 20, containing information on all the subjects listed in Article 21 for the four provinces, but not for the ICT. However, the Government provides relevant information regarding ICT in its report indicating that the annual labour inspection report for ICT is currently under compilation. The Committee notes that the Government’s report contains additional information on the subjects listed in Article21 for 2023 and 2024. In this respect, the Committee recalls that, according to Article20(2) labour inspection annual reports shall be published within a reasonable time after the end of the year to which they relate and in any case within twelve months. The Committee requests the Government to continue to regularly publish and communicate to the ILO the annual labour inspection reports that contain information on all subjects listed in Article 21 of the Convention. In this respect, it requests the Government to communicate the labour inspection report for ICT once it becomes available.