Employers must account for risks to workers under eighteen, including inexperience, awareness and maturity. In Great Britain, the Management of Health and Safety at Work Regulations 1999 set relevant assessment and protection duties. A separate document is not automatically required if an existing assessment already addresses the young person’s circumstances.
The reason for a separate duty is that young workers face elevated risk for reasons that go beyond inexperience. Their physical development isn’t complete. Their perception of risk is not yet calibrated to adult workplace conditions. They may be reluctant to raise concerns with adult managers. And they often don’t yet know what “normal” looks like in a workplace, so they can’t easily tell when something is being asked of them that shouldn’t be.
This page covers the duties for workers under 18, the additional rules for children below the applicable school-leaving age, work experience and apprenticeships.
Definitions
The regulations use two terms, and the distinction matters.
A young person is anyone under the age of 18.
For these purposes, a child is someone below the minimum school-leaving age. The relevant leaving dates depend on the UK nation and date of birth; being sixteen does not always mean the child-employment rules have ended.
The Management Regulations protect young people under 18. Additional restrictions apply to children below the applicable school-leaving age; this is not simply an under-16 category in every circumstance.
The legal framework
Regulation 19 of the Management of Health and Safety at Work Regulations 1999 is the specific duty. It requires the employer to ensure that young persons employed by him are protected at work from any risks to their health or safety which are a consequence of their lack of experience, of absence of awareness of existing or potential risks, or of the fact that young persons have not yet fully matured.
Regulation 3 requires the assessment to consider matters including inexperience, maturity, workplace layout, exposure to agents, equipment, work organisation and training. Regulation 19 sets protections and restrictions on employing young people in hazardous work.
The 1999 regulations sit on top of two other frameworks:
- The Children (Protection at Work) Regulations 1998, which restrict the types of work children may do and the hours they may work, and require local authority work permits for some employments.
- The Working Time Regulations 1998, which set specific limits on hours, breaks and rest periods for young workers.
For specific industries — agriculture, construction, manufacturing with dangerous machinery, work with hazardous substances — additional sector-specific provisions may apply.
What’s prohibited or restricted
Regulation 19(2) prohibits young workers from being employed for work which is “beyond his physical or psychological capacity”; involves harmful exposure to certain hazardous substances; involves harmful exposure to radiation; involves a risk of accidents which he is unlikely to recognise or avoid because of his lack of experience, training or attention to safety; or involves a risk to health from extreme cold or heat, noise or vibration.
Do not treat ordinary controls for adults as automatically sufficient for a young worker. Check the specific prohibitions and whether any narrowly defined training exception applies, as well as the person’s capabilities and supervision needs.
For a young person who is no longer a child, regulation 19 allows specified exceptions only where the work is necessary for training, a competent person supervises it and risk is reduced to the lowest level reasonably practicable. Apprenticeship status alone is not an exemption.
Restrictions on children
Children below the applicable school-leaving age face additional child-employment restrictions, including limits on permitted work and hours.
Child-employment restrictions cover permitted work, hours, breaks and local permits. GOV.UK sets out restrictions including work during school hours, before 7 am or after 7 pm, and more than two hours on school days or Sundays. Check the rules and local by-laws before arranging work; a family connection is not a general exemption from safety duties.
Local authorities have additional powers to make by-laws governing children’s employment, and many require employers to obtain a work permit before employing a child. Permits are typically issued by the local authority’s education department and may attach further conditions. Employers planning to employ children — including for paper rounds, retail Saturday jobs and similar — should check the local authority’s specific requirements before the work starts.
The assessment in practice
A young persons risk assessment has the same shape as any general workplace assessment — the five-step framework — but with specific attention to the factors that elevate risk for young workers.
The assessment should consider the work being done, not just the workplace as a whole. A 17-year-old apprentice on a construction site doing the same work as adult colleagues faces different risks than a 16-year-old working on the till in the same employer’s office. The relevant question is what this young person is exposed to and whether the controls are calibrated to their level of experience and physical development.
Specific factors to consider include the supervision arrangements (intensity, qualifications of the supervisor, ratio), the induction received, the equipment being used (and whether the young worker has the strength and reach to use it safely), the working pace expected, the hazards present in the workplace generally (whether the young worker is exposed to them or insulated from them), and the working hours and break patterns.
Consider the young person’s needs before work starts and review the existing assessment where necessary. For a child, give the parent or guardian understandable information about significant risks and protective measures before the work begins.
Work experience placements
Work experience is covered by the employer’s workplace health and safety arrangements. The assessment should account for the activities and the student’s maturity, understanding and any particular needs; no standard placement length determines the duty.
The employer is responsible for workplace health and safety during a placement. Schools or placement organisers should check that suitable risk-management arrangements exist and pass on relevant information about the student. HSE says they do not need extra paperwork or to approve the employer’s assessment.
In practice, employers offering work experience placements need to:
- Check before the student arrives that the existing assessment covers the activities and young-person factors; review it if this is a first placement or the student has particular needs.
- Brief the student on hazards and controls at induction (with parental information beforehand where the student is a child).
- Provide appropriate supervision — work experience students should not be working unsupervised in any role with material hazards.
- Confine the student’s work to activities suitable for their age and experience.
- Have arrangements in place for any incident or concern, including how the school will be contacted.
Employer liability insurance must cover work experience students. Most standard policies do, but the cover should be confirmed before the placement.
Apprentices and under-18s in real workplaces
A 17-year-old apprentice in a construction trade, an engineering company or a hospitality role presents the most demanding application of regulation 19. The apprentice is in a real workplace, doing real work, with real hazards — and the regulation requires that exposure to those hazards is controlled to the level appropriate for someone without complete physical maturity or full adult risk awareness.
Structured training and supervision can help an apprentice develop safely, but they do not permit unrestricted exposure to hazards. Apply the legal restrictions and the specific conditions of any training exception before allocating work.
What an apprentice cannot do is be treated as a junior adult worker with the same expectations as their colleagues. The supervision intensity, the equipment they’re given, the tasks they’re asked to do, and the working hours all need to be calibrated to their age and experience. A construction principal contractor accepting a 17-year-old apprentice on site has the same duty to assess and control as for any other young worker, regardless of whether the apprentice’s employer is a sub-contractor with their own H&S arrangements.
For young workers above school-leaving age but under 18, the Working Time Regulations normally limit work to 8 hours a day and 40 hours a week, with a 30-minute break after more than 4.5 hours, 12 hours’ daily rest and 48 hours’ weekly rest. Limited exceptions apply. Children below school-leaving age have separate, stricter child-employment rules.
Induction, training and supervision
Three elements consistently distinguish workplaces that handle young workers well from those that don’t.
Induction has to be thorough, age-appropriate and verified — the young worker should not be left to “figure it out” or to learn from observing colleagues. Specific time should be set aside before the young worker starts substantive work to cover the workplace layout, the hazards, the controls, the procedures, and who to ask if they’re unsure.
Training has to be matched to the tasks the young worker will do. Where the work involves equipment, hazardous substances, manual handling or any specific hazard with its own regulation, the relevant training is required — not as an extra, but as a precondition.
Supervision needs to be intensive at the start and to taper as competence builds. A young worker left unsupervised in a hazardous environment because their formal supervisor was called away is exactly the situation regulation 19 is designed to prevent.
Records and review
The assessment record should identify the young workers covered, the specific risks considered, the controls in place, the supervision arrangements, and the further actions if any. Where the worker is a child, the record should confirm that the parent or guardian has been informed.
Review is required when the young worker’s role changes, when they progress through training stages, when new hazards are introduced, or at intervals reflecting the structured progression of their experience. A young worker who has been competently working for six months is at a different point on the risk curve than one who started yesterday — and the assessment should evolve accordingly.
Where this connects in the cluster
Young persons risk assessment intersects with manual handling (because physical development is incomplete and guideline figures need adjustment), COSHH (because under-18s face restrictions on exposure to certain hazardous substances), and working at height (where additional supervision and equipment considerations apply for young workers).
An existing general assessment can cover young workers if it adequately considers the relevant factors. Review it when circumstances or individual needs require, rather than assume a separate form is always necessary.
For employers who take on work experience placements or apprentices regularly — particularly schools, training providers, construction firms, hospitality groups and retailers — formal Risk Assessment Training helps build the assessor competence the duty requires, with placement-specific arrangements layered on top.
Frequently asked questions
What counts as a young person under UK health and safety law?
A young person is under eighteen. A child is below the applicable minimum school-leaving age, which depends on the nation and leaving date. The Great Britain Management Regulations protect young workers, with additional rules for children.
Do work experience students need a separate risk assessment?
Not automatically. HSE says an existing assessment is sufficient if it already covers the specific factors for the young person. Review it before a first placement or where particular needs or unfamiliar risks require changes. A separate document is not the legal test.
Can a 17-year-old apprentice do everything an adult can?
No automatic exemption applies because someone is an apprentice. Assess their capabilities, apply the young-worker restrictions and working-time rules, and check the precise conditions for any necessary supervised training involving restricted work.
Who issues a child work permit?
Check the relevant local council’s child-employment rules before work begins. Permit arrangements and by-laws vary; do not assume that the council where the child lives is always the authority responsible for the workplace.
What working hours can a 16- or 17-year-old work?
Young workers above school-leaving age but under 18 normally have an 8-hour daily and 40-hour weekly limit, a 30-minute break after more than 4.5 hours, 12 hours’ daily rest and 48 hours’ weekly rest. Limited exceptions apply. Children below school-leaving age are subject to separate restrictions.
Related guides
- How often should a risk assessment be reviewed?
- Risk assessment: the HSE's five steps explained
- Manual handling risk assessment
Sources & references
- HSE — Assessing risks to young people
- HSE — Work-experience advice for schools and colleges
- Management Regulations 1999, regulation 19
- Management Regulations 1999, regulation 3
- GOV.UK — Child employment and local rules
- GOV.UK — Rest breaks for young workers
Build the assessor competence regulation 19 requires with accredited online training.
Explore the Risk Assessment Training course →
Mark writes about workplace health & safety, risk assessment and accredited online training for Risk Assessment Training, part of Online CPD Academy.