Complete Guide to Hire-Time Safety and Health Training | Law, Procedures, and Multilingual Delivery

TL;DR

• All eight items required across all industries and all employment types from April 2024 (令和6年4月) (omission rules abolished)
• Full-time, contract, part-time, dispatch, secondment, foreign workers — everyone, regardless of employment type or nationality
• Online delivery is allowed (provided learner identification and 3-year record retention)
• Dispatched workers are the dispatching company's responsibility
• For foreign workers, delivery in a language they understand is effectively mandatory

Hire-time safety and health training is a legal obligation imposed on every company that hires new workers. The April 1, 2024 (令和6年) revision abolished omission rules that previously applied only to certain industries, making delivery of all eight items mandatory across every industry and every employment type.

It must be conducted for everyone, including foreign workers, regardless of the industry. This article organizes the post-expansion hire-time safety and health training — the scope of the obligation under the law, the eight training items, eligibility for online delivery, responsibility under dispatch, record retention, and how to move toward multilingual delivery — from the practical viewpoint of HR, general affairs, and on-site supervisors.

1. What Is Hire-Time Safety and Health Training?

Article 59, Paragraph 1 of the Industrial Safety and Health Act (労働安全衛生法 / Industrial Safety and Health Act) states:

When an employer newly hires a worker, the employer shall provide that worker with education on safety or health relating to the work they will engage in, in the manner prescribed by ordinances of the Ministry of Health, Labour and Welfare.

In other words, "once you hire a worker, you must conduct safety and health training on the work they will perform" — a universal obligation that applies regardless of industry or employment type.

1-1. The Subject Is "Every Worker"

Regular employees, contract employees, part-timers, casual hires, dispatched workers, seconded employees, foreign workers — regardless of employment type or nationality, everyone is in scope.

For foreign workers in particular, an excuse such as "we couldn't conduct training because they didn't understand Japanese" does not hold up under the duty of care (安全配慮義務 / safety duty of care under Article 5 of the Labor Contract Act) either. Delivery in a language the worker can understand is effectively mandatory.

1-2. Timing: "At the Time of Hire"

"At the time of hire" refers to the stage after the employment contract is signed but before the worker begins their duties. New graduate hires, mid-career hires, rehires, and rehires accompanied by contract renewal are all in scope.

In addition, Article 59, Paragraph 2 requires equivalent training to be conducted again when work content changes (department transfer, job role change).

2. The April 2024 Revision: What Changed

Until then, the hire-time safety and health training had the following omission rules.

Before the revision (through March 2024)

Under Rule 35, Paragraph 1 of the Industrial Safety and Health Regulations, the training content lists eight items, but for industries other than specific ones such as forestry, mining, construction, transportation, and cleaning, items 1 to 4 (machinery hazards, protective gear, work procedures, pre-work inspection) could be omitted.

That meant office-type industries and parts of the service industry were allowed to deliver only items 5 to 8 (disease prevention, tidiness, emergency response, others).

After the revision (from April 1, 2024)

This omission rule was abolished, making it mandatory for every employer, regardless of industry, to deliver all eight items (1 to 8).

Important Change

Restaurants, retail, accommodation, services, IT — industries that previously qualified for omissions must now deliver all eight items in full from April 1, 2024. "We're mostly office workers, so it doesn't apply" no longer holds.

Why was it expanded?

The Ministry of Health, Labour and Welfare points to rising workplace accidents in office work and the tertiary industry. In fact, the number of injuries with four or more days of lost work has trended upward for three consecutive years, with "slips and falls," "falls from height," and "overexertion / unnatural posture" rising notably in retail, accommodation, and services. Because many of these risks can be prevented through basic hire-time training, the agency concluded that training should be required regardless of industry.

3. The Eight Training Items (Rule 35 of the Industrial Safety and Health Regulations)

The statutory training content is the following eight items.

3-1. Weighting of Each Item

Required time per item is not prescribed by law, but in practice, 2–4 hours total is common. Construction and other high-risk industries may spend about six hours.

When delivered in multiple languages for foreign workers, subtitles, dubbing, or interpretation is required, so it is smooth to assume 1.5x–2x preparation time.

4. Is Online Delivery Allowed?

Bottom line: yes.

4-1. MHLW Circular

The MHLW circular issued on January 25, 2021 — "Treatment of Training under the Industrial Safety and Health Act Conducted via the Internet" — officially recognizes delivery via e-learning or other online formats.

It must, however, meet the following conditions.

Requirements for online delivery

• The training content must cover the eight statutory items
• There must be a mechanism to confirm that the learner themselves actually completed the training
• Training records must be retained for 3 years
• Opportunities for Q&A and comprehension checks must be provided

4-2. How to Verify Learner Identity

For verifying "the learner actually completed the course," the recommended combination is:

• Face authentication (identity confirmation during the course)
• Random comprehension quizzes (mid-course comprehension checks)
• Course logs (viewing time, progress by chapter)
• Final exam (setting a passing threshold)

Major e-learning services (SAT, CIC, Labona, etc.) all implement this in some form.

4-3. Designing Against Fast-Forward / Skip

For special education, "preventing fast-forward and skipping" is effectively a required feature. For hire-time training there is no explicit requirement, but from a strict-operation standpoint, choose a service with fast-forward prevention.

5. Responsibility under Dispatch / Secondment

5-1. Dispatched Workers

For dispatched workers, the dispatching company (the staffing agency) holds the duty to deliver hire-time training. When the host company's "work content changes," the dispatching company is responsible for delivering "work-change-time training."

The dispatching company must record the date, time, and content of the training in its management ledger, and this too is subject to 3-year retention.

5-2. Seconded Workers

For seconded workers, the answer depends on the contract between the receiving and sending companies. The mainstream interpretation, however, is that the receiving company that actually receives the labor becomes the "employer". It is safest to re-deliver hire-time training at the receiving company.

5-3. Sole Proprietors / Contracted Workers

Sole proprietors and contracted workers are not "workers" in the formal sense, so they are technically outside the scope of hire-time training. However, "new-entry training at construction sites" (the prime contractor's responsibility) is imposed separately — and there too, the requirement of delivery "in a language the worker understands" applies.

"We delivered the training" is not enough. The duty of safety and health training is only fulfilled once you have created a state where "the worker actually understood."

6. Record Retention Period and Format

6-1. Statutory Retention Period

Under Rule 38 of the Industrial Safety and Health Regulations, records of hire-time training must be retained for 3 years.

6-2. Items to Record

6-3. Paper vs Digital

Paper record management is high-risk. Specifically:

• Records of former employees become scattered
• Cannot be presented to the prime contractor during audit
• Cannot be presented during an inspector's on-site investigation

We strongly recommend automatic e-learning record storage.

7. Multilingual Delivery Checkpoints

For companies employing foreign workers, multilingual delivery of hire-time training is effectively mandatory.

7-1. Selecting Languages

It must be delivered in the worker's native language or the language they understand best. Considering the major nationalities of foreign workers in Japan, the priority order is:

1. Vietnamese (about 570,000 people)
2. Simplified Chinese (about 400,000 people)
3. English (used by people from the Philippines, Myanmar, Nepal, etc.)
4. Indonesian (about 200,000 people)
5. Others (Thailand, Myanmar, Nepal, etc. typically through English)

Covering these five languages handles most cases.

7-2. Subtitles vs Dubbing vs Translated Text

7-3. Multilingual Comprehension Tests

Not just the main training — the comprehension test must also be in the worker's native language. If the test itself is only in Japanese, you cannot actually verify whether the training was understood.

8. Selection Criteria When Adopting E-Learning

8-1. Required Features

8-2. Services to Compare

When comparing major e-learning services, check the features above plus per-seat pricing, minimum onboarding headcount, and support coverage.

In particular, multilingual support differs significantly between providers and is a decisive selection criterion for companies employing foreign workers.

9. Related: Skill Development Employment / Special Education

Two systems closely related to hire-time safety and health training.

9-1. The Skill Development Employment System (effective April 2027)

A new system to replace the Technical Intern Training System takes effect in April 2027. Skill Development Employment workers are protected as "workers" under the Labor Standards Act and the Industrial Safety and Health Act, so all safety and health training obligations — including hire-time training — apply unchanged.

For details, see "Safety and Health Training Obligations under the Skill Development Employment System (Effective April 2027)."

9-2. Difference from Special Education

Hire-time training is "basic education for every worker"; special education is "additional education for workers engaged in dangerous or hazardous work." Workers operating forklifts, slinging loads, working in full-body harnesses, etc., must receive special education in addition to hire-time training.

10. Summary

What employers need now is to evolve hire-time training from "going through the motions" to "the worker actually understands, and it ties directly to site safety."

Key Takeaways

1. From April 2024, all eight items required across every industry and every employment type. "We're mostly office workers" no longer holds.
2. The subject is universal. Regular employees, dispatched workers, seconded workers, and foreign workers — every worker.
3. Without delivery in a language the worker can understand, the obligation is not fulfilled (duty of care).
4. Online delivery is allowed. Learner identification and 3-year record retention are required.
5. For dispatched workers, the dispatching company holds responsibility. Records must be retained in the management ledger for 3 years.

Related Articles

• Complete Guide to Safety and Health Training for Foreign Workers
• Safety and Health Training Obligations under the Skill Development Employment System (Effective April 2027)

Primary References

• Industrial Safety and Health Act, Article 59 (e-Gov Law Search)
• Industrial Safety and Health Regulations, Articles 35 and 38 (e-Gov Law Search)
• Scope of hire-time and work-change safety and health training expanded from April 2024 (FPEO Labor and Social Security Attorneys)
• Safety and health training (Workplace Safety Site / MHLW)
• "Safety and health training" at hire is mandatory! Content and methods explained (mediment)