Reiwa 6 (April 2024) Expansion of On-Hire Safety & Health Training in Japan — Scope and 8 Mandatory Items

TL;DR

• Effective April 1, 2024 (Reiwa 6) — the omission clause in 労働安全衛生規則 (Industrial Safety and Health Regulations) Article 35, paragraph 1 was abolished.
• Before the revision, 4 items could be omitted except in forestry, mining, construction, transport, and cleaning.
• After the revision, all 8 items are mandatory for every industry and every employment type.
• Part-time staff, dispatch workers, and foreign workers are equally covered.
• Violations are subject to corrective recommendations and guidance from the Labour Standards Inspection Office.

On April 1, 2024 (Reiwa 6), the framework for on-hire safety and health training in Japan changed substantially. The 4 items that used to be "omittable depending on industry" became mandatory across every industry and every employment type.

Office-heavy companies, IT, retail, hospitality, and service businesses tended to assume "this doesn't apply to us." Not anymore. All 8 items are now a duty regardless of industry. This article organizes — for compliance officers — what changed in the revision, the scope and the list of required items, and the statistics behind the change.

1. Key points of the revision — what changed

Article 35, paragraph 1 of 労働安全衛生規則 lists 8 items that must be covered in on-hire training. Before the revision, items 1 through 4 (hazards of machinery, protective equipment, work procedures, start-of-work inspection) could be omitted outside specific industries.

The April 1, 2024 revision completely abolished this omission clause.

Before-and-after comparison

*1: Forestry, mining, construction, transport, and cleaning.

To put it plainly, under the pre-revision regime, the line "we're in an industry where omission is allowed" was actually used on the ground. After the revision, that escape hatch is gone, and office-centric workplaces, stores, warehouses, and worksites alike must cover the same 8 items.

2. What the old omission clause was about (context)

Why did this omission clause exist in the first place? Historically, the idea was to concentrate training resources on industries with many dangerous or harmful tasks (forestry, mining, construction, transport, and cleaning).

Over the past decade and more, however, occupational accidents in the tertiary sector (retail, hospitality, services, healthcare, and welfare) have been rising. Office and service-sector worksites are now seeing real cases of falls, slips, and back injuries, and the rationale for treating these items as "omittable" has eroded.

Background of the revision (MHLW notice)

In March 2023, the Industrial Safety and Health Subcommittee of the Labor Policy Council recommended the abolition of the omission clause; in September 2023, the partial revision of the 労働安全衛生規則 (Industrial Safety and Health Regulations) was promulgated (MHLW Ordinance No. 108). After a one-year public-notice period, it took effect on April 1, 2024.

3. The complete list of 8 mandatory items (労安規則第35条第1項)

This is the heart of the article. The 8 items that every on-hire training must include, regardless of industry, are as follows.

Step 1: Hazards or harmfulness of machinery, raw materials, and how to handle them

The hazards of machines, tools, and raw materials used in the work, and how to handle them safely. For office staff, this includes copiers and shredders; for stores, slicers and kitchen equipment.

Step 2: Performance and handling of safety devices, harmful-substance suppression devices, and protective equipment

The performance and correct use of protective equipment (gloves, safety glasses, masks, etc.) and safety devices. "We just lend them out" does not satisfy the training duty.

Step 3: Work procedures

Explanation of standard operating procedures (SOPs). It is good practice to include the hazards of deviating from those procedures.

Step 4: Inspections at the start of work

Items and checklists for pre-shift inspections. Training that builds the habit of confirming equipment, tools, and protective gear status.

Step 5: Causes and prevention of diseases that may arise from the work

Heat illness, back pain, dust, chemical exposure, eye strain from VDT work — work-specific health risks and how to prevent them.

Step 6: Maintaining order, organization, and cleanliness

Strict practice of so-called "3S" / "5S." Directly tied to preventing slip-and-fall accidents.

Step 7: Emergency measures and evacuation in case of accidents

First aid and evacuation routes in case of injury, fire, or earthquake. For foreign workers, multilingual dissemination is especially important.

Step 8: Other matters necessary for the safety or hygiene of the work

Items specific to the industry or job type. Increasingly, harassment prevention, mental health, and infection control are included here.

4. What "covered work" means — the meaning of removing industry limits

The phrase "covered work" has caused some confusion after the revision. To organize it:

• Covered industries: industry restrictions are gone (= every industry is in scope).
• Covered work: the 8 items must be delivered as they relate to the specific work the worker will perform.

In other words, a convenience-store cashier doesn't need forklift handling training, but "hazards of the machines used at the register," "falls and robbery response that can occur in the store," and "use of protective equipment such as gloves" must all be addressed under their respective items.

This is the point: there is no item you may skip. The post-revision correct practice is to instantiate each item in the context of the actual work.

5. Background: what the statistics show

According to the MHLW's "Status of Industrial Accidents," in Reiwa 5 (2023) the number of workers killed or injured with 4 or more days of absence was 135,371, up 0.5% year over year, marking the third consecutive year of growth. The increase is particularly pronounced in the tertiary sector.

By industry, the trends look like:

• Retail: falls, cuts and abrasions, and motion-related strain.
• Social welfare facilities: back pain, falls, and violence (against staff).
• Restaurants: cuts and abrasions, burns, and falls.
• Land freight transport: falls from heights and motion-related strain during loading and unloading.

Accidents in the tertiary sector are rising in domains long regarded as "unlikely to produce serious incidents." Thorough on-hire basic training remains the single most effective preventive measure. — Ministry of Health, Labour and Welfare, 14th Industrial Accident Prevention Plan (Reiwa 5–9)

To be candid, this expansion is a strong message from the MHLW: "office and service industries too need to take basic training seriously."

6. Implementation deadline and practical points

The effective date is April 1, 2024. The obligation is already in force. In principle, training must be completed immediately after hiring and before the worker is assigned to duties.

If non-implementation is uncovered, the Labour Standards Inspection Office will issue corrective recommendations or guidance. There are even cases where egregious instances were referred to prosecutors as violations of the 労働安全衛生法.

And we can't overlook the civil liability that follows an accident. If "no training was provided" comes to light, it ties directly to the risk of damages based on breach of the duty of care for safety (Labor Contract Act Article 5).

With the omission clause gone, "our industry isn't covered" no longer works — neither legally nor in practice.

Summary

The April 2024 (Reiwa 6) expansion repositions on-hire safety and health training from "an obligation for specific industries" to "a basic operation for every employer." More than a year after enforcement, even Labour Standards Inspection Office checks now standardly assume the omission clause is gone.

If your workplace has not adapted, audit your 8-item coverage immediately. Especially in industries that previously omitted items, redesigning your training content — and considering multilingual delivery that includes foreign workers — is the next step.

Key Takeaways

1. Since April 1, 2024, the omission clause in 労働安全衛生規則 Article 35, paragraph 1 has been completely abolished.
2. Implementing all 8 items is a legal duty across every industry and every employment type.
3. There is no industry-based restriction on coverage; the content of each item is tailored to the specific work.
4. Non-implementation directly carries risks of corrective guidance and breach of the duty of care for safety.
5. For foreign workers, delivering training in a language they understand becomes practically mandatory.

Primary references

• Ordinance Revising Part of the Industrial Safety and Health Regulations (Reiwa 5 MHLW Ordinance No. 108)
• Industrial Safety and Health Act Article 59
• Industrial Safety and Health Regulations Article 35
• MHLW: Status of Industrial Accidents in Reiwa 5
• 14th Industrial Accident Prevention Plan (Reiwa 5–9)

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