What training does the EU OSH Framework Directive require?
The EU OSH Framework Directive (Council Directive 89/391/EEC) requires every employer to ensure each worker receives adequate safety and health training specific to their workstation or job. Article 12 sets four trigger points: recruitment, a transfer or change of job, new or changed work equipment, and new technology. Training must be adapted to new risks, repeated periodically if necessary, given during working hours, and never charged to workers.
By the Knowledge Foundry editorial team. How we write and check these pages
- Published
- Updated
- Reading time
- 8 min
- Jurisdiction
- European Union (applied through each Member State's national law)
- Regulator
- National labor inspectorates enforce the transposing laws; the European Commission monitors transposition; the European Agency for Safety and Health at Work (EU-OSHA) provides guidance
Key takeaways
- Article 12 of Directive 89/391/EEC is the core training duty: adequate, job specific safety and health training for each worker.
- Training is triggered on recruitment, transfer or change of job, new or changed equipment, and new technology, and must be repeated periodically if necessary.
- Training may not be at the workers' expense and must take place during working hours.
- Designated safety workers, first aid, firefighting and evacuation staff, and workers' safety representatives have their own training rights and duties.
- The directive binds employers through each Member State's transposing law, so the national act is what an inspector enforces.
What is the EU OSH Framework Directive?
The OSH Framework Directive is Council Directive 89/391/EEC of June 12, 1989, the basic European Union law on occupational safety and health. It sets general principles for preventing occupational risks and requires employers to inform, consult, and train workers. As at September 2026 it remains in force and continues to underpin every later EU workplace safety directive.
According to the European Agency for Safety and Health at Work (EU-OSHA), the directive applies to all sectors of activity, public and private, except specific public service activities such as the armed forces, the police, or certain civil protection services. A series of individual directives (on work equipment, personal protective equipment, manual handling, display screen equipment and other topics) was adopted on its basis. The Framework Directive continues to apply in full to those areas, but where an individual directive is more stringent or specific, the individual directive prevails.
The EU makes two main kinds of binding law. A regulation applies in its entirety and directly in every Member State. A directive sets a goal that each country must achieve, but each country writes its own law to reach it, a process called transposition. The OSH Framework Directive is a directive, so employers comply with their national law. In Portugal, for example, it is transposed by Law 102/2009, covered in Portugal's OHS training requirements.
What does Article 12 require?
Article 12(1) requires the employer to make sure each worker receives adequate safety and health training that is specific to their workstation or job, at defined trigger points. The text reads: "The employer shall ensure that each worker receives adequate safety and health training, in particular in the form of information and instructions specific to his workstation or job".
The directive lists four events that trigger training:
- on recruitment
- in the event of a transfer or a change of job
- in the event of the introduction of new work equipment or a change in equipment
- in the event of the introduction of any new technology
The training must also be adapted to take account of new or changed risks and repeated periodically if necessary. The directive does not set a fixed refresh interval or a minimum number of hours. The employer decides what "adequate" means from its risk assessment, which Article 9 requires it to hold. Setting a defensible cycle is covered in how to set mandatory training refresh cycles.
Article 12(2) extends the duty to people who are not the employer's own staff. The employer must ensure that workers from outside undertakings working on its premises "have in fact received" appropriate instructions about the health and safety risks of their activities there. This is a verification duty: the host employer has to check, not assume.
Who must be trained under the directive?
Every worker must be trained, and certain roles carry additional training duties. Article 3 defines a worker as any person employed by an employer, including trainees and apprentices but excluding domestic servants.
| Group | Article | What the directive requires |
|---|---|---|
| All workers | Article 12(1) | Adequate, job specific safety and health training at the four trigger points, adapted to new risks and repeated periodically if necessary |
| Workers from outside undertakings | Article 12(2) | The host employer ensures they have in fact received appropriate instructions on the risks of their activities on site |
| Workers' representatives with a specific safety and health role | Article 12(3) | Entitled to appropriate training |
| Designated protective and preventive workers | Article 7(5) | Must have the necessary capabilities and means; Member States define those capabilities |
| First aid, firefighting and evacuation workers | Article 8(2) | Their number, training, and equipment must be adequate for the size and specific hazards of the undertaking |
| Workers entering areas of serious and specific danger | Article 6(3)(d) | Only workers who have received adequate instructions may have access |
Who pays for the training and when must it happen?
The employer pays, and worker training happens during working hours. Article 12(4) states that the training for workers and for workers' safety representatives "may not be at the workers' expense or at that of the workers' representatives".
Worker training under Article 12(1) must take place during working hours. Training for workers' safety representatives must take place during working hours or, in accordance with national practice, either within or outside the undertaking. This sits alongside the broader rule in Article 6(5) that safety and health measures may in no circumstances involve workers in financial cost.
How do information, consultation, and worker duties connect to training?
Training is one of several linked duties, and an inspector will usually look at them together. The employer must inform workers of risks and preventive measures, consult them on how training is planned, and workers must then act in line with the training they received.
- Information (Article 10): workers and their representatives must receive all necessary information on safety and health risks and on protective and preventive measures, for the undertaking in general and for each type of workstation or job.
- Consultation (Article 11(2)(e)): workers or their safety representatives must be consulted in advance and in good time on the planning and organization of the training referred to in Article 12.
- Worker duties (Article 13): each worker must take care of their own safety and health and that of others "in accordance with his training and the instructions given by his employer", including correct use of machinery, dangerous substances, and personal protective equipment.
Article 13 is why training records matter in incident investigations. If a worker's duty is measured against their training, the employer needs to show what that training covered and when it was delivered. Record keeping is covered in how to prepare training records for an audit.
How does the directive apply in each Member State?
Each Member State enforces the directive through its own law, which can go further than the directive but not below it. Article 18(1) required Member States to bring the necessary national laws into force by December 31, 1992, and Article 1(3) confirms the directive is without prejudice to national provisions that are more favorable to worker protection.
In practice, this means a multinational employer finds the same core Article 12 triggers in every Member State, but different national detail: some countries set hours, specific course content, certified providers, or penalties. Portugal's Law 102/2009 states in its Article 2 that it transposes Directive 89/391/EEC, and it adds a duty to consult on the OHS training program at least once a year. A training program designed for the EU should map each national requirement back to the shared directive obligation, as described in how to map training to compliance obligations.
What evidence shows compliance with Article 12?
Good evidence shows that training was triggered at the right moment, matched the job and its risks, and changed when risks changed. A completion date on its own does not show that the training was job specific or adequate.
| Obligation | Learning outcome | Evidence |
|---|---|---|
| Training on recruitment | New worker can identify the main hazards of their job and the controls in place | Induction record dated before or at start of work, linked to the job's risk assessment |
| Training on transfer or change of job | Worker can apply the controls specific to the new role | Role change record with matching training record and assessment result |
| Training on new equipment or technology | Worker can operate the new equipment safely | Equipment change log cross referenced to training records and practical sign off |
| Adapted to new or changed risks | Worker knows the revised procedure | Content version history showing updates after risk assessment changes |
| Outside workers instructed (Article 12(2)) | Contractor knows site hazards and emergency arrangements | Site induction or contractor confirmation checked before work starts |
| Consultation on training (Article 11(2)(e)) | Not applicable: governance step | Minutes or records of consultation with safety representatives on the training plan |
A training matrix that links roles, risks, and required training makes the trigger points visible, and an audit trail of content versions shows that training kept pace with risk changes.
How does Knowledge Foundry approach this?
Knowledge Foundry models each workstation's hazards and controls as structured concepts with assessment points, linked to the risk assessment that justifies them. When equipment, technology, or a risk changes, the affected concepts, and the people who need retraining, can be identified from those links, and the same structure can be mapped to each Member State's transposing law.
Frequently asked questions
Does the OSH Framework Directive set a minimum number of training hours?
No. Article 12 requires adequate, job specific training at defined trigger points and periodic repetition if necessary, but sets no hours or frequency. Individual directives and national laws may add specific requirements, so the transposing law in each Member State should be checked.
Can an employer charge workers for mandatory safety training?
No. Article 12(4) states that the training may not be at the workers' expense or that of their representatives, and Article 6(5) says safety and health measures may in no circumstances involve workers in financial cost. Worker training must also take place during working hours.
Does the directive apply to contractors and agency staff?
Article 12(2) requires the host employer to ensure that workers from outside undertakings working on its premises have in fact received appropriate instructions about the risks. The contractor's own employer keeps its training duties. Directive 91/383/EEC adds specific rules for fixed-term and temporary workers.
Is e-learning acceptable for Article 12 training?
The directive does not prescribe a delivery method. It requires training that is adequate and specific to the workstation or job. Generic online modules may cover general content, but job specific hazards, equipment use, and emergency roles often need practical instruction and assessment. See e-learning vs instructor led compliance training.
Sources
- Council Directive 89/391/EEC on the introduction of measures to encourage improvements in the safety and health of workers at work, EUR-Lex, Publications Office of the European Union
- Directive 89/391/EEC: OSH Framework Directive, European Agency for Safety and Health at Work (EU-OSHA)
- Types of legislation, European Union
- Lei n.º 102/2009: regime jurídico da promoção da segurança e saúde no trabalho (consolidated), Diário da República
This page is general information, not legal or compliance advice. Check the primary sources above and obtain advice for your circumstances. See our editorial standards.