Safety Representative

The purpose of the arrangement is for the safety representative to

• act as an intermediary between the employees and the employer, by assisting the employer in the preventative HSE work (making sure employees are safe and not subjected to danger); and
• be an important part of the employees’ right to participation and co-determination in the workplace. Through the safety representative, the employees have the ability to influence the undertaking’s efforts to create a safe and secure working environment.

The Working Environment Act requires all workplaces to have at least one safety representative. Undertakings with fewer than 5 employees may agree to make other arrangements.

If the safety representative is made aware or learns of improper working conditions in the workplace, they have a duty to notify the employer. This includes:

• danger to life or health,
• harassment and discrimination, and
• injury and illness.

The safety representative is not responsible for making sure the working environment meets the requirements laid down in law but must report censurable conditions and ensure that potential measures are addressed with the employer. One key foundation for this is that the employer must keep the safety representative informed about the working environment in the undertaking.

Responsibility for making sure the working environment meets the legal requirements rests solely with the employer.

The employer is responsible for making sure the undertaking has a sound working environment

It will always be the employer who is responsible for making sure the undertaking has a sound working environment. The safety representative shall help the employer identify risk factors and assist in finding measures to ensure that the work does not negatively impact the employees’ health and welfare.

If the safety representative learns of circumstances that may expose workers to danger or accidents in the workplace, they shall immediately notify the employer and give the employer the chance to rectify the situation within a reasonable period of time. The safety representative shall determine what constitutes a reasonable period of time in each instance.

What if the employer is unable or unwilling to rectify the working environment issues?

If so, the safety representative may contact the working environment committee (arbeidsmiljøutvalget), if the undertaking has one. The safety representative may also contact the Labour Inspection Authority for advice and guidance.

The safety representative protects the interests of all employees and speaks on behalf of the employees in matters concerning health, safety and environment (HSE). This includes any hired-in workers and independent contractors who work in close association with the undertaking. Safety representatives should also contribute if employees have a home office. 

The safety representative is a link between management and all employees in matters concerning the working environment. It is important that both management and the employees have a shared understanding of the safety representative’s responsibilities and limitations.

The safety representative’s role in employee issues and whistleblowing processes

As the safety representative is intended to be a voice for all employees, they should be hesitant to serve as the party representative for an individual employee in an employee issue. In such cases, the safety representative may be present at meetings as an observer and adviser to ensure the process is properly handled. Read more about this in the section “What is the difference between a safety representative and an employee representative?”

In HSE cases, however, the safety representative may address issues that only affect an individual employee.

Should the safety representative also protect the interests of management?

The safety representative plays a clear role as a representative of the employees in matters concerning the working environment. But who protects the interests of management in matters concerning the working environment? The answer to this will depend on how the undertaking has been divided into safety areas.

If management has been designated as their own safety area, a safety representative shall be elected or appointed among management. This safety representative will then be responsible for protecting their interests in HSE-related matters. If management is not designated as a separate safety area, managers can, like all other employees, contact the safety representative for their safety area.

This is particularly relevant for employees with management responsibilities, such as foremen or supervisors, who have the same working hours as other employees. While these employees have management responsibilities, they are not considered part of the undertaking’s top management. That said, managers in particularly independent or supervisory positions may also contact the safety representative as an employee.

The undertaking’s top management, however, always represent the employer and are not part of the safety representative’s area of responsibility like the other employees are.

If a manager does seek assistance from the safety representative, it is important to clarify that the manager in question then is acting in their role as employee, and not as a representative of the employer. It is also important to clarify who has decision-making authority on the matter, and to whom the safety representative may present this case. In some cases, it would be preferable for the chief safety representative to handle the matter, especially if the organisational structure lends itself to this approach.

A general duty of confidentiality applies to safety representatives and senior safety representatives

The safety representative and senior safety representative must keep confidential any information they learn as part of their role, specifically

• information of a private nature
• information that others may exploit for commercial purposes, such as technical installations, production methods, analyses and calculations, or trade secrets

These are specific types of sensitive information protected by other legislation, including the Personal Data Act and the Marketing Control Act. This means the safety representative has a duty to stay informed on the laws and regulations that apply to different types of information and how these affect confidentiality. 

The safety representative or senior safety representative cannot discuss or distribute any information covered by confidentiality, unless the person concerned expressly authorises the safety representative to do so. 

The safety representative is bound by confidentiality, but also has a duty to report

The safety representative’s duty of confidentiality is not universal – something that applies regardless of the circumstances. The safety representative must carefully consider which types of information are covered by confidentiality, to whom confidentiality applies, and how confidentiality is balanced against considerations of the working environment and of the safety representative’s duty to report. 

What may trigger the safety representative’s duty to report?

The duty of confidentiality may be set aside if the safety representative has a duty to forward the information in-house in order to mitigate accidents or health risks in the undertaking. The safety representative and senior safety representative are not bound by confidentiality vis-à-vis the employer in cases that may have serious consequences for the working environment, such as 

• risk of injury and death
• harassment and discrimination
• injury and illness 

The safety representative must be conscious of their role in protecting the working environment. It may be necessary to set confidentiality aside to prevent dangerous or detrimental conditions in the workplace, as well as to support any employees who are experiencing problems related to the working environment. The safety representative must weigh considerations of keeping confidentiality and of taking the necessary steps to ensure a safe and protective working environment. 

The safety representative must be conscious of their duty to report any issues or conditions that may endanger the employees’ health, safety or welfare in the workplace. This could entail reporting breaches of rules or regulations, dangerous situations or any other issues demanding attention. The safety representative’s special duty to report dangerous conditions applies both to the employees in the workplace and to making the employer aware of the issue. It is important to keep in mind that reports must be made in a considerate manner, protecting the rights of both the person giving notice and of any other affected parties. In principle, the employer is responsible for rectifying issues that may pose a risk of accidents or a danger to health, but the safety representative may also personally intervene if they are able to eliminate the risk without the employer’s involvement.

Employees have a duty to contribute

Employees have a duty to contribute to a sound working environment, as well as a safe and health-promoting working environment in their workplace. In addition, the employee has a special duty to report any issues that may pose a danger to life or health. The same applies if they learn of or experience harassment or discrimination in the workplace. Such reports are a key premise for the employer and safety representative being able to monitor conditions in a sound manner. 

It is important to note that employees cannot personally order the safety representative to keep something confidential. The safety representative must inform the employees of this prior to any dialogue. The safety representative needs the necessary freedom to protect the working environment in the undertaking and to perform their duties in a sound manner. Access to anonymous reporting can, however, be ensured through the undertaking’s internal reporting procedures (either through the safety representative or other employee representatives).

Because of this, it is important for the safety representative to be able to balance considerations of confidentiality, the working environment and the duty to report. This entails exercising discretion and good judgment in various situations, making it possible to perform the role of safety representative while simultaneously protecting the rights of the employees and the working environment in the undertaking.

It can be difficult to spot the difference between the role of safety representative and the role of employee representative with a trade union (tillitsvalgt). But these are two separate roles.

The employee representative’s sole responsibility is to protect the interests of the union members under the collective agreement. Membership in a trade union is not compulsory, but it is a right employees in Norway have.

The role of the employee representative with a trade union is not regulated by law, but follows from a collective agreement or basic agreement. Among other things, employee representatives protect the employees’ rights under contracts, collective agreement, etc.

What are the roles of the employee representative and the safety representative in personnel matters?

Ordinary terminations, personnel matters and pay disputes are therefore not the responsibility of the safety representative – they are the responsibility of the employee representative. The safety representative may be asked to assist, however, because not all employees are members of a trade union. In such cases, it is important that the safety representative makes it clear that they are not representing the party, but they may be present as an observer during meetings, to contribute advice.

In cases where the issues or conflicts are caused by the working environment, or have consequences for the working environment, the safety representative may also play a role.

It is possible to be both an employee representative and a safety representative at the same time, but this would entail protecting the interests of one’s own members (e.g. in a dispute), whereas the role of the safety representative is to safeguard the working environment of all employees. It is not in conflict with laws and regulations to serve as both an employee representative and as safety representative at the same time, but the Labour Inspection Authority does not recommend it, as these two roles easily could end up in conflict with each other. Any person who holds both roles, must be very careful to distinguish between the two.

Among other things, safety representatives shall:

• actively participate in the undertaking’s HSE work. This includes the employees’ psychosocial work environment;
• consult on the planning and implementation of measures that impact the working environment in their safety area;
• consult on the establishment, execution and maintenance of systematic HSE work (internal control); and
• participate at all stages of work on the internal control system and may personally take initiative in several stages.

Safety inspections

The safety representative shall carry out regular safety inspections, where the goal is to make sure the undertaking complies with statutory HSE requirements. In order to fulfil this role, the safety representative shall regularly carry out systematic inspections of the workplace within their designated safety area. 

It is the safety representative who shall take the initiative to plan and conduct these safety inspections. However, it is recommended that the manager or another employer representative also participates. The employer has the overall responsibility for HSE in the undertaking, and by participating in the safety inspection, management gains better insight into the actual working environment within the company. This, in turn, facilitates quicker handling of non-conformities and the implementation of risk-reducing measures. 

Depending on the undertaking’s activities, the safety representative shall also monitor to ensure that:

• machinery, technical devices, chemical substances and various work processes do not pose a safety risk to workers;
• protective devices and personal protective equipment are available in suitable quantities, and that such equipment is readily available and in good working condition;
• workers receive necessary instruction, practice and training;
• the work is adapted, so that workers can perform the work in a manner that is not harmful to their health or safety; and 
• notices of occupational accidents are submitted to the Labour Inspection Authority.

If the Labour Inspection Authority performs an inspection, the safety representative shall participate. The safety representative shall follow up to make sure the employer complies with any orders and guidelines given by the Labour Inspection Authority.

The safety representative shall listen to their colleagues and consult with them before solutions are presented to the employer. If the undertaking has an occupational health service (bedriftshelsetjeneste) or safety personnel, it would be natural for the safety representative to collaborate with them.

Specific duty to consult the safety representative

The employer has a particular duty to consult the safety representative in cases involving:

• Risk assessment and follow-up of workers under 18 years old
• Limited HSE training for safety representatives and working environment committee (WEC) members (less than 40 hours)
• Assessment of whether working hour arrangements are sound, especially in situations involving exemptions from the rules concerning working hours (night work, work on Sundays, and for workers in senior and particularly independent posts)
• Risk assessments in connection with work involving high risk and particularly high risk (use of chemicals, biological factors, asbestos, noise, etc.)
• If an enterprise is applying for certification as a staffing enterprise, cleaning company or expert enterprise. There is no specific requirement for a written statement, but the safety representative must be consulted in the design of the general HSE documentation that is to be included in the application. 

Written statement from the safety representative in applications

It may also be necessary to obtain a written statement from the safety representative in the following applications to the Labour Inspection Authority:

Building application – if the enterprise does not have a WEC

When planning new construction or structural changes in a building that is to be used as a workplace, the workers must contribute in the application process. This means the workers must be involved in the planning and be given an opportunity to comment on the structural solutions.

If the enterprise does not have a working environment committee (WEC), the employer must include a statement from the safety representative. If the enterprise has a WEC, the WEC must prepare a statement. It is nevertheless recommended that the local safety representative participate in any reviews of the application documents. 

Building application (in Norwegian)

Application for extended overtime limits

The employer must discuss the use of overtime with employee representatives or other representatives of the workers. The Labour Inspection Authority also recommends involving the safety representative, especially in assessing the soundness of the working hour arrangement outlined in the application. Minutes from the discussion meeting must always be included in the application.

Apply for extended overtime limits (in Norwegian)

Application for a permit to work with asbestos

All enterprises working with asbestos must have a permit from the Labour Inspection Authority. Before submitting the application to the Labour Inspection Authority, the enterprise’s safety representative, working environment committee and occupational health service must be consulted on the application and given an opportunity to comment.

Apply for a permit to work with asbestos (in Norwegian)

Advance permit for youth work

If a child under 15 years old or a child attending lower secondary school will be working in the enterprise, the enterprise must apply for an advance permit from the Labour Inspection Authority. The employer must perform a risk assessment before the child starts work and must prepare an action plan outlining measures to mitigate risk, ensuring that the child is not subjected to any detrimental physical or mental strain. The risk assessment and action plan must be signed by the manager and the safety representative.

Advance permit for youth work (in Norwegian)

All applications for exemptions from regulations (particularly applications for exemptions involving high-risk work, such as diving, biological factors, explosive work, work at height, etc.) 

An exemption permit means that an exemption is granted from statutory requirements in specific cases where certain circumstances apply. 

All applications for exemptions from regulations must be submitted to the Labour Inspection Authority. The application must include information that makes it possible for the Labour Inspection Authority to consider whether the enterprise’s working environment is safe and healthy. In order for the Labour Inspection Authority to be able to process the application, the Authority requires that statements from the working environment committee or the safety representative be included in the application.

The Labour Inspection Authority has created templates that the applicants may use. These are available on the Labour Inspection Authority’s website.

All undertakings with 30 or more employees (or 10–30 employees if one of the undertaking’s parties demand it) must appoint a working environment committee (WEC). If the undertaking does not have a working environment committee, the safety representative must also:

• assess and prepare statements on matters concerning the occupational health service, safety representative and working environment committee (the internal safety service);
• assess training programmes that have an impact on the working environment;
• process construction or reconstruction plans that require a building application and approval from the Labour Inspection Authority;
• process other plans of significant importance for the working environment, such as machinery purchases, measures for increased productivity (rationalization) and other restructuring, working time arrangements, safety measures and the establishment and maintenance of internal control systems; and
• review reports on occupational illnesses, occupational accidents and occupational hygiene surveys, and contribute to the employer investigating the cause of the problems and implementing measures to prevent reoccurrence.

The safety representative shall have access to all information necessary to fulfil their obligations under the Working Environment Act. The employer must keep the safety representative informed of working conditions within the enterprise and provide access to relevant documents and registers.

The employer has a duty to inform the safety representative about the working conditions within the enterprise, including information on: 

• occupational illnesses within the enterprise
• occupational accidents and near-misses
• industrial hygiene reports and measurements
• relevant safety rules, guidelines, orders and recommendations 

The safety representative must also be provided access to:

• the employer’s log of personal injuries and occurrences of occupational illness
• orders and other administrative decisions imposed on the enterprise by the Labour Inspection Authority 

If the employer does not provide such information of its own initiative, the safety representative may demand its release.  The safety representative shall review such documents and contribute to the identification of likely causes, as well as to the employer implementing measures to prevent recurrence. In enterprises with no working environment committee, the safety representative shall also contribute to the mapping of occupational illnesses and occupational accidents and ensure that the employer implement the necessary preventive measures. 

The employer must make arrangements to give the safety representative the time they need to carry out the safety work in an appropriate manner.
Normally, these tasks and responsibilities shall be carried out during ordinary working hours.

In principle, the safety representative personally determines how much time is needed to properly carry out the tasks and responsibilities of the role. If the safety representative’s assessment conflicts with the employer’s assessment, the safety representative may contact the Labour Inspection Authority to consult on the matter.

The employer and the safety representative should discuss the regular and routine tasks of the safety representative, so that the workload is adjusted with the other responsibilities of the safety representative.

Please note that it must at all times be possible for the safety representative to suspend their work if unforeseen situations arise that require the safety representative’s intervention.

The occupational health services (OHS) shall assist the employer, employees, the working environment committee and the safety representative in creating a safe working environment that promotes good occupational health. The employer shall ensure that the OHS provides assistance when contacted by employees, safety representatives, or the working environment committee.

Employees are encouraged to contact the occupational health service (OHS) when needed. An agreement with the OHS gives all employees the right to contact the service and request professional assistance on matters related to the working environment, without having to go through the employer first.

However, the scope of assistance included in the OHS agreement may vary between undertakings. In some cases, the OHS must clarify matters with the employer before expenses are incurred, for example if the enquiry concerns services outside the standard package. Any additional costs must be approved by the employer.

OHS personnel are bound by a duty of confidentiality under the Health Personnel Act.

Normally, all undertakings must have at least one safety representative. All employees are counted, including any part-time or temporary employees.

If the undertaking has fewer than 5 employees (1–4 employees), the employer and the employees may agree upon a different arrangement instead of a safety representative. The number of employees includes both permanent employees (full time and part-time) and temporary employees.

Content requirements for agreements on different arrangements

An agreement on a different arrangement where there is no safety representative must be made in writing and include a description of how matters of safety specifically shall be handled.

Among other things, the agreement must include information on:

• who the employee’s representative or contact person is;
• necessary working environment measures;
• how often meetings are to be held and where;
• how matters of safety shall be reported;
• how the employer, in consultation with the employees, shall handle risks;
• the employer’s duties in HSE work; and
• the employee’s duty to participate.

The agreement period may not exceed two years, and all employees must sign the agreement.

When must the “different arrangement” be replaced by a safety representative?

• If the undertaking’s number of employees increases to 5 or more during the agreement period, a safety representative must be appointed. All employees are counted, including any part-time or temporary employees.
• The Labour Inspection Authority may, in connection with inspections and based on an assessment of the risks present, order undertakings with fewer than 5 employees to appoint a safety representative.

Regardless of whether or not an undertaking has a safety representative, the employer must ensure that all employees receive necessary training and information on how to safely carry out the work.

Template for agreement concerning a different arrangement

The Labour Inspection Authority has prepared a template that can be used to conclude an agreement between the employer and the employee concerning a different arrangement.

This template is intended as an aid in drawing up the agreement; the undertaking is not obligated to use the template. The template comes in PDF format, where

• some content comes pre-filled and the text is fixed
• some content provides guidelines on information that must be included in the agreement

The document can be accessed here:

Safety representative – agreement concerning alternative arrangement (pdf)

If you are having problems downloading the template, you can contact Signform via e-mail: info@signform.no

The number of safety representatives needed in an undertaking will depend on the undertaking’s size, risk factors and working conditions. As a norm, there should be one safety representative per unit or shift if so indicated by the risk factors present in the undertaking.

There is no definite yes or no answer to the question of whether undertakings that hire seasonal workers must appoint a safety representative, even if the undertaking has more than five employees during certain seasons.

In an inspection, Arbeidstilsynet (the Norwegian Labour Inspection Authority) will perform an assessment, taking into account the following factors: 

• The number of temporary employees hired by the enterprise annually.
• The duration of temporary employments each year
• The nature of the work
• The risk factors present in the workplace
• The predictability of work for the employer (does the employer know that the same employees will return to work for the enterprise again next year?)
• Is the cost of compliance for the undertaking proportionate to the presumed profit? Are the time and costs of safety representative training reasonable if the employee is only going to be working for the undertaking for a few weeks or months?

If an employer who hires seasonal workers decides not to appoint a safety representative, the employer must prepare written documentation of having considered all the factors on this list.

In other respects, undertakings with seasonal workers are subject to the same requirements as undertakings with fewer than five employees. Read more about this in the section “Undertakings with fewer than five employees may agree to a different arrangement (template for agreement)”.

Please note that the Arbeidstilsynet may come to a different conclusion than the employer in connection with an inspection. In such cases, Arbeidstilsynet may order the undertaking to appoint a safety representative.

Each safety representative shall have their own clearly defined safety area (verneområde). This area should be small enough that it is possible for the safety representative to have full overview of the area, in order to appropriately carry out the tasks and responsibilities of the role. The size of the area is not necessarily dependent on the number of workers – the nature of the work and the working conditions in general must also be taken into account. If the undertaking has more than one unit or shift, one safety representative shall normally be appointed for each unit or shift.

If the undertaking has a working environment committee

In undertakings with a working environment committee (WEC), the committee is responsible for dividing the workplace up into safety areas, thus also determining the minimum number of safety representatives.

If the undertaking does not have a working environment committee

In undertakings that do not have a working environment committee, the local trade union(s) or representatives of the employees (where there are no trade unions) shall decide the division, after consulting with the employer.
Read more about the division into safety areas in Section 3-1 of the Regulations concerning Organisation, Management and Employee Participation.

If the safety representative considers that the life or health of employees is in immediate danger and such danger cannot be averted by other means, the safety representative has the authority to halt the work. The term ‘immediate danger’ means the danger is present in the moment.

One example of immediate danger is workers working on a roof with no fall protection or using a saw with no protective device.

Long-term harm to health after short-term exposure

The safety representative may halt work in cases where there is a risk of harm to health in the long term. The determining factor is whether the danger is imminent in the sense that harm to health may occur after short-term exposure, even if the effects of what the worker has been or may be exposed to, will not manifest until later.

Examples:

• The safety representative may halt demolition work if they suspect the rubble contains asbestos. Demolition of buildings with eternit siding (containing asbestos), for example, could be halted until the employer has measured the potential asbestos content.
• Some occupations come with the risk of threats and violence. Such experiences may cause delayed injuries in persons subjected to them. If the safety representative deems that the measures implemented by the employer to mitigate these risks are not sufficient, the safety representative may halt work until satisfactory measures have been implemented.

Read more about violence and threats in the workplace (in Norwegian).

Long-term harm to health after long-term exposure

The safety representative may not halt work if disease or injury only occurs after long-term exposure. Such cases are less acute and may be prevented in other ways that do not involve the halting of work.

If the safety representative halts work, they must immediately notify the employer. The notice must include information:

• that the work has been halted, and
• on the reason why the work has been halted.

The safety representative must consider whether to halt all or some of the undertaking’s activities to prevent danger to life or health. If the situation, for example, involves unsafe work on a roof, it will be sufficient to call the workers down from the roof. Work that is performed elsewhere in the workplace and that does not entail any risk, may continue.

The safety representative shall help the employer find solutions that may help enable work to resume.

If they agree on a solution, work may be resumed without contacting the Labour Inspection Authority.

If no solution can be found, the employer or the safety representative must contact the Labour Inspection Authority. The employer and the safety representative must first try to resolve the disagreement, but if the employer either does not agree that work should be halted, or if the parties cannot agree on which solutions are needed before work can resume, the Labour Inspection Authority may be contacted.

If the employer or safety representative contacts the Labour Inspection Authority, work cannot resume until the Labour Inspection Authority has decided that work may resume.

The senior safety representative has the same authority to halt dangerous work as the safety representative. Therefore, the senior safety representative may halt work independently of the safety representative’s assessment.

However, if a safety representative has halted work, the senior safety representative cannot overrule this decision. Similarly, the safety representative cannot overrule the senior safety representative’s decision to halt work.

The safety representative is not liable for losses incurred as the result of halting work due to danger to life and health

The safety representative is not liable for any economic loss incurred by the undertaking as a result of halting work due to imminent danger to the worker’s life and health. This also applies in cases where it turns out that the safety representative overestimated the risk and the halting of work was unnecessary.

The safety representative may be held liable if the work was halted for reasons beyond danger to life and health

If work is halted for reasons other than danger to life and health, the safety representative may be liable for damages. This includes situations where work is halted in demonstration against measures the employer wants to implement, if such measures are unrelated to dangers to life and health.

Things to consider when you are appointing a safety representative

• It is the employees who decide who should be safety representative.
• Safety representatives are elected by the employees.
• The employer, or a person managing the undertaking on behalf of the employer, cannot be elected safety representative.
• The safety representative should be a respected and skilled employee (trusted by the employees), with at least two years experience in the undertaking and good insight into work tasks.
• Safety representatives are elected for two years at a time.
• Safety representatives can be reelected for multiple periods, unless replacement is indicated for special reasons. Reelection could be beneficial, because it could take a while to familiarize oneself with the work, and experience is important.

Supervisors can be elected safety representative, but the Labour Inspection Authority does not recommend this solution. The reason is that the role of safety representative easily conflicts with the role of supervisor.

All employees have a duty to participate in organized HSE work in the workplace, and as such cannot refuse election or appointment as safety representative.

Safety representatives are elected for a period of two years at a time, and cannot be elected for a shorter or longer period than two years.

The role as safety representative can only be resigned if the safety representative:

• leaves the undertaking, or
• transitions to permanent work in a different safety area within the undertaking.

Therefore, the safety representative cannot resign from the role or refuse to carry out the safety representative function.

However, the Labour Inspection Authority does not recommend appointing an unwilling safety representative. In such cases, we recommend a new election, or for the deputy (if the undertaking has one) to step in for the rest of the period.

The employees or the employer cannot demand that a safety representative step down.

The appointment can be made:

• on the basis of a majority vote among the employees; or
• by the local trade unions in accordance with set rules.

If only one candidate is put forward, a formal election does not need to be carried out. However, the election committee must inform employees of the candidate’s name and the proposer before the appointment, to ensure that employees have an opportunity to raise any objections.

If only one candidate is up for election, an election should nevertheless be held. It may, however, be sufficient that the employees be given opportunity to object to the candidate. The election committee must therefore announce the candidate's name and the name of their proponent before the election. If there are no objections, the candidate may be considered to have been elected.

Read more about the appointment of safety representatives in Chapter 3 of the Regulations concerning Organisation, Management and Employee Participation.

The employer must ensure that the safety representative receives necessary training to exercise their role responsibly. The minimum requirement is 40 hours of training.

The employer and the Labour Inspection Authority may consider additional training if the tasks or other aspects of the undertaking indicates that additional training is needed.

It may also be relevant with a refresh course at a later stage, but this is not mandatory by law.

In some cases, the employer and the employees may agree to have less than 40 hours of training. Such agreement must be based on the risks in the undertaking indicating that less training will be sufficient. In such cases, an assessment of both the content and the scope of the training must be made.

Such assessments should be made in writing, and must be prepared by the employer and the employees jointly. If the parties cannot agree, the minimum requirement of 40 hours shall apply.

Read more about the requirements of safety representative training in Section 3-19 of the Regulations concerning Organisation, Management and Employee Participation. Duration of the training of safety representatives and members of working environment committees. 

The training can take place on courses organised by various course providers. The safety representative is entitled to participate in courses organized by the local labour union (trade union) where the safety representative is a member.

• The training shall preferably take place during working hours.
• The employer shall cover all costs of the training.
• During training, the safety representative shall be on leave with full pay.
• If the training takes place outside working hours, the safety representative shall be entitled to pay, as if during ordinary working hours, but not to overtime pay. The safety representative shall also be entitled to pay when the training is in the form of remote education completed outside working hours.

Before training, the safety representative’s preparations should include:

• familiarizing themselves with the rules that apply to the safety work;
• acquire any necessary additional knowledge, such as finding out which regulations apply to the work tasks performed in the workplace; and
• ensure access to the Working Environment Act, Working Environment Regulations and the Internal Control Regulations. You can find this legislation here.

Read more about the requirements of training in Section 3-18 of the Regulations concerning Organisation, Management and Employee Participation. Training of safety representatives and members of working environment committees.

All undertakings with more than one safety representative must have a senior safety representative. The senior safety representative coordinates the work of the safety representatives.

Senior safety representatives are either elected among the safety representatives, or another person who holds or has held a position of trust within the undertaking can be appointed. Unlike for safety representatives, a deputy must always be appointed for the senior safety representative.

The appointment can either come as a result of a vote among the safety representatives, or by local trade unions appointing the senior safety representative in accordance with the rules provided in the Regulations concerning Organisation, Management and Employee Participation.

The senior safety representative shall guide and assist the safety representatives, as well as coordinate the work of the safety representatives. In case of doubt concerning how to distribute matters between the safety representatives in the undertaking, the senior safety representative may decide.

Matters that affect several safety areas shall be submitted to the senior safety representative, and it may be natural for the senior safety representative to assume responsibility for the process in such cases. Beyond this, the senior safety representative shall not take on the tasks of the safety representatives, even if the performance of the safety representative is not satisfactory.

The senior safety representative shall be part of the working environment committee as one of the representatives of the employees. It is natural for the senior safety representative to participate in processes that affect the working environment at a general level.

Read more about senior safety representatives in Section 3-5 of the Regulations concerning Organisation, Management and Employee Participation.