Every year, trade businesses take on apprentices, work experience students and young employees. Most employers want to do right by them — but many do not know that employing anyone under 18 carries a specific legal duty that goes beyond a standard risk assessment.
If you employ or plan to employ anyone under the age of 18, including apprentices, you have obligations under Regulation 19 of the Management of Health and Safety at Work Regulations 1999 (MHSWR). Here is what that means in plain language, and what you need to do before they start.
The Legal Duty: MHSWR 1999, Regulation 19
Regulation 19 of the Management of Health and Safety at Work Regulations 1999 places a specific duty on employers to:
- Carry out a risk assessment before a young person starts work
- Consider the specific factors that make young workers more vulnerable
- Identify activities the young person must not carry out
This is a legal requirement. If you employ a young person without first completing a young person risk assessment, you are in breach of the Regulations — regardless of whether anything goes wrong.
The duty applies however the young person is engaged — full-time employee, apprentice, work experience placement, holiday work or part-time weekend job. If they are under 18 and working for you, the duty applies.
Young Person vs Child: The Legal Distinction
UK law draws a clear line between two categories:
- Young person: Anyone under the age of 18 but above the minimum school leaving age (currently 16 in England and Wales). This covers apprentices, college-age employees and part-time workers.
- Child: Anyone of compulsory school age, typically under 16. Most commonly encountered in trade businesses as school work experience placements.
The protections are stricter for children. An employer taking on a school work experience student must not only complete the specific risk assessment but must ensure their existing assessments actively address the additional factors for young people. In some circumstances, local authority notification obligations may apply depending on the nature of the work.
For trade businesses taking on apprentices, the young person definition (16-17) is the most common scenario.
What the Risk Assessment Must Additionally Consider
A young persons risk assessment template is not a standard risk assessment with a different title. Regulation 19 specifically requires employers to take into account additional factors unique to young workers:
Inexperience and Lack of Awareness of Risk
Young workers have not yet developed the intuitive risk awareness that comes from years on site. An apprentice might not recognise a dangerous situation that an experienced tradesperson would spot in seconds. Your assessment needs to acknowledge where inexperience creates additional hazard — and your controls must reflect that, through closer supervision, staged introduction to tasks, and explicit instruction rather than assumed understanding.
Immaturity
Psychological immaturity can affect judgement and behaviour in ways adult workers would not typically exhibit — a tendency to take shortcuts, to underestimate consequences, or to take risks to impress peers. This is not a criticism of young workers; it is a recognised aspect of adolescent development. Your assessment should factor in appropriate supervision levels and make clear which tasks require direct oversight.
Physical Development
Young workers are still physically developing. Their musculoskeletal systems are more vulnerable to strain and long-term injury from heavy lifting, repetitive movements or awkward postures. A manual handling task manageable for a fit adult may be genuinely dangerous for a 16 or 17-year-old. Weight limits and task repetition levels may need to be adjusted for young workers.
Specific Factors to Document
Your young persons risk assessment should specifically address:
- The nature of work the young person will carry out
- The equipment they will be required to use
- The substances or agents they may be exposed to (including COSHH-regulated materials)
- The work processes and organisation of work
- The level of training, instruction and supervision that will be provided
Prohibited Activities for Young Workers Under UK Law
The Management of Health and Safety at Work (Amendment) Regulations 2006 set out categories of work that young persons must not carry out, other than as part of supervised training. Prohibited activities include:
- Work beyond their physical or psychological capacity
- Exposure to toxic or carcinogenic agents, or substances causing chronic health effects
- Work involving harmful exposure to radiation
- Work where there is a risk of accidents that young people may not be expected to recognise due to inexperience, immaturity or lack of training
- Work in conditions of extreme cold, heat, noise or vibration
For trade businesses specifically:
- Young workers must not operate certain machinery without training and close supervision — including power tools, plant equipment and vehicles
- Roofing work at height requires specific risk controls and supervision for anyone under 18
- Exposure to hazardous substances such as solvents, adhesives, lead or asbestos-containing materials requires written controls that explicitly address the young worker's exposure
A school work experience student faces even stricter restrictions and should in practice be limited to low-risk, closely supervised activities. Any doubt about whether a task is suitable — assume it is not, until you have assessed it.
Practical Guidance for Trade Businesses Taking on Apprentices
If you are a plumber, gas engineer, electrician, roofer or painter taking on an apprentice or young worker, here is a practical checklist:
Before they start:
- Complete a written young persons risk assessment before the first day
- Review your existing risk assessments to confirm they address the specific factors for young people — if they do not, update them
- Check whether any tasks on your planned programme are prohibited activities for under-18s
First day induction:
- Cover the specific risks identified in the assessment in plain language
- Make clear what they can and cannot do unaccompanied
- Record that this induction has taken place, with the date and their signature
Supervision:
- Assign a named, experienced supervisor
- Start with a higher level of supervision and reduce it progressively as competence is demonstrated and documented
Ongoing training records:
- An apprenticeship training plan from a college or training provider is not the same as a safety training record
- Document safety training separately — what they were trained on, when, and who signed it off
Review:
- Revisit the assessment if the young person moves to a new task, new site or new piece of equipment
You do not need a separate risk assessment for every individual work experience student, as long as your existing assessments already actively address the specific young person factors. HSE is clear that those factors must be considered — not just assumed to be covered.
Records: How Long to Keep Them
Retain the young persons risk assessment for the duration of employment plus a minimum of three years after the worker leaves. Given that musculoskeletal conditions and other long-term health effects may not manifest for years after exposure, keeping records until the worker reaches age 25 is a widely adopted and sensible approach for young worker documentation.
Need Help Getting This Right?
Young worker risk assessments often get overlooked when businesses are busy getting on with the job. But if something goes wrong and you cannot demonstrate that a proper assessment was completed before the young person started, the consequences — enforcement action, civil claims, reputational damage — can be significant.
At SafeCompli, I help trade businesses get their health and safety documentation in order quickly and without unnecessary complexity. If you take on apprentices and are not certain your assessments are up to scratch, visit www.safecompli.co.uk or get in touch directly.