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When you hire foreign workers from China or Taiwan, is there a duty to give safety and health education in their native language?

Illustration of an inclusive workplace for international employees
Joji Uramatsu

Joji Uramatsu

Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant), Gyoseishoshi (Certified Administrative Procedures Legal Specialist), Registered Real Estate Transaction Specialist — 四葉社会保険労務士事務所/四葉行政書士事務所

Regardless of nationality, when you hire a worker or change their work content, you have a duty to give safety and health education at hiring and the like (Industrial Safety and Health Act, Article 59, paragraphs 1 and 2). The items to teach are the 8 items set in the Ordinance on Industrial Safety and Health, Article 35, paragraph 1, and from the amendment in force on April 1, 2024, the mechanism for omission by industry was removed, so all 8 items are now required in all industries, including service industries such as nursing care. For foreign workers, it must be done in a way the person can understand, such as their native language (the Ministry of Health, Labour and Welfare's guidelines for foreign workers). If you fail to give the education, the safety consideration duty (Labor Contract Act, Article 5) is questioned when an accident occurs.

In short: Regardless of nationality, when you hire a worker or change their work content, you have a duty to give safety and health education at hiring and the like (Industrial Safety and Health Act, Article 59, paragraphs 1 and 2). The items to teach are the 8 items set in the Ordinance on Industrial Safety and Health, Article 35, paragraph 1, and from the amendment in force on April 1, 2024, the mechanism for omission by industry was removed, so all 8 items are now required in all industries, including service industries such as nursing care. For foreign workers, it is required to be done in a way the person can understand, such as their native language (the Ministry of Health, Labour and Welfare's guidelines for foreign workers; Notification No. 276 of 2007). With technical intern training and specified skills, post-entry training and the life orientation overlap on safety, but the safety and health education for the work itself is separately required under Article 59. If you fail to give the education, the safety consideration duty (Labor Contract Act, Article 5) is questioned when a labour accident occurs. From the viewpoint of a shakai hoken roumushi's labour management, this page sets out the content of hiring-time education, doing it in the native language or easy Japanese, the extra layers under technical intern training and specified skills, and the relationship with labour accidents — leaving residence-status conformity to a gyoseishoshi under a separate engagement.

At companies that take in people from China or Taiwan in manufacturing, construction, nursing care and the like, people often wonder "may we finish the safety and health education in Japanese only" and "is there a duty to do it in the native language." This page is for such managers and labour staff.

What do you teach in the safety and health education at hiring (Industrial Safety and Health Act, Article 59)?

When an employer hires a worker, it must give safety or health education (Industrial Safety and Health Act, Article 59, paragraph 1). The same applies when the work content is changed (the same Article, paragraph 2). When putting a worker on dangerous or harmful work, special education is separately required (the same Article, paragraph 3).

The content to teach is, among the following 8 items of the Ordinance on Industrial Safety and Health, Article 35, paragraph 1, those relating to the work the worker engages in.

#Education item
1The danger/harm of machines, raw materials, etc., and how to handle them
2The performance of safety devices, harmful-substance control devices and protective gear, and how to handle them
3Work procedures
4Inspection at the start of work
5The causes and prevention of diseases that may arise from the work
6Keeping things in order, tidy and clean
7Emergency measures and evacuation at the time of an accident, etc.
8Other matters necessary for the safety or health of the work

Before the amendment, in "other industries" not falling under manufacturing, construction and the like (Order for Enforcement of the Industrial Safety and Health Act, Article 2, item 3 — for example medical and welfare, commerce, service industries), education for items 1 through 4 could be omitted. However, the amendment in force on April 1, 2024 (Ministry of Health, Labour and Welfare Ordinance No. 91 of 2022, promulgated May 31, 2022) deleted this omission provision, so all 8 items are now mandatory in all industries. Manufacturing and construction already needed all items, but industries such as nursing care, which could previously omit them, must now carry out items 1 through 4 as well.

Do you need to educate foreign workers in their native language or easy Japanese?

Safety and health education is required to be done in a way the foreign worker can understand the content. The Ministry of Health, Labour and Welfare's "Guidelines for employers to appropriately address the improvement of employment management of foreign workers" (the guidelines for foreign workers; Notification No. 276 of 2007) provide that safety and health education be carried out in a way foreign workers can understand. The related notice "On the promotion of safety and health education for foreign workers, etc." (Ki-hatsu 0328 No. 28 of March 28, 2019) also states that it be done in a way that can be understood, such as by using the person's native language.

The law does not have wording that uniformly requires the "native language," but carrying it out formally in Japanese only does not amount to having given education if the person has not understood. In practice, you arrange a "way that can be understood" with the following measures.

MeasureContent
Native-language materialsPrepare materials and audiovisual materials in traditional and simplified Chinese for people from China and Taiwan
Easy JapaneseSupplement with short sentences, furigana, and diagrams or illustrations
Interpretation / assistanceAsk a senior worker from the same country/region who can speak Japanese to interpret or assist
Confirming understandingDo not explain one-sidedly; confirm understanding and repeat

The relationship with the duty to show the labour conditions themselves in the native language is covered in Foreign workers' equal remuneration and the labour-condition notice. Which language and method amount to a "way that can be understood" is checked by a qualified professional according to the person's Japanese ability and the danger of the work.

What education is added under technical intern training and specified skills?

Under technical intern training and specified skills too, the safety and health education at hiring and the like (Article 59) is required just as for Japanese workers. On top of that, the system's own mechanisms overlap on safety content.

  • Technical intern training: Post-entry training includes subjects that help with life and skill acquisition in Japan, including safety and health (the technical intern training operation guidelines). This is training under the system and does not replace the Article 59 education tailored to the actual work on site.
  • Specified skills (No. 1): Among the mandatory support the accepting side provides, the life orientation includes information on safety in daily life, such as responses at times of disaster or emergency. This too is separate from the safety and health education for the work itself.

In other words, even if the person has received post-entry training or a life orientation, it is safest to separately carry out the Article 59 education tailored to your own site and work. The scope and hours of each system's training and support can change under the operation guidelines, so fixed figures are not given here.

If you have not given the education, what is questioned when a labour accident occurs?

Workers' accident compensation insurance applies regardless of nationality or residence status, and insurance benefits are paid for work-related and commuting accidents. The relationship between travel from a dormitory to the site and labour accidents is covered in Foreign workers' dormitories and commuting accidents. The problem is the civil liability that arises apart from insurance benefits.

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An employer owes a duty to give necessary consideration so that workers can work while their life and body are kept safe (the safety consideration duty) (Labor Contract Act, Article 5). If you put someone on dangerous work without their understanding the language and an accident occurs, failing to educate in a way they could understand may be assessed as a breach of the safety consideration duty. It has been pointed out that there are court cases finding safety education given to foreign workers in Japanese only to be insufficient. In addition, failing to give the Article 59 education itself can be subject to corrective guidance from the Labour Standards Inspection Office, and depending on the nature of the violation, can become a question of penalties.

What is questionedBasis
Workers' accident insurance benefits (regardless of nationality)Workers' Accident Compensation Insurance Act
Civil damages (breach of the safety consideration duty)Labor Contract Act, Article 5
Administrative guidance / penalties (failure to educate)Industrial Safety and Health Act, Article 59, etc.

The final judgment on whether a particular case amounts to a breach of the safety consideration duty is made in light of the circumstances (this article does not make a definitive judgment).

What can 四葉社会保険労務士事務所 do for you?

四葉社会保険労務士事務所 in Kohinata, Bunkyo Ward, handles, for the acceptance of foreign workers including people from China and Taiwan, designing the system for carrying out safety and health education at hiring and the like, how to prepare native-language and easy-Japanese materials and records, organising safety and health management including special education and health check-ups, putting work rules and labour relations in order, and procedures at the time of a labour accident. The initial consultation is free. We quote according to the content and the number of employees; for how fees are thought about, see the fee schedule, and the questions we are asked most often are on the FAQ page.

The conformity of the residence status and acting as agent for applications are the work of a gyoseishoshi; we will guide you to contract with them separately, as an independent business entity. This office does not accept referral fees.

Frequently asked questions

Q. Must foreign workers' safety and health education always be done in the native language?
A. The provisions do not uniformly require "in the native language," but the guidelines for foreign workers (Notification No. 276 of 2007) and the related notice ask that it be done in a way the person can understand the content. Doing it formally in Japanese only does not amount to having given education if the person has not understood. You arrange a "way that can be understood" with materials in traditional and simplified Chinese, easy Japanese, diagrams and illustrations, interpretation or assistance by a senior worker from the same country, and confirming understanding.

Q. Do nursing-care offices also need the education on machines and protective gear (items 1 through 4)?
A. Yes. The amendment in force on April 1, 2024 removed the mechanism for omission by industry, so all 8 items of the Ordinance on Industrial Safety and Health, Article 35, paragraph 1 are now required in all industries, including service industries such as nursing care. Previously "other industries" could omit items 1 through 4, but after the amendment, nursing-care sites too educate on the danger of the equipment and tools they use and how to handle protective gear, tailored to the work.

Q. If someone has received the technical intern post-entry training, can we skip the safety and health education at our company?
A. No. Post-entry training includes subjects covering safety and health, but this is training under the system and does not replace the Article 59 education at hiring and the like tailored to your own site and work. The specified-skills life orientation is the same — it is separate from the safety and health education for the work itself. At joining and when work changes, it is safest to carry out education tailored to your own work again.

Q. If an accident happens after putting someone on work without the language getting through, what is the company questioned on?
A. Workers' accident insurance applies regardless of nationality and benefits are paid, but separately the employer owes a safety consideration duty (Labor Contract Act, Article 5). If you put someone on dangerous work without educating them in a way they could understand and an accident occurs, you may be questioned for civil damages as a breach of the safety consideration duty. Failing to give the Article 59 education can also become a question of corrective guidance from the Labour Standards Inspection Office or, depending on the nature, penalties.

Sources for this article

  • Industrial Safety and Health Act (労働安全衛生法, Act No. 57 of 1972), Article 59, paragraphs 1 and 2 (safety and health education at hiring and on change of work content), paragraph 3 (special education for dangerous and harmful work) (confirmed against e-Gov on October 18, 2026)
  • Ordinance on Industrial Safety and Health (労働安全衛生規則, Ministry of Labour Ordinance No. 32 of 1972), Article 35, paragraph 1 (the 8 items of education at hiring and the like). The amendment in force on April 1, 2024 (Ministry of Health, Labour and Welfare Ordinance No. 91 of 2022, promulgated May 31, 2022) deleted the former paragraph-1 proviso (the provision allowing omission of items 1 through 4 in the "other industries" of Order for Enforcement, Article 2, item 3), making the 8 items mandatory in all industries (confirmed against e-Gov and Ministry of Health, Labour and Welfare materials on October 18, 2026)
  • Guidelines for employers to appropriately address the improvement of employment management of foreign workers (the guidelines for foreign workers; Ministry of Health, Labour and Welfare Notification No. 276 of 2007). Carrying out safety and health education in a way foreign workers can understand (referenced October 18, 2026)
  • On the promotion of safety and health education for foreign workers, etc. (Ki-hatsu 0328 No. 28 of March 28, 2019, Ministry of Health, Labour and Welfare). Doing it in a way that can be understood, such as by using the native language (referenced October 18, 2026)
  • The subjects of post-entry training in the technical intern training operation guidelines (edited by the Immigration Services Agency and the Ministry of Health, Labour and Welfare), and the mandatory support (life orientation) for specified skills No. 1. The hours and proportion of each subject can change under the operation guidelines, so they are not given as fixed values (referenced October 18, 2026)
  • Labor Contract Act (労働契約法, Act No. 128 of 2007), Article 5 (the safety consideration duty) (confirmed against e-Gov on October 18, 2026)

This article does not go so far as to decide whom you should consult. Designing the system for carrying out safety and health education, how to prepare native-language materials and records, putting safety and health management and work rules in order, and procedures at the time of a labour accident are the work of a shakai hoken roumushi. The conformity of the residence status and acting as agent for applications are the work of a gyoseishoshi; each is carried out by an independent business entity and contracted separately. This office does not accept referral fees. The cost of consulting 四葉社会保険労務士事務所 is set out in the fee schedule, and the questions we are asked most often are on the FAQ page.

This article is general information. Judgments that fit your particular circumstances are made by a qualified professional after a meeting. Written by Joji Uramatsu (Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant), Gyoseishoshi (Certified Administrative Procedures Legal Specialist), Registered Real Estate Transaction Specialist).

Shall we start by reviewing how you work?

四葉社会保険労務士事務所 (Kohinata, Bunkyo-ku; a 5-minute walk from Myogadani Station on the Tokyo Metro Marunouchi Line) helps you, starting with a review of your current labour practices.

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