What safety and health education does Japan's Industrial Safety and Health Act require?

Japan's safety and health education duties sit in three layers of law: the Act passed by the Diet, a Cabinet Order made by the Cabinet, and a Ministerial Ordinance made by the Ministry of Health, Labour and Welfare (MHLW). They are enforced by Labor Standards Inspection Offices (Rōdō Kijun Kantokusho), the local offices under each Prefectural Labor Bureau.

Article 90 of the Act gives Labor Standards Inspection Office chiefs and labor standards inspectors responsibility for administering the Act, and article 91 lets inspectors enter workplaces, question people and inspect books and documents (Industrial Safety and Health Act, e-Gov). MHLW lists the bureaus and inspection offices by prefecture on its locations page.

Every employer must give safety or health education to each worker on hiring (yatoiire-ji kyōiku) and again when the worker's work content changes. Article 59(1) states, in the official English translation: "Having begun to employ a new worker, the employer must educate that worker in safety or health as it relates to the operations in which the worker is to be engaged, pursuant to Order of the Ministry of Health, Labour and Welfare." Article 59(2) applies the same duty when "the substance of the worker's work has changed" (Japanese Law Translation).

Article 35(1) of the Ordinance requires the education to be given without delay (chitai naku) and to cover whichever of the following items are needed for safety or health in the worker's operations (Ordinance on Industrial Safety and Health, e-Gov):

1. The hazards or harmfulness of machinery, raw materials and similar items, and how to handle them.
2. The performance and handling of safety devices, harmful substance control equipment and protective equipment.
3. Work procedures.
4. Inspections at the start of work.
5. The causes and prevention of illnesses that may arise in the work.
6. Keeping the workplace orderly, tidy and clean.
7. Emergency measures and evacuation in accidents.
8. Other matters needed for safety or health in the work.

Article 35(2) lets the employer omit an item for a worker who is recognized as having sufficient knowledge and skill in it. Before April 1, 2024, employers in certain industries could also skip part of the list. MHLW's summary of the chemical substance reforms states that this industry exemption was abolished from that date, so all workplaces that make or handle hazardous chemicals must deliver the chemical safety content (MHLW chemical regulation overview). For onboarding design, see how to structure onboarding for regulated roles.

Special education (tokubetsu kyōiku) is the training an employer must give before assigning a worker to any dangerous or harmful operation listed in the Ordinance. Article 59(3) of the Act requires it, and article 36 of the Ordinance lists the operations in items numbered up to 41, several with sub-items.

• Machinery and vehicles: arc welding (item 3), forklifts with a maximum load under 1 ton (item 5), tail gate lifters on trucks (item 5-4), and small vehicle type construction machinery under 3 tons (item 9).
• Electrical work: work on high voltage or low voltage live circuits (item 4) and servicing vehicles with built in batteries over 50 volts to earth (item 4-2).
• Lifting: cranes under 5 tons (item 15), mobile cranes under 1 ton (item 16) and slinging for loads under 1 ton (item 19).
• Health hazards: oxygen deficient spaces (item 26), specified dust work (item 29) and asbestos work (item 37).
• Automation and height: teaching and inspecting industrial robots within their range of motion (items 31 and 32), scaffolding assembly and dismantling (item 39), rope access work (item 40), and full harness fall arrest work at 2 meters or more where a work platform is hard to provide (item 41).

Article 37 allows a subject to be omitted for a worker with sufficient knowledge and skill in it. Article 38 is the only record rule in this part of the Ordinance: after giving special education, the employer must make a record of the participants, subjects and similar details and keep it for three years. Article 39 leaves the detailed subjects and hours for most listed operations to standards set by the Minister of Health, Labour and Welfare.

Special education is not the same as licensed work. Under article 61 (shūgyō seigen, restrictions on work), operations listed in article 20 of the Cabinet Order, such as forklifts with a maximum load of 1 ton or more, cranes of 5 tons or more and boiler handling, may only be done by holders of a license (menkyo) from the Director of the Prefectural Labor Bureau or people who have completed a registered skill training course (ginō kōshū). Article 61(3) requires the person to carry the license or certificate while working (Cabinet Order, e-Gov). MHLW publishes a combined list of licenses, skill training courses and special education on its qualifications page.

Employers in industries listed by Cabinet Order must educate foremen and other people newly taking on a role that directly guides or supervises workers, known as shokuchō kyōiku. Operations chiefs (sagyō shunin-sha), who hold separate statutory qualifications, are excluded. Article 19 of the Cabinet Order lists construction; manufacturing, except tobacco manufacturing, textiles (other than spinning and dyeing and finishing), clothing and other textile products, and paper products (other than cellophane); electricity; gas; automobile maintenance; and machinery repair.

The scope widened on April 1, 2023, when food manufacturing and newspaper publishing, publishing, bookbinding and printed matter processing were added (MHLW chemical regulation overview). Article 40(2) of the Ordinance sets minimum hours for each topic group:

The total is 12 hours. Article 40(3) allows a topic to be omitted for a person recognized as having sufficient knowledge and skill in it. The Ordinance does not prescribe a record or a refresher cycle for foreman education.

Four further provisions shape a training program in Japan: an effort duty for workers already in hazardous jobs, planning and reporting for designated workplaces, chemical management officers, and the 2025 heat stroke rule.

• Article 60-2 (effort duty): employers "must endeavor" to educate people currently engaged in dangerous or hazardous operations, following a guideline the Minister publishes. It is a duty to make efforts, not an enforceable requirement.
• Ordinance article 40-3 (plans and reports): at designated workplaces, and workplaces the Prefectural Labor Bureau Director designates considering accident rates, the employer must prepare a specific education plan under articles 59 and 60 and report the results for each April to March year to the Labor Standards Inspection Office by April 30.
• Chemical management officers (kagaku busshitsu kanrisha): from April 1, 2024, each workplace that makes, handles or supplies chemicals subject to risk assessment must appoint one (Ordinance article 12-5). Their duties include the education workers need on labels, safety data sheets, risk assessment and exposure measures. At sites that manufacture these chemicals, the officer must have completed a course set by the Minister or be recognized as having equivalent ability (Ordinance article 12-5(3)); MHLW's overview shows that course's curriculum totaling 12 hours (MHLW chemical regulation overview).
• Heat stroke (Ordinance article 612-2): from June 1, 2025, before work likely to cause heat stroke, employers must set up a reporting system and written procedures for responding to symptoms, and make both known to the people doing the work (MHLW Ordinance No. 57 of 2025). This is a communication duty, but in practice it becomes a briefing that should be evidenced.

Failing to give special education is the most serious education breach: article 119 makes a breach of article 59(3) punishable by up to six months of confinement (kōkinkei) or a fine of up to 500,000 yen. Article 119 covers breaches of article 61(1) as well, meaning assigning unlicensed or untrained people to restricted work.

• Hiring and change of work education: article 120 makes a breach of article 59(1), including as applied by 59(2), punishable by a fine of up to 500,000 yen.
• Corporate liability: article 122 fines the company or individual business owner as well as the person who committed the breach, when the breach is in the course of the business.
• Foreman education: article 60 is not listed in articles 119 or 120, so it carries no direct criminal penalty. It is still a mandatory duty that inspectors can cite.

The Japanese text of article 119 now uses kōkinkei, the single custodial sentence that replaced separate forms of imprisonment under Japan's criminal law reform. The English translation, last updated for Act No. 71 of 2018, still reads "imprisonment for a term not exceeding six months". Always check the current Japanese text on e-Gov.

The Act on Partial Amendment of the Industrial Safety and Health Act and the Working Environment Measurement Act (Act No. 33 of 2025), promulgated on May 14, 2025, takes effect in stages, with the last provisions due within five years of promulgation. For training, the key date is April 1, 2027, when a new article 59(4) requires sole proprietors and small business owners who work themselves (sagyō jūji yakuin-tō) to receive special education before doing listed dangerous work at the same site as workers (MHLW key points leaflet).

• Penalty: the comparison table shows article 119 being amended to cover breaches of the new article 59(4) (MHLW comparison of old and new text).
• Effort duty: article 60-2 is rewritten so that employers must endeavor to educate workers currently in hazardous jobs, and the same owners must endeavor to receive such education.
• Guideline: MHLW revised the guideline on education for people in dangerous or harmful work on May 25, 2026, applying from April 1, 2027 (MHLW guideline notice).
• Stress checks: workplaces with fewer than 50 workers must run stress checks from a date set by Cabinet Order, within three years of promulgation.

Principal contractors that manage mixed sites should consider how they will confirm, from April 2027, that owner operators working on site have received special education, not only their own employees. MHLW keeps the commencement orders, ordinances and circulars on its amendment page.

Yes, if it meets the same legal conditions as classroom delivery. An MHLW circular issued on January 25, 2021 and last revised on September 2, 2026 states that e-learning must satisfy the statutory scope of subjects, education hours and instructor requirements, use the necessary teaching materials, and properly confirm that the participant actually took the course (MHLW e-learning circular).

The circular also notes that completion certificates for skill training courses for restricted work under article 61 cannot be issued digitally, because the worker must carry the certificate. For a training team, the practical tests are identity and attendance verification, time on task that meets the minimum hours, and an assessment step that shows the content was understood. These map directly to completion tracking versus competency verification.

A workable approach is to treat each education type as a separate obligation with its own trigger, content source and evidence standard. The table below is illustrative, not MHLW guidance: the "record required by law" column reflects the Ordinance text, and the evidence column is good practice for showing an inspector the duty was met. Adapt it in your own training matrix and compliance obligations register.

For guidance on assembling this evidence, see how to prepare training records for an audit and how to set up verification of competency.

Knowledge Foundry models each article of the Act and Ordinance, each listed operation and each role as linked concepts with defined assessment points, before any training content is written. When a Cabinet Order or Ordinance change adds an industry or operation, as in 2023, 2024 and the 2027 changes, the affected roles and evidence requirements can be traced from the framework rather than rediscovered course by course.