Romania: EWCO comparative analytical report on Information, consultation and participation of workers concerning health and safety in SMEs

  • Observatory: EurWORK
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  • Published on: 21 Deireadh Fómhair 2010



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Disclaimer: This information is made available as a service to the public but has not been edited or approved by the European Foundation for the Improvement of Living and Working Conditions. The content is the responsibility of the authors.

The provisions of the Health and Safety at Work Framework Council Directive 89/391 have been transposed into Romanian law starting with 2006. Among the practical concerns for health and safety at work an important step was made during the institutional twinning programme, PHARE RO 04/IB/SO-01, regarding the 'Implementation of Harmonised Safety and Health at Work Legislation in Small and Medium Enterprises, of which good practices must be more promoted'. However, the information and data regarding health at safety at work in small and medium sized enterprises are still poor.

Background information

The general issue

According to several studies (Walters, 2002, HSE, 2005), Health and Safety management shows significant differences between large companies and SMEs. In these latter, especially among micro-enterprises (less than 10 employees) and small ones (10-49 employees), H&S regulation is a lot of times perceived more as a burden to comply rather than a competitive opportunity because of stronger pressure over costs, company struggle for survival, lack of both financial and human resources. Further, in micro and small firms employers do not always own adequate OSH managerial skills and knowledge and they often see with suspicious the support offered by public agencies.

The extent of workers’ involvement is ambiguous: on the one hand could be easier because of direct relationship with ownership, while lower skills and shorter average tenure and the lack of OSH workplace representatives, due to legal threshold and/or non-unionization, make workers less involved in taking care of H&S on the other.

Regulatory Framework

The Health and Safety at work Framework Council Directive 89/391 introduces general prevention principles applicable to all occupational risks, aimed to ensure a higher degree of protection of workers at work through the implementation of preventive measures to guard against accidents at work and occupational diseases. The directive establishes the obligation on employers to adequately inform (art. 10) and to consult his/her employees and their representatives (art.11) by allowing them “to take part in discussions on all questions relating to safety and health at work”, thus including their right to make proposals and to a balanced participation. Finally, the directive sets an obligation on the employer to adequately train at his expenses his/her employees (art. 12) and their representatives, with regular repeals in order to take into account of technological and organizational changes and to the insurgence or changes of new risks.

The H&S at work strategy 2007-2013 stresses the importance of SMEs, high-risk sectors and subcontracting in achieving the target of a 25% cut of work accidents within 2013: in particular, SMEs are seen as more vulnerable since they have “fewer resources to put complex systems of protection in place, while some of them tend to be more affected by the negative impact of health and safety problems”.

The strategy envisages a simplification and adaptation of the existing legislation to SMEs and various forms of support in its implementation, such as dissemination of good practices, training of employees, development of simple risk assessment tools and guidelines, access to affordable and good quality prevention services, and economic incentives. Labour inspectors should play a twofold role both “as intermediaries to promote better compliance with the legislation in SMEs, primarily through education, persuasion and encouragement” and “when necessary, through coercive means”,

Member States are invited to “take steps to facilitate access to good quality prevention services” particularly in favour of SMEs, to improve health surveillance of workers while avoiding inflating the formal requirements, to incorporate into their national strategies specific measures (financial assistance, training tailored to individual needs, etc.). Further, Member States and the social partners are encouraged to promote “the practical, rapid implementation of the results of basic research by making simple preventive instruments available to enterprises and in particular to SMEs”.

The second programme of Community action in the field of health (2008–2013) and the 2008 "European Pact for Mental Health and Well-being" , together with framework agreements on work-related stress (2004) and violence, bullying and harassment at workplace (2007) show both an important shift from the original notion of H&S, as stated by the 1989 directive, towards a more general “well-being” approach, and the prominent role played by social dialogue in its advance.

Figures and trends

Eurostat figures over work accidents (2002-2006) show the highest incidence rates in medium companies (50-249 employees), while micro-enterprises (1-9 employees) show the highest rates over fatal accidents. These trends seem to depend on the impact of manufacturing, construction and transports, while in the other services industries trends are not so clear-cut. However, Eurostat figures by industry and company size are not complete in order to provide an adequate assessment over time. Further, new risks emerge and work-related diseases (WRDs) evolve from the so-called “hygienic” risk factors towards “psychosocial” ones reflecting changes in working conditions.

Similarly Eurofound 4th EWCS does not show a clear-cut relationship between work accidents, risks for health and work-related diseases with company size. When asked “Do you think your health or safety is at risk because of your work?” (question 32) and “Does your work affect your health, or not?” (question 33), respondents working in small companies (10-49 employees) report the lowest scores. However, the share of respondents not well informed on H&S (question 12) declines from 15.3% in companies with 2 to 9 employees to 11.2% in companies over 250 employees: on average, such a share tend to increase since 1995 (see the full descriptive report). Similarly, both training and involvement over organizational issues are positively correlated with company size and could display indirectly a positive effect on H&S. Composition effects with respect to age (small companies show younger population), and industry (wider proportion of SMEs in services) should be taken into account.

Questionnaire

1. National settings and regulatory framework (max 400 words)

- How is the 1989 Framework directive on H / S and in particular information / consultation practically implemented in SMEs? Any data available? Do administrative reports exist in particular from the Labour Inspectorate?

The provisions of the 'Health and Safety at Work Framework Council Directive 89/391' have been transposed into Romanian law through the Law on Safety and Health at Work no. 319/2006 (effective from 1 October 2006), and Government Decision no. 1425/2006, approving the administrative rules of application of the former.

The Labour Inspection Office (Inspecţia Muncii, IM) Report for 2007 shows that, over the period 1 March 2006 – 30 November 2007, the IM and the Austrian Agency for European Integration and Economic Development conducted an institutional twinning programme, PHARE RO 04/IB/SO-01, regarding the 'Implementation of Harmonised Safety and Health at Work Legislation in Small and Medium Enterprises'.

The general aim of the programme was to develop awareness among employers and employees in SMEs with regard to the importance of implementing the relevant legislation. The programme included six pilot centres opened in small and medium enterprises in sectors like: construction, agriculture, in furniture, chemical, textile & leather industries, and in transport-distribution, designed to function as models of good health and safety at work practices. A risk assessment was made in each such pilot centre, and a plan of action was drawn up for the improvement of working conditions, the observance of which was then monitored.

Based on the experience gained in the pilot centres, a 'H&S Risk Assessment Guideline in SMEs' was put out in 150,000 copies and distributed to employers, together with the 'National Action Plan of the Labour Inspection Office for the period 2007-2012', for promoting effective compliance with risk assessment rules in small and medium sized enterprises.

The results of this research work were fed back to employers and employees by various channels: documentary materials (fliers, posters, and TV spot announcements), information sessions with the participation of employer and employee representatives, labour medicine experts and labour inspectors.

The conclusions can be accessed on the web page of the IM, where, during the project, a special section devoted to health and safety at work in small and medium enterprises was created (http://www.inspectiamuncii.ro/ssmimm/), where information can also be found on the relevant national and European legislation, good European and Romanian practices documented in the six pilot centres, and other informative materials.

- Does its implementation in micro and small companies follow similar patterns than in medium ones?

No information available regarding differences in the patterns of implementation between micro, small and medium companies.

- Is H&S the current focus of legislation or did it evolve by incorporating “well-being at work” as the basic concept?

An important step forward was the enactment of the Law no. 319/2006, which bridged the theretofore approach of the classical 'work protection' legislation (Law no. 90/1996) to the broader concept of 'health and safety at work', which aims at bringing to the core of corporate attention the communication based on mutual trust, the common awareness of the important role health and safety at the workplace can play, and at developing confidence in the efficiency of preventive measures.

The Public Health Institute Bucharest (Institutul de Sănătate Publică Bucureşti, ISPB), which makes an annual report on 'Occupational morbidity in Romania', militates, in its papers, for the necessity to have a strategic approach of the matter from the perspective of the concept of 'well-being at the work place'. Generally, it is argued by the necessity of a polydimensions approach of the health and safety at work, including the physical, mental and social welfare of workers, in order to assure the well-being at work.

The new national strategy on health and safety at work (the speedy implementation of which was demanded by the social partners as part of the anti-crisis measures for 2009), shows that an important part has been assigned to 'recognising the role that healthy and secure work places have in increasing a company’s productivity and competitiveness, and in providing well-being at the work place.'

- The Community strategy health and safety at work for 2007-2012 calls upon the member states to work out and implement strategies to reduce the number of industrial accidents and occupational diseases; are the SMEs specially singled out in the national strategies and cooperation between social partners underlined / foreseen / called for?

The 'National Strategy on Health and Safety at Work for 2008-2013' refers to the growth in the number of SMEs as a 'threat' to implementing the strategy, based on a SWOT analysis.

As a matter of fact, at the debates on the strategy, held in the Commission for Social Dialogue of the Ministry of Labour, Family and Social Protection (Ministerul Muncii, Familiei şi Protecţiei Sociale, MMFPS), the National Council for Private Small and Medium Enterprises of Romania (Consiliul Naţional al Întreprinderilor Private Mici şi Mijlocii din România, CNIPMMR), an employer organisation representative at national level, vetoed the draft as proposed, and demanded, among others, that new specific objective be introduced designed to 'support the SMEs in the implementation of the legislation in force' (through the simplification and adaptation of the existing legislative framework to the specifics of the SME’s, self employed and independent activities, financial aid, programmes for the development of knowledge in health and safety at work matters, etc.).

The project of the strategy contains, in the others an objective regarding 'the identificaton of the most apropiate methods to stimulate the activities of work accidents and occupational diseases prevention, especially for small and mediu sized enterprises'

The strategy emphasises that 'considering that its objective is to bring about a change in values, attitudes and behaviour for all the parties involved in preventing labour hazards – government, employers organisations, trade unions, companies, workers, prevention services providers – the role of social partnership, be it bi or tripartite, is very important'. Therefore, to sustain this, the Strategy proposes to 'intensify the cooperation between the institutions and authorities that have health and safety at work responsibilities, and the social partners'. To achieve this, the strategy suggests that a Tripartite National Committee for Health and Safety at Work be created. Unfortunatelly, at the beginning of 2010 the strategy remains in the phase of project.

In addition to this, the CNIPMMR requested measures to 'put in place a social partnership and effective qualitative social dialogue in work-related H&S matters, through: permanent exchange of information between the three parties on the contents of national strategies, on the objectives and implemented measures; improvement of the legal framework, so as to encourage the growing participation and competence of the social partners in work-related H&S matters; consultation of the SMEs organisations whenever work-related H&S measures are introduced; tripartite monitoring of progress made, including through comparative studies on counterpart work safety standards in other EU Member States; thorough assessment of work-related H&S status in Romania, with the active participation and consultation of all interested parties, particularly of the social partners.

2. The micro-level settings: the role of H&S representatives (max 700 words)

- From what level onwards / number of employees onwards, is it legally binding to establish an H&S Committee in the companies? What’s its role and function?

Government Decision no. 1425/2006 makes compulsory the establishment of an H&S committee in all companies with at least 50 workers. Labour inspectorates may rule that H&S committees be set up in ventures of less than 50 employees, if the nature of the venture’s business and the identified risks so demand.

Labour inspectorates don't provide until now reports regarding the implementation of this provision.

To meet their obligation of informing, consulting and encouraging the participation of workers in H&S matters, such H&S committees have the task to:

  • analyse and make proposals regarding the health and safety policy, and the plan for the prevention and protection at work, according to the venture’s internal rules of order or by-laws;

  • monitor compliance with the prevention and protection plan, provide for the allocation of the means required for compliance, and assess efficiency of both for the purpose of improving working conditions;

  • analyse the possibility of introducing new technologies, the choice of new equipment, with due consideration for the consequences such changes may have for the workers’ health and safety at work; make proposals for remedial measures;

  • analyse the choice, purchase, maintenance, and use of working equipment, and of the individual and collective labour protection devices;

  • analyse how the external provider of labour protection and prevention services carries out its duties, and advise on its further retainer or replacement;

  • propose measures for the organisation of work places, with due consideration, where applicable, for the groups that are vulnerable to specific risks;

  • analyse the complaints received from workers with regard to working conditions, and to how the persons and/or the independent supplier of H&S services fulfil their duties;

  • verify that the H&S provisions, and the measures ruled by the labour inspector and health inspectors are complied with;

  • analyse the workers’ proposals on how labour accidents and occupational hazards should be prevented, on how working conditions should be improved, including the risk assesment; based on this, propose measures for the improvement of working conditions, and their addition to the prevention and protection plan;

  • investigate into work accidents, professional diseases, and other hazards, and propose technical measures based on such investigation;

  • verify that its own directives and the working instructions are complied with, and make a written report on its findings;

  • debate the written report submitted to it at least once a year by the head of the corporate entity, with regard to the H&S status, the actions taken to this effect, the effects of such actions in the reporting year, and the proposals for the prevention and protection plan for the following year.

- From what level onwards / number of employees onwards are risk prevention representatives elected? Are they distinct representatives from H&S Committee and work councils?

Law no. 319/2006 and Government Decision no. 1425/2006 stipulates that the risk prevention representatives are elected by and from the employees in all companies, regardless of the size of the company.

These persons are also members of the H & S Committee, founded in the companies with more than 50 employees. The labour inspector may request the establishment of H & S Committee in companies with less than 50 workers, related to the content of activities and identified risks.

- Does the H&S Committee deal with individual health related complaints? Does it have the right to initiate action?

Yes, it does. According to Government Decision no. 1425/2006, the H&S committee must examine the complaints made by workers against working conditions and the H&S internal officers and/or the external supplier of H&S services, and may verify how its own instructions and the working instructions are complied with, submitting then its written findings to the employer.

- Do regional/territorial risk prevention representatives exist, covering several small SME’s?

No data available.

- Is there special H&S training foreseen for OSH representatives/committees? Is it adequate in order to cope with both emerging risks and legislative and technological changes in SMEs?

OSH representatives must fulfil a number of minimal training requirements:

  • be high school graduates – sciences stream or technology stream;

  • be graduates of an H&S course of at least 40 hours and a curriculum including at least: the general legal framework and concepts related to H&S; knowledge about general hazards and their prevention; knowledge of the hazards specific for the industrial sector they are called to cover, and means to prevent them; knowledge of first aid techniques.

- In order to carry out prevention policies, does a right exist for the H&S Committee to carry out surveys, call in outside independent experts? Who finances the costs of the operations / expertise? Does this right exist also in SMEs?

The H&S committees may conduct their own internal inquiries.

The current legislation makes no explicit provision regarding the possibility of consulting independent experts (except for labour inspectors), nor how the costs incurred in doing so should be covered.

- Does the H&S Committee have the right to consult the Labour Inspectorate?

Government Decision no. 1425/2006 provides that labour inspectors may be invited to attend the meetings of the H&S committees.

- Does regular reporting, annual reports exist which describe enterprises occupational diseases, assess the occupational risks at the workplace and present prevention policies? Are they submitted to the H&S Committee for discussion before publication?

According to Government Decision no. 1425/2006, an employer must submit, once a year, to the H&S committee, a written report that should reflect: the H&S status in the company; actions taken during the year and an assessment of their efficiency; proposals for the prevention and protection plan for the following year. The report, endorsed by the H&S committee must be further submitted, within the first ten days of the following year, to the local labour inspectorate.

The employer must also inform the H&S committee of the conclusions regarding the health and work safety hazards, the measures to prevent and protect taken at company and workplace levels, the first aid measures put in place, the fire control, fire fighting, and worker evacuation measures.

- Is the H&S Committee, when providing a high standard of working conditions and of occupational health and safety seen as a positive competition factor? Can the image of the companies be regarded as important in the context for winning major contracts? Do companies refer to the activities of the H&S Committee in their Annual report of activities, to the existence of day-to-day bargaining and the management of working conditions by the H&S Committee? Do and how differ the approaches between micro/small, medium and large companies?

In general, small and medium enterprises do not release annual reports, and less so information on their H&S policies and activities. From the information available to us, the only public reports coming from SMEs are those issued by the six pilot centres during the institutional twinning programme PHARE RO 04/IB/SO-01 regarding the 'Implementation of Harmonised Safety and Health at Work Legislation in Small and Medium Enterprises'.

Such information can be found also in the documentary materials presented by various companies during the campaigns for 'Safer, Healthier and More Productive Jobs' called by the Romania Centre of the European Agency for Safety and Health at Work (EASHW), by IM or the National Institute for Research in the field of Labour and Social Protection (Institutul Naţional de Cercetare Ştiinţifică în Domeniul Muncii şi Protecţiei Sociale, INCSDMPS).

No data available regarding the importance of good H&S practices as a competition factor.

3. Social partners and the role of collective bargaining (max 300 words)

Please summarize specific arrangements on H&S for SMEs and SME-dominated industries, and how territorial OSH representatives could intervene at workplace.

The only agreement that explicitly provides solutions for H&S problems in SMEs is the agreement signed by the social partners in the construction sector: 'Sectoral Social Agreement in Construction Sector for 2007-2009' (RO0702059I).

Under this agreement, the Builders’ Social Fund (Casa Socială a Constructorilor, CSC), a bipartite body set up by the social partners in this sector, has for a purpose to:

  • promote and permanently improve H&S techniques, until occurrence drops to ‘nil’, and to minimise their effects, when they occur;

  • conduct awareness campaigns among building site workers on potential hazards, applicable health and safety measures, through ad-hoc inspections and briefings on site, with the aid of their own mobile teams;

  • perform building site auditing and certification and provide compliant sites with a ‘green spot’ certificate, as a proof of good practice;

  • provide consultancy services to construction companies for the purpose of diminishing hazards, and improving health and safety at work;

  • organise top quality continuous vocational training programmes (through the Construction Workers’ Guild, the Office for Safety of Working Environment, etc.), in order to enhance the value of labour force both on the domestic and the international markets.

What is the role of Social partners in drawing guidelines and implementing H&S and work organization intervention aimed to prevent work accidents and WRDs? What is the role of labour inspectorates, social security institutions, OSH services and national agencies in promoting local-level experiences in SMEs? Please summarize, if there exist, the extent of the cooperation between these latter and social partners.

As a rule, both the IM and the EASHW have involved in their actions representatives of the social partners. Their opinion was sought during the drafting of the national strategy for health and safety at work, during the writing of the 'H&S Risk Assessment Guideline in SMEs'. For the implementation and monitoring stage of the strategy, the proposal has been made to set up a Tripartite Committee for Health and Safety at Work (yet to be validated).

During the PHARE RO 04/IB/SO-01 institutional twinning programme the representatives, both local and national, of the social partners were constantly invited to take part and to be consulted.

Another example of involvement of the social partners are the campaigns for 'Safer, Healthier, and More Productive Jobs' conducted by the Romania Centre of the EASHW, in cooperation with the IM and INCSDMPS, for the purpose of promoting safety and health at work, transfer of knowledge, access to concrete instruments and useful information in the management of occupational hazards, and for the purpose of protecting health and increasing productivity in small and medium enterprises.

4. Figures, quantitative and qualitative studies. (max 800 words)

Are there specific surveys which prove that standards of working conditions, health and safety within small enterprises as compared to larger ones are significant lagging behind?

No information is available on surveys containing evidence that H&S standards in the SMEs are different from those in large companies. The ad hoc module of 'Household Labour Force Survey' on health and safety at workplace in the second quarter 2007, provided by the National Institute of Statistics (Institutul Naţional de Statistică, INS) don't provide data by enterprise size.

But statements on such differences do appear quite often in the press releases of the IM, without, however, details on what the differences are. The releases only stress that more, substantive, support must be rendered to the SMEs from this point of view, because they form the bulk of the Romanian economy, and because one of their common trait is the lack of financial and human resources that would enable them to provide best working conditions.

While debating the main objectives of the 'National Action Plan of the Labour Inspection for the period 2007-2012, for Promoting Effective Compliance with Risk Assessment Rules in Small and Medium Enterprises', the surveys carried by the IM revealed the existence of significant deficiencies with respect to compliance with the relevant legislation, and estimated that the amount required to improve compliance in some 30% to 50% of these enterprises is in the region of EUR 150-300 per worker, totalling some EUR 0.6-1.2 billion for all companies across the entire Romanian economy.

The main reasons behind these findings, according of raports of control provided by IM, are the lack of financial human ressorces in small and medium sized enterprises as comparing with the big ones. The number of fatal work accidents in companies with less than 50 employees is twice biger than the number registered in big companies.

The importance of the problem is motivated also by the proportion of this segment in the economy: SMEs accounted 90% of the total number of companies and more than 60% of the number of workers in economy.

Do these surveys also investigate the impact of training, information and consultation over working conditions also in SMEs?

No data available.

When surveys lack, are there qualitative studies investigating the impact of involvement and training on working conditions and health in SMEs?

An evaluation of the SME representatives that took part in the 10 information sessions on H&S at work, held during the institutional twinning programme PHARE RO 04/IB/SO-01, revealed the lack of knowledge and of specific training in risk assessment and prevention techniques.

The results of the information, consultation, and vocational training activities in the six pilot centres were considered positive and posted on the IM site, with the proposal of extending the procedures used in the six pilot centres to all sectors of the national economy, and of involving all local labour inspectorates.

In general, the press releases of the IM representatives, the documentary materials resulting from the campaigns for 'Safer, Healthier, and More Productive Jobs' conducted by the Romania Centre of the EASHW and INCSDMPS, sometimes in cooperation with the CNIPMMR, provide information on the various dimensions of the impact of involvement and training on health and working conditions in the SMEs, without, however, providing quantitative figures.

Develop on the findings / results. Please mention / enumerate / give links.

Details can be found in the presentation titled 'Dynamic of occupational hazards in SMEs in 2007', delivered by an IM representative at the seminar held in Bucharest, 2007, and available at http://imm.protectiamuncii.ro/bucuresti2007/ , during the 'Safer, Healthier, and More Productive Jobs' campaign organised by the Romania Centre of the EASHW.

According to study, the work accidents frequency index (number of injured persons at 1,000 employees) at national level was 0.96, as comparing 1.48 for medium sized companies; for the persons with length of service less than one year the frequency index was 0.32 at national level and 0.58 for medium sized enterprises and 0.5 for small enterprises. The sectoral distribution of the injured persons revealed a higher frequency index for small and medium sized enterprises than the national average in agriculture, construction and transport.

5. Good practices for SMEs: company/territorial level (max 200 words)

Are there well known examples for specific collective agreements in a given sector covering working conditions, H&S in particular in SME’s which go far beyond legislation? Are they exceptions or the rule? Please report at least one example at national level and at least two at territorial/company level.

The good practices applied in the six pilot centres in various areas of the country, that were organised during the institutional twining programme PHARE RO 04/IB/SO-01 are available in a special section of the IM web site, devoted to labour health and safety in SMEs, at http://www.inspectiamuncii.ro/ssmimm/p7.html.

The presentation includes information on the six small and medium enterprises in the construction, agriculture, furniture, chemical, textile & leather, and transport-distribution sectors, as model enterprises where the best practices on health and safety at work were identified.

The presentations on good practices in these pilot centres feature data on: how the activities for the prevention and protection at work are organised, the contents of the prevention and protection plans, its effects, forms of cooperation between employer and employees for the purpose of improving health and safety issues at work.

For example, SC DANBRED Arges (Arges county, South region), from agriculture sector, were identified: a global approach of the well-being at workplace taking into account the new emerging risks; preoccupations to strengthen of the employer responsibility in order to assure the health and safety at workplaces for all the employees taking into account the general principle of prevention; a specialised department with tasks in the field of information the employees regarding enforcement the measures in the field of safety at work; the evaluation of an annual report on workers' health, the incidence of medical leaves and occupational diseases.

At SC FILOCONSTRUCT Sarichioi (Tulcea county, South-East region), developing activities in construction sector, the prevention activities are developed by: an appointed worker; an externalised service of prevention and protection activities; the committee for health and safety at work; three representatives of workers.

Each site of the company has its own plan for health and safety at work, a coordinator for this plan, and the representatives of the workers, specific rules regarding each workplace, different contents of training programmes in the field of health and safety and specific knowledge, periodically tested.

References

  • HSE (2005), Obstacles preventing worker involvement in health and safety. Research Report 296. http://www.hse.gov.uk/research/rrpdf/rr296.pdf

  • Walters D. (2002), Regulating health and safety in small enterprises. PIE, Peter Lang, Brussels

PhD Constantin Ciutacu, Institute of National Economy, Romanian Academy

[1] Question 28a_1 “Have you undergone: Training paid for or provided by your employer, or by yourself if you are self-employed?”; Question 28a_2: “Training paid for or provided by your employer, or by yourself if you are self-employed - number of days”; question 28b_1. “Have you undergone: Training paid for by yourself?”; question 28b_2. “Training paid for by yourself - number of days”; question 28c: “Have you undergone: On-the-job training?”; question 28d. “Have you undergone: Other forms of on-site training and learning?”

[2] Question 30b: “Over the past 12 months have you been consulted about changes in the organisation of work and / or your working conditions?”; question 30d. “Over the past 12 months have you discussed work-related problems with your boss?”

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