Korea Enterprises Federation warns honorary safety inspectors could become union leverage tool, calls for caps

The Korea Enterprises Federation called on the government Monday to revise a recently amended Occupational Safety and Health Act that removed limits on the number of honorary industrial safety inspectors workers can nominate. The federation warned that appointing honorary inspectors en masse could allow unions to exploit work-stoppage requests and workplace inspection participation as bargaining tools — contrary to the system's original purpose of broadening worker participation in safety.

The federation said it submitted a formal reform proposal on the honorary industrial safety inspector regime to the Ministry of Employment and Labor on Monday.

Honorary industrial safety inspectors were introduced to promote voluntary accident-prevention efforts at worksites. They may participate in labor inspectors' workplace audits, demand safety measures from employers, and request work stoppages when they judge there to be an imminent risk of industrial accident. They are also authorized to request emergency health screenings and to guide workers on safety compliance.

The controversy stems from amendments to the Occupational Safety and Health Act and its subordinate regulations that took effect Saturday. Under the previous law, the minister of employment and labor "may appoint" individuals recommended by worker representatives as honorary inspectors; the amended law changed that to "shall appoint."

A procedural requirement for worker representatives to consult employers before nominating candidates was also removed. The ministry's internal rule mandating a limit of one honorary inspector per workplace was likewise deleted. The result, the federation said, is a structure in which worker representatives can nominate an unlimited number of candidates and the government is obligated to appoint them all. The amendments also newly require that honorary inspectors at a given workplace participate when the ministry conducts an audit there.

The federation warned that the removal of numerical limits could prompt mass nominations aimed at boosting leverage in wage and collective bargaining negotiations rather than advancing workplace safety. Such moves are already emerging at some manufacturing sites. One manufacturer, identified only as Company A, is reportedly preparing to nominate hundreds of workers as honorary inspectors, while another, Company B, is considering nominating its entire workforce — potentially tens of thousands of people.

If honorary inspectors are appointed in large numbers, the federation said, a flood of work-stoppage requests could disrupt normal production schedules and process management. While hazards are assessed and addressed, production delays would mount, and the resulting pressure to recover lost output by increasing workloads could paradoxically raise the risk of accidents.

The federation also said workplace inspection efficiency could suffer. With many honorary inspectors offering conflicting opinions, on-site reviews by labor inspectors could drag on, and the existing safety management chain of command — including safety and health managers and supervisory personnel — could face confusion.

The federation further raised concerns that normal personnel and labor management could become subject to disputes. The Occupational Safety and Health Act prohibits employers from treating honorary inspectors unfavorably because of their duties. The federation said even legitimate performance evaluations or job reassignments could be challenged as "unfavorable treatment," and conflicts over how much of inspectors' activity time qualifies for paid leave could also grow.

The administrative burden on the Employment and Labor Ministry is also expected to increase. Regional employment and labor offices must process nomination documents, issue appointment certificates and inspector credentials, and handle appointment notifications and future dismissal reviews. Because the government must also operate regional and industry-specific honorary inspector councils and provide training at least once a year, a sharp rise in the number of appointees would expand both the budget required and the workload involved.

As a minimum safeguard against the system's potential side effects, the federation proposed setting caps based on workplace size — one for workplaces with fewer than 1,000 workers, up to three for those with between 1,000 and 10,000 workers, and up to five for those with 10,000 or more.

The federation also called for reinstating a requirement that worker representatives obtain employer consent before nominating candidates. It further proposed tightening nomination rules to require submission of a statement of reasons, a work plan, and a record of safety and health experience and activities, in order to screen for candidates with relevant expertise.

If amending the law takes time, the federation asked the ministry to first revise its internal rules to recommend appropriate caps by company size. The proposal also called for allowing regional employment and labor offices to request supplementary documents when nominations are incomplete, and for extending the appointment processing period to up to six months to handle large-scale nominations.