Enforcement of Occupational Safety Health OSH at Workplaces by DOSH

T H E R E P U B L I C O F U G A N D A
OFFICE OF THE AUDITOR GENERAL
www.oag.go.ug | E-mail: info@oag.go.ug
WORK
SAFTEY
FIRST
ENFORCEMENT OF OCCUPATIONAL SAFETY AND

HEALTH ACTIVITIES AT WORKPLACES BY THE
DEPARTMENT OF OCCUPATIONAL SAFETY AND
HEALTH UNDER THE MINISTRY OF GENDER
LABOUR AND SOCIAL DEVELOPMENT
A REPORT BY THE AUDITOR GENERAL
D E C E M B E R , 2 0 1 6
THE REPUBLIC OF UGANDA
ENFORCEMENT OF OCCUPATIONAL SAFETY

AND HEALTH ACTIVITIES AT WORKPLACES BY
THE DEPARTMENT OF OCCUPATIONAL SAFETY
AND HEALTH UNDER THE MINISTRY OF
GENDER LABOUR AND SOCIAL DEVELOPMENT
A REPORT BY THE AUDITOR GENERAL
DECEMBER, 2016
ENFORCEMENT OF OCCUPATIONAL SAFETY AND HEALTH ACTIVITIES AT WORKPLACES BY THE DEPARTMENT OF OCCUPATIONAL
4
SAFETY AND HEALTH UNDER THE MINISTRY OF GENDER LABOUR AND SOCIAL DEVELOPMENT | A REPORT BY THE AUDITOR GENERAL
AUDITOR GENERAL
AUDITOR GENERAL’S MESSAGE
31st December 2016
The Rt. Hon. Speaker of Parliament

Parliament of Uganda
Kampala
ENFORCEMENT OF OCCUPATIONAL SAFETY AND HEALTH

ACTIVITIES AT WORKPLACES BY THE DEPARTMENT OF
OCCUPATIONAL SAFETY AND HEALTH UNDER THE MINISTRY OF
GENDER, LABOUR AND SOCIAL DEVELOPMENT
In accordance with Article 163 (3) of the Constitution, I hereby submit my

report on the audit undertaken on enforcement of occupational safety
and health activities at workplaces by the Department of Occupational
Safety and Health under the Ministry of Gender, Labour and Social
Development
My office intends to carry out a follow – up at an appropriate time
regarding actions taken in relation to the recommendations in this
report.
I would like to thank my staff who undertook this audit and the staff
of the Ministry of Gender, Labour and Social Development for the
assistance offered to the audit team during the period of the audit.
John F. S. Muwanga
AUDITOR GENERAL
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TABLE OF CONTENTS
TABLE OF CONTENTS
6
TABLE OF CONTENTS
LIST OF TABLES..................................................................................................................... ii
LIST OF FIGURES................................................................................................................... ii
LIST OF ACRONYMS............................................................................................................... iii
EXECUTIVE SUMMARY........................................................................................................... iv
CHAPTER ONE
INTRODUCTION
1.1 Background............................................................................................................... 2
1.2 Motivation.................................................................................................................. 2
1.3 Description of the audit area.................................................................................... 3
1.4 Overall audit objective............................................................................................... 5
1.5 Specific audit objectives............................................................................................ 5
1.6 Audit scope................................................................................................................ 5
CHAPTER TWO
AUDIT METHODOLOGY
2.1 Sampling................................................................................................................... 7
2.2 Data collection methods........................................................................................... 7
CHAPTER THREE
SYSTEMS AND PROCESS DESCRIPTION
3.1 Roles and responsibilities of key players................................................................ 11
3.2 Process description................................................................................................. 12
CHAPTER FOUR
FINDINGS, CONCLUSIONS AND RECOMMENDATIONS
4.1 Registration of workplaces and equipment certification....................................... 17
4.2 Inspection and monitoring of osh activities............................................................ 21
4.3 Osh training and sensitization................................................................................. 26
GLOSSARY OF TERMS........................................................................................................... 30
APPENDICES......................................................................................................................... 31
Appendix I: Organizational Structure of DOSH.................................................................... 31
Appendix II: Workplaces Sampled/Inspected by the Audit Team........................................ 32
Appendix III: Tools and testing equipment required for OSH inspections.......................... 33
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LIST OF TABLES
Table 1: Showing funding to Department of OSH................................................................. 5
Table 2: NTR collected from workplaces over the three (3) year period............................ 17
Table 3: Showing the delay by workplaces to renew registration certificates................... 18
Table 4: Showing the delay to renew equipment certificates.............................................. 19
Table 5: Comparing total inspections conducted from different sources of the DOSH.... 21
Table 6: Showing level of compliance with OSH requirements at the sampled
workplaces........................................................................................................................... 23
Table 7: Showing inspection reports presented to the audit team..................................... 25
LIST OF FIGURES
Figure 1: Processes for management of occupational safety and health activities.......... 12
Figure 2: Trend analysis of workplace registration and NTR collected............................. 18
Figure 3: Showing some of the procured but unutilized OSH equipment at DOSH........... 22
Figure 4: Showing status of compliance of PPE by workers at some workplaces visited...... 23
ii
LIST OF ACRONYMS
COFTU Central Organization of Free Trade Unions
DOSH Department of Occupational Safety and Health
DLG District Local Government
MPS Ministerial policy statement
FUE Federation of Uganda’s Employers
IFMS Integrated Financial Management System
ILO International Labour Organization
KCCA Kampala Capital City Authority
MoGLSD Ministry of Gender, Labour & Social Development
MDAs Ministries, Departments and Agencies
NTR Non Tax Revenue
NOSHP National Occupational Safety and Health Policy
NOTU National Organization of Trade Unions
OSH Occupational Safety and Health
OSHMIS Occupational Safety and Health management Information System
PPE Personal Protective Equipment
SSASHEW Strengthening Safeguards, Safety and Health at Workplaces
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EXECUTIVE SUMMARY
Occupational safety and health (OSH) is defined as the science of anticipation, recognition,
evaluation and control of hazards arising in or from the workplace that could impair the
health and wellbeing of workers, taking into account the possible impact on the surrounding
communities and the general environment1. OSH therefore deals with the prevention of
work-related injuries and diseases as well as the protection and promotion of the health of
workers. It aims at the improvement of working conditions and environment.
In Uganda, the Ministry of Gender, Labour and Social Development through the Department
of Occupational Safety and Health is responsible for administration and enforcement of the
Occupational Safety and Health Act, No 9, 2006.
Despite government efforts to improve safety and health of all workers in the country through
funding enforcement of OSH activities, repealing of the Factories Act, 1964 that led to the
enactment of the OSH Act, 2006 and statutory instrument No. 87 (2014), limited impact has
been registered due to inadequate enforcement of the OSH Act 2006.
Although Uganda’s economy has registered a number of achievements, various aspects of
occupational safety and health (OSH) have not been adequately addressed. Management of the
OSH issues at workplaces continue to be left unattended to by different sectors of government
and private sector. Currently Uganda’s labour productivity is the lowest in East Africa due
to poor working conditions as one of the factors identified by the Social Development Sector
Investment Plan II 2011/12 to 2015/16.
The Office of the Auditor General undertook a value for money audit on the enforcement
of Occupational Safety and Health activities at work places by the MoGLSD, to identify the
challenges faced, analyse their underlying causes and make recommendations to address
them.
KEY FINDINGS
1) Registration of workplaces and equipment certification
Registration of work places

It was noted that out of the estimated one million work places in the country, only 756 were
registered by the MoGLSD as at 30th June 2015. It was further noted that of the 756 workplaces
registered, none was a government entity.
It was also established that 39 of the workplaces registered by the Department of Occupational
Safety and Health (DOSH) from 2010 to 2012 had not renewed their certificates as at 30th June
2015 yet their statutory period of renewal had elapsed. There were also delays by workplaces
to apply for renewal of their registration certificates.
1 ILO Fundamental Principles of Occupational Health and Safety
iv
Plant Examination and Equipment Certification
The statutory period for renewal for a number of equipment certified between 2012 and 2015 had
elapsed as at 30th June 2015. There were also notable delays by workplaces to apply for renewal of
their equipment certification.
2) Inspection and monitoring of OSH activities

Out of the estimated one million work places in the country, only 476 were inspected over the three (3)
years under review ,broken down as 212,125 and 139 in the FY 2012/13, 2013/14 and 2014/15, respectively.
It was further established that whereas the Ministry procured analytical and clinical laboratory equipment
worth UGX 509,702,346 to facilitate inspections, and laboratory analysis and testing in April 2014, the
Department has neither a designated analytical nor clinical laboratory for analysis and testing; and the
Department has not fully trained the inspectors on the use of the equipment, given their complexity.
3) OSH training and sensitization

Although DOSH carries out sensitization through print and electronic media, breakfast meetings with
media houses, commemorating world day for safety and health at work (28th April), and gazetting of the
national OSH week before 28th April every year. It was noted that more emphasis is put on workplace
registration which has resulted into limited awareness of OSH at the workplaces.
4) Coordination mechanisms
Coordination with NEMA on review of Environmental Impact Assessments (EIAs)
Out of 1,624 EIAs approved by NEMA during the 3 years under review, MoGLSD reviewed only 92 EIAs
representing 5.7% of the reports, leaving 1,532 EIAs (94.3%) not reviewed.
Coordination with Local Governments on approval of architectural drawings/ plans

The Department of Occupational Safety and Health reviewed and approved only 75 building plans from
Kampala, Wakiso, Entebbe, Mukono and Lyantonde districts, and realized UGX 67,700,000 from approval
fees. It was also noted that there was a conflict of mandates in the OSH Act and the Physical Planning
Act, 2010. While Section 42 of the OSH Act, 2006 requires all local governments and developers to submit
architectural drawings/plans to the Department of OSH (DOSH) for review and approval, the Physical
Planning Act, 2010 does not provide for submission of these plans to DOSH for review and approval.
Coordination with Ministry of Health and Uganda Police on occupational injuries and diseases
It was noted that there was limited information sharing between the three bodies regarding statistics
of occupational-related accidents, diseases, injuries and fatalities. As a result the DOSH did not have
an up to date database relating to occupational accidents, injuries and diseases.
KEY RECOMMENDATIONS
1. The MoGLSD should develop a comprehensive strategy to ensure that all workplaces are registered
and registration certificates are renewed upon expiry. This strategy should provide for the following
aspects among others:
• Extensive and sustained sensitisation about the importance of workplace registration and equipment
certification;
• Close collaboration with other government agencies to keep track of existing and new workplaces
that require to register; and
• Invoke the penalty clauses for non-compliance so as to ensure OSH compliance at workplaces.
Where the penalty is not punitive, the Ministry should bring up this anomaly for consideration when
the OSH Act is being reviewed.
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2. Develop and implement a systematic risk regarding registration of new workplaces
assessment criteria to identify and assess and promotion of OSH through chain-linkage
OSH hazards, and prioritize workplaces for engagement and information-sharing.
inspection to enable the Ministry provide 10. MoGLSD, in collaboration with NEMA and
assurance that the available resources are District Local Governments, should plan
used to carry out the most critical inspections. for and review all EIAs and Architectural
3. Put in place mechanisms to maximize the drawings/plans, respectively, in order to
number and impact of workplace inspections improve OSH measures, identify upcoming
through informed planning for inspections workplaces and collect NTR.
and ensuring that feedback is given following 11. MoGLSD should engage Ministry of Health and
inspections. the Uganda Police Force to obtain up/to/date
4. Enforce penalties and sanctions for non- information relating to occupational-related
compliant workplaces as indicated in the accidents, diseases, injuries and fatalities
inspection reports. In addition, where the so as to ascertain the trends of accidents,
penalties are not deterrent, the Ministry should injuries and diseases which will enable it
consider including this issue as it reviews the develop and implement interventions aimed at
OSH Act. minimizing occupational accidents, diseases
5. MoGLSD should liaise with the Ministry of and injuries.
Public Service to fill the staffing gaps and 12. MoGLSD should also establish a framework
also strengthen collaboration with other for a coherent and comprehensive National
government organs namely, districts as these Safety and Health data management system.
have labour officers who can be used to further
enforce OSH through inspections and follow
up. OVERALL AUDIT CONCLUSION
6. The MoGLSD should develop a framework
The Occupational Safety and Health Act, 2006, was
for OSH training, awareness and information
enacted by Parliament to provide for the right of
sharing at all levels and also enhance
persons to work under satisfactory, safe and healthy
cooperation with civil society organizations
conditions. However, despite the existence of the
(NOTU, COFTU and FUE) to train and sensitize
Act, many workers in Uganda are not aware of their
employers, workers and the general public in
rights to a safe and healthy working environment
all aspects of OSH, rather than focusing only
and have remained exposed to unhealthy working
on registration to promote a safety culture of
conditions, faulty plants and equipment, dangerous
managing risks and hazards at work places.
civil works and constructions leading to ill health
7. The MoGLSD should also fast track the approval
and death.
of the National OSH policy. This will create
awareness on how work-related accidents
Enforcement of the OSH legislation has not
and diseases can be prevented and provide for
been effective due to inadequate awareness
equitable compensation benefits to those who
and sensitization on OSH standards, limited
are injured or contract occupational diseases.
personnel and logistics, absence of the National
8. To enhance the current coordination efforts,
OSH Policy and an OSH Laboratory to analyze
MoGLSD should consider entering into
exposure measurement samples and to test
memoranda of understanding with the various
personal protective equipment. There is need
Agencies (NEMA, District local governments,
for the MoGLSD to develop a framework for OSH
Ministry of Health and Uganda Police) to
training, awareness and information sharing at
spell out their roles, responsibilities and
all levels as well as enhance cooperation with civil
expectations in the workplace occupational
society organizations (NOTU, COFTU and FUE) to
and safety value chain.
train and sensitize employers, workers and the
9. MoGLSD should follow up with stakeholders to
general public in all aspects of OSH.
ensure the implementation of resolutions made
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1
CHAPTER ONE
CHAPTER ONE
1
CHAPTER ONE
INTRODUCTION
1.1 BACKGROUND
Occupational safety and health (OSH) is defined as the science of anticipation, recognition, evaluation
and control of hazards arising in or from the workplace that could impair the health and wellbeing of
workers, taking into account the possible impact on the surrounding communities and the general
environment2. OSH therefore deals with the prevention of work-related injuries and diseases as well
as the protection and promotion of the health of workers. It aims at the improvement of working
conditions and environment.
In Uganda, the Ministry of Gender, Labour and Social Development through the Department of
Occupational Safety and Health, is responsible for administration and enforcement of the Occupational
Safety and Health Act, No 9, 2006 through registration of work places, inspection and monitoring of
OSH activities at workplaces, education, training and creating awareness through dissemination of
information on occupational safety and health among workers, employers and the general public.
1.2 MOTIVATION
According to the ILO statistics presented on the World Day for safety and health at work on 28th
April 2016, 6,300 people die every day as a result of occupational accidents or work-related diseases,
more than 2.3 million deaths per year. 317 million accidents occur on the job annually; many of
these resulting in extended absences from work. The human cost of this daily adversity is vast and
the economic burden of poor occupational safety and health practices is estimated at 4 per cent
of global Gross Domestic Product each year.
The ILO aims to create worldwide awareness of the dimensions and consequences of work-related
accidents, injuries and diseases and to place the health and safety of all workers on the international
agenda and to stimulate and support practical action at all levels.
Despite global efforts to address OSH concerns, these work-related accidents still occur each
year. Continued and renewed efforts are therefore required to address this challenge.
In Uganda, the Occupational Safety and Health Act, 2006 requires employers to compensate their
workers in case they suffer work related injuries.3 Uganda is also a signatory to the ILO conventions
and the ILO standards that require workers to be protected from sickness, disease and injury
arising from their employment. The preamble of the ILO Constitution specifically provides that
“the protection of the worker against sickness, disease and injury arising out of employment” is a
fundamental element of social justice. Uganda has not developed its own standards on occupational
safety and health but uses a mixture of ILO standards and those of the United States.4
Despite existence of the Occupational Safety and Health Act, 2006 and the ILO standards, many
2 ILO Fundamental Principles of Occupational Health and Safety
3 Occupational Safety and Health Act, No 9 2006
4 Occupational Safety and Health Profile for Uganda page 36
2
workers in Uganda are not aware of their rights to a safe and healthy working environment
and have remained exposed to unhealthy working conditions, faulty plant and equipment,
dangerous civil works and constructions leading to ill health and death.5 As a result, when they
are injured or fall sick due to the poor conditions at the workplace, or die on duty, employers
take advantage of their ignorance of the law and do not compensate them.
In addition, due to inadequate awareness and sensitization on OSH standards, limited personnel
and logistics, enforcement of the OSH legislation has not been effective. For example while
the ILO standard of inspector to worker ratio is 1:500, in Uganda, the population employed
is estimated at 7.9 million6 as compared to the 18 inspectors7, which implies an inspector to
worker ratio of 1:438,889 . This is compounded by the absence of the National OSH Policy and
an OSH Laboratory to analyze exposure measurement samples and to test personal protective
equipment, such as respirator cartridges or glove resistance to chemicals.8
Work place accidents have been manifested in perpetual occurrences of fire outbreaks,
collapse of walls at construction sites and emerging work related illnesses. For example, the
most up to date records in the Ministry of Gender, Labour and Social Development indicated
that 1,520 people were injured at various workplaces in Uganda from 2006 to 2008 and 856
workers contracted various occupational diseases and illnesses in the year 2007 alone. Also to
note is that from 2008 to 2009, over 40 buildings collapsed killing and injuring many workers
in Uganda9. There have also been reports of fires in several buildings/ workplaces all over the
country. Cases include Haruna towers in Wandegeya in 2014, Olam Uganda Limited Namanve
in 2013, and Crest form in 2015, among others10.
There have also been reports of non-compliance with occupational safety and health requirements.
For example, it was reported that the Ministry of Gender, Labour and Social Development
threatened to close 300,000 institutions over non-compliance with Occupational Safety and
Health requirements. The compliance rates across the country stand at 30% whreas in
government institutions compliance stands at 45%11.
It is against this background that the Office of the Auditor General found it necessary to
conduct an audit on the enforcement of Occupational Safety and Health activities at work
places by the MoGLSD, identify the challenges faced, analyse their underlying causes and
make recommendations to address them.
1.3 DESCRIPTION OF THE AUDIT AREA

1.3.1 Legal Framework and Mandate for enforcement of OSH
The Occupational Safety and Health Act, 2006, was enacted by Parliament in fulfilment of
the constitutional obligation to enact laws to provide for the right of persons to work under
satisfactory, safe and healthy conditions12. Sections 3 and 4 of the Act mandate the Commissioner
OSH and any other inspectors appointed under the Act to administer and enforce its provision.
5 Occupational Safety and Health issues in Uganda Feb 4th, 2008

6 UBOS Statistical Abstract, 2015 page 25
7 FY 15/16 Staffing level
8 International Labour Conference 98th Session, 2009 Report III (Part 1B)
9 Project Proposal for Strengthening Safeguards, Safety and Health at Workplaces (SSASHEW)
10 Press statement by Hon. Minister MoGLSD Monday February 9th 2015
11 MOGLSD Press Statement February 2015
12 The Constitution of the Republic of Uganda (1995) as amended; Article 40(1) (a)
3
1.3.2 Objectives
The objectives13 of the department of OSH (DOSH) are:
• To minimize occupational accidents, diseases and injuries at work places.
• To promote good health of the worker at the workplace.
• To promote good working conditions.
• To promote construction of safe and healthy workplaces.
• To promote awareness of occupational safety and health among workers, employers
and the general public through training.
1.3.3 DOSH Activities

In ensuring enforcement of OSH at workplaces, DOSH carries out the following activities:
i) Developing/reviewing occupational safety and health policy, laws, regulations, technical
standards, strategy, guidelines, code of conduct and manuals.
ii) Registering all workplaces in the country.
iii) Conducting general and statutory inspection of workplaces and equipment certification.
iv) Educating and creating awareness about OSH among employers and employees.
v) Reviewing and approving architectural drawings/plans (water, electrical, civil and
building works) of public, commercial and industrial workplaces to ensure that OSH
requirements have been incorporated.
vi) Monitoring, recording and interpreting statistical data of industrial accidents, diseases
and health hazards.
vii) Undertaking investigations of occupational accidents and diseases.
viii) Carrying out medical surveillance of workplaces.
ix) Carrying out research on occupational hazards and diseases and publishing reports.
1.3.4 Organization Structure

The organization structure of the Department of Occupational Safety and Health provides for
a total of 47 staff (38 Technical staff and 9 support staff). The Department has two divisions,
namely: Safety Division and Health Division. Details of the organization structure are in
Appendix I.
During the financial year 15/16, the department had 22 staff, 18 of whom were qualified
inspectors in the fields of Health, Engineering, Environment, Chemistry, Hygiene, Food
science, and 4 were administrative or support staff. The Department is headed by the
Commissioner in charge of Occupational Safety and Health who reports to the Director,
Labour, Employment and Occupational Safety and Health. The Commissioner is assisted by
an Assistant Commissioner (OSH) and three (3) Principal Safety Inspectors.
1.3.5 Funding
Enforcement of occupational safety and health activities by the MoGLSD is financed solely by
the Government of Uganda. Enhanced funding was secured by the Ministry from Government in
order to pursue its major function of effective enforcement through the project “Strengthening
Safeguards, Safety and Health at Workplaces (SSASHEW)”.The department received UGX
7,451.72 million during the three years under review. Details of funding during the period
are shown in Table 1 below.
13 The Occupational Safety and Health Department Brochure
4
Table 1: Showing funding to Department of OSH
Actual/Released
Programme Name/ Financial Budgeted Amount
Amount in (UGX
Budget line Years (UGX in Million)
Million)
2012/2013 610.00 513.42

2013/2014 413.05 382.25
OSH Department
2014/2015 673.00 671.07
Sub-Total: 1,696.05 1,566.74
2012/2013 2,000 2,000

SSASHEW Project 2013/2014 2,000 1,940.78
2014/2015 2,000 1,944.20
Sub-Total: 6,000 5,884.98
Total Funding 7,696.05 7,451.72

Source: OAG analysis of the Ministerial Policy Statements (MPS), financial statements and payment
files
1.4 OVERALL AUDIT OBJECTIVE

The overall audit objective was to determine whether MoGLSD adequately enforced compliance
with the Occupational Safety and Health Act, 2006 through workplace registration, inspection
and monitoring, education, training and awareness creation.
1.5 SPECIFIC AUDIT OBJECTIVES

The specific objectives of the audit were:
i. To establish the extent of workplace registration and equipment certification countrywide
and the fees (NTR) collected.
ii. To assess the extent and impact of inspections and monitoring of OSH activities at work
places.
iii. To establish whether DOSH effectively promotes occupational safety and health through
sensitization and awareness among stakeholders.
1.6 AUDIT SCOPE

The audit focused on enforcement of Occupational Safety and Health at workplaces by the
Department of Occupational Safety and Health, under the Ministry of Gender, Labour and
Social Development. The audit covered three (3) financial years of 2012/13, 2013/14 and
2014/15 and involved visiting both public and private workplaces in different parts of Uganda.
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CHAPTER TWO
CHAPTER TWO
6
CHAPTER TWO
AUDIT METHODOLOGY
The audit was conducted in accordance with the International Organization of Supreme Audit
Institutions (INTOSAI) Performance Auditing Standards and the Performance Auditing guidelines
prescribed in the Office of the Auditor General (OAG) Value for Money (VFM) audit manual.
The standards require that the audit be planned in a manner which ensures that an audit of
high quality is carried out in an economic, efficient and effective way and in a timely manner.
2.1 SAMPLING
Workplaces in the country are estimated at over one million. From this population 50 workplaces
were selected and these included thirty one (31) private entities and 19 public entities. The
thirty one (31) private entities were selected from mining and manufacturing sectors, and
trade unions. Twenty eight (28) out of the thirty one (31) private entities were selected from the
mining and manufacturing sectors because their operations and production processes, such
as: use of corrosive and toxic chemicals, noise, heavy plant and equipment, expose workers
to industrial accidents. Three (3) Trade union organizations were also selected given their
role of advocating for the protection of workers from hazards and adherence to occupational
safety and health, while the public entities were selected at random. The team visited the
selected entities to corroborate information already collected through document review and
interviews. Details of the selected workplaces are in APPENDIX II.
2.2 DATA COLLECTION METHODS

The team relied on document review, interviews and physical observations to obtain information
on the different specific audit objectives as detailed below:
Audit Objective 1: To establish the extent of workplace registration and equipment

certification countrywide and the fees (NTR) collected
To assess this objective, the team interviewed MoGLSD/DOSH staff to establish the mechanisms
in place to ensure that all work places are registered. The team reviewed the workplace register,
list of certified equipment and the Non Tax Revenue records maintained by MoGLSD and
corroborated this with registration certificates, plant examination and equipment certificates
to ascertain the actual number of registered workplaces, equipment certified and the actual
realized Non-Tax Revenue.
The OSH Act was also reviewed to determine how long a workplace certificate or equipment
certification is valid before it expires. We then calculated the delay (in days) to renew as at 30th
June 2015 by analysing information from the Occupational safety and Health Management
Information System (OSHMIS) i.e. Date of First Registration/ Certification, Expiry/Due Date
and Date of Renewal.
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Audit Objective 2: To assess the extent and impact of inspections and monitoring of OSH
activities at work places
The team reviewed the Ministry’s work plans, budgets, ministerial policy statements and
annual departmental performance reports for the three years to establish how many of the
planned inspections were undertaken. Interviews were also conducted with Management
to establish the reasons for variances in planned inspections.
The team then analysed expenditure records in the payment vouchers over the years to
establish whether the funds received for inspections were used for the intended purpose.
To assess the extent of inspections as compared to the estimated workplaces in the country,
we determined the number of workplaces an inspector should visit in a quarter, using the
DOSH work performance and administration arrangements, and used this to compute what
would be the maximum number of inspections DOSH could undertake in a year. We then
compared this maximum number of inspections to the estimated workplaces in the country.
To assess the effectiveness and impact of the inspections undertaken, the audit team
interviewed MoGLSD staff to establish whether any risk criteria was followed in identifying
areas for inspection; the inspection checklist was also reviewed to establish whether it was
detailed and workplace specific; availability and use of inspection equipment were determined
through physical inspection of equipment, and review of records indicating missing equipment.
Reviewed available statistics on occupational-related accidents, diseases, injuries, fatalities
from MoGLSD collected from workplaces during inspections to ascertain the trend of
occupational injuries, accidents and determine the impact of inspections on the occurrence
of workplace hazards.
To establish action taken following inspection (thus effectiveness), we reviewed inspection

reports and the respective feedback given by inspectors to the workplaces. Using a sample
of the inspection reports, the team tested, on a sample basis, whether the recommendations
detailed in the inspection reports were implemented by the workplaces.
Audit Objective 3: To establish whether DOSH effectively promotes occupational safety

and health through OSH training and sensitization among stakeholders
To verify whether the Ministry conducts education, training and awareness among workers,
employers and the general public, the team interviewed officials from DOSH to establish
whether there is a framework for OSH training, awareness and information sharing at all
levels and whether it is working as envisaged.
We interviewed workers and employers to ascertain if they had been sensitized by DOSH
about OSH and then assessed the level of compliance.
The team also reviewed the DOSH work plans, annual performance reports, ministerial policy
statements for the years under review to ascertain the OSH studies/ research prioritized
and conducted and whether the results were disseminated to stakeholders and the general
public. Furthermore, we:
• Reviewed the Ministry’s correspondences with the key stakeholders in relation to

promotion of safety and health, and the respective progress meeting minutes to establish
whether there is a chain linkage collaboration and coordination with key MDAs.
• Reviewed the MoGLSD training needs assessment report for DOSH to ascertain the
training needs and the extent of implementation of the training plan.
8
• Interviewed trade union representatives (NOTU, COFTU) and representatives of
Federation of Uganda Employers to ascertain the extent of collaboration with MoGLSD
in advocating for adherence to OSH.
• Reviewed minutes of meetings held between MoGLSD and stakeholders to foster
cooperation on OSH, and interviewed MoGLSD officials to establish follow-up on the
resolutions made.
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3
CHAPTER THREE
CHAPTER THREE
10
CHAPTER THREE
SYSTEMS AND PROCESS DESCRIPTION

This chapter presents the key players in the enforcement of Occupational Safety and Health
and their roles and responsibilities. It also presents the systems and processes in the
enforcement of OSH activities at work places.
3.1 ROLES AND RESPONSIBILITIES OF KEY PLAYERS
Key Player/Entity Role/Responsibility
The Ministry is responsible for development of policies,

Ministry Of Gender, Labour and
standards and regulations that assist in the enforcement of
Social Development (MoGLSD)
the Occupational Safety and Health Act, 2006.
The department is responsible for:

• Registration of work places, conducting research on
causes of occupational accidents, investigation of
accidents and creating awareness on OSH.
• Inspection of workplaces to ascertain good working
conditions and safeguard against occupational injuries,
accidents, and diseases.
• Carrying out specific inspections with regard to
working methods, production methods and processes
Department of and planning of industrial buildings with an aim of
Occupational Safety and improving productivity.
Health (DOSH) • Carrying out medical inspections of workplaces and
statutory inspection / examination of pressure vessels,
lifts and lifting equipment.
• Ensuring all public, industrial and commercial
structural plans and drawings of workplaces are in
line with OSH requirements before approval by the
commissioner OSH.
• Carrying out OSH education, training and awareness
creation among workers, employers and the general
public.
11
They mainstream OSH systems and integrate OSH activities in
Other Line ministries the sectoral budgets and investment plans.
National Environment Is required to consult DOSH to ensure Occupational Safety and
Management Authority Health issues are identified and addressed before approving
(NEMA) any Environmental Impact Assessment.
These are required to implement the OSH law and best practice
Employers requirements to promote safety and health at workplaces,
budget for and fund OSH safety measures.
These support risk control strategies developed by employers

Workers
and labour unions for known and emerging hazards.
• These aim at protecting workers from hazards, such as,

Workers’ and Employers chemical, biological, physical, ergonomic and psycho-
Organizations social hazards.
such as NOTU, COFTU and FUE • They advocate for adherence to OSH policy, report
incidents and risks to management among others.
3.2 PROCESS DESCRIPTION

Management of OSH activities at workplaces includes the processes illustrated in Figure 1 below.
Figure 1: Processes for management of occupational safety and health activities

Inspection and Monitoring
12
Registration of workplaces
The registration of workplaces is the first process point of management of OSH in the country
which guides government on the analysis, planning, inspection, training and operations of
OSH systems in the country.
Section 40(2) of the OSH Act, 2006 requires that before any person occupies or uses any
premises as a workplace, he/she applies for the registration of such premises by notifying
the Commissioner in writing of his/her intention in not less than one month before he/she
occupies or uses the premise as a workplace. Where premises of an existing workplace are
taken over, a written notice must be sent to the Commissioner at least one month before
operations commence. On the other hand, notice can be sent within one month after the
date when the premises were first occupied or used. The notice shall include the name of
the occupier, date of commencement, number of persons employed by gender, physical
location of the workplace, postal address, nature of the work to be carried out, nature of
the mechanical power if it is to be used, particulars of steam boilers if they are to be used,
nature of hazardous chemicals if to be used and whether these have been distinctively
labelled and their effects on the reproductive system, whether an industrial waste treatment
plant is to be used and the method of handling effluents, whether the premises is to use
lifts, cranes, chain blocks, forks, gas plants, air receivers; whether provisions have been
made for sanitary installations, first aid treatment, emergency plans, supply of drinking
water, washing facilities, the maximum number of persons per shift where persons are to
work in shifts.
After the appropriate fee is paid, the Commissioner then issues a certificate of registration
in the names of the occupier. The certificate of registration is renewable every three (3)
years. It is an offence, (under Section 41(5) of the OSH Act, 2006), for any person to occupy
or use any premises as a workplace without first having been issued with a certificate of
registration. Where the Commissioner of Occupational Health and Safety Services refuses
to issue a certificate of registration, he/she must, if so required by the applicant, state in
writing the grounds of such refusal.
Inspection and Monitoring of Work places

The Department of Occupational Safety and Health conducts inspections of the workplaces
to ensure that workplaces are free from occupational hazards that may cause injuries,
illness or death to employees and the inspections will cover issues of safety, health and
welfare of the workers. Inspection is a core activity of the department and is categorized
into; general/routine inspections, statutory/specialized inspections and review and approval
of architectural drawings.
Planning is essential for effective enforcement of occupational safety and health activities.
Therefore, planning for inspection is done to determine what, where, when, who, and how to
conduct the inspections. Items that are most likely to develop unsafe or unhealthy conditions
because of stress, wear, impact, vibration, heat, corrosion, chemical reaction or misuse are
identified by inspectors during planning. Workplaces to be inspected are selected taking
into consideration statutory requirements, risk assessment; follow up actions, complaints
received from workers and new workplaces that need to be registered.
13
Planning is an integral part of any inspection activity to identify which areas/workplaces
to be inspected and what is required in terms of resources. Inspection planning takes into
consideration the appropriate protective gear, equipment and plant necessary to conduct
the inspections.
a) General Inspections
General workplace inspections are carried out so as to/ listen to the concerns of workers
and supervisors, gain further understanding of jobs and tasks, identify existing and potential
hazards, determine underlying causes of hazards, monitor hazard controls (personal protective
equipment, engineering controls, policies, procedures) and recommend corrective action.
In the event of non-compliance with the OSH requirements, the inspector points out such
issues to the respective employer immediately after the inspection and consequently an
inspection report is issued to management of the workplace which is given chance to take
corrective action within a specified period. A follow up inspection is later done to ascertain
if corrective actions was undertaken.
However, if during the inspection a scenario arises where there is imminent danger to the
worker(s), property or environment according to judgment of the Inspector, the activity being
undertaken can be stopped immediately until corrective measures are instituted.
b) Statutory inspections
These inspections, which are targeted to verify whether plant and equipment in the workplace
have been certified by DOSH and are fit for purpose, are conducted in line with Occupational
Safety and Health Act, 2006. Some of the equipment includes steam boilers, air receivers,
gas receivers, mobile cranes, tower cranes, power generators, overhead cranes, lifting
chains, shackles and lifts.
The OSH Act, 2006 stipulates the time period for examination/ inspection of Hoists and lifts,
Steam boilers and Steam receivers.
According to section 69(3) every hoist or lift is examined at least once every six (6) months,
section 77(1), requires inspection of a steam boiler and all its fittings and attachment by an
authorized person at least once every fourteen months and section 79(1) requires inspection
of a steam receiver and all its fittings and attachment by an authorized person at least once
every twenty six (26) months.
Once a notification of the use of machinery has been done by the proprietor in possession
of the plant and equipment to the Commissioner DOSH, the inspector arranges for the
inspection and certification of the machinery.
• Depending on the recommendations in the statutory inspection report, a follow up
inspection/examination may be done within a stated period; otherwise the next inspection/
examination is done after the statutory period stipulated above has elapsed.
• Where the workplace has plant and equipment but has not communicated to the
Commissioner DOSH, the Commissioner has the right to carry out an examination/
statutory inspection of such plant and/or equipment once its existence is known by
DOSH.
• Contraventions of the above sections are considered as General offence (Section 103
of the OSH Act-General offences). In case of prosecution to be considered, Sections
104(General Penalty), 105(Application for an alternative remedy) and 110(Prosecution
14
of offences) apply.
In circumstances where the workplace or an occupier contravenes any section of the
OSH Act, for example not informing the commissioner about existence of plant and
equipment in his work premises, he commits an offence under section 103 of the
OSH Act, and is punishable under section 104,105 and 110 of the OSH Act.
c) Review and approval of workplace architectural drawings and plans

According to Section 42 of the Occupational Safety and Health Act, 2006, a plan and any
architectural drawings of a new workplace and any alterations of an existing workplace
should be submitted in five sets by the proprietor to the Commissioner DOSH for approval
before the construction or alteration begins. The Commissioner then assesses the
drawings/plans and issues a Uganda Revenue Authority (URA) payment registration slip
to the proprietor. The proprietor effects payment to URA bank accounts and thereafter
returns the receipt to MoGLSD for issuance of the approved plans. Upon receipt of the
plan/drawing from the local authorities/ proprietor, the OSH team reviews the plan in
line with OSH Act and thereafter approves or sends it back to the proprietor to address
the OSH requirements.
Upon inspection of workplaces, an inspection report is issued. Monitoring, which is done

in line with the period specified in the report, is done during the subsequent routine
inspection to ensure compliance. Inspections indicate best/good practice, identify areas
of non-compliance with the OSH Act & those that require an in-depth analysis, indicate
where immediate corrective action is needed, identify trends, and propose corrective action.
OSH training and sensitization
This aims at creating awareness and improving health and safety in workplaces for increased
productivity. Training and sensitization is done to/ obtain commitment of media houses
to investigate and report OSH issues, create OSH awareness among MDAs, employers,
workers and the general public.
OSH awareness is done by MGLSD through breakfast meetings with media houses, using
both print and electronic media, commemorating world day for safety and health at work
(28th April), gazetting of the national OSH week before 28th April every year, establishing a
chain linkage collaboration and coordination with key MDAs, promoting workplace health
programmes, and training ToTs from MDAs, employers and workers, establishing a focal
contact person in every MDA to spearhead OSH issues among other strategies.
OSH education by MoGLSD is done by promoting integration of OSH into vocational and
tertiary curriculum.
MoGLSD prioritizes conducting research in the areas of accident reporting and investigation,
occupational diseases in the flower industry, accident and injury prevention in the construction
industry, OSH issues in the oil and gas downstream operations and effectiveness of the
safety committees at workplaces to educate and create awareness among all players in
OSH.
15
4
CHAPTER FOUR
CHAPTER FOUR
16
CHAPTER FOUR
FINDINGS, CONCLUSIONS AND RECOMMENDATIONS

This section contains the major findings, conclusions and recommendations from the audit.
4.1 REGISTRATION OF WORKPLACES AND EQUIPMENT

CERTIFICATION
4.1.1 Registration of Workplaces

Under Section 40(1) of the OSH Act, 2006, the Commissioner is required to keep a register of all
workplaces. Section 40(2) of the OSH Act, 2006 requires a person to notify the Commissioner
in writing of his/her intention to occupy or use a premise as a workplace in not less than one
month before he/she occupies or uses the premise as a workplace. After the appropriate
fee is paid, the Commissioner then issues a certificate of registration in the names of the
occupier. The certificate of registration is renewable every three (3) years. It is an offence,
(under Section 41(5) of the OSH Act), for any person to occupy or use any premises as a
workplace without first having been issued with a certificate of registration.
a) First-time registration of workplaces

Through review of documents and interviews with MoGLSD officials, it was noted that whereas
workplaces in the country are estimated at over one million, only 756 (0.1%) workplaces
had been registered by MoGLSD as at 30th June 2015. It was further observed that out of
the 756 registered work places, none was a government entity.
A trend analysis of workplace registration and NTR collected over the years is shown in
Table 2 and Figure 2 below:
Table 2: NTR collected from workplaces over the three (3) year period
Financial Years Total No. of Registered Workplaces Sum of NTR Collected (UGX)
2012/2013 100 24,680,000
2013/2014 148 108,875,440
2014/2015 508 822,250,000
Grand Total 756 955,805,440

Source: OAG analysis of annual performance reports from MoGLSD and OSHMIS data
17
Figure 2: Trend analysis of workplace registration and NTR collected
Source: OAG analysis of OSHMIS data on workplace registration and NTR collections
Table 2 and Figure 2 above show that over the 3-year period, the number of entities registered
increased from 100 entities in 2012/13, to 148 entities in 2013/14, and to 508 entities in
2014/15. Further analysis shows that the spike in registration in 2014/15 (245% increment
from 2013/14) occurred in Quarter (Q) 3 (333 workplaces) and Quarter 4 (104 workplaces).
This corresponded to media briefings, in Q2 and Q3 by the Ministry, sensitizing people about
the obligation to register work places, and setting deadlines for compliance (31st December
and 28th February 2015, respectively).
b) Renewal of workplace registration certificates

Through document review, the audit team noted that 39 of the workplaces registered by
DOSH from 2010 to 2012 had not renewed their certificates as at 30th June 2015 yet their
statutory period of renewal had elapsed.
Through analysis of workplace registration certificates and the Occupational Safety and Health
Management Information System (OSHMIS) data relating to workplace registration, we noted
that there were delays by workplaces to apply for renewal of their registration certificates.
Table 3: Showing the delay by workplaces to renew registration certificates
Delay in days to renew registration certificates No. of workplaces
1 – 50 14
51 – 100 08
101 – 200 14
201 – 300 03
TOTAL 39
Source: OAG analysis of OSHMIS data on registration of workplaces
Table 3 above shows that out of the thirty nine (39) workplaces sampled, fourteen (14)
18
workplaces took between one (1) to fifty (50) days to renew their registration certificates, eight
(8) workplaces took between fifty one (51) to one hundred (100) days, fourteen (14) took between
one hundred and one (101) to two hundred (200) days and three (03) workplaces took between
two hundred and one (201) to three hundred (300) days to renew their workplace registration
certificates.
4.1.2 Plant Examination and Equipment Certification

a) Renewal of Plant and Equipment Examination certificates
According to section 72 (7), 69 (3) , 77 (1) and 79 (1) of the OSH Act, 2006, lifting equipment,
appliance and gear, hoists or lifts, steam boilers and receivers should be examined by an
authorized person at least once every fourteen (14) months, six (6) months, fourteen (14) months
and twenty six (26) months respectively.
Once a notification of the use of machinery has been done by the proprietor in possession of
the plant and equipment to the Commissioner DOSH, the inspector arranges for the inspection
and certification of the machinery.
Through document review, the audit team noted that the statutory period for renewal for a
number of equipment certified between 2012 and 2015 had elapsed as at 30th June 2015.
Through analysis of workplace registration certificates and OSHMIS data relating to equipment
certification, the audit team noted that there were delays by workplaces to apply for renewal of
their equipment certification as shown in Table 4 below.
Table 4: Showing the delay to renew equipment certificates

Plant/Equipment Range of delay by days
Lifting equipment, appliance & gear 10-649
Steam boilers 30-679
Lifts/ hoists 297-884
Source: OAG Analysis of OSHMIS data on equipment certification
From the data tabulated above, it took between 10 and 649 days to apply for renewal certificates
of lifting equipment, 30 and 679 days for steam boilers and between 297 and 884 days for lifts/
hoists.
The audit team attributed delayed and non-registration of workplaces and equipment certification
to lack of awareness by the respective occupiers of workplaces and the persons in possession
of the plant and equipment coupled with absence of a strategy (self-regulating) by DOSH geared
towards ensuring registration of all workplaces , inadequate system/mechanism to monitor
compliance, manual registration system rather than an online one so as to encourage registration,
and non-punitive penalties provided for under section 104 (fine not exceeding 24 currency points
or imprisonment for a term not exceeding 12 months or both) for non-compliance.
Inadequate registration may also lead to limited information capture by DOSH on existing and
risky workplaces which would facilitate and inform planning for enforcement of OSH activities;
this may also hamper setting interventions meant to improve OSH at workplaces. Faulty plant
and equipment, and unsafe workplaces may go undetected which may cause injuries, diseases
(ill health) and /or death to workers. In addition, with non-registration of workplaces and
certification of plant and equipment, the Government is losing potential revenue which would
have been collected as NTR during the process of issue of certificates for workplaces, and plant
and equipment.
19
Conclusion
The Ministry neither registered all workplaces nor certified all plant and equipment in the
country and did not invoke the penalty clauses for non-compliance as required by the OSH Act,
2006. The Ministry’s role of enforcing OSH at workplaces is thus compromised if the majority
of workplaces have not been registered since as part of the registration, the workplaces are
required to indicate the location of the workplace, nature of work to be carried out, hazardous
chemicals to be used at the workplace; thus without such information, DOSH may not be aware
of the magnitude and extent of potential hazards at the workplaces in the country which would
help it to devise mechanisms and interventions to effectively monitor and enforce compliance.
Management Response
The Ministry intends to contract OSH private service providers to undertake OSH registration,
statutory equipment examination and inspections on behalf of Government. Once the OSH Act
provisions are fully implemented, it is expected that workplaces will be safe and healthy in
accordance with the law, but the process will also generate considerable amount of revenue
per year to the Consolidated Fund. The Ministry estimates to collect UGX 50billion annually.
Besides revenue generation, the implementation of this law has great benefits, which among
others, include; (i) creation of approximately 200,000 jobs mainly scientists to oversee, safety,
health and quality management issues at workplaces (ii) reduction of the national disease
burden since the law focuses on the prevention of diseases, illnesses and injuries in workplaces
and (iii) enhancement of productivity and competitiveness of enterprises as there will be less
accidents and diseases that contribute to lost time at work but also companies and enterprises
will find it easier to acquire International Standards Certification and or Accreditation.
The Ministry has set up a Technical Committee comprised of officers from MoFPED, Ministry
of Justice & Constitutional Affairs (MoJCA) and MGLSD to develop the Terms of Reference
to enable the Ministry contract OSH private service providers to undertake OSH registration,
statutory equipment examination and inspections on behalf of Government.
Audit Comment
Setting up a Technical Committee by the MoGLSD to develop the Terms of Reference for
contracting OSH private service providers to undertake OSH registration, statutory equipment
examination and inspections on behalf of Government is a good initiative. However, management
should also consider the need to build capacity within the Ministry for sustainability.
Recommendation
• MoGLSD should hasten implementation of the plan it is currently developing to enable it
implement OSH registration, statutory equipment examination and inspections.
• MoGLSD should develop a comprehensive strategy to ensure that all workplaces are
registered and registration certificates are renewed upon expiry. This strategy should
provide for the following aspects among others:
• Extensive and sustained sensitisation about the importance of workplace registration
and equipment certification;
• Close collaboration with other government agencies to keep track of existing and new
workplaces that require to register; and
• MoGLSD should invoke the penalty clauses for non-compliance so as to ensure OSH
compliance at workplaces. Where the penalty is not punitive, the Ministry should bring
this for consideration when the OSH Act is being reviewed.
20
4.2 INSPECTION AND MONITORING OF OSH ACTIVITIES
4.2.1 Inspections undertaken by DOSH

According to Section 6 (a) of the Occupational Safety and Health Act 2006, an inspector has
the power to enter, inspect and examine any workplace and every part of it, if he/she has
reasonable cause to believe that any person is employed in it. The inspections are done to
ascertain good working conditions and safeguard against occupational injuries, accidents,
and diseases.
Table 5: Comparing total inspections conducted from different sources of the DOSH
Inspections conducted Total
Source
2012/13 2013/14 2014/15 inspections
OSHMIS* 614 898 1310 2,822
Departmental Annual
212 125 139 476
Performance reports
Summary of inspection reports - - - 9,287
Source: OAG analysis of OSHMIS database, annual performance reports and summary inspection
reports
* The inspections conducted combine the workplaces and the plant and equipment inspected.
From Table 5 above, it is noted that the MoGLSD reflected varying figures for inspections
conducted for the years under review in the various source documents it maintained. According
to OSHMIS, the number of inspections DOSH conducted were 2,822 while the departmental
annual performance reports and inspection summary reports reflected 476 inspections
and 9,287 inspections, respectively. A breakdown of the summary reports per year was not
availed to the audit team. Based on the varying figures presented, coupled with failure by
the Ministry to avail inspection reports to back up the inspections undertaken, audit could
not verify the actual number of inspections undertaken by the DOSH.
Scenario showing possible inspections based on staffing levels

Out of 48 approved staff positions, 22 are currently filled, leaving twenty six (26) positions vacant. Only 18 of the existing staff are
OSH inspectors, the rest being support staff. Inspection of workplaces is done in teams as per the department’s arrangement.
According to a loose minute to the Permanent Secretary dated 20th January 2015 (Status Report for six (6) months on Workplace
Registration, July 2014 to date), seven (7) teams were formed for Kampala, Wakiso, Mukono and six (6) teams for upcountry
workplace inspections. Each team was required to conduct 92 inspections every quarter as follows: Two months in the quarter
were dedicated to inspecting at least 3 workplaces in Kampala, Wakiso and Mukono every day for three days in a week (totalling
72 inspections per team); while the third month in each quarter was dedicated to conducting 20 upcountry workplace inspections.
Using the information from this loose minute, the audit team then computed the total inspections that would be expected to be
conducted by the 7 (seven) teams in a year as shown below:
Given that each team is supposed to undertake 72 inspections per quarter around Kampala, Wakiso and Mukono, then the
seven teams would carry out a total of 504 inspections (72 X 7) in a quarter and hence 2016 inspections (72 x 7 x 4) annually. For
upcountry inspections, each team is supposed to undertake 20 inspections each quarter, therefore, six teams would undertake
a total of 120 inspections quarterly (20 X 6) resulting into 480 inspections in a year (20X6X4). The total number of inspections
annually from each team would therefore add up to 2,496. On the basis the above information, MGLSD should have planned to
undertake 2,496 inspections during the year 2014/15 instead of the planned 600 inspections.
Further analysis on workplaces in the country and staffing levels was carried out to establish the sufficiency of staff. Given that
there is an estimated one million workplaces in the country, and assuming a maximum of 1 inspection per workplace yet in some
cases more than 1 type of inspection can be conducted, the Department would only carry out (2,496) 0.2% inspections of the
estimated workplaces in the country with the available staffing levels. The International Labour Organization (ILO) standard of
inspector to worker ratio is 1:500, however in Uganda the estimated population employed is 7.9 million thus with 18 inspectors,
\this implies an inspector to worker ratio of 1:438,889.
21
The audit team further attributed inadequate inspections to inadequate equipment to facilitate
inspection. This equipment included measuring tools/equipment for testing boilers, air
receivers, electrical, building and safety equipment.
Through interviews and review of a list compiled by DOSH detailing the equipment needed
for effective inspections, it was noted that some of the equipment on the list was to be used
in analytical and clinical laboratories yet these laboratories were not in place.
Furthermore, a review of the procurement files revealed that the Ministry procured analytical
and clinical laboratory equipment worth UGX 509,702,346 to facilitate inspections, and laboratory
analysis and testing. This equipment was delivered to DOSH in April 2014. The audit team
however, noted that the department has neither a designated analytical nor clinical laboratory
for analysis and testing; and the department has not trained the inspectors on the use of the
equipment given their complexity.
As a result, save for the digital thermometer, stethoscope and the digital blood pressure
monitor, equipment (worth UGX 506,398,346) is not being used for its intended purpose.
Failure to use the equipment within the warranty period may result into the items not being
replaced at the supplier’s cost in case the equipment is defective; in addition, non-use may
lead to deterioration of the equipment. Figure 3 below shows photographs of some of the
unused equipment.
Figure 3: Showing some of the procured but unutilized OSH equipment at DOSH
First aid kit, Field Stain kit, Glucometer etc Binocular microscope sealed in its pack
Source: OAG photographs taken during field inspections
As a result of inadequate inspections, OSH hazards may go undetected thus making it difficult to
enforce OSH requirements to safeguard against occupational injuries, accidents, and diseases.
For example, during field inspections, using a sample of 50 workplaces, the team utilized the
inspection checklist to assess compliance with the OSH requirements specified in the OSH
Act, 2006, and ILO guidelines. The extent of compliance with the different requirements is
represented in Table 6 as well as Figure 4 below.
22
Table 6: Showing level of compliance with OSH requirements at the sampled workplaces
% non-
OSH Requirement Compliant Non-compliant
compliance
Written Workplace Occupational Safety
10 40 80%
and Health Policy
OSH officers to manage workplace
Occupational Safety and Health 12 38 76%
activities.
Clear fire exits 9 41 82%
Fire alarms in place 14 36 72%
Fire drills conducted for staff 8 42 84%
Possession of first aid box/ facility 10 40 80%
Training of first aiders/ establishment

8 42 84%
of clinic
Standard content list to detail the
5 45 90%
contents of the first aid box
Expired (un-serviced) fire
44 6 12%
extinguishers
No fire extinguishers 35 15 30%
Source: OAG findings from field observations and interviews
Of the 50 workplaces sampled, 26 manufacturing and 4 mining companies were visited; at

the time of audit inspection, employees in 6 of the manufacturing companies were found not
wearing appropriate protective equipment and clothing. None of the staff at all the 4 mining
companies had the right Personal Protective Equipment and clothing (PPE).
Figure 4: Showing status of compliance of PPE by workers at some workplaces visited
Miners not wearing protective gear- Lukwago Employees not wearing proper protective
Gold mine-kitumbi subcounty in Mubende shoes- Tibeti-Hima mining company
23
Employee working without proper safety wear- Employee mixing chemicals without proper
African mining in Jinja protection- Ali metals & trading Co Ltd
Employee working at a hot melting point without fire Workers covering their faces with polythene bags
protective wear and safety shoes- Tian Tang Group as eye protection wear while welding at Shumuk
Aluminum industries Ltd
Congested work station without clearly marked Employee welding without eye protection, safety
pathways- Steel and Tube industries shoes and overall- Landy industries (U) Ltd
Source: OAG photographs taken during field inspections
24
4.2.2 Feedback to inspected workplaces
An inspector is required upon inspection of a workplace and examination of plant and equipment
to produce an inspection report detailing the results of inspection, recommendations and
the timeframe within which the workplace should address the raised anomalies.
In the course of the audit, DOSH availed to the audit team only 118 reports (25%) of the
reports relating to the 476 inspections undertaken over the period under review as shown
in Table 7 below.
Table 7: Showing inspection reports presented to the audit team

Inspections Inspection Reports % of Inspection
Financial Year
Undertaken presented reports
2012/2013 212 0 0%
2013/2014 125 20 16%
2014/2015 139 98 71%
TOTAL 476 118 25%
Source: OAG analysis of inspection reports and departmental annual performance reports
Non availability of reports was attributed to poor record keeping by officials from DOSH.
Without the results of inspection, it is difficult to follow up with the workplaces to establish
if the recommendations were implemented; and to analyse cross cutting issues across
workplaces which would be used to come up with interventions to address the OSH issues
identified during inspections.
Conclusion
MoGLSD does not have systematic risk assessment criteria to identify and prioritize workplaces
for inspection. Without prioritizing workplaces for inspection, the ministry could not provide
assurance that the most risky areas are considered for inspection. It was not possible to
confirm the the extent and impact of inspections and monitoring of OSH activities at work
places.
Management Response
The Ministry has started the process of building an Occupational Safety and Health
Management Information System. Once the system is updated and upgraded, it will be able
to systematically categorize and prioritize criteria system.
At the time of the Audit, the Officers were being trained in the use and maintenance of
the equipment. Equipment and tools are now being used by the officers. The Ministry is
constrained by office space. Discussion is ongoing with MoFPED to acquire appropriate
office space so that equipment can be kept in appropriate manner.
The Ministry is also in the process of building a robust filing system that will require office
space and technological information system. Each workplace will be with a file and this will
make it easier for tracking and follow up on any issue with a particular workplace.
Audit Comment
The proposed interventions as explained in the management responses would be a step in
the right direction. Management should however note that it needs to come up with a risk
assessment criteria which it will then incorporate in the OSHMIS because OSHMIS on its
own cannot generate a risk assessment criteria but rather uses the criteria input to help
categorise and generate priority areas/workplaces to be inspected.
25
In addition, although management indicated that workers, employers and the general
the equipment and tools were being used, this was public through, breakfast meetings with
not the case especially for equipment related to media houses, using both print and
the analytical and clinical lab since these labs were electronic media, commemorating world
not in place yet. For the other equipment, without day for safety and health at work (28th
a designated/appropriate office space to keep the April), gazetting of the national OSH week
equipment, the likelihood that this equipment will before 28th April every year, establishing
be improperly stored or even misplaced is high. a chain linkage collaboration and
coordination with key MDAs, promoting
Recommendations workplace health programmes, and
Management should: training Trainer of Trainers (ToTs)
• Develop and implement a systematic risk from MDAs, employers and workers,
assessment criteria to identify and assess establishing a focal contact person in
OSH hazards, and prioritize workplaces for every MDA to spearhead OSH issues
inspection to enable the Ministry provide among other strategies.
assurance that the available resources are
used to carry out the most critical inspections. The audit team noted that DOSH carries
• Put in place mechanisms to maximise the out sensitization through print and
number and impact of workplace inspections electronic media, breakfast meetings
through informed planning for inspections with media houses, commemorating
and ensuring feedback is given following world day for safety and health at work
inspections. (28th April), gazetting of the national
• Enforce penalties and sanctions for non- OSH week before 28th April every year.
compliant workplaces as indicated in the The audit team interviewed workplace
inspection reports. In addition, where the proprietors and employees from the
penalties are not deterrent, the Ministry workplaces sampled for the audit and
should consider including this as it reviews noted that though OSH encompasses
the OSH Act. the employer and employee obligations,
• Develop guidelines and policies to cope with more emphasis is put on workplace
the current technological advancements. registration which has resulted in limited
• Develop a management information system awareness of OSH at the workplaces.
to ensure proper recording of inspection Workplace registration was emphasized
findings and tracking of follow up of issues because upon registration, workplaces
raised on all inspections undertaken. are required to pay a fee which is revenue
• Ensure proper and safe storage of inspection to government.
equipment to avoid loss through theft,
misplacement or misuse. The audit team also noted that the
• Liaise with the Ministry of Public Service to national OSH policy that is required to
fill the staffing gaps and also strengthen help the government, employers and
collaboration with other government organs workers to create awareness on how
like districts as these have labour officers who to reduce a number of work-related
can be used to further enforce OSH through accidents and diseases in the country
inspections and follow up. by adopting and implementing a culture
of prevention was still in draft and is yet
4.3 OSH TRAINING AND to be approved.
SENSITIZATION
One of the objectives of DOSH is to promote
awareness of occupational safety and health among
26
Management Response purposeful for short, medium and long
It is very true that OSH workplace term (future) OSH inspection, advisory and
registration is emphasized because enforcement planning services because
of the following critical reasons: in order to inspect, an appropriate multi-
i. It is a legal requirement that is disciplinary team based on the workplace
derived from the Constitution of processes/methods/products/work
Uganda, Article 39 that provides environment must be constituted. Different
for every Ugandan a right to a workplaces have different statutory equipment
clean and healthy environment which have varied periods of examination. So,
and Article 40 (1) ( a) that requires without the workplace data, it is difficult to
Parliament to enact laws to undertake OSH inspection smartly.
provide for the right of persons to The Ministry has started the process
work under satisfactory, safe and of developing a training programme for
healthy conditions. These Articles employers, employees and government staff.
have been operationalised However, sensitization and awareness of all
by Occupational Safety and key stakeholders is ongoing.
Health Act, No. 9 of 2006 and
its attendant Regulations and Audit Comment
Sections 40/41points out the The training programme should be fast tracked
legal requirement for Workplace and should form part of a broader framework for
registration; OSH training, awareness and information sharing
For proper OSH inspection planning, to sensitize and create awareness among key
advisory and enforcement stakeholders.
services, the Ministry requires a Recommendation
database of all private and public • MoGLSD should develop a framework for OSH
workplaces such that the services training, awareness and information sharing
required are well planned, at all levels and also enhance cooperation with
budgeted and monitored. This civil society organizations (NOTU, COFTU and
is so because OSH services were FUE) to train and sensitize employers, workers
never decentralized and various and the general public in all aspects of OSH
workplaces have unique safety rather than only registration to promote a
and health issues that calls for safety culture of managing risks and hazards
prior critical activities related to at workplaces.
planning. There is no agency that • The MoGLSD should also fast track the
registers both public and private approval of the National OSH policy. This
enterprises nor captures the OSH will create awareness on how work-related
parameters contained in the OSH accidents and diseases can be prevented
Workplace Registration Form. and provide for equitable compensation
ii. Registration is part of the benefits to those who are injured and contract
commitment to safety at work occupational diseases.
which should be paid for like
it is currently done for trading 4.4 Coordination mechanisms
licenses, business registration According to the Occupational Safety and Health
etc. profile for Uganda 2004, MoGLSD is supposed
Therefore, it should be noted that to spearhead coordination with government and
the fees payment and registration non-governmental bodies to promote occupational
is not linked to immediate safety and health in the country.
inspection. Registration is Through an interview with the Commissioner of
27
the Department of Occupational Safety and Health, representing 5.7% of the reports, leaving
it was revealed that the MGLSD is supposed to 1,532 EIAs (94.3%) not reviewed. This was
coordinate with the Ministry of Health in matters attributed to inadequate staffing levels in
relating to statistics of occupational related the DOSH.
accidents, diseases and injuries, Uganda Police The limited review of EIAs by MoGLSD may
Force in enforcement of the OSH requirements result in some workplaces with insufficient
and in providing statistics relating to occupational OSH provisions being approved. It is also a
injuries and fatalities, Uganda Revenue Authority, missed opportunity for MoGLSD to identify
Uganda Registration Services Bureau, Ministry of and register new workplaces which would aid
Trade, Tourism and Industry, Ministry of Finance, planning for future inspections and generate
Planning and Economic Development (MOFPED), NTR for the Government.
in matters relating to all registered companies and b) Coordination with Local Governments on
businesses in the country and also issues regarding approval of architectural drawings/ plans
integrating OSH requirements in their policies Review of the annual performance reports for
and investment plans, Civil Society Organizations the construction section of MoGLSD for the
(FUE, COFTU and NOTU) in enforcing occupational three years, revealed that the Department
safety and health activities through a Tripartite reviewed and approved only 75 building plans
Charter arrangement among others. from Kampala, Wakiso, Entebbe, Mukono
and Lyantonde districts and realized UGX
The Ministry officials stated that they were pursuing 67,700,000 from approval fees.
chain-linkage engagement of stakeholders, c) Coordination with Ministry of Health and
sensitization and training and appointment of focal Uganda Police on occupational injuries and
contact officers in each public institution. They also diseases
organised a stakeholders’ meeting to enhance MoGLSD is supposed to coordinate with the
coordination on issues regarding registration of all Ministry of Health and the Uganda Police
workplaces and compliance to the OSH Act 2006.14 Force in matters relating to statistics of
It was further noted through review of several occupational-related accidents, diseases,
correspondences that the MoGLSD had written injuries and fatalities.
to several MDAs and higher local governments
requiring them to ensure enforcement of the It was noted that there was limited information-
OSH Act. However, the Department of OSH did sharing between the three bodies regarding
not follow up with the stakeholders to ensure statistics of occupational-related accidents,
implementation of the resolutions made. diseases, injuries and fatalities.
Limited information sharing was attributed to lack
The following issues were noted by the audit team of a comprehensive management information
in as far as coordination of MoGLSD and some system to facilitate information sharing yet upon
stakeholders is concerned: an occupational accident, injury or disease, the
a) Coordination with NEMA on review of case is reported to Uganda police and/or a health
Environmental Impact Assessments (EIAs) facility.
MoGLSD is the lead agency for OSH countrywide. As a result of limited information sharing, DOSH
As such, coordination with NEMA in regard did not have an up to date database relating to
to assessing EIAs submitted to NEMA would occupational accidents, injuries and diseases.
facilitate promotion of OSH among developers.
The audit team noted that out of 1,624 EIAs Conclusion
approved by NEMA during the 3 years under There has been minimal engagement of the
review, MoGLSD reviewed only 92 EIAs stakeholders by the Ministry. The Ministry needs to
sensitize and put in place coordination mechanisms
14 Review of the departmental technical meeting min-
for enforcement of OSH to be appreciated by all
utes (DOSH)
stakeholders.
28
Management Response • MoGLSD should follow up with stakeholders
The Ministry continues to engage to ensure the implementation of resolutions
stakeholders’ both horizontally made regarding registration of new workplaces
and vertically. For instance sectoral and promotion of OSH through chain-linkage
sensitization meetings on implementation engagement and information-sharing.
of the OSH Act, and coordination • MoGLSD, in collaboration with NEMA and
mechanisms have been organized and District Local Governments, should plan
continue to be organized. For instance, for and review all EIAs and architectural
horticulture, labour unions and beaches drawings/plans respectively in order to
are planned to be undertaken. improve OSH measures, identify upcoming
workplaces and collect NTR.
NEMA is obliged to submit the EIAs for • MoGLSD should engage Ministry of Health and
review and comments to MOGLSD before the Uganda Police Force to obtain up-to-date
approval. It is a bad practice and illegal for information relating to occupational-related
NEMA to approve EIAs without comments accidents, diseases, injuries and fatalities so
from MoGLSD since MoGLSD is mandated as to ascertain the trend of accidents, injuries
for oversight functions relating to Social and diseases which will enable it develop
Assessment Framework. NEMA should and implement interventions to aimed at
be advised to always submit EIAs to minimizing occupational accidents, diseases
MoGLSD. This condition is improving and injuries.
and we are now receiving more EIAs • MoGLSD should also establish a framework
from NEMA for review. for a coherent and comprehensive National
Safety and Health data management system.
The OSH Act, 2006 derives its mandate
from Articles 39 and 40 of the Constitution
of the Republic of Uganda. The Physical
OVERALL AUDIT CONCLUSION
Planning Act, 2000 focuses on the land
The Occupational Safety and Health Act, 2006,
uses while OSH Act focuses on safety
was enacted by Parliament to provide for the
and health issues at work.
right of persons to work under satisfactory, safe
In regard to coordination with MoH and
and healthy conditions. However, despite the
Uganda Police on occupational injuries
existence of the Act, many workers in Uganda
and diseases, The Ministry plans to
are not aware of their rights to a safe and healthy
upgrade the OSHMIS. It will be established
working environment and have remained exposed
in districts and at enterprise level. The
to unhealthy working conditions, faulty plants and
terms of reference to this critical activity
equipment, dangerous civil works and constructions
have already been developed.
leading to ill health and death. Enforcement of
the OSH legislation has not been effective due to
Recommendations
inadequate awareness and sensitization on OSH
• To enhance the current coordination
standards, limited personnel and logistics, absence
efforts, MoGLSD should consider
of the National OSH Policy and an OSH Laboratory
entering into memoranda of
to analyze exposure measurement samples and
understanding with the various
to test personal protective equipment. There is
agencies (NEMA, district local
need for the MoGLSD to develop a framework for
governments, Ministry of Health,
OSH training, awareness and information sharing
and Uganda Police) to spell out
at all levels as well as enhance cooperation with
their roles, responsibilities and
civil society organizations (NOTU, COFTU and FUE)
expectations in the workplace
to train and sensitize employers, workers and the
occupational and safety value chain.
general public in all aspects of OSH.
29
GLOSSARY OF TERMS
Person or organization employing workers under a written or verbal contract of

employment which establishes the rights and duties of both parties, in accordance
Employer with national law and practice. Governments, public authorities and private companies
as well as individuals may be employers.
A state of complete physical, mental and social well-being and not merely the absence
Health of disease or infirmity
A state in which one is unable to function normally and without pain. It is an abnormal
process in which aspects of the social, physical, emotional, or intellectual condition
Ill health and function of a person are diminished or impaired compared with that person’s
previous condition.
Occupational An occurrence arising out of, or in the course of, work which results in: fatal occupational
injury or non-fatal occupational injury.
accident
Occupational A disease contracted as a result of an exposure to risk factors arising from work
activity.
disease
Occupational Anything that has potential to cause harm to a person at work
Hazard
The promotion and maintenance of the highest degree of physical, mental and social
Occupational well-being of workers in all occupations by preventing departures from health,
Health controlling risk and the adaptation of work to people, and people to their jobs.
Occupational Refers death, any personal injury or disease resulting from an occupational accident.
injury
The likelihood of an undesired event with specified consequences occurring within a
specified period or in specified circumstances. It may be expressed either as a frequency
Risk (the number of specified events in unit time) or as a probability (the probability of a
specified event following a prior event), depending on the circumstances.
The process used to determine the likelihood of people being exposed to injury, illness
Risk assessment or disease in any situation identified during the hazard identification process; and also
the severity of the illness, injury or disease.
The ways in which safety is managed in the workplace, and often reflects “the attitudes,
Safety culture beliefs, perceptions and values that employees share in relation to safety”
Workers’ A system of benefits provided by law to employees who experience work-related

injuries or occupational diseases regardless of fault
compensation
All places where workers need to be or to go by reason of their work and which are
Workplace under the direct and indirect control of the employer
Work related A disease with multiple causal agents which may include factors in the work
environment.
disease
30
APPENDICES
4.4 Appendix I: Organizational Structure of

DOSH
Commisioner
Occupational
Safety & Health
Assistant Assistant
Commissioner/ Commissioner/
Occupational Occupational
Safety(1) Health (1)
Principal Principal Principal

General Principal Principal Principal Principal
Specialzed Occupational
Training General safety Prosecution Health Occupational
Safety Physcian (1)
Inspector(1) Inspctor(3) Inspctor (1) Inspector(1) Hyginist (1)
Inspector(2)
Senior General Senior Senior Senior

Senior Prosecution Senior Health Senior
safety Inspctor Speciliazed Occupational
General Inspctor (1) Inspector(1) Occupational
(4) Safety Physcian (1)
Training Hyginist (1)
Inspector(2)
Inspector(1)
General Prosecution Health Occupational

Inspctor Speciliazed Inspector(1) Physcian(1) occupational
General Safety Safety Hyginist (3)
Training Inspctor (4) (1) Inspector
Inspector
(4)
(1)
Senior Senior
Occupational Labalatory
Nurse (1) Technician (1)
Occupational Labalatory
Nurse(1) Technician(1)
31
4.5 Appendix II: Workplaces Sampled/Inspected by
the Audit Team
S/No. PUBLIC WORKPLACES S/No PRIVATE WORKPLACES
1 Entebbe District Local Government 1 Roofings Limited

2 Mbarara District Local Government 2 Tian Tang Group Limited
3 Moroto District Local Government 3 Crest foam
4 Kasese District Local Government 4 Riley Packaging (U) ltd
5 Kamwenge District Local Government 5 Landy industries (U)
6 Iganga District Local Government 6 Crestanks Limited
7 Tororo District Local Government 7 Sugar Corporation Uganda Limited
8 Mbale District Local Government 8 Shumuk Alminuium rolling mill
9 Jinja District Local Government 9 Sadolin paints
10 Mukono District Local Government 10 Parambot distillers
11 Wakiso District Local Government 11 Mukwano industries
12 Mubende District Local Government 12 SCD Uganda ltd
13 Ministry of Works and Transport 13 Britannia allied industries ltd
14 Kabarole District Local Government 14 Ali Metals and trading Co. Limited
Ministry of Gender, Labour and Social
15 15 Tororo Cement Industries
Development
16 Mubende Referral hospital 16 Global Paper
17 Fort Portal Regional Referral hospital 17 Steel rolling mills ltd
18 Mbale Regional referral Hospital 18 Kakira sugar works
19 Kampala Capital City Authority (KCCA) 19 Lugazi sugar works
20 Sun belt Uganda ltd
21 Tibeti - Hima mining company
22 Bakhresa Grain milling Uganda ltd
23 Tembo Steel Rolling Mills
24 Abacus Parenteral Drugs Limited
25 Central organization of free trade unions (COFTU)
26 Sky fat Tannery Limited
27 Quality Plastics(U) Limited
28 Leather Industries of Uganda Limited
29 African Minerals Uganda Ltd
Anglo Uganda Corporation – International Gold
30
mine, Mubende district
Lukwago Gold mine, Mubende District-kitumbi
31
sub-county
Kampala gold mine, Mubende District-Kitumbi
32
sub-county
33 Federation of Uganda employers (FUE)
34 National organization of trade unions (NOTU)
32
14 Appendix III: Tools and testing equipment required
for OSH inspections
SNO EQUIPMENT QTY PURPOSE
Structural Integrity Assessment
1 Visual / Optical Inspection

For visual inspection, detailed recording of
1.1 Digital camera 23
structural characteristics
For structural monitoring, periodic recordings and
1.2 Video recorder 5 damage evaluation with the objective of detecting
any possible structural changes
Aid in the external examination of structures from
1.3 Binoculars 5 ground level, particularly for roofs and higher level
walls
Used in internal examination, particularly in
1.4 Touch light 23 parts of buildings /construction sites with limited
illumination
To locate and study small ( up to 2 – 3 micron
1.5 Magnifying glass / Monocular Lens 5 wide) cracks in in-situ concrete surfaces and
other such structural behaviour
1.6 Steel tape 23 To measure lengths, widths, heights, etc.
2 Concealed object inspection,

Detects rebar location and depth of the bars, upto
2.1 Magnetic cover meter 5
a depth of 7 – 8 inches within concrete
For indirect visual inspection of parts where
2.2 Fiberscope or video probe 5 coverings and other obstructions / accessibility
constraints exist e.g. through drilled holes, etc
Optical bore scope to inspect hidden voids and
2.3 endoscope 5
cavities in bridges and other structural elements
3 Dampness inspection
To measure temperature in rooms, work areas or
3.1 Digital thermometer with a probe 5
even cracks / structural orifices
To determine fabric and air moisture levels, or
3.2 Hygro test kit / hygrometer
even location of leaks in say flat roofs
Half-cell Potential Wheel measuring Measures the state of corrosion and determines
3.3 5
instrument continuity of reinforcement in a concrete element
Stress and strain survey. Measurement of Cracks
4
in Building
4.1 Steel rule 23 To measure and mark straight lines on structures
Magnifying glass fitted with a
4.2 5 Same as 1.1 E above
graticule
Demec gauge (Mechanical strain
4.3 5 To monitor changes in crack width
gauge)
Check for expansion-contraction joint fillers and
chemical attack. Also for measuring / surveying
4.4 Calliper 23
vertical and horizontal movements in concrete
structures – requires long term observation
33
Assessment of Concrete Strength Using Rebound
5
Hammer.
Schmidt Hammer / Concrete rebound Indicates the compressive strength of hardened
5.1 5
or penetration hammer; concrete
Electronic theodolite (transit) integrated with an
electronic distance meter (EDM) to read slope
5.2 Total Station 5
distances from the instrument to a particular
point.
Equipment to locate the position, depth and size of
5.3 Rebar locator 5
reinforcement bars in a concrete element
To measure & ensure adequacy of width of points
of ingress and egress, including area of window
/ ventilation openings, head room, ergonomic
5.4 Measuring Tapes 23
height of work stations, corridor widths, heights of
balustrades / edge protection, excavation depth,
distance to excavation edge, etc
Equipment to measure oxygen, carbon dioxide,
carbon monoxide, and other gases within confined
spaces; for the prevention of three kinds of
atmospheric hazards:
5.6 Gas meter 5 • flammable, combustible, or explosive
atmosphere
• oxygen-enriched or oxygen-deficient
atmosphere
• Atmospheric contaminants.
Equipment to ascertain slip resistance of floors to
5.7 Slip tester 5
prevent slips, trips, and falls
Equipment to ascertain adequacy of lighting and
5.8 Illuminometer 5
illumination in outdoor and indoor work areas
Equipment to ascertain adequacy of indoor air
5.9 IAQ meter, with various parameters 5 quality (IAQ) with adequate ventilation, humidity
and temperature, noise levels, etc
Equipment to measure vibrations on a given object
5.10 Vibration meter 5
at a given distance from the vibration source.
Equipment to ascertain adequacy / safety of
5.11 Testers 5
electrical connections ; earthing & insulation -
Equipment to ascertain presence or absence of
dangerous air borne chemicals or chemicals
5.12 in water; to identify and quantify airborne
contaminants in order to determine the level of
worker protection needed.
5.13 Life jackets 23 To be used when working / inspecting over water
Kit for maintaining in inspectors’ official vehicle
5.14 First Aid kit 5
for use during the course of work
6 Occupational Health :MEDICAL EXAMINATION EQUIPMENT
Weighing scales ,medical 150kg
6.1 4 For taking the body weight
Seca762
6.2 Height scale (Roller –type ,sec206) 4 For measuring the height of the client
6.3 Overhead adjustable lamps 4 For improving visibility during examination
6.4 Wall –mounted sphygmomanometer 4 For measuring the blood pressure
6.5 Audiometer 3 For examining the ears –hearing function
34
For isolation of sound during the testing for
6.5 Audiometric hearing sound booths 3
hearing levels
6.6 Electrocardiograph 3 For examination of the heart function /beats
Spirometer (lung function test
6.7 3 For measuring the lung functions
machine
Breathe alcohol testing
6.8 23 For measuring the level of alcoholic intoxication
devices(Breathalyzer)
6.8 Personal human vibration monitor 23 For measuring the vibration exposure
Hand dynamometer (grip strength For measuring the strength of the hand grip during
6.9 23
meter ) rehabilitation /after trauma
6.10 Otoscope ,beta 100,heine 5 For examination of the ears
6.11 Laryngoscope set Macintosh 5 blades 5 For examination of the throat
6.12 Torch ,examination ,penlight ,Heine 10 For giving extra light during examination
6.13 Ophthalmoscope,mini3000,heine 10 For examining the eyes

Portable hand held slit lamp
6.14 10 For examination the eye fundus
3200with a case
6.15 Vision chart (snellen’s chart ) 23 For measuring visual acuity
Ishihara 38-plate colour blindness
6.16 23 For checking for colour blindness
test
Patella hammer
6.17 10 For examination of the body reflex
,percsssion,200mm,dejerine
For measuring the width, length and
6.18 Tape measure 10
circumferences
To use to press the tongue while examining the
6.19 Tongue depressor 100
throat
For assess the ability to hear and the vibration
6.20 Tuning fork ,512hz,hartmann 12
sensation
6.21 Diagnostic set ,complete ,Gowllands 5 For medical examination
6.22 Oximeter 10 for determining the oxygen saturation in the body

a monitoring device that measures and numerically
6.23 Capnometers 10 displays the concentration of carbon dioxide in
exhaled air—
6.24 Thermometer 10 For measuring body temperature
For listening to sounds produced within the
6.25 Stethoscope 10
body(heart, breathing bowel sounds )
7.0 Procedure / Examination Room Equipment
7.1 Instrument tray with a cover 10 For storage and easy/safe movement of items
7.2 Trolley multi-purpose 10 For storage and easy/safe movement of items
7.3 X-ray view boxes 5 For viewing the x-ray films
7.4 Autoclave 5 For sterilizing medical equipment

Nebulizer, sunmist 4650e,sunrise For delivering broncho dilators in vapour form to
7.6 10
medical patient
35
For storing and sterilizing in equipment
7.7 Steriliser drums stainless steel 10
7.8 Ear syringe ,metal 10 For flushing impacted wax out the ear
7.9 Bowl ,stainless steel 3 litres 10 Container for equipment
7.10 Kidney dishes 20 Container for medical equipment
7.11 Gallipots 20 Container for antiseptic solution
7.12 Instrument box with lid 20x9x5cm 10 For storage and easy transportation of instruments
8 Occupational Health Laboratory
8.1 Digital Haemoglobin Meter 10 Measure the level of haemoglobin in the blood
8.2 Stop clock ,table mount 10 For timing tests

Differential counter, manual
8.3 10 For measuring blood cells
,parameter
8.4 Incubator ,Laboratory ,53ltrs 3 For warming samples
8.5 Glucometer 10 For rapid diagnostic test
8.6 Glucose strips 1000 For rapid diagnostic test
8.7 Timer ,60 minutes 10 For timing Laboratory tests

Centrifuge, haematocrit
8.8 3 For measuring haematological indices
210,hettich
Colorimeter, model
8.9 3 For measuring electrolyte s in the body
co7000,wpa pip
Adjustable blood sampler For taking small aliquots of blood from the test
8.10 1000
pipette tube
Measuring cylinder glass 1ltr
8.11 500 For measuring reagents
& 500ml
8.12 Perti dish glass 1 pair 50 For holding samples
8.13 Spirit lamp 4 For provision of extra light/heating sample

Test tube rack metallic for 24
8.14 1 For holding/storage of test tubes
tubes
8.15 Test tubes 1000 For holding samples
8.16 Vacutainers(EDTA & plain) 1000 Corrections samples
8.17 Tourniquet 10 For venipuncture
8.18 Malaria test strips 1000 For rapid diagnostic test

Rapid hepatitis B antibody test
8.19 1000 For rapid diagnostic test
strips
Rapid salmonella typi igg/igm
test strips
8.21 Rapid pyloric 20 test 1000 For rapid diagnostic test
8.22 Rheumatoid factor latex 1000 For rapid diagnostic test

Rapid hepatitis C virus
antibody test strips
36
9 Occupational health-Clinic Furniture /furnishing
9.1 Examination couch 3 For examining on clients to lay on
9.2 Medicine cabinet with locks 3 For storage

Pedal –operated waste baskets with
9.3 10 waste management
lid and liner
for storage of drugs /vaccines and Laboratory
9.4 Refrigerator 2 2
samples
9.5 Ward screen 4 panel 3 For ensuring privacy
9.6 Steps 3 For climb on to the examination couch
9.7 Mattress with PVC cover ,adult 5 For the resting on
9.8 Camera ,35mm and accessories 5 For recording incidences
9.9 Stool -adjustable 4 For good working position
9.10 Wall clock 3 For noting the time
10 EMERGENCY RESUSCITATION
10.1 Oxygen gas 3.5m3(medium )cylinder 3 For resuscitation
10.2 Resuscitator ,adult ,marki ,v, ambu 3 For resuscitation
10.3 Suction pump ,hand /foot operated ,T 4 For resuscitation
10.4 Airway Guedel (Size 00,0,1,2,3) 10 For resuscitation
10.5 Automated external defibrillator 4 For resuscitation
10.6 Rescue Ambulance 2 Emergency Rescue
11 Occupational Hygiene equipment

For the accurate calibration of all industrial
11.1 Air Sampling Calibrators 10
hygiene and environmental air sampling pumps.
to assess aerosol concentrations of contaminants
11.2 Air Sampling Pumps 23
such as dust, gases or other vapours
11.3 Calibration Gas & Regulators 10 Calibration
facilitates in the assessment of aerosol
11.4 Dust & Particulate Monitors 23 concentrations of contaminants such as dust,
smoke, fumes and mists
11.5 IAQ Indoor Air Quality 23 Air quality assessment
Lead in Paint Analysers, X-Ray
11.6 10 Analysis of lead
Fluorescence (XRF)
Gas Emission/Combustion Test
11.7 23 Gas emission analysis/ detection
Equipment
11.8 Noise Dosimeters 23 to measure worker noise exposure
Monitoring radiation and electromagnetic fields
11.9 Radiation & EMF Meters 23
(EMF)
11.10 Respirator Fit Testing 23 respiratory fit testing equipment
37
11.11 Sound Level Meters 23 measures noise pollution
Monitors for heat stress analysis, humidity,
11.12 Temperature & Humidity Meters 23
temperature, dew point, voltage and current.
11.13 Heat Stress Meters 23 Temperature assessment
11.14 Vibration Analysers 23 Vibration assessment
11.15 Digital Hand Held Light Meters 23 Illumination assessment
11.16 Detector Tubes 1000 Sample collection
11.17 Moisture Content Meters 23 Moisture assessment
11.18 Air Velocity Meters 5 Ventilation assessment
11.19 Oil Content Analyser 5 Oil analysis
11.20 IR Cameras 5 Infra-red rays detection
11.21 Shipping Cases & Gear Bags 10 Carrying sample
12 Tools and Testing Equipment for Statutory Equipment

Hydrostatic Test Pumps - Electrical
12.1 5 Testing integrity/leakages of pressure vessels
& Manual
Testing pressures in the pressures vessels and
12.2 Pressure Gauge 5
boilers
12.3 Dye Penetrant Test Kit 5 Detecting cracks on machinery
12.4 Ultrasonic Test Kit 5 Detecting the integrity and cracks in machines
Boiler Water Quality Test Kit/Analysis
12.5 5 Monitoring the quality of boiler water
Kit
Gas detection in confined spaces(boilers and
12.6 Gas Test Kit( H2s, C0, 02) 5
pressure vessels, LPG tanks)
12.7 X-ray crack detection kit 5 Detection of cracks in machinery
12.8 Testing Loads Assessing of carrying/ lifting capacity of equipment
13 Computer &Soft wares

Software packages for hygienic/
engineering measurement and 5
analysis
Computers 23
Scanners 5
Printers 5
Photocopiers 2
Others
Set of Spanners
Hammers
Hacksaw
Pipe Wrench
38
39
THE REPUBLIC OF UGANDA
OFFICE OF THE AUDITOR GENERAL
P.O.Box 7083, Kampala,

Tel: +256 414 344 340 Fax: +256 414 345 674
E-mail: info@oag.go.ug

Enforcement of Occupational Safety Health OSH at Workplaces by DOSH

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T H E R E P U B L I C O F U G A N D A

OFFICE OF THE AUDITOR GENERAL

www.oag.go.ug | E-mail: info@oag.go.ug

ENFORCEMENT OF OCCUPATIONAL SAFETY AND

A REPORT BY THE AUDITOR GENERAL

ENFORCEMENT OF OCCUPATIONAL SAFETY

A REPORT BY THE AUDITOR GENERAL

31st December 2016

The Rt. Hon. Speaker of Parliament

ENFORCEMENT OF OCCUPATIONAL SAFETY AND HEALTH

In accordance with Article 163 (3) of the Constitution, I hereby submit my

LIST OF ACRONYMS............................................................................................................... iii

1.6 Audit scope................................................................................................................ 5

Table 3: Showing the delay by workplaces to renew registration certificates................... 18

Table 4: Showing the delay to renew equipment certificates.............................................. 19

Table 6: Showing level of compliance with OSH requirements at the sampled

Table 7: Showing inspection reports presented to the audit team..................................... 25

Figure 2: Trend analysis of workplace registration and NTR collected............................. 18

Figure 4: Showing status of compliance of PPE by workers at some workplaces visited...... 23

COFTU Central Organization of Free Trade Unions

DOSH Department of Occupational Safety and Health

DLG District Local Government

MPS Ministerial policy statement

FUE Federation of Uganda’s Employers

IFMS Integrated Financial Management System

ILO International Labour Organization

KCCA Kampala Capital City Authority

MoGLSD Ministry of Gender, Labour & Social Development

MDAs Ministries, Departments and Agencies

NTR Non Tax Revenue

NOSHP National Occupational Safety and Health Policy

NOTU National Organization of Trade Unions

OSH Occupational Safety and Health

OSHMIS Occupational Safety and Health management Information System

PPE Personal Protective Equipment

SSASHEW Strengthening Safeguards, Safety and Health at Workplaces

Registration of work places

1 ILO Fundamental Principles of Occupational Health and Safety

2) Inspection and monitoring of OSH activities

3) OSH training and sensitization

Coordination with Local Governments on approval of architectural drawings/ plans

1.3 DESCRIPTION OF THE AUDIT AREA

5 Occupational Safety and Health issues in Uganda Feb 4th, 2008

1.3.3 DOSH Activities

1.3.4 Organization Structure

13 The Occupational Safety and Health Department Brochure

2012/2013 610.00 513.42

Sub-Total: 1,696.05 1,566.74

2012/2013 2,000 2,000

Sub-Total: 6,000 5,884.98

Total Funding 7,696.05 7,451.72

1.4 OVERALL AUDIT OBJECTIVE

1.5 SPECIFIC AUDIT OBJECTIVES

1.6 AUDIT SCOPE

2.2 DATA COLLECTION METHODS

Audit Objective 1: To establish the extent of workplace registration and equipment

To establish action taken following inspection (thus effectiveness), we reviewed inspection

Audit Objective 3: To establish whether DOSH effectively promotes occupational safety

• Reviewed the Ministry’s correspondences with the key stakeholders in relation to

SYSTEMS AND PROCESS DESCRIPTION

3.1 ROLES AND RESPONSIBILITIES OF KEY PLAYERS

Key Player/Entity Role/Responsibility