Health and Safety in Translation: 7 Mistakes Employers Make
A group decides its health and safety documents should be available in local languages. Somebody runs the policy and the induction deck through a translation service, the files go into the shared drive with country suffixes, and the item is marked complete.
It is a reasonable instinct and it usually fails, for a reason that is easy to state and hard to act on. The legal test in most jurisdictions is not whether information was provided in a language. It is whether the people receiving it could understand it, and whether the document is the one that country's law actually requires.
Seven mistakes, in roughly the order organisations make them.
1. Treating translation as the obligation
The obligation is comprehension, and it is expressed that way.
Regulation 10 of the Management of Health and Safety at Work Regulations 1999 requires employers to provide employees with comprehensible and relevant information on the risks and the preventive measures. Regulation 13 requires employers to take into account employees' capabilities as regards health and safety when entrusting tasks, and to provide adequate training.
Comprehensible is doing the work in that first provision. A translated document that nobody reads, or that reads as machine output, does not deliver comprehensible information, and an employer relying on it has met the form of the duty rather than its substance.
The practical test is simple and uncomfortable. Ask three people in that population to explain the arrangement back to you. If they cannot, the document has not discharged anything.
2. Assuming the language of the country is the language of the workforce
The mistake that produces well-intentioned failure.
A Warsaw delivery centre may operate in English internally and employ people who speak Polish, Ukrainian and Russian at home. A London office may employ cleaners and security staff whose first language is not English. Manila and Kuala Lumpur operations are frequently multilingual by default.
The relevant question is not which country the office is in. It is which languages the people in it actually understand well enough to act on safety information under pressure, which is not the same as the language they conduct business in. Fluency in professional English does not reliably survive an alarm, and HSE addresses the wider point in its material on vulnerable workers.
3. Translating the group document instead of producing the local one
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The most consequential error for anyone operating across borders, and the theme that recurs in every jurisdiction.
Several countries require a specific instrument in a specific form. France requires a DUERP in a prescribed format. Romania requires an individual training record on a prescribed model. Mexico applies official standards with their own instruments. Saudi Arabia requires safety instructions displayed in Arabic. Poland requires records tied to a national training structure.
None of those is satisfied by a translated version of your group policy, however good the translation. A correctly translated wrong document is still a wrong document, and it is arguably worse than nothing because it creates the appearance of compliance.
4. Ignoring the ones that must be legally certified
A narrower point that catches people out.
Some jurisdictions require documents submitted to authorities to be in the official language, and some require certified translation for particular purposes. Where a document will be produced to an inspectorate, filed with a ministry or relied on in a proceeding, check whether an ordinary translation is acceptable before commissioning one.
This applies to a small proportion of your material and it is exactly the proportion that matters most when it is needed.
5. Forgetting signs, and the fact that they are regulated separately
Safety signage has its own rules and its own logic, which is largely pictorial for good reason.
In Great Britain the Health and Safety (Safety Signs and Signals) Regulations 1996 govern this, supported by HSE's guidance publication L64. The prescribed sign system is designed to be understood without reading, which is a considerable advantage in a multilingual workplace and one that organisations undercut when they add English-only text to compliant pictograms and treat the text as the message.
Where words are genuinely necessary, they need to be in languages the workforce reads. Where they are not, the pictogram is doing the job and should be allowed to.
6. Translating the words and not the arrangement
The subtler failure, and the one a good translator cannot prevent.
Health and safety documents are full of concepts that do not map cleanly between systems. A British risk assessment, a German Gefährdungsbeurteilung and a French DUERP are not the same artefact with different names. A "competent person" means something specific in Britain, something else again in Belgium's prevention adviser and Luxembourg's designated employee, and something else in Romania's designated worker.
Translate the term literally and you produce a document that describes a role your local arrangement does not have. The material needs to be produced by someone who knows what the local instrument is, which is a different skill from language.
7. No version control, so the translations drift
The administrative failure that undoes the rest.
The English document gets updated after an incident, a reorganisation or a legislative change. The eight translations do not, because updating them requires remembering they exist and finding the budget again. Eighteen months later the group has one current document and eight that describe arrangements it no longer operates.
This is a straightforward records problem and it is solved the same way as every other records problem: one register showing which document, which language, which version and when it was last reviewed, which is where health and safety consultants and software are worth more together than either alone. Periodic health and safety audits then confirm the local versions still match both the English and the law.
What good looks like
| Element | Weak | Strong | |---|---|---| | Standard applied | Translated into the local language | Comprehensible to the people receiving it | | Language selection | The official language of the country | The languages the workforce actually understands | | Document type | Group policy, translated | The instrument that country's law requires | | Certification | Ordinary translation throughout | Certified where the purpose demands it | | Signage | Pictograms plus English text | Compliant pictograms, words only where needed | | Concepts | Terms translated literally | Produced by someone who knows the local instrument | | Maintenance | Translated once | Versioned, reviewed, tracked in one register |
The row that carries the most risk is the third. Everything else on this list produces a weaker arrangement. That one produces a compliant-looking arrangement that does not comply.
Where this leaves a multi-country group
Two conclusions worth acting on.
Translation is a downstream activity, not a compliance strategy. Decide what each country requires first, produce it there, and translate only the material that genuinely needs to move between languages, which is usually group-level guidance rather than statutory instruments.
Comprehension is testable, so test it. Ask people. Run a short check during induction. Whether a workforce understands its evacuation procedure is knowable in an afternoon, and the answer is more useful than any document review.
All of the European variants above derive from the same EU Framework Directive 89/391/EEC obligation to inform and train workers, implemented nationally in each member state's own form, and HSE's introduction to managing health and safety covers the British baseline.
Where Arinite fits
Arinite coordinates locally qualified practitioners in each jurisdiction, which means documents are produced in the required form and the required language rather than translated into approximate equivalents. We support 1,500+ businesses across 50+ countries and protect 100,000+ employees, with 95%+ client retention over 15+ years. Our health and safety consultants work extensively with IT and software, finance and banking and professional services organisations with multilingual workforces.
Our global health and safety consultants establish what each country requires as an artefact rather than as a translation, and our international health and safety consultants keep that current as your footprint changes.
If your health and safety documents exist in six languages and nobody has checked whether they describe the right thing, a free gap analysis is the right place to start.
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Arinite Health & Safety Consultants
Health & Safety Expert at Arinite
