A recent HSE prosecution following the death of an 18-year-old apprentice has highlighted the consequences of inadequate supervision, unsafe material storage and poorly managed lone working.

Apprentices are workers, not additional labour who can automatically be left to get on with a task. Employers and contractors must assess their capability, provide suitable training and supervision, and only allow them to undertake work that they can perform safely.

The legal requirements are particularly specific for anyone under 18, but the wider duties to protect, instruct and supervise apply to apprentices and inexperienced workers of every age.

Are Your Apprentices Being Properly Supervised?

Apprenticeships are essential to the future of construction. They give new entrants an opportunity to develop practical competence while helping employers build a sustainable workforce.

However, an apprentice is still learning. A qualification programme, CSCS card or completed site induction does not automatically demonstrate that someone can recognise every hazard, make safe decisions under pressure or work without supervision.

That point was reinforced by a recent HSE prosecution involving the death of apprentice joiner Chloe Bidwell⁠. The 18-year-old was working alone at a renovation property when unsecured board materials fell and fatally crushed her. HSE found inadequate risk assessment, supervision, lone-working arrangements and material-storage procedures. The company was fined £50,000, while its managing director received a suspended prison sentence after pleading guilty under section 37 of the Health and Safety at Work etc. Act 1974. (HSE Media Centre⁠)

This was not a complex hazard requiring an unusual technical solution. It involved basic failures to identify how heavy board materials could fall, decide how they should be stored and ensure an inexperienced worker was properly supervised.

Young and inexperienced workers face additional risks

HSE advises that people who are new to a workplace can be especially vulnerable because they may lack experience, be unfamiliar with the environment, hesitate to raise concerns or be eager to impress colleagues and managers. HSE states that workers can be as likely to have an accident during their first six months as during the remainder of their working life. (HSE⁠)

Age is only one factor. A 25-year-old starting their first construction job may need more support than a 17-year-old apprentice who has already completed a structured placement with close supervision.

A suitable assessment should therefore consider:

• Age and maturity.
• Previous construction experience.
• Familiarity with the particular workplace.
• Understanding of the task and its hazards.
• Physical and psychological capability.
• Ability to recognise when conditions have changed.
• Confidence to stop work and raise concerns.
• Language, literacy or additional learning needs.

The supervision level should be determined by the worker’s actual capability and the risk of the task—not simply by how long they have been employed.

What does the law require?

General employer duties

Under section 2 of the Health and Safety at Work etc. Act 1974⁠, employers must ensure, so far as is reasonably practicable, the health, safety and welfare of their employees. This includes providing safe systems of work and adequate information, instruction, training and supervision.

Directors and senior managers should also understand the potential personal consequences of neglect. Section 37 of the Act⁠ allows individuals to be prosecuted where a company offence occurred with their consent or connivance, or was attributable to their neglect. The recent apprentice case demonstrates that these provisions are not theoretical. (HSE Media Centre⁠)

Construction-specific duties

Under regulation 15 of the Construction (Design and Management) Regulations 2015⁠, contractors must provide workers under their control with appropriate supervision, instructions and information so that construction work can be carried out safely. (Legislation.gov.uk⁠)

The wider competence requirements in CDM regulation 8⁠ require contractors to possess the necessary skills, knowledge, experience and organisational capability. In practical terms, an individual who does not yet have the experience needed for a task must work under suitable supervision while that capability is developed. (Legislation.gov.uk⁠)

A card or certificate may provide useful evidence of training or qualification, but it does not remove the contractor’s responsibility to confirm that the worker can undertake the actual task safely.

Additional duties for workers under 18

The law defines a young person as someone under 18. Regulation 19 of the Management of Health and Safety at Work Regulations 1999⁠ requires employers to protect young people from risks arising from their lack of experience, lack of awareness of existing or potential risks, or incomplete maturity. Certain work must not be given to a young person where it exceeds their physical or psychological capacity or exposes them to specified serious risks, except in limited circumstances involving necessary training and competent supervision. (Legislation.gov.uk⁠)

These additional requirements stop applying once the person reaches 18. However, the general duties under the Health and Safety at Work etc. Act and CDM continue to apply, including the need to consider inexperience and provide appropriate supervision.

Workers under 18 also usually have enhanced working-time protections, including a 30-minute break when working more than four and a half hours, 12 hours’ daily rest and 48 hours’ weekly rest. (GOV.UK⁠)

Is lone working by an apprentice automatically prohibited?

Health and safety legislation does not impose a universal ban on lone working. HSE’s general lone-working guidance⁠ requires employers to assess and manage the risks before anyone works without close or direct supervision. (HSE⁠)

However, the HSE inspector involved in the recent prosecution stated that apprentices should not be working alone on a construction site. That statement reflected the circumstances of a young, inexperienced apprentice being left without suitable supervision in an active renovation environment. (HSE Media Centre⁠)

In our professional view, lone working should not be authorised simply because the task appears routine. Before an apprentice or inexperienced worker is left alone, the employer would need compelling evidence that:

• The task is genuinely low risk.
• The worker has demonstrated competence.
• Foreseeable changes and emergencies have been considered.
• Communication and monitoring arrangements are effective.
• The worker knows when to stop and seek assistance.
• The decision is consistent with the risk assessment and site rules.

For many construction activities, direct or readily available supervision will remain necessary.

Induction is only the starting point

A site induction usually explains general hazards, emergency arrangements and project rules. It cannot provide all the task-specific skills and experience a new worker requires.

HSE’s guidance on training and supervising young people⁠ advises employers to check that instructions have been understood and to monitor progress so that additional training or adjustments can be provided. Young workers may require more supervision than experienced adults. (HSE⁠)

A practical supervision system should include:

1. A named supervisor who understands that they are responsible for the apprentice.
2. A structured task briefing explaining the work, hazards, controls and limits of authority.
3. Demonstration and supported practice before independent work is considered.
4. Observed competence checks, rather than relying only on verbal confirmation.
5. Progressive authorisation, identifying which tasks may be completed independently and which still require direct supervision.
6. Regular conversations, including checking whether the apprentice feels pressured, confused or unable to raise concerns.
7. Documented review points so supervision is reduced only when competence has been demonstrated.

Managers and supervisors can strengthen these skills through IOSH Managing Safely and Working Safely training⁠ and role-appropriate Construction Management and Supervisory NVQs⁠.

Do not overlook working culture and wellbeing

New IOSH research involving 500 workers aged 18–25⁠ found that 34% felt uncomfortable taking full rest breaks or switching off outside working hours. Fifteen per cent had taken time off during the previous year because of work-related stress, depression or anxiety, while 42% said they left education without a clear understanding of workplace health, safety and wellbeing. (IOSH⁠)

These findings are not specific to construction, but the message is relevant. Young employees may be reluctant to admit that they do not understand a task, are struggling physically or feel unsafe.

The answer is not another poster telling people to “speak up”. Supervisors need to create opportunities for workers to raise concerns without embarrassment or fear of being labelled difficult. This can be supported by suitable policies, competent supervision and practical Mental Health Awareness Training⁠.

Material storage must be planned, not improvised

The apprentice prosecution also provides a direct lesson about material storage. HSE found that large boards had been stored vertically and unsecured, creating a foreseeable collapse risk. (HSE Media Centre⁠)

HSE’s construction material-storage guidance⁠ advises contractors to designate suitable storage areas, plan deliveries, keep access routes clear and actively manage housekeeping throughout the project. Specialist HSE guidance also warns that board materials are heavy and that falling boards are a recognised cause of fatal and serious accidents. (HSE⁠)

Storage arrangements should therefore be included within project planning, RAMS, inductions and routine site inspections—not left to whichever worker happens to unload or move the materials.

Our professional view

Apprentices should be treated as people developing competence, not as low-cost labour who can be assigned routine-looking tasks without oversight.

The strongest employers establish a structured pathway from induction through supervised practice to verified competence. They make it clear what the apprentice may do, who is supervising them and how progress will be reviewed.

Where an organisation cannot demonstrate those arrangements, a review of its health and safety management, risk assessments and site-inspection arrangements⁠ should be treated as a priority. Our existing guide to the health and safety policies every construction company should have⁠ also provides a useful starting point for reviewing the wider management system.

Action Checklist for Construction Employers

• Identify all apprentices, young people and inexperienced workers.
• Confirm who is responsible for supervising each person.
• Review risk assessments before an under-18 starts work.
• Assess competence against the actual tasks being assigned.
• Set clear limits on work that cannot be completed unsupervised.
• Check that supervisors have sufficient time and competence.
• Review lone-working arrangements and emergency contact procedures.
• Verify that materials are stored securely and cannot topple.
• Check understanding after inductions and toolbox talks.
• Provide a clear route for workers to raise concerns.
• Review supervision following changes in task, location or equipment.
• Record competence decisions and progressive authorisations.

Frequently Asked Questions

Does every apprentice require constant supervision?

Not necessarily. The appropriate level depends on the person’s competence, experience and the risks of the task. However, supervision should only be reduced after competence has been demonstrated, not merely because the person has been employed for a certain period.

Is a separate young-person risk assessment legally required?

A suitable and sufficient risk assessment must consider the additional factors affecting workers under 18. HSE advises that this does not always need to be a completely separate document if the existing assessment already properly addresses those factors. (HSE⁠)

Can an apprentice work alone?

There is no universal legal prohibition, but lone working must be risk assessed. For an inexperienced apprentice on an active construction site, the employer would need to demonstrate that the work, competence, communication and emergency arrangements made the decision safe.

Does an NVQ prove someone can work without supervision?

An NVQ provides evidence that occupational competence has been assessed against a qualification standard. Employers must still confirm that the individual is competent for the specific work, equipment, environment and conditions they are being asked to manage.

Who is responsible when an apprentice works for a host contractor?

Responsibilities depend on the employment and placement arrangements. The employer, host organisation, training provider and any apprenticeship training agency should cooperate and clearly define who will control the work, assess risks and provide supervision. (HSE⁠)