PDCA: Hiring, Documentation, Medical Exams and Work Assignments

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SCOPE: Child Labour & Young Workers

Hiring, documentation, medical exams and work assignments

To achieve and maintain compliance with the below noted "Related Laws" on YOUNG WORKERS-Hiring, Documentation, Medical Exams and Work Assignments, it is necessary to have the following management system foundations in place -following the PLAN, DO, CHECK, ACT system structure: 

  • Up-to-date legal requirements and commitments (policies/activities) that ensure all young workers are correctly documented, assessed, and registered to be able to work for the company and understand aspects of occupational health and safety (non-hazardous tasks, night work or overtime) prior to starting work.
  • Procedures and accountability to implementing the young workers' policies/activities, particularly identifying and screening children in the hiring process and appropriate protections regarding health and safety.
  • General training for management and workers on the young workers' policies/activities and technical training for managers/hiring team/human resources staff on effective age verification process during hiring. 
  • Documentation of procedures on screening and young workers' protections.
  • Periodic Management System Owner and Team Members review how effectively the overall system performs.


  • Meeting legal requirements.
  • Aligning with customer's requirements.
  • Protection of children's health, wellbeing, development, and access to education.

The following sections provide a detailed example of the PLAN, DO, CHECK, ACT contents needed. This content can be used as a starting point by any factory to build out their management system and cross-check and compare an existing system.

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Access and review the requirements (laws) on: Young Workers and "Related Laws" (noted at the bottom of this page) and any other risks/opportunities assessment and standards applicable such as customer's requirements, etc. 


Set up your teams to ensure that your system has the appropriate staff overseeing and implementing all the (input/output) activities and continuously monitoring the system. 

  • Senior Management - The Senior Management team and the specific Functional Team Members must continuously work together throughout the PLAN-DO-CHECK-ACT cycles to impact sustainable change and improve overall system performance. 
  • Functional Team Members - The Senior Personnel /Human Resources Manager  will rely on the Production Manager and the Hiring, the Payroll (Wages and Benefits) Manager and Recruitment Manager to fulfill the requirements of the laws regarding Young Workers – Hiring, Medicals and Work Assignments. They must continuously communicate with the Senior Management team and other relevant stakeholders consistently and routinely to impact sustainable change and improve overall system performance. 
  • Ongoing Support - Worker feedback and participation. Others could include external stakeholders such as non-governmental organisations.


Determine how your factory will meet the legal requirements on Young Workers. What your factory needs to do (activities/processes/procedures) to meet your overall system objectives  and show that your factory is committed to complying with the law. 

You may need to assess your current system practices with the system input activities list below and identify the gaps for improvements. 

  • Implement ID documentation checks to ensure all workers are 16 or older.
  • Implement medical examinations prior to starting work and annually until young workers turn 18 to ensure suitability for work.
  • Registration of juvenile workers with the Ministry of Labor. Occupational safety and health training for all new workers.
  • Implement overtime controls for young workers in Jiangsu Province and other provinces where zero overtime is allowed.
  • Identify hazardous work activities in the company that young workers are prevented from participating in.




With the required activities(process/procedures) in place, the system's primary owners must continuously communicate and train all managers and workers on the legal requirements and your factory's commitments towards it. 

  • Provide initial and refresher training for staff involved in recruitment, selection, and hiring of young workers. 
  • Ensure job advertisement and job descriptions state the minimum hiring age and restrictions for young workers. 
  • Train managers and supervisors on procedures to systematically protect young workers from occupational hazards, including the prohibition of overtime. 
  • Communicate the company’s young worker policy to any staffing/ recruitment agencies placing workers in the factory. 
  • In all instances where training is required, records of training will need to be kept. 


The results (Outputs/Outcomes) from all the activities are listed below. These are the methods/processes/procedures that should be in place to ensure that Young Workers are properly protected in the workplace. 

  • Onboarding forms to capture key information. Verification of age with copies of identity documents to ensure workers are 16 years or older. Copies of the identity document on each worker's file.
  • Assigned owner and process to register young workers with the Ministry of Labour.
  • Medical examination process for all new workers and annually thereafter until they turn 18.
  • Occupation Health and Safety training and onboarding including controls to prevent assignment to work that young workers may not do.
  • Process to assign young workers to non-hazardous work categories in the factory. Record the work assignment on file and update the worker file if changes occur.


Below are a few templates to help you manage/organize your system process. You can adjust it as you see fit to work for your facility or your existing management system.





Review owners include the Functional Team Members and specific criteria below:

  • Review of each Output should be carried out by another senior staff member within the company or through an independent second or third-party audit. 
  • Review Owners can be limited to senior company managers such as the Chief Executive Officer or Head of Human Resources. 
  • Alternatively, for in-house review, other Management System owners can review each other’s Management System on a rotational basis. 


It should never be assumed that every Input/Output activity has been carried out correctly. Review Owners need to make sure all the activities are adequately implemented and working smoothly:  

  • Outputs/Outcomes from the DO section are up to date. This means the Review Owners essentially confirm all the Activities in the PLAN/DO sections have been carried out correctly. For example, regularly review young worker job assignments to check that restrictions on the job type and working hours meet legal/factory requirements. 
  •  Conduct an inspection in the factory -check the documentation and interview workers to confirm the Activities (processes/procedures) are correctly implemented to produce the Outputs/Outcomes that meet the requirements of the laws applicable to the Management System. For example, feedback from newly hired young workers on the recruitment, selection, and hiring process they went through, including for workers placed through third-party contractors. 


  • Any findings arising from the process review are escalated to the Management System Owner and Team members mentioned in the PLAN section. This is done using the Escalation Process and Tracking Guidance template in the DO section. 
  • A corrective action for the findings is carried out through the Owner and Team members. 
  • Findings or faults observed in the Management System, its Activities Input/Outputs are summarized for presentation and actions by Factory Manager with Management System Owner and Team Members.


  • For continuous improvement in your system on the employment of young workers requirements, you will need to ensure:
  • Periodic review of the system by Factory Manager with Management System Owner and Team Members of findings in the CHECK section should result in a directive to improve or update the PLAN, DO and CHECK sections.
  • Management makes a written commitment with an implementation timeline to implement these improvements (take immediate corrective and preventive actions).
  • Continuously review the improvements made at the time of the deadlines to ensure they are adequate or need further improvement
  • Repeat the PLAN-DO-CHECK-ACT process, adjust and re-adjust the objectives, input/output activities, and evaluate the effectiveness and corrective action plans.


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