Identify barriers without labelling people
The INSST analyses language knowledge alongside other employment conditions affecting migrant workers. Distinguish oral understanding, reading instructions and technical vocabulary. Fluent everyday conversation does not establish understanding of a work authorisation or alarm.
Assessment should consider the task and organisational environment. Ask what support the person needs, recognise their experience and observe how they interpret relevant instructions. Do not infer lack of capability from an accent, background or manner of expression.
Information and training people can understand
Article 19 of Spain’s Occupational Risk Prevention Law (LPRL) requires sufficient and appropriate theoretical and practical training. Providing a document in a language someone does not understand does not demonstrate that they have learned to work safely. OSHA also recommends adapting training to language and level of understanding.
Use specific sentences, consistent vocabulary, workplace images and demonstrations where they clarify meaning. Machine translation may provide a draft, but a critical instruction needs competent review. Pictograms help and must be explained; they do not guarantee a shared interpretation on their own.
Check understanding through practice
Ask the person to explain the action in their own words or demonstrate it under safe conditions. This is more useful than simply asking whether they understood. Check task limits, warning signals and situations requiring them to stop and ask for help in particular.
If an error arises, review both the explanation and available conditions. Repeating the same sentence more loudly does not resolve an unfamiliar technical term. Checking should enable correction and learning without humiliating or penalising someone who raises a question.
Enable reporting, participation and support
There must be a way to report a hazard even if the person cannot write confidently in the usual language. An accessible contact, language support and clear channels can facilitate communication. Also define how suggestions will receive a response.
Initial support does not replace training or necessary supervision. Avoid depending on a single colleague who may change shifts or be absent. Ensure temporary and external workers receive the information relevant to them before exposure begins.
Review the system and its evidence
Record content, language or support used, practice completed and outstanding needs. A signature may document an action but does not by itself establish understanding. Update materials when equipment, processes or instructions change.
Observe whether particular reports recur or some teams do not participate in meetings. These signals may reveal communication barriers. Analyse the process without turning background or language data into unjustified personal risk classifications.
Hypothetical example: a stop instruction
A person experienced in production does not know the local meaning of a stop instruction. The trainer uses a demonstration and reviewed material in an understandable language. The person is then asked to identify when to stop the equipment and whom to notify.
The check reveals ambiguity also affecting other colleagues. The general instruction is corrected and the whole team’s practice verified. Improvement addresses a system barrier rather than attributing the problem to someone’s background.
