Do You Have Apprentices? Today's HSE Prosecution Exposes a Hidden Legal Requirement Most Employers Miss

If you employ apprentices, work experience students, or anyone under 18, you are legally required to conduct a separate young persons risk assessment — on top of your standard health and safety risk assessment. Most UK employers have never heard of this requirement. Today, a Rotherham manufacturing firm found out the hard way.

MTL Advanced Ltd was prosecuted by the Health and Safety Executive (HSE) on 30 March 2026 after a 17-year-old apprentice was seriously injured by a metal cutting guillotine during a training task. The HSE found that the company had failed to carry out the legally required separate young persons risk assessment. When inspectors visited the site, they found additional failings — including exposure to live electrical parts.

The legal requirement is clear. The consequences of missing it are severe. And the awareness gap is vast.

---

What Happened at MTL Advanced Ltd?

MTL Advanced Ltd, based in Rotherham, employed a 17-year-old apprentice as part of a training programme. During the course of their work, the apprentice was put near a metal cutting guillotine — a piece of heavy industrial equipment capable of causing catastrophic injury. The apprentice was seriously hurt.

When the HSE investigated, they found the firm had not conducted a young persons risk assessment before placing the apprentice near the machinery. This is a distinct legal obligation, separate from the company's general health and safety risk assessment. The HSE also identified additional failings during their site inspection, including the exposure of workers to live electrical parts.

The prosecution resulted in a fine and a public enforcement record. The firm's name is now on the HSE's published enforcement database — visible to clients, partners, and prospective employees.

The injury, the prosecution, and the reputational damage were all preventable.

---

The Legal Requirement You Probably Haven't Heard Of

Under the Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999, employers must assess the health and safety risks to all their employees. This is your standard risk assessment.

But there is an additional requirement that applies specifically when you employ young people — defined as anyone under 18 years of age. This includes:

• Apprentices
• School or college work experience students
• Saturday staff under 18
• Young trainees on government-funded programmes
• Any worker, part-time or full-time, under the age of 18

The Young Persons Regulations (contained within the Management of Health and Safety at Work Regulations 1999) require employers to conduct a separate young persons risk assessment before the young person starts work.

This is not a box to tick within your existing health and safety file. It is a standalone document.

---

What a Young Persons Risk Assessment Must Cover

A compliant young persons risk assessment must specifically consider:

Physical capacity Young workers may not have the physical strength or stamina of experienced adults. Heavy lifting limits, equipment weight requirements, and physically demanding tasks must be assessed with this in mind.

Inexperience and lack of awareness Young workers are, by definition, less likely to recognise workplace hazards. Your assessment must identify where their inexperience creates additional risk — and document what additional training, supervision, or restrictions you have put in place.

Exposure to hazardous machinery Under Regulation 19, young workers cannot operate certain types of machinery without specific authorisation and training. The risk assessment must list the machinery they will encounter and confirm they are either restricted from using it or have received appropriate training.

Chemical and biological hazards Some substances and biological agents are off-limits for young workers entirely. Your risk assessment must confirm that the young person will not be exposed to hazards that are prohibited under the Young Persons Regulations.

Physical and psychological development Young people are still developing. The risk assessment should consider whether the role or environment could harm their long-term development — including noise levels, temperature, ergonomic stress, and psychological pressures.

Supervision requirements For young workers, supervision must be adequate for their age and experience. Your risk assessment should specify the level of supervision in place.

This is a document that takes 30–60 minutes to complete properly. It must be done before the young person starts work — not after an incident.

---

Which Sectors Need to Act Now

This affects every sector. But the risk is highest — and the awareness lowest — in:

Manufacturing and engineering — machinery, cutting equipment, heavy plant, chemicals. The MTL Advanced prosecution is a direct warning.

Construction — power tools, working at height, heavy materials, site vehicles. CDM Regulations add further complexity when young workers are involved.

Hospitality and catering — commercial kitchen equipment (slicers, fryers, ovens), alcohol licensing restrictions, manual handling.

Retail — stock room equipment, bale compactors, delivery handling, lone working.

Trades — plumbing, electrical, carpentry, automotive. Young apprentices routinely work alongside hazardous tools and substances.

Beauty and hairdressing — chemical exposure (dyes, peroxide, acetone), electrical equipment, ergonomic risk.

Food production — processing machinery, knives, cold storage, chemical cleaning agents.

If your business has ever employed anyone under 18 — even for a week's work experience — the legal obligation applied.

---

What the HSE Looks For During an Inspection

When HSE inspectors visit a business with young workers, they will specifically ask to see the young persons risk assessment. This is not an obscure or rarely enforced obligation — it is a documented priority in HSE guidance.

Inspectors will check:

1. That the assessment exists and is separate from the standard risk assessment
2. That it was completed before the young person started work
3. That it specifically addresses the young person's inexperience and the hazards in their role
4. That the assessment was reviewed if the young person moved to a new task or area
5. That a parent or guardian was informed of the assessment if the young person is of compulsory school age (under 16)

The last point catches many employers off guard. If you took on a Year 10 student for work experience, you were legally required to inform their parent or guardian of the risks identified — before they started.

---

The Cost of Getting It Wrong

The MTL Advanced prosecution joins a long list of HSE enforcement actions that trace back to failures around young worker safety. Penalties vary based on company size and the severity of the harm, but the consequences go beyond the fine:

• Public enforcement record — visible on the HSE enforcement database
• Prohibition notices — the HSE can stop your operations on the spot
• Improvement notices — legally binding requirements with deadlines
• Criminal prosecution — directors can be personally liable under HSWA 1974 Section 37
• Civil claims — the injured worker can pursue a personal injury claim separately

For a small business, a prosecution on record can affect insurance premiums, tender eligibility, and client trust for years.

---

What to Do Right Now

If you employ or plan to employ anyone under 18, here are the steps:

Step 1: Check whether you have a young persons risk assessment Look in your health and safety file. Not your general risk assessment — a specific young persons risk assessment for each young worker or category of young worker.

Step 2: If you don't have one, create one before the young person next comes in Use a template that covers the areas above: physical capacity, inexperience, machinery access, chemical exposure, supervision, and psychological development.

Step 3: Review it whenever their role changes If the apprentice moves to a new area, takes on a new task, or is exposed to new equipment, the risk assessment must be reviewed and updated.

Step 4: Notify parents if the young person is of compulsory school age If they're under 16, parents or guardians must be informed of the key risks before they start.

Step 5: Document everything The risk assessment must be written down. Verbal assessments have no legal standing. Keep the signed document in your H&S file alongside your other risk assessments.

---

📄 Need a template? ComplianceAlert's document library includes a free young person risk assessment template, alongside 30+ other UK compliance documents. Available to Pro and Enterprise subscribers — or download the free set at compliancealert.co.uk/documents.

---

FAQs

Do I need a young persons risk assessment even for one week's work experience? Yes. The obligation applies from day one. If the young person is under 18 and working on your premises in any capacity, you must have a young persons risk assessment in place before they start.

Does this apply to apprentices over 18? No — the specific young persons risk assessment requirement applies to workers under 18. However, apprentices over 18 must still be covered by your standard risk assessment, and additional training and supervision obligations may apply under your apprenticeship agreement.

Can I use my existing general risk assessment and add a section? Technically the law requires a separate assessment that specifically addresses the circumstances of the young person. In practice, the safest approach is to create a standalone document rather than an addendum — this makes it clear to inspectors that you took the obligation seriously.

What if my apprenticeship provider handles training — is the obligation on them? No. The Health and Safety at Work Act places the duty on the employer — the business where the apprentice works. Your training provider does not discharge this obligation on your behalf.

I run a small business with one apprentice. Does this still apply? Yes. There is no minimum headcount threshold. The obligation applies to any employer who employs a young person, regardless of size.

---

TL;DR

• A Rotherham firm was prosecuted by the HSE today after a 17-year-old apprentice was seriously injured
• The specific failure: no separate young persons risk assessment
• This is a distinct legal obligation under HSWA 1974 and the Management of Health and Safety at Work Regulations 1999
• It applies to any employer with workers under 18: apprentices, work experience students, part-time staff
• The assessment must cover inexperience, machinery access, chemical exposure, physical capacity, and supervision
• If the young person is under 16, parents must be notified before they start
• Non-compliance can result in prosecution, fines, prohibition notices, and personal liability for directors

---

Not sure where your business stands on health and safety compliance? Take our free 3-minute Compliance Score quiz — 20 questions, instant results, no sign-up required. 👉 compliancealert.co.uk/compliance-score

Want to stay ahead of enforcement updates like this? ComplianceAlert monitors HSE enforcement actions, new regulations, and compliance deadlines across all UK sectors — and sends you plain-English alerts before they affect your business. 👉 Start your free 7-day trial at compliancealert.co.uk — no credit card required.

---