Agiliton
Sector obligation map

Mandatory training obligations in regulated manufacturing

11 training duties across 12 instruments binding Manufacturing (Regulated), plus 10 that bind you whatever your sector — statute, rulebook, statutory guidance and licence conditions. Every one traced to its clause, its date and its published source, and each one labelled with what makes it a training duty.

JurisdictionUnited Kingdom
Built2026-08-12
Training duties21
Instruments20
Verified21 of 21
Every entry traced to a published clause

Your operators are trained. The sub-paragraph that catches you is the one about the people who supervise them.

Manufacturing carries a dense stack of substance- and equipment-specific training duties, and they are drafted with a consistency that makes the gaps predictable. Most specify what the training must contain; almost none specify how often it must happen.

That combination is the trap. An annual refresher satisfies an interval nobody set, while the enumerated content the regulation actually requires — the named substances, their exposure limits, the findings of the risk assessment — goes undelivered.

The obligations

Each clause carries a label saying why it is a training duty. Where the instrument does not use the word, we cite the guidance or the case that makes training the way you discharge it. Where we cannot cite anyone, it is not listed as a training duty at all.

says trainThe instrument itself requires training, instruction or CPD.
competenceThe instrument requires competence, qualification or knowledge. Training is the usual means; the instrument does not name it.
guidanceThe binding duty is an outcome. Official guidance under the instrument names training as how it is discharged.
case lawThe binding duty is an outcome. Case law makes training the operative discharge.
ClauseWho must be trained or assessedWhat is requiredIntervalEvidence required
The Provision and Use of Work Equipment Regulations 1998
Regulation 9(1) and 9(2)
says train
named role — every person who uses work equipment, and separately every employee who supervises or manages its useQuoted, 9(1): "Every employer shall ensure that all persons who use work equipment have received adequate training for purposes of health and safety, including training in the methods which may be adopted when using the work equipment, any risks which such use may entail and precautions to be taken." 9(2) applies the same duty to "any of his employees who supervises or manages the use of work equipment".None specified — the measure is adequacy, not interval.Not specified in the regulation itself.
The Control of Substances Hazardous to Health Regulations 2002
Regulation 12(1) and 12(2)
says train
named role — every employee liable to be exposed to a substance hazardous to healthQuoted, 12(1): "Every employer who undertakes work which is liable to expose an employee to a substance hazardous to health shall provide that employee with suitable and sufficient information, instruction and training." 12(2) then enumerates what it must include — the names of the substances and the risk they present, any relevant workplace exposure limit, access to the safety data sheet, the significant findings of the risk assessment, the precautions and actions to be taken, and the results of any exposure monitoring.None specified.Not specified in the regulation itself.
The Control of Noise at Work Regulations 2005
Regulation 10(1) and 10(2)
says train
named role — employees exposed at or above the lower exposure action value, AND their representativesQuoted, 10(1): "Where his employees are exposed to noise which is likely to be at or above a lower exposure action value, the employer shall provide those employees and their representatives with suitable and sufficient information, instruction and training." 10(2) enumerates eight required topics including the exposure limit and action values, how to detect and report signs of hearing damage, and the entitlement to health surveillance.None specified. The trigger is the lower exposure action value.Not specified in the regulation itself.
The Control of Vibration at Work Regulations 2005
Regulation 8(1) and 8(2)
says train
named role — employees at risk from, or exposed at or above the action value to, vibration, and their representativesQuoted, 8(1): the employer must provide information, instruction and training where "(a) the risk assessment indicates that there is a risk to the health of his employees who are, or who are liable to be, exposed to vibration; or (b) employees are likely to be exposed to vibration at or above an exposure action value". Note the disjunctive: a risk identified by assessment triggers the duty even BELOW an action value.None specified.Not specified in the regulation itself.
The Personal Protective Equipment at Work Regulations 1992
Regulation 9(1) and 9(2)
says train
named role — every worker provided with PPEQuoted, 9(1): where PPE must be provided, "the employer shall also ensure that [the worker] is provided with such information, instruction and training as is adequate and appropriate to enable [the worker] to know— (a) the risk or risks which the personal protective equipment will avoid or limit; (b) the purpose for which and the manner in which personal protective equipment is to be used; and (c) any action to be taken by [the worker]" to keep it in good repair. 9(2): the information and instruction is not adequate "unless it is comprehensible to the persons to whom it is provided".None specified.Not specified in the regulation itself.
The Dangerous Substances and Explosive Atmospheres Regulations 2002
Regulation 9(1) and 9(2)
says train
named role — employees where a dangerous substance is present at the workplaceQuoted, 9(1): where a dangerous substance is present, the employer shall provide employees with "(a) suitable and sufficient information, instruction and training on the appropriate precautions and actions to be taken by the employee in order to safeguard himself and other employees at the workplace; (b) the details of any such substance" including its name, the risk it presents, access to the safety data sheet and the relevant legislative provisions; "and (c) the significant findings of the risk assessment." 9(2) requires it to be adapted to significant changes in the work.None specified. 9(2) requires adaptation on significant change in the type or method of work.Not specified in the regulation itself.
The Health and Safety (First-Aid) Regulations 1981
Regulation 3(2)
says train
named role — the persons appointed to render first aidQuoted, 3(2): an employer shall provide "such number of suitable persons as is adequate and appropriate in the circumstances for rendering first-aid to his employees if they are injured or become ill at work; and for this purpose A PERSON SHALL NOT BE SUITABLE UNLESS HE HAS UNDERGONE SUCH TRAINING AND HAS SUCH QUALIFICATIONS as may be appropriate in the circumstances of that case."None specified in the regulation. The interval commonly cited (3-yearly requalification) comes from HSE guidance, not from reg 3.Not specified in the regulation itself.
The Control of Lead at Work Regulations 2002
Regulation 11(1) and 11(2)
says train
named role — every employee liable to be exposed to leadQuoted, 11(1): "Every employer who undertakes work which is liable to expose an employee to lead shall provide that employee with suitable and sufficient information, instruction and training." 11(2) enumerates the content, including the risk lead presents to health, any relevant occupational exposure limit, action level and suspension level, access to the safety data sheet, and the significant findings of the risk assessment.None specified.Not specified in the regulation itself.
The Ionising Radiations Regulations 2017
Regulation 15(1)(a) and 15(1)(b)
says train
named role — employees engaged in work with ionising radiation; plus an information duty toward other persons directly concernedQuoted, 15(1): "Every employer must ensure that— (a) those of its employees who are engaged in work with ionising radiation are given appropriate training in the field of radiation protection and receive such information and instruction as is suitable and sufficient for them to know— (i) the risks to health created by exposure to ionising radiation as a result of their work; (ii) the general and specific radiation protection procedures and precautions...; and (iii) the importance of complying with the medical, technical and administrative requirements of these Regulations; (b) adequate information is given to other persons who are directly concerned with the work with ionising radiation".None specified.Not specified in the regulation itself.
Directive 2009/104/EC concerning the minimum safety and health requirements for the use of work equipment by workers at work
Article 9, with Article 6(b)
says train
named roles — (a) workers given the task of using work equipment; and (b) separately, the workers specifically designated under Article 6(b) to carry out repairs, modifications, maintenance or servicing of equipment involving a specific riskQuoted, Article 9: "Without prejudice to Article 12 of Directive 89/391/EEC, the employer shall take the measures necessary to ensure that: (a) workers given the task of using work equipment receive adequate training, including training on any risks which such use may entail; (b) workers referred to in Article 6(b) receive adequate SPECIFIC training." Article 6(b), which defines that second group: "in the case of repairs, modifications, maintenance or servicing, the workers concerned are specifically designated to carry out such work."None. Note the opening words — this sits ON TOP of Framework Directive Article 12, which supplies the four triggers and the free/working-hours requirements.Not specified in Article 9.
Directive 98/24/EC on the protection of the health and safety of workers from the risks related to chemical agents at work
Article 8(1)
says train
named population — workers and/or their representatives, where hazardous chemical agents occur in the workplaceQuoted, Article 8(1): "Without prejudice to Articles 10 and 12 of Directive 89/391/EEC the employer shall ensure that workers and/or their representatives are provided with: — the data obtained pursuant to Article 4 of this Directive, and further informed whenever a major alteration at the workplace leads to a change in these data, — information on the hazardous chemical agents occurring in the workplace, such as the identity of those agents, the risks to safety and health, relevant occupational exposure limit values and other legislative provisions, — TRAINING AND INFORMATION ON APPROPRIATE PRECAUTIONS AND ACTIONS to be taken in order to safeguard themselves and other workers at the workplace, — access to any safety data sheet provided by the supplier". It further requires that the information is "provided in a manner appropriate to the outcome of the risk assessment... This may vary from oral communication to individual instruction and training supported by information in writing, depending on the nature and degree of the risk" and is "UPDATED TO TAKE ACCOUNT OF CHANGING CIRCUMSTANCES".No interval, but two standing requirements: re-inform on a major alteration changing the Article 4 data, and keep the information updated for changing circumstances.Not specified in Article 8.

Binds you whatever your sector

10 further obligations sit outside Manufacturing (Regulated) regulation and bind you as an employer or as a deployer of AI. They are the ones a sector-by-sector review misses, because nobody who reads only their own rulebook ever reaches them.

ClauseWho must be trained or assessedWhat is requiredIntervalEvidence required
EU AI Act (Reg (EU) 2024/1689)
Article 4 (AI literacy)
says train
defined population — quoted from the pre-amendment text: "their staff and other persons dealing with the operation and use of AI systems on their behalf"AS ENACTED: providers and deployers were to take measures to ensure, to their best extent, a sufficient level of AI literacy of their staff and other persons dealing with the operation and use of AI systems on their behalf, taking into account technical knowledge, experience, education and training, the context of use, and the persons on whom the systems are used. AS AMENDED from 2026-07-27 by the Digital Omnibus on AI: AI literacy remains an obligation on providers and deployers, but no specific or 'sufficient' level is mandated; the Commission and Member States take a stronger role in promoting AI literacy. The obligation on deployers of HIGH-RISK AI systems to ensure staff are trained for human oversight remains in place.none specifiednone specified
Article 26(2)
says train
named population — the natural persons assigned to exercise human oversightQuoted: "Deployers shall assign human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support."none specifiednone specified in this paragraph
Employment Rights Act 2025
Whole Act — training provisions at s.65 and related
says train
named role — trade union equality representatives, not the general workforceThe Act's training provisions concern whether a trade union equality representative has undergone sufficient training to carry on those activities, with notice requirements on the union and reference to a relevant ACAS or Secretary of State Code of Practice. It is not a mandatory workforce training duty of the kind the rest of this map records.none specifiedWritten notice from the trade union to the employer
Equality Act 2010
Section 109(4), with section 109(1)
case law
Allay (UK) Ltd v Gehlen [2021] UKEAT/0031/20 — stale or inadequate training defeats the s.109(4) 'all reasonable steps' defence, making training the operative discharge.
all staff — the defence turns on steps taken to prevent employees doing discriminatory actsAn employer is liable for anything done by a person in the course of their employment. Quoted from 109(4): "In proceedings against A's employer (B) in respect of anything alleged to have been done by A in the course of A's employment it is a defence for B to show that B took all reasonable steps to prevent A—(a) from doing that thing, or (b) from doing anything of that description."none specifiedThe employer must SHOW the steps taken. The burden sits with the employer.
UK GDPR
Article 24, read with Article 5(2)
guidance
UK GDPR Article 39(1)(b) — read at source 2026-08-12 — names staff training as an element of compliance with the Regulation: the data protection officer must "monitor compliance with this Regulation... including the assignment of responsibilities, awareness-raising and training of staff involved in processing operations, and the related audits". LIMIT OF THIS CITATION, stated plainly: Article 39 applies only where Article 37 requires a DPO to be appointed, so it does not by itself establish a training duty for every controller. It establishes that the Regulation treats staff training as part of compliance. The unconditional citation would be the ICO Accountability Framework, which has NOT been read — see not_yet_searched.
not specified — training is not expressly named in Article 24Quoted: "the controller shall implement appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is performed in accordance with this Regulation." Those measures must be reviewed and updated where necessary, and are to include appropriate data protection policies where proportionate to the processing activities. Article 5(2) supplies the accountability principle itself: "The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1" — that is, with all six data protection principles: lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; and integrity and confidentiality.measures to be reviewed and updated where necessary — no intervalThe controller must be able to DEMONSTRATE compliance. This is the accountability limb.
The Regulatory Reform (Fire Safety) Order 2005
Article 21, with articles 3 and 6
says train
all staff — quoted: "his employees"Quoted, 21(1): the responsible person "must ensure that his employees are provided with adequate safety training (a) at the time when they are first employed; and (b) on their being exposed to new or increased risks because of" transfer or change of responsibilities, new or changed work equipment, new technology, or a new or changed system of work. 21(2): that training must "(a) include suitable and sufficient instruction and training on the appropriate precautions and actions to be taken by the employee in order to safeguard himself and other relevant persons on the premises; (b) be repeated periodically where appropriate; (c) be adapted to take account of any new or changed risks; (d) be provided in a manner appropriate to the risk identified by the risk assessment; and (e) TAKE PLACE DURING WORKING HOURS."Trigger-based, not periodic: on first employment AND on each of four listed changes. "Repeated periodically where appropriate" — no interval stated.none specified in the article
The Management of Health and Safety at Work Regulations 1999
Regulation 13(2), with 13(1) and 13(3)
says train
all staff — every employee, on recruitment and again on each triggering changeQuoted, 13(2): "Every employer shall ensure that his employees are provided with adequate health and safety training— (a) on their being recruited into the employer's undertaking; and (b) on their being exposed to new or increased risks because of— (i) their being transferred or given a change of responsibilities within the employer's undertaking, (ii) the introduction of new work equipment into or a change respecting work equipment already in use within the employer's undertaking, (iii) the introduction of new technology into the employer's undertaking, or (iv) the introduction of a new system of work into or a change respecting a system of work already in use within the employer's undertaking." 13(1) separately requires the employer, "in entrusting tasks to his employees, [to] take into account their capabilities as regards health and safety."No fixed interval. The duty is TRIGGER-BASED — on recruitment, and on each of the four changes listed in 13(2)(b).Not specified in the regulation itself.
Health and Safety at Work etc. Act 1974
Section 2(2)(c), with section 2(1)
says train
all staff — scoped by what is 'necessary to ensure' their health and safetyQuoted, s.2(2)(c): the employer's general duty extends in particular to "the provision of such information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of his employees." This is the primary-legislation parent of the MHSWR reg 13 duty. Note the double qualifier: training is owed only so far as it is BOTH 'necessary to ensure' health and safety AND 'reasonably practicable'.None. The measure is necessity, not interval.Not specified in the section.
Council Directive 89/391/EEC (the Framework Directive) on the introduction of measures to encourage improvements in the safety and health of workers at work
Article 12(1) and 12(4)
says train
all staff — 'each worker'Quoted, 12(1): "The employer shall ensure that each worker receives adequate safety and health training, in particular in the form of information and instructions specific to his workstation or job: — on recruitment, — in the event of a transfer or a change of job, — in the event of the introduction of new work equipment or a change in equipment, — in the event of the introduction of any new technology. The training shall be: — adapted to take account of new or changed risks, and — repeated periodically if necessary." Quoted, 12(4): "The training referred to in paragraphs 1 and 3 MAY NOT BE AT THE WORKERS' EXPENSE... The training referred to in paragraph 1 MUST TAKE PLACE DURING WORKING HOURS."No fixed interval. Trigger-based on four named events, PLUS two standing qualities the UK implementation does not spell out as clearly: adapted to new or changed risks, and "repeated periodically if necessary".Not specified in Article 12.
Article 12(2)
says train
named population — workers from OUTSIDE undertakings and/or establishments engaged in work in your undertaking. Contractors, agency staff, visiting engineers, maintenance crews.Quoted in full: "The employer shall ensure that workers from outside undertakings and/or establishments engaged in work in his undertaking and/or establishment HAVE IN FACT RECEIVED appropriate instructions regarding health and safety risks during their activities in his undertaking and/or establishment."None — triggered by the outside workers being engaged in work in your undertaking.Not specified, but note the wording: the employer must ensure they "have in fact received" the instructions. That is a verification duty, not a provision duty — it is not discharged by having issued something.

Related duties — not training obligations

1 provisions that sit alongside the duties above without themselves requiring training. They are here because they are the ones most often mistaken for training duties, or most often missed when scoping them. We separate them rather than pad the count.

ClauseWho it concernsWhat is requiredIntervalEvidence required
The Manual Handling Operations Regulations 1992
Regulation 4(1)(b)(ii) and 4(3)(c), with 4(1)(b)(iii)
related
not directly specified — training enters as a risk-reduction step and as a mandatory factor, not as a named populationMHOR does not contain a standalone duty to train, but it is NOT silent on training, and the two limbs together are why manual handling training is genuinely expected. Reg 4(1)(b)(ii) requires the employer to "take appropriate steps to reduce the risk of injury to those employees... to the lowest level reasonably practicable". Reg 4(3) then provides that "in determining the appropriate steps to reduce that risk regard shall be had in particular to— ... (c) his knowledge and training". So the employee's training is a factor the employer MUST weigh, and training is capable of being one of the 'appropriate steps' the employer is required to take. Separately, 4(1)(b)(iii) requires "general indications and, where it is reasonably practicable to do so, precise information on— (aa) the weight of each load, and (bb) the heaviest side of any load whose centre of gravity is not positioned centrally" — that limb is an information duty. Schedule 1 also asks, as an assessment factor, whether the job requires "special information or training for its safe performance".None. The measure is the risk-reduction outcome, not an interval.Not specified in regulation 4.

Where gaps commonly sit

The supervisor limb is a separate duty in its own sub-paragraph

PUWER 1998 regulation 9(1) requires training for everyone who uses work equipment. Regulation 9(2) then requires it, separately and in its own words, for “any of his employees who supervises or manages the use of work equipment”.

These are two duties, not one duty with a wide population. Training the operators and briefing the supervisors informally satisfies 9(1) and leaves 9(2) open.

A generic COSHH module does not discharge the lead duty

The Control of Lead at Work Regulations 2002 regulation 11(2) requires the training to cover lead’s own occupational exposure limit, action level and suspension level — thresholds that do not exist in COSHH.

COSHH regulation 12(2) is equally specific in its own domain: the names of the substances, their workplace exposure limits, and access to the relevant safety data sheets. Neither is satisfied by hazard-awareness training that never names the substance on the site.

The radiation duty extends past the radiation workers

Ionising Radiations Regulations 2017 regulation 15(1)(a) requires appropriate training for employees engaged in work with ionising radiation. Limb (b) then requires adequate information for “other persons who are directly concerned with the work”.

That second group sits outside the radiation-worker matrix by definition — maintenance, cleaning, adjacent production — which is exactly why it goes unrecorded.

If you operate on both sides of the Channel, your two matrices miss opposite things

The UK provisions here implement EU directives, so the duties look interchangeable. Two of them are not.

Work equipment. PUWER reg 9(2) extends the training duty to employees who supervise or manage the use of work equipment. Directive 2009/104/EC Article 9(b) instead extends it to workers designated under Article 6(b) to carry out “repairs, modifications, maintenance or servicing” of specific-risk equipment — and asks for specific training, not merely adequate.

Chemical agents. COSHH reg 12(2) prescribes the content. Directive 98/24/EC Article 8(1) prescribes the delivery method too: information must be “provided in a manner appropriate to the outcome of the risk assessment… from oral communication to individual instruction and training supported by information in writing, depending on the nature and degree of the risk”. One e-learning module for everyone is not automatically compliant on the EU side.

Run one matrix across both estates and you satisfy the supervisor limb in Britain while missing the maintenance limb in Germany — and vice versa.

Two things the Framework Directive makes absolute, and the UK does not spell out

Directive 89/391/EEC Article 12(4): the training “may not be at the workers’ expense” and “must take place during working hours”. Neither is qualified by reasonable practicability.

Asking staff to finish an e-learning module in their own time, unpaid, is a breach however good the content is.

Article 12(2) then reaches people you do not employ: the employer must ensure workers from outside undertakings working on their premises “have in fact received” appropriate health and safety instructions. MHSWR reg 13 has no equivalent — it is confined to “his employees”. And “have in fact received” is a checking duty, not a providing one, over a population whose records you do not hold.

Coverage

This map states what it did not check as well as what it did. A map that quietly omits its own gaps is worth less than one that marks them.

Searched and found

11 obligations across 12 instruments, each read directly from the published source on 2026-08-12.

Searched and found nothing

Recorded because “we searched and found nothing” is a different fact from “we did not search”.

  • The Manual Handling Operations Regulations 1992 — WHOLE INSTRUMENT (full revised text — TWO occurrences, and NEITHER is a standalone duty to train — but the instrument is NOT silent on training, and an earlier version of this record wrongly said it was. Reg 4(3)(c) requires that, in determining the appropriate steps to reduce manual handling risk, "regard shall be had in particular to... his knowledge and training". Schedule 1 asks, as an assessment factor, whether the job requires "special information or training for its safe performance". Read with the reg 4(1)(b)(ii) duty to reduce risk to the lowest level reasonably practicable, this is why manual handling training is properly regarded as required — the duty is structural rather than express. What MHOR does NOT contain is any training interval or any express 'must train' clause. CORRECTION NOTE: this map previously asserted that 'training' does not appear in the operative text of reg 4. That was wrong; it was derived from reading reg 4(1) only, and reg 4(3) was inserted by amendment in 2002.
Not searched

Their absence is not evidence that they contain no training duty.

  • COMAH 2015 (SI 2015/483) — reg 7 read 2026-08-12, no express training duty on that provision; the major accident prevention policy and safety report training limbs are unread.
  • Pressure Systems Safety Regulations 2000 reg 11 — read 2026-08-12, no express training duty found on that provision.
  • HSE ACOPs L22 (PUWER), L138 (DSEAR), L5 (COSHH), L132 (Lead) — the entire ACOP layer is unread for this sector.
  • Electricity at Work Regulations 1989 reg 16 — read 2026-08-12; it is a competence provision and did not return training wording. Needs a proper competence record rather than being dropped.
  • REACH / CLP supplier and downstream-user duties as they touch worker instruction.
  • Sector-specific regimes not yet scoped: food manufacturing (Regulation (EC) 852/2004 Annex II Ch XII food-hygiene training), medical devices, and automotive.
  • Scotland and Northern Ireland equivalents of every instrument above.
  • EU daughter directives still unread for this sector: 2009/148/EC (asbestos), 92/57/EEC (construction sites, the CDM analogue), 2003/10/EC (noise), 2002/44/EC (vibration), 89/656/EEC (PPE), 90/269/EEC (manual handling), 2004/37/EC (carcinogens). All confirmed plain-fetchable on EUR-Lex 2026-08-12 and each carries a named training or information article.
  • NATIONAL transposition of the EU records above. A directive binds the member state; the text an employer actually follows is the national instrument (Germany ArbSchG/BetrSichV, France Code du travail). Member States may exceed the Directive, so these records are the FLOOR, not any one country's law.

Sources

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