Student worker safety: getting your file in order before the first shift

In brief

Belgian well-being legislation does not treat a student worker as an ordinary employee. Book X, title 3 of the code on well-being at work places student workers in a category of their own, with obligations of their own for you as the employer. Three of them must be settled before the student works a single hour: the risk assessment, the induction, and in certain cases a prior health assessment. On top of that comes a ban on operating powered handling equipment, with two narrowly defined exceptions. The FPS Employment names insufficient supervision and guidance as one of the reasons why workers aged 18 to 24 have half again as many occupational accidents as other categories. Working through a staffing agency does not transfer these duties: as the user undertaking you remain responsible for well-being on your shop floor, and you supply the workstation sheet.

You probably know the scenario

Mid-November. The warehouse is running on one and a half shifts, year-end orders are coming in, and eight student workers start on the same day, three of whom have never set foot in a warehouse. The team leader has fifteen minutes. He points out the emergency exit, says where the safety shoes are, and lets the rest reveal itself during the work. Everyone is content until a finger gets caught in a roll container.

That quarter of an hour is exactly where the law expects something else from you. Not paperwork for the sake of paperwork, but a few steps that are mandatory for this group of workers, precisely because they are young and inexperienced. Below is what has to happen, when, and which part sits with your staffing partner.

Why do separate rules apply to student workers?

Because the legislator treats young people as a distinct risk group. Article X.3-2 of the code on well-being at work lists five categories of young people. The student worker under a student employment contract is category e, and on several points the rules there are stricter than for pupils or interns.

The reasoning the FPS Employment gives is matter-of-fact: young people often pay insufficient attention to safety, lack experience, and their development is sometimes not yet complete. That is not a reproach to the student. It is an observation your organisation has to design the workstation around.

The figure the FPS attaches to it is the one worth remembering: among workers aged 18 to 24, the rate of occupational accidents is half again as high as among other categories of workers. The FPS links this explicitly to insufficient supervision and guidance. In a sense that is good news, because supervision is something you control.

What has to be ready before the first working day?

Three things, and the order is not a detail.

The risk assessment. You carry out an analysis of the risks to which the young person is exposed at work, in order to assess all risks to their safety, their physical and mental health, and their development. That analysis takes place before the work begins. It is renewed at least once a year, and again whenever the workstation changes significantly. A student who packed boxes in November and moves to returns handling in December is on a different workstation.

Induction and guidance. This too is a preventive measure, and it too must be arranged before the employment starts, after advice from the prevention adviser heading the internal service and from the committee for prevention and protection at work. The stated purpose is to help the young person adapt to and integrate into the working environment, so that they are able to perform the work properly.

Health surveillance, where it applies. See the next section, because this depends on the role and the age.

Who needs a prior health assessment?

There are two tracks. Appropriate health surveillance applies as it does to any worker: for a safety function, a function involving heightened vigilance, or an activity with a defined risk.

Alongside that sits specific health surveillance that exists only for young people. It consists of a prior and a periodic health assessment, and it is mandatory for young people who are minors, for young people performing night work between 8 p.m. and 6 a.m., and for those performing work that is normally prohibited but permitted here because it is necessary for their vocational training.

Note that this is a well-being rule and not a working-time rule. The 8 p.m. threshold comes from the code and is separate from the question of when night work begins in distribution and e-commerce. If you put seventeen-year-olds on an evening shift running past eight, specific health surveillance applies, even where that shift is not classed as night work under working-time law.

May a student worker operate a pallet truck or a forklift?

This is where employers most often go wrong, and it is also the rule with the clearest boundaries.

The starting point is a ban. Student workers may in principle not operate powered equipment used for moving, lifting, stacking, storing or unstacking loads, or for loading and unloading lorries. The ban applies in undertakings and storage premises, and also at locations used periodically or temporarily for events. A forklift falls squarely within it.

There are exactly two exceptions, each with conditions that apply cumulatively:

• From the age of 18: a platform truck or a pallet truck. The speed is limited to 6 kilometres per hour for pedestrian-operated equipment and to 16 kilometres per hour for ride-on equipment. The controls require continuous action by the operator and return automatically to neutral, applying the brake.
• From the age of 16: a pedestrian-operated pallet truck, with the speed limited to 6 kilometres per hour.

In both cases the following also applies: the student has a sufficient sense of responsibility and has received adequate training, the activities take place in the presence of an experienced worker, you or a member of the line management verify that the preventive measures work, and the opinion of the competent prevention adviser and of the committee has been sought in advance.

A reach truck, a stacker or a forklift does not appear on that list. They remain prohibited, however quickly the student appears to learn.

When may a student perform dangerous work after all?

Rarely, and never casually. For dangerous work listed in annex X.3-1 of the code, think of welding and cutting or operating dangerous machinery, the ban can be departed from if four conditions are met together. The student worker is at least 18. Their field of study corresponds to the work covered by the ban, for example an electrical programme for work on electrical installations. The activities take place in the presence of an experienced worker. And the opinion of the prevention adviser and the committee has been sought beforehand.

That second condition is often read too generously. It has to be a programme specifically aimed at teaching that work, and the assessment is made case by case. The FPS recommends looking at the curriculum and questioning the student about the content of their studies. A construction student is not automatically a student who may weld.

What changes if you work through a staffing agency?

Not what you might hope. For as long as the agency worker is working at your site, you as the user undertaking are answerable for the application of the well-being provisions. The risk assessment of the workstation and the preventive measures on the floor remain your responsibility, because it is your workstation.

What does shift is the administrative part and the selection. Before calling on an agency worker, you inform the agency of the professional qualifications required and of the well-being information relating to the work to be performed. That is done through the workstation sheet. On that basis the agency selects a suitable candidate, and before the placement it passes that information on to the agency worker.

The FPS notes drily that drawing up such a sheet should cost you little effort, because you will already have carried out a risk evaluation for that work. In practice that is the test: an employer who cannot complete the sheet probably does not have a risk assessment for that workstation.

The law also contains a mutual duty. Article 12ter of the Well-being Act obliges you to refuse the services of an agency that you can know is not meeting its obligations towards its agency workers. Article 12quater places the mirror duty on the agency: it must refuse to supply workers to a user undertaking that it can know is not meeting its obligations. The law lists the warning signs too, such as a workstation sheet that omits the significant risks, agency workers who turn out to be doing work other than that described, or an abnormal number of accidents at the same user undertaking.

What does this mean for your year-end planning?

In practical terms, your deadline moves forward. Not to the first working day, but to the moment you know which workstations you will fill with student workers. Requests for advice to the prevention adviser and the committee take time, and for minors or night work a prior health assessment comes on top of that.

A workable order for the coming weeks:

• Write down the workstations, not the headcount. Twenty students says nothing about your file, three workstations does.
• Pull out the risk assessment for each workstation and check the date. Older than a year, or the post has changed: it needs renewing either way.
• Separate the posts that involve equipment. Decide now what the student will and will not operate, and record the derogation together with the required opinions.
• Schedule the induction as a task with a name attached. A mentor who is trained in the risks, who knows which work must be supervised, and who is given the time and the authority to do it.

That last point is the cheapest of the four and the only one that bears directly on the accident figure this article opened with.

Conclusion

The obligations around student workers are not heavy administration, but they do come first. A risk assessment that arrives after the first shift arrives too late. An induction that happens while working is not an induction. And a pallet truck is not a forklift, even when both stand in the same aisle. If you work with a staffing partner, well-being on your floor remains your responsibility, but you do not have to carry the selection, the transfer of information and the employer role yourself.

Are you still looking for qualified staff?

Recruit a Student is the specialised student staffing agency of Belgium. We take over the employer role, the student employment contracts, the Dimona declarations and the payroll in full, and we make sure the information from your workstation sheet reaches the student before they start. You keep control of the shop floor, we take the administration off your hands.

Request a no-obligation quote or ask us to call you back. To read more about the forms of cooperation: temporary staffing and pool management.

Student staffing agency with national coverage and local expertise

We work from two Belgian offices, Antwerp and Brussels, and place students throughout Belgium. In Ghent we run a student pool, and from Antwerp we also place students in Zeeland. Our candidate pool numbers 500 active students. We have been active in Belgium since 2016, starting with the logistics process at Brussels Airport.

Personal contact at our locations

You get one fixed point of contact who knows your sector and your workstations. Soukayna Theijs, known as Suki, works from Antwerp. Max Pierre works from Brussels.

• Antwerp: Silversquare Antwerp Tower, Frankrijklei 5 (401), 2000 Antwerp
• Brussels: Silversquare North, Koning Albert II Laan 4, 1000 Brussels
• Telephone: +32 14 15 17 35
• E-mail: info@recruitastudent.be

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Frequently asked questions

Do I need a separate risk assessment for every student worker?

No, the assessment belongs to the workstation and not to the person. It must, however, exist before the young person starts, be renewed annually, and be redone whenever that workstation changes significantly.

From what age may a student work for us?

For light, non-industrial work the minimum age is 15, following the Royal Decree of 19 April 2026 published in the Belgian Official Gazette on 4 May 2026. That says nothing about what the young person may do: the prohibitions and the health surveillance in the code apply in full, and for minors a prior health assessment is mandatory.

May a 17-year-old student worker operate a pallet truck?

Yes, provided every condition is met. From the age of 16 a student worker may operate a pedestrian-operated pallet truck limited to 6 kilometres per hour, with adequate training, in the presence of an experienced worker, and after the opinion of the prevention adviser and the committee. A platform truck or a ride-on pallet truck is only permitted from the age of 18.

Who is liable if an accident happens to an agency worker?

During the period the agency worker is working at your site, you as the user undertaking are answerable for applying the well-being provisions on the floor. The agency is the legal employer and is answerable for the contract, the declarations and the payroll. The Well-being Act additionally obliges both parties not to accept the other's non-compliance, through articles 12ter and 12quater.

What has to be in a workstation sheet as a minimum?

The professional qualifications required for the role and the well-being information relating to the work to be performed, meaning the risks of that specific workstation and the measures that go with them. The agency selects on that basis and passes the information to the agency worker before the placement starts.

Does specific health surveillance also apply to an evening shift?

Specific health surveillance is mandatory among others for young people performing night work between 8 p.m. and 6 a.m. That threshold from the code stands apart from working-time rules on when night work begins. If your evening shift runs past 8 p.m., check whether your young workers fall under specific surveillance.