Two Billion Workers with No Safety Rules

The ILO estimates that 2 billion workers — 60% of the global workforce — work in the informal economy: street vendors, domestic workers, waste pickers, subsistence farmers, home-based garment workers, artisanal miners, construction day-laborers. Every occupational safety and health (OSH) framework in existence — ILO conventions, OSHA regulations, EU Framework Directive 89/391 — is predicated on a formal employment relationship with an identifiable employer who has legal obligations to provide safe working conditions, training, and personal protective equipment. Informal workers have no identified employer, no workplace address, no employment contract, and no regulatory coverage. They are not "exempt" from OSH protections — they are simply invisible to the regulatory architecture. The result is that the workers with the highest exposure to occupational hazards have zero regulatory protection.

Informal workers account for a disproportionate share of occupational deaths and injuries: an estimated 80% of the 2.78 million annual work-related deaths occur in low- and middle-income countries where informality rates exceed 70%. Informal construction workers face fatality rates 5–10× higher than formal construction workers in the same countries. Informal waste pickers have blood lead levels 3–5× safe limits. Home-based garment workers are exposed to dyes, solvents, and dust with no ventilation requirements. The absence of OSH standards for these workers is not a gap — it is the default condition for the majority of the world's working population.

ILO Recommendation 204 (2015) on the "Transition from the Informal to the Formal Economy" acknowledges the gap but provides no mechanism for extending OSH protections to workers who remain informal — its strategy assumes formalization is achievable, which decades of development experience have shown is slow at best. Some countries have attempted sector-specific regulations (India's Building and Other Construction Workers Act, 1996; South Africa's Sectoral Determination for Domestic Workers), but enforcement requires identifying employers and workplaces that, by definition, are undocumented. Community-based health worker programs (e.g., for artisanal miners, waste pickers) provide health services but are not regulatory instruments and cannot set enforceable safety standards. The fundamental mismatch is architectural: OSH regulation is built on the employer's duty to provide a safe workplace, and informal work has neither a defined employer nor a defined workplace.

OSH frameworks that are anchored to the work activity and hazard, not to the employment relationship. This could include: (1) hazard-specific standards applicable to anyone performing the activity (e.g., anyone cutting stone must have dust suppression, regardless of employment status); (2) supply-chain responsibility mechanisms where the buyer of informal labor (the formal company at the top of the supply chain) bears OSH obligations downstream; or (3) technology-mediated safety systems (mobile-delivered safety guidance, low-cost PPE distribution through community cooperatives, worker-owned monitoring platforms) that bypass the employer-mediated model entirely. The adjacent success of environmental regulation — which applies to polluting activities regardless of the polluter's employment arrangements — provides a conceptual model.

A team could design a mobile-phone-based hazard communication system for a specific informal sector (e.g., informal brick kilns, street food vendors, waste pickers), testing whether mobile-delivered, language-appropriate safety guidance changes behavior. A policy team could draft an activity-based OSH standard for one informal sector and model its enforceability and cost. An engineering team could design ultra-low-cost PPE ($1–$5 range) for a specific informal sector hazard. Relevant disciplines: occupational health, public policy, industrial design, mobile technology, development studies.