In brief
Many office-based businesses assume that the Occupational Health and Safety Act is written for factories and building sites, and that a fire extinguisher and a first aid box cover the rest. The Ergonomics Regulations, 2019 say otherwise in their first operative words. They apply to "any employer or self-employed person who carries out work at a workplace, which may expose any person to ergonomic risks", and they have been in force since 06 December 2019. [1][2] Where they apply, they require an ergonomic risk assessment by a competent person before the work starts, repeated "at intervals not exceeding two years", with training for each employee before placement and records kept for up to forty years. [1][2] An office that carried out its first assessment when the regulations arrived is now on its fourth two-year cycle. This article sets out what the regulations require, why an office is not outside them, and five questions that show whether your own clock has started.
What the regulations actually require
The Ergonomics Regulations, 2019 were made under section 43 of the Act and published as Government Notice R. 1589 in Government Gazette 42894 on 06 December 2019, with effect from the date of publication. [1][2] They define an "ergonomic risk" as "a characteristic or action in the workplace, workplace conditions, or a combination thereof that may impair overall system performance and human well-being". [1] Nothing in that definition is limited to machinery, lifting or heavy industry.
The core duties are short and specific. [1]
- Risk assessment. Regulation 6(1) requires the employer, "before the commencement of any work that may expose employees to ergonomic risks", to have an ergonomic risk assessment performed by a competent person, after consulting the health and safety committee or representatives for that workplace. Regulation 6(2) requires it to be "conducted at intervals not exceeding two years" and to include a complete hazard identification, the persons who may be affected and how, an analysis and evaluation of the risks, and their prioritisation. [1][2]
- Review on change. Regulation 6(3) requires the assessment to be reviewed if it is no longer valid, if controls are no longer effective, if better controls become available, if there has been a change in the work methods, the type of work or the equipment used, or if an incident or medical surveillance points to ergonomic risk as a contributing factor. [1][2]
- Training. Regulation 3 requires a training programme for employees and others who may be exposed, covering the regulations, the sources and nature of the risks, the controls in place and how to report a risk. Regulation 3(2) requires the training "prior to the placement of the relevant employee in the workplace", with refresher training at intervals the committee or representative may recommend. [1]
- Control. Regulation 7 requires exposure to be prevented or, where that is not reasonably practicable, adequately controlled in accordance with the hierarchy of controls. [1]
- Medical surveillance, only where indicated. Regulation 8 requires medical surveillance where the risk assessment indicates it or an occupational health practitioner recommends it. It is not automatic for every employee. [1][2]
- Records. Regulation 10 requires records of the training, the risk assessments, the controls and their maintenance, and any surveillance. Risk assessment and surveillance records must be kept for at least 40 years, control and maintenance records for three years, and training records for as long as the employee remains at the workplace. They must be made available to an inspector on request. [1]
Regulation 12 makes a failure to comply with regulations 3 to 10 an offence, punishable by a fine or imprisonment of up to 12 months. [1]
Why an office is not outside them
The scope test in regulation 2 is whether the workplace "may expose any person to ergonomic risks". [1] It is not a list of sectors and it contains no office exemption. Whether a particular office does carry such a risk is, under the regulations themselves, a question the risk assessment exists to answer, and regulation 6 requires that assessment to be done before the work starts. An office that has never assessed has therefore not established that the regulations do not apply to it; it has simply not asked.
The Department's own explanatory notes, published in the same gazette, make two points that matter for a small office. First, the risk assessment "may be carried out by an employee who is familiar with the task, provided they have the competency to do so", with an external professional suggested where the task is complex. [1] A small practice does not automatically need an outside ergonomist. Second, the notes describe the regulations as an ergonomics programme "integrated into existing occupational health and safety programmes", not a stand-alone exercise. [1]
Inspectors do write ergonomics up. In the Department's December 2025 Gauteng blitz, a manufacturer received prohibition notices that included "ergonomic issues", according to the Department's own advisory as republished by Labour Guide. [3] The Department's findings from the Sunninghill construction blitz of 28 August 2026 listed failures relating to ergonomic risk assessments and worker training, as reported in our earlier article on that inspection. [4] Both were industrial sites, and we do not suggest that offices are being targeted on this point. What the two findings show is that the regulations are live enforcement material rather than a dormant schedule.
The United Kingdom offers a useful cross reference, because there the office case is spelled out. Its Health and Safety (Display Screen Equipment) Regulations apply to workers who use screens daily for continuous periods of an hour or more, and require a workstation assessment, risk reduction including breaks, eye tests on request, and training. The regulator states that this applies to fixed workstations, mobile workers, home workers and hot-desking staff. [5] South Africa has no screen-specific regulation of that kind; its Ergonomics Regulations are broader and less prescriptive, which is precisely why so many offices have never connected them to the desk.
Where the clock usually stops
The difficulty is rarely the first assessment. It is everything that resets the clock afterwards, because almost none of it is a safety event.
The two-year interval runs from the last assessment, not from a date in a gazette, so no calendar reminds anyone. A review is triggered by "a change in the work methods", "the type of work carried out" or the equipment used, and in an office those changes arrive as a move to hybrid working, a new floor plan, hot-desking, a furniture order or a new practice-management system. [1] They are decided by partners, facilities and IT, and none of them is routed to the person who holds the assessment. Training is due before placement, and placement happens in HR. The resulting record must survive forty years, long after the person who wrote it has left. [1]
Five questions for an office-based employer
Each has a yes or no answer.
- Has an ergonomic risk assessment ever been performed for your workplace, and is it dated within the last two years?
- Was it carried out by someone you can show was competent to do it, after consulting your health and safety representatives or committee where you have them?
- Since that assessment, has anything changed in how, where or with what your people work, and was the assessment reviewed when it did?
- Does every new employee receive the regulation 3 training before starting work, and can you show it for the person who joined most recently?
- Where are the assessment and training records kept, and would they still be found if the person responsible left tomorrow?
An office that answers yes to all five is ahead of most of its peers. An office that answers no to the first has not yet started the clock the regulations set.
GRC Shop view
This section is opinion and interpretation, not a statement of law.
In our view the Ergonomics Regulations are the clearest example in South African OHS law of a duty that an office believes is not its business. Most of what a professional practice associates with the Act, the extinguisher service, the first aid box, the evacuation plan, arrives on someone's calendar from outside. The ergonomic clock does not. It starts on the day of the practice's own last assessment and it is reset by the practice's own decisions about space, furniture, systems and ways of working. We read regulation 6(3) as reaching a move to hybrid or home-based work, because that is a change in work methods, and we treat the question of how far a home desk is a "workplace" as one of interpretation that each employer should take advice on rather than assume away.
Compliance files go stale. Our system keeps yours current. The assessment a practice commissioned is usually sound on the day it is signed. What fails is afterwards: the office moves, the team goes hybrid, new people start, and none of it reaches the file, so two years later the assessment still reads well and no longer describes the office. The GRC Shop platform does one thing, and its OHS app is currently the only app on it: it keeps a single managed, live record of a business's OHS obligations, assessments, training and evidence, with the dates that matter attached, so that the person the Act holds accountable can see the current position without asking anyone to send it.
If you would like to see what that looks like for your practice, request a quote at https://www.grcshop.co.za/get-a-quote
Abbreviations
- DSE: display screen equipment
- HSE: Health and Safety Executive (United Kingdom)
- OHS: occupational health and safety
References
[1] Department of Employment and Labour, "Occupational Health and Safety Act, 1993: Ergonomics Regulations, 2019", Government Notice R. 1589, Government Gazette 42894, with Annexure 1 Explanatory Notes, 06 Dec 2019. https://www.gov.za/sites/default/files/gcis_document/201912/42894rg10177gon1589.pdf
[2] Shangoni Management Services, "Ergonomics Regulations, 2019 Published", 11 Dec 2019. https://shangoni.co.za/ergonomics-regulations-2019-published/
[3] Labour Guide South Africa, republishing a Department of Employment and Labour media advisory, "We are not done yet with our inspection blitzes, vowed Employment and Labour Deputy Minister, Sibiya", 05 Dec 2025. https://labourguide.co.za/health-and-safety/news/we-are-not-done-yet-with-our-inspection-blitzes-vowed-employment-and-labour-deputy-minister-sibiya
[4] GRC Shop, "Eleven subcontractors were not on site. The principal contractor answered for all of them.", 30 Aug 2026. https://www.grcshop.co.za/blog/insights-2/eleven-subcontractors-were-not-on-site-the-principal-contractor-answered-for-all-of-them-30
[5] Health and Safety Executive, "Working safely with display screen equipment", updated 20 Mar 2025. https://www.hse.gov.uk/msd/dse/index.htm