Workplace sun protection policy in South Africa: what employers need to know

Solar ultraviolet (UV) radiation is one of the most common workplace hazards in South Africa, and one of the least managed. The World Health Organization and the International Labour Organization estimate that nearly one in three deaths from non-melanoma skin cancer worldwide is caused by working under the sun. In South Africa, basal cell carcinoma is the second most common histologically confirmed cancer in men according to the National Cancer Registry 2024.

A written policy is where a serious programme starts. It turns good intentions into duties, controls and records that hold up during an audit or an incident investigation.

Is sun protection a legal requirement?

South African law does not have a UV-specific regulation. The duty comes from the general provisions. Section 8 of the Occupational Health and Safety Act 85 of 1993 requires every employer to provide and maintain, as far as reasonably practicable, a working environment that is safe and without risk to the health of employees. That includes identifying hazards, assessing risks and putting controls in place, with information and training for workers.

On mines, the Mine Health and Safety Act 29 of 1996 sets similar duties to identify hazards and assess and control risk. Surface work exposes crews to UV for long periods, so it belongs in that risk assessment.

This article is general guidance, not legal advice. Your SHE practitioner or legal adviser should confirm how the duties apply to your operation.

What a workplace sun protection policy should contain

1. Purpose and scope: which sites, roles and contractors are covered.
2. Responsibilities: management, supervisors, SHE staff, workers and contractors.
3. Risk assessment method: how UV exposure is assessed per role and site, and how often.
4. Controls, in hierarchy order: scheduling and elimination, substitution, engineering (shade), administrative (training, UV index communication) and PPE (clothing, hats, eyewear, sunscreen).
5. Supply and access: where sunscreen, hats and eyewear are issued, and how they are replenished.
6. Training: who receives what training, and refresher frequency.
7. Monitoring and review: KPIs, audit frequency and the annual review date.
8. Health support: how workers can raise skin concerns and access professional advice, with confidentiality protected.

Rolling the policy out

A policy only works if supervisors can enforce it in seconds. We recommend a simple sequence:

• Run a baseline UV risk assessment across six control categories (our free tool covers 26 controls).
• Adopt the policy through the health and safety committee so worker representatives are part of it.
• Brief supervisors first, then run 45-minute worker sessions.
• Place sunscreen dispensers at the point of work: gates, change rooms, vehicles.
• Use the 5-Step visual system on posters and in toolbox talks.
• Audit quarterly and report aggregated results to management.

Start with a free template

Our basic Workplace Sun Protection Policy template follows this structure and can be adapted for your sites. Download it from the resources page, or run the free UV risk assessment first to see where your gaps are.