To the Tanzanian
The Ministry of Labour and Employment
- Ensure labor officers identify child labor
in mining through regular and systematic visits to licensed and unlicensed small-scale
mines and rigorous interviews with employees to determine their ages. They
should take steps to withdraw, rehabilitate, and integrate children involved in
mining and other worst forms of child labor. Labor officers should issue
compliance orders to employers who use child labor and initiate legal action where
necessary. Government measures must respect human rights and should not lead to
retribution or punishments that exceed the penalties outlined in the mining regulations,
the Law of the Child Act, and the Employment and Labour Relations Act.
- Ensure labor officers, in coordination with social
welfare officers and other relevant ministries, withdraw and rehabilitate
children who have been commercially sexually exploited in mining areas, and
take steps to ensure the prosecution of perpetrators.
- As part of annual reports, measure and publish
the number of children withdrawn from mining and other worst forms of child
labor, as well as the number of compliance orders issued to employers for using
- Work collaboratively with the Ministry of
Energy and Minerals so that mining officials inform labor officers of large
informal sites with child labor. Labor officers should also accompany mining
officials to large gold rush sites to inspect for child labor.
- Increase the number of labor officers and
create incentives to minimize turnover. Train all inspectors on child labor
issues, and ensure they have sufficient resources such as vehicles and fuel to
visit the mines.
- Implement the National Action Plan for the
Elimination of Child Labour and track its success.
- Conduct a new national survey on child labor
- Train mining officials, social welfare
officers, community development officers, and other relevant government
officials on child labor. Clarify the responsibilities of all divisions and
departments who have an obligation to act on child labor.
- Conduct awareness-raising and outreach on
the hazards of child labor in mining, in conjunction with other relevant
ministries such as the Ministry of Energy and Minerals, the Ministry of
Education, the Ministry of Gender, Development and Children, and the Ministry
of Health and Social Welfare. Outreach should target small-scale miners in
licensed and unlicensed mines, artisanal mining associations, and parents in
artisanal mining communities.
The Ministry of Energy and Minerals
Child Labor in Small-Scale Gold Mining
- Explicitly address child labor and mercury
exposure in current efforts to promote the development and professionalization of
artisanal mining, including through the government-led ‘Strategy to
Support Artisanal and Small-Scale Mining Development’.
- Train mining officials to fully enforce
current laws prohibiting child labor in mining.
- If child labor is found on licensed mines,
require Primary Mining License (PML) holders to end the use of child labor.
Conduct follow-up inspections and impose penalties such as fines, in accordance
with mining regulations, if employers fail to remove child labor.
- If child labor is found on unlicensed
mines—which are not covered by mining regulations—remind employers
of child labor laws and encourage them to comply. Inform the Ministry of Labour
and Employment for further inspection and penalties.
- Inform the Ministry of Labour and Employment
about the location of unlicensed gold rush sites where large numbers of
children may be working.
- Request managers on licensed mines to document
the ages of all the employees working on the site.
- Strengthen efforts to formalize the
artisanal and small-scale gold mining sector by, for example, investigating and
removing potential obstacles to obtaining a PML, increasing the pace at which
land becomes available to unlicensed miners, and disseminating information
about land available for small-scale gold mining. However, as part of these
efforts, the government should not engage in a mass clampdown of unlicensed mining
- Join the National Intersectoral Coordination
Committee on Child Labor to highlight issues and propose strategies to address
child labor in mining.
- Allow mining officials to focus on
inspecting mines for compliance with mining regulations and use other members
of staff to collect revenues from the mines.
- Revise the mining regulations so that
brokers and dealers are required to have child labor due diligence procedures
- Urge gold traders and companies to eliminate
child labor from their supply chain, to support child labor programs, and to
stop buying gold from children.
Mercury Use in Small-Scale Gold Mining
- Prioritize ending the most harmful practices
of mercury use on licensed mines, including the use of mercury by children, burning
the amalgam in residential areas, and burning the amalgam in the open. Conduct
research to identify and address factors contributing to unsafe practices.
- Enforce current regulations that require the
use of retorts and protective gear. Work to supply retorts to miners that are
affordable, capable of being replaced, and sensitive to miners’
- Conduct research and facilitate discussions
with small-scale miners on the use of mercury alternatives.
- Continue to introduce mercury-free gold extraction
- Replace individual environmental action
plans with a clear checklist of basic environmental practices that all
small-scale miners should follow.
- Raise awareness on the most harmful uses of
mercury, in particular the use of mercury by children and pregnant women, among
community members, health officials, and relevant ministries such as the
Ministry of Labour and Employment.
- Draft a national action plan on the
reduction of mercury in small-scale mining that prioritizes activities to reduce
the risk to the most vulnerable populations, such as children and pregnant
women living and working in artisanal mining areas. The plan should be
developed in close consultation with Nongovernmental Organizations (NGOs)
working on child labor in artisanal mining, environmental NGOs, experts and UN
The Ministry of Education
- Instruct district officials to investigate
and eliminate illegal primary school contributions to ensure that they do not
thwart access to education in mining areas. Continue to invest in improving
school infrastructure and facilities to minimize the need for schools to charge
- Increase support to orphans and other
vulnerable children so they can enroll in primary and post-primary education.
- Invest in afterschool activities such as
sports and games to help encourage attendance and discourage children from
going to the mines after class.
- Increase access to post-primary education in
mining areas by providing opportunities to students who fail the Primary School
Leaving Examination to retake the test and compete for a place at a secondary
school and by increasing the number of vocational training opportunities
available to students after primary school.
- Continue to expand nurseries and other early
learning and childcare institutions so young children do not have to accompany
their parents to the mines.
The Department of the Environment Vice
- Amend the National Strategic Plan for
Mercury Management, in consultation with small-scale miners, the Ministry of
Health and Social Welfare, and civil society, in accordance with the Minamata
Convention on Mercury. The plan should include a strong health response with
provisions for periodic data-gathering on mercury levels (possibly in
conjunction with other research where blood samples are collected), training
for health workers on the health effects of mercury, and using health officials
to carry out awareness-raising activities.
- Launch and implement the plan as soon as
possible and focus on taking immediate steps to reduce exposure to mercury,
particularly among children, and train health officials to recognize symptoms
of extreme mercury poisoning.
- Lead efforts to ratify the Minamata
Convention on Mercury.
The Ministry of Health and Social Welfare
- Develop a comprehensive health sector
response to mercury exposure in mining areas with a particular focus on child
health. This program should seek the input of occupational health and mercury
experts. In particular:
medical personnel on mercury intoxication;
the health system’s capacity to carry out biomonitoring of mercury levels
in urine in mining areas, and mercury in blood, hair, and breast milk in at
least one reference laboratory;
the health system’s capacity to diagnose mercury poisoning and
mercury-related health conditions;
the health system’s capacity to treat the effects of mercury exposure and
awareness of the health risks of mercury use in small-scale mining at child
health and antenatal clinics;
a pilot program for testing and, to the extent possible, treatment of
children’s mercury levels in a small-scale mining area with the goal of
expanding it to all affected areas.
- Improve access to primary healthcare for
children and reproductive health education and services on HIV/tuberculosis in
small-scale mining areas through, for example, well equipped mobile clinics
with skilled healthcare workers.
- Ensure that girls who are victims of sexual
violence and commercial sexual exploitation have access to post rape
healthcare, including post exposure prophylaxis (PEP) for HIV.
- Encourage social welfare officers and other parasocial
workers to identify and protect girls who work in mining from sexual
- Implement the new National Costed Plan of Action for Most
Vulnerable Children, which aims to strengthen the capacity of communities
and local government actors to protect the most vulnerable children,
including children involved in the worst forms of child labor, and ensure
their access to health, education, and other child protection services.
The Ministry of
Community Development, Gender and Children
- Take action to end commercial sexual
exploitation and assist the victims, as part of efforts to develop and
implement the National Plan of Action to Prevent and Respond to Violence
against Children. In particular, activities should include legal assistance,
appropriate health and counseling services, and access to education, vocational
training, or other social reintegration measures for victims.
The Government Chemist Laboratory Agency, Ministry
of Health and Social Welfare
- Take steps to prevent the illegal trade of
mercury by investigating and acting on the sources of illegal mercury and by
enforcing laws that require mercury traders to apply for a permit.
- Work with donors to conduct periodic surveillance
on mercury exposure and intoxication in artisanal communities with a particular
focus on child health. To minimize the amount of resources used, these
initiatives may be carried out as part of other research that collects blood
The Ministry of Finance
- Allocate finances for the implementation of
the National Action Plan for the Elimination of Child Labor, the National Strategic
Plan on Mercury Management, the National Costed Action Plan on the Most Vulnerable
Children, and the National Plan of Action to Prevent and Respond to Violence
To Local and Village
- Adopt bylaws that provide village officials
legal authority to act when they find child labor in mining.
Artisanal Miners’ Associations
- Develop a code of conduct or policy for
Tanzania’s artisanal gold mining sector, obliging members to undertake
measures towards the elimination of child labor in artisanal gold mining and to
take action on mercury. Monitor the use of child labor and mercury on
Large-Scale Gold Mining Companies
- Develop programs to address child labor and
mercury use in small-scale mining, in consultation with local government, NGOs,
and regional miners’ associations, as part of community engagement
- Consider becoming involved in the Multi-Stakeholder
Partnership with the government and World Bank. Fund pilot projects to remove
children from small-scale gold mines and reduce mercury exposure through this
To the African Union
- As part of the African Union Mining Vision
Action Plan, ensure that all artisanal and small-scale mining policies, laws,
regulations, standards and codes address child labor and mercury use in small-scale
- The African Committee on the Rights and
Welfare of a Child should investigate child labor in small-scale gold mining.
To Donor Countries, the
World Bank, and Relevant UN Agencies
- Provide financial, political, and technical
support for the above-mentioned measures. In particular, support:
- The National Action Plan for the Elimination
of Child Labor, including to programs for the strengthening of district level
child protection systems, and withdrawal of children working in artisanal
- The third Tanzania Social Action Fund (TASAF
III), a social protection scheme that benefits vulnerable children and that
ties cash transfers to regular school;
- Measures to end the use of mercury by child
- Measures to introduce technologies that
reduce exposure to mercury in small-scale gold mining, such as retorts;
- Initiatives to support the ratification of
the Minamata Convention on Mercury.
- The International Labour Organization should
make child labor in artisanal mining a priority issue.
- The World Bank should ensure that all
projects in Tanzania that involve artisanal and small-scale mining, such as the
Sustainable Management of Mineral Resources Project (SMMRP) and the
Multi-Stakeholder Partnership, include initiatives that are designed to
decrease child labor in mining, increase access to education for children from
artisanal and small-scale mining families, and reduce the exposure of children
and adults to mercury. The impact of these initiatives on child labor and
mercury exposure should be explicitly measured through the results frameworks
of all relevant projects.
To Tanzanian and International Companies Trading in
Tanzanian Artisanal Gold
- Establish a thorough due diligence process,
including regular monitoring, to eliminate child labor in your supply chains. Monitors
should be independent and the results of monitoring should be published.
Companies should visit artisanal mines to ensure they have accurate information
about child labor. If there are reports that child labor is being used,
companies should specifically investigate these reports. The due diligence
process should also include procedures to address adverse human rights impacts.
- Where necessary, Tanzania’s government
and international companies should train suppliers on how to identify and
address child labor.
- In the event that child labor occurs,
companies buying the gold should take action to address the situation. In
particular the companies should:
- Immediately inform government authorities
and urge them in writing to take measures to end the use of child labor in
small-scale gold mining within a specified timeframe, for example, to seek
measurable improvements within one year through labor inspections and improved
access to education;
- Immediately inform suppliers and urge them
to take measures to end the use of child labor in their supply chain within a
specified timeframe, such as two years, in order to facilitate children’s
transition out of work.
- Encourage and support credible and effective
measures to end child labor, for example, through projects that improve access
to education and withdraw children from child labor.
- Develop and publish a code of conduct or
policy on child labor if they have not done so yet. Implementation of such a
code or policy should be independently monitored by a credible third party.
- Cooperate with associations of gold miners
to develop a sector-wide code of conduct on child labor in Tanzania’s