Health + Safety Best Practices for Limited English Proficiency Employees 

Health + Safety Best Practices for Employees with Limited English Proficiency 

A worker with limited English proficiency (LEP) who is starting a new job in a high-hazard industry is expected to master unfamiliar tasks, comply with safety protocols, and understand what to do in the event of an injury. Failure to fully comprehend instructions can have serious occupational health and safety repercussions. 

Employers in industries covered by Occupational Health and Safety (OSHA) regulations have a duty to provide training in languages other than English. There are also opportunities for companies to voluntarily adopt best practices to help protect LEP workers and prevent costly accidents, injuries, and workers’ compensation claims. 

Composition of the LEP Workforce 

The U.S. government defines LEP individuals as those who do not speak English as their primary language and have a limited ability to read, speak, write, or understand the English language. The Bureau of Labor Statistics (BLS) reported in 2024 that people of Hispanic or Latino ethnicity comprised nearly half (48.7%) of the foreign-born labor force in the U.S., while people from Asian countries accounted for 24.6%. Workers from numerous other countries made up the remainder. 

KFF, a health policy organization, estimated in 2024 that 47% of immigrant adults in the U.S. have LEP. The top five languages spoken by LEP employees were Spanish (63%), Chinese (7%), Vietnamese (3%), Arabic (2%), and Tagalog (2%).  

In 2023, the most recent year with complete data, an estimated 33 million immigrants were in the U.S. workforce, including about 23 million lawful immigrants and 10 million unauthorized immigrants, according to the Pew Research Center. In a report released Aug. 21, 2025, Pew reported that 19% of the U.S. civilian labor force was comprised of immigrants, a 20% decline since January 2025, mainly attributed to changes in public policy. 

Why This Matters 

In a Survey of Immigrants conducted by KFF and the Los Angeles Times: 

• 55% of employees with LEP reported experiencing discrimination at work 
• 53% encountered language barriers in interactions, including access to healthcare services 
• 29% said LEP made it difficult for them to get or keep a job 

Multiple studies have linked language barriers with higher risk for work-related injuries and fatalities. BLS data show that that foreign-born workers are more likely than U.S.-born workers to have jobs in higher-risk industries like natural resources, construction, maintenance, production, transportation, material handling, and healthcare and hospitality services.  

With immigration policy at the forefront of political discourse, English language proficiency in America has become a focal point. President Trump signed Executive Order 14224 on March 1, 2025, designating English as the official language of the United States. This order rescinded Executive Order 13166, which was signed by President Clinton in 2000 to require federal agencies and recipients of federal funding to improve access to their services for those with LEP. 

Executive Order 14224 is not a statute. It does not apply to private employers, nor does it prohibit federal agencies from offering services in languages other than English. The order also does not override occupational health and safety regulations, federal civil rights laws, or state legislation that facilitates access to multilingual resources. However, it is expected to have ripple effects in U.S. workplaces. 

Some federal government agencies are in the midst of a movement toward reducing access to certain federal resources in languages other than English. In a memo, the U.S Justice Department recommends actions that can be taken by federal agencies, including: 

• Discontinuing production of multilingual documents and products 
• Considering English-only services for certain programs, grants, and policies  
• Using artificial intelligence and machine translation as an alternative to person-to-person translation services 
• Redirecting funds saved by reducing translation services to research and programs that improve English proficiency and assimilation  

OSHA Standards 

OSHA requires that workplace training be provided in a language and vocabulary that employees can understand. Safety signs and symbols must be easily recognizable and Globally Harmonized System (GHS) labels clearly marked on toxic chemical containers.  

Applicable standards include the General Duty Clause (Section 5(a)(1) of the OSH Act), which requires employers to provide a workplace “free from recognized hazards that are causing or are likely to cause death or serious physical harm,” and Hazard Communication (29 CFR 1910.1200(h), which is intended to protect employees from risk of exposure to toxic substances. Hazard communication in general industry ranked second on the top-10 list of the most frequently cited standards in fiscal year 2024. The percentage of violations associated with LEP is not specified. 

Commercial Driver Requirements 

The Federal Motor Carrier Safety Administration (FMCSA) sets and enforces minimum national standards for commercial driver medical exams to help ensure safe operation of commercial motor vehicles on U.S. roadways. Per 49 CFR part 391.11: General Qualifications of Drivers, a commercial driver must be able to read and speak the English language sufficiently enough to converse with the general public,  understand highway traffic signs and signals in English, respond to official inquiries, and make entries on reports and records. 

Employers are considered to be responsible for determining whether a job candidate or employee is sufficiently proficient in English to qualify for a commercial driver’s license. Via an online occupational and environmental medicine discussion forum, Natalie Hartenbaum, M.D., M.P.H., president and chief medical officer of OccuMedix and an expert on transportation medicine, recently shared information she obtained from the FMCSA in response to a request for clarification on medical examiner (ME) responsibilities. 

“The ME must be able to communicate sufficiently (does not specify that the exam cannot be conducted in a different language) to perform the examination and review the medical history,” she wrote. “The driver must complete the medical history portion of the form and sign that the information they provide is accurate and complete.”  

In response to Dr. Hartenbaum’s inquiry, the FMCSA stated that: 

“MEs are not required to certify the extent to which a driver understands English. However, MEs should only conduct examinations when they are confident that they can communicate with drivers to the level that allows for a thorough examination to be conducted. As the signature authority on the Medical Examiner’s Certificate, Form MCSA-5876, MEs can turn the driver away if the level of English is not proficient enough to conduct the examination. Therefore, if the certifying ME cannot obtain a complete medical history to appropriately proceed with conducting a physical qualification examination with or without an interpreter, the ME should not conduct the examination.”  

Occupational Health + Safety Best Practices 

Recommended best practices across all industry types help ensure that employees with LEP comprehend safety protocols and the value of occupational health interventions and wellness programs.  

For employees, recommendations include: 

• Providing OHS training materials and signage in employees’ native language.  
• Using certified translators and bilingual trainers who are familiar with applicable technical terms 
• Deploying a mix of modalities (e.g., videos, infographics, educational handouts) suitable for diverse audiences and literacy levels 
• Applying plain language principles, such as those proposed by the U.S. Department of Labor. 

For leadership, suggestions include: 

• Retaining bilingual or multilingual supervisors 
• Creating programs to support peer mentor-protégé relationships 
• Adopting a workplace health train-the-trainer model 
• Use teach-back methods to confirm comprehension 
• Investigating incident causes to identify potential language-related training gaps 

How WorkCare Supports LEP Employees 

WorkCare’s 24/7 Injury Care telehealth triage program provides immediate, privacy-protected access to professional interpreters via its vendor, LanguageLine Solutions, when there is a need for translation during a provider-employee encounter. Callers are directed to select a language: Spanish, French Canadian, Haitian Creole, Bengali, or “other.”  When “other” is selected, the caller is prompted to identify the desired language.  

An interpreter is connected with the provider and employee on a conference line to assist with telehealth triage, which typically includes identifying symptoms and providing care guidance. Advantages for employers include not having to rely on workplace supervisors, family members, or other third parties who are not professionally trained as interpreters or who may have a communication bias.  

WorkCare also uses LanguageLine to translate medical documents, questionnaires, and educational materials like videos, posters, and wellness newsletters into languages other than English. Our Occupational Health Screening team refers employees to qualified providers throughout the U.S. for work-related medical surveillance exams. We retain occupational medicine physicians who review exam results and make fitness-for-duty recommendations. An interpreter may be used for clarifications during exams or for follow-up on medical findings. We also employ bilingual administrative and clinical staff who provide on-site and virtual support. 

Enhance Communication With Your Workforce 

A KFF study found that people with limited proficiency in English are less likely than English speakers to have health insurance coverage and more likely to have limited access to high-quality healthcare. Language barriers between providers and employees can result in adverse health outcomes that affect workforce productivity and overall quality of life.  

In some cases, the only medical screening exam a job applicant or an employee receives is one that is performed by an occupational health provider to evaluate physical and mental readiness for work. A work-related exam may be used to identify reasonable accommodations or temporary job restrictions, or it might reveal a previously undetected personal medical condition that requires further evaluation and treatment. 

WorkCare supports employers in their efforts to meet the occupational health and safety needs of their employees in a multitude of ways – whatever language(s) they speak. Contact us today to learn about ways we can help you enhance communication across your enterprise for optimal workplace health, safety, and productivity results.