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The Committee notes the Government’s report and its replies to the comments made by the General Confederation of Labour – Liberty of Cameroon (CGT–Liberté) in 2007 and 2008 and by the General Union of Workers of Cameroon (UGTC) in October 2008 concerning various shortcomings of the labour inspection system in relation to the requirements of the Convention.
Article 3(1)(a) and (b) of the Convention. Duties of labour inspectors. Based on the information contained in the annual inspection report for 2008, the Committee notes that, instead of ensuring the presence of labour inspectors at the workplace with a view to enforcing the legal provisions relating to conditions of work and the protection of workers, most of the working time of labour inspectors is devoted to resolving labour disputes through conciliation activities. In such conditions, these activities are clearly detrimental to the discharge of their primary duties as defined in Article 3(1) of the Convention. The Committee is bound to draw the Government’s attention to paragraph 2 of the same Article which stipulates that any further duties which may be entrusted to labour inspectors shall not be such as to interfere with the effective discharge of their primary duties or to prejudice in any way the authority and impartiality which are necessary to inspectors in their relations with employers and workers. Furthermore, Paragraph 8 of the Labour Inspection Recommendation, 1947 (No. 81), specifically advises against entrusting inspectors with the duty to act as conciliator or arbitrator in proceedings concerning labour disputes. In a previous report (2004), the Government had justified the allocation of these duties to inspectors by a need to relieve the pressure on the courts. However, the Committee considers that the volume of work created by these duties results in a disproportionate mobilization of the labour inspectorate’s resources to the detriment of its activities relating to enforcement, advice and improvement of the legislation referred to in the Convention. Given that labour disputes are often caused by a lack of understanding of the legal provisions or failure to comply with them, inspectors can make a major contribution to reducing labour disputes through educational activities and, if necessary, repressive action. The Committee therefore requests the Government to indicate the measures taken to ensure that the conciliation or mediation duties undertaken by labour inspectors in the event of a labour dispute do not interfere with the discharge of their primary duties and to provide information on any progress made in that regard, as well as any relevant document.
With regard to the specific matter of the supervisory powers of labour inspectors, raised by the CGT–Liberté, the Committee notes that, according to the Government, this matter should be examined in the context of the overall revision of the Labour Code under way. The Committee requests the Government to provide information on the progress made with regard to the draft reform of the Labour Code, including in particular the developments affecting the nature and scope of the powers of labour inspectors in relation to Articles 12, 13 and 17 of the Convention. It would be grateful if the Government would provide a copy of any relevant draft or final text.
Articles 6, 9 and 10. Labour inspection staff (composition, status and conditions of service). According to the Government, the inspection staff is composed of 106 inspectors (77 men and 29 women). Noting with interest that the National School of Administration and Magistracy (ENAM) reopened in 2006, the Committee requests the Government to provide information on the developments relating to the number and qualifications of labour inspectors during the period covered by the next report, including their geographical distribution.
The Committee understands, based on the information contained in the Government’s report received in 2008, that the remuneration of labour inspectors was increased by 15 per cent under Decree No. 2008/099 of 7 March 2009 applicable to both civilian and military staff, with retroactive effect from 1 April 2008. In response to the allegation made by the CGT–Liberté that the remuneration, working conditions and benefits of other administrators graduating from the ENAM are more favourable than those granted to labour inspectors, the Government emphasizes in its communication received in 2009 that “the Head of State has raised the salaries of public servants, including labour inspectors, in full fairness and without discrimination”. Noting that the annual inspection report for 2008 mentions various categories of inspection staff (inspectors, controllers, assistant controllers, clerks, contract public servants, decision-makers and other staff), the Committee requests the Government to indicate those who have the status of labour inspector under section 105 of the Labour Code and to provide further information on the status and conditions of service of each category of staff carrying out inspection activities.
Article 11. Means of action of inspectors. In reply to the point raised by the UGTC concerning the lack of means of action (computer equipment and means of transport) of the labour inspectorate, the Government pointed out in a communication sent to the ILO dated 5 December 2007 that, under the three-year budgetary programme for the period 2008–10, departmental labour offices were to be equipped with rolling stock. The Committee requests the Government to provide further information on the developments relating to the number of vehicles in the labour inspectorate’s fleet, to ensure, in any case and if necessary with the help of international financial cooperation, that labour inspectors are provided with the means essential for the performance of their duties (computerized office equipment, transport facilities, consumables etc.) and to keep the Office informed of any progress made in that regard.
Article 5(b). Collaboration between labour inspection officials and the social partners. In reply to the UGTC’s allegations concerning the lack of collaboration between the labour inspectorate and the social partners, the Government indicated in its 2008 report that such collaboration took place at both the national level within the National Labour Advisory Commission, the National Occupational Safety and Health Commission and the Synergy Committee and at the regional level within the decentralized services through inspections by labour inspectors, occupational safety and health committees, committees organizing labour day celebrations and various commissions. Drawing the Government’s attention to the guidance provided in Part II of Recommendation No. 81 on the types of collaboration possible between the labour inspectorate and organizations of employers and workers, the Committee would be grateful if the Government would provide details, as well as any documents available, on the content of the collaboration that takes place within or with the above bodies taking into account the objective of the Convention.
Articles 20 and 21. Annual report of the labour inspectorate. The Committee notes with interest that, following efforts lasting many years, a report on the work of the labour inspectorate for 2008 has been provided and contains information and statistics on inspections by branch of activity, industrial accidents, the workplaces and workers covered and the violations noted and penalties imposed. However, it notes that the Government once again expresses a need for technical assistance from the ILO to overcome various practical obstacles (inconsistent compliance with periodic reporting obligations across the various bodies and shortcomings in the methods of collecting and processing data) to the preparation of an annual report in accordance with the provisions of Articles 20 and 21.
Further to its general observation of 2009, the Committee also notes with interest the Government’s indication that studies have been launched with a view to creating a register of workplaces liable to inspection. It emphasizes the importance of creating and regularly updating a register (containing, in accordance with paragraph (c) of Article 21, information on the workplaces liable to inspection and the number of workers employed therein) to assess the rate of coverage of the inspectorate in relation to its area of competence and determine measures to improve it. The Committee trusts that the technical assistance from the Office requested by the Government for the purposes of preparing and publishing an annual inspection report as required by the Convention will therefore also concern the measures to be implemented to create and then update a register of workplaces. It would be grateful if the Government would keep the ILO informed of the steps taken in that regard, including the implementation of inter-institutional cooperation, as well as any difficulties encountered.
Finally, noting in the magazine of the Ministry of Labour and Social Security (MTSS) dated 1 January 2010 that the number of diseases included on the list of occupational diseases covered under the social security system has increased from 44 to 49 under Order No. 051/MINTSS/SG/DSST, the Committee requests the Government to ensure that the labour inspectorate is informed of cases of occupational disease, so that the relevant information is also included in the abovementioned annual report, in accordance with paragraph (g) of Article 21.
The Committee takes note of the Government’s report received at the ILO on 1 September 2008 and the enclosed documentation. It also notes the observations on the application of the Convention by the General Union of Cameroon Workers, received on 20 October 2008. It proposes examining the report and the trade union’s observations at its next session, as well as any other comments that the Government might wish to submit on the points raised in these observations.
The ILO received on 23 November 2006, the Government’s reply to observations from the General Union of Cameroon Workers (UGTC) dated 30 August 2006 which the Committee had examined at its previous session. The Committee notes that new observations reached the ILO from the UGTC on 21 August 2007 and from the Confederation of Labour – Liberty of Cameroon (CGTL) on 12 September 2007. The Committee notes that the observations from these organizations, which the ILO sent to the Government in September 2007, largely concern matters raised in the Committee’s observation of 2006. The Committee hopes that the Government will reply to the latter observation in its report due in 2008.
1. Articles 1, 6, 10, 11, 13, 16, 20 and 21 of the Convention. Insufficient staff, pay conditions and means of action of labour inspectors. Annual report on the work of the inspectorate. Inefficient and deteriorating inspection system. In reply to the UGTC’s observations of 2006 on the lack of inspectors and material facilities, the Government indicates that the inspectorate works in all ten provinces of the country and that the new organizational chart of the Ministry of Labour and Social Security provides for inspection services to be established in the departments and in certain districts with a high concentration of labour. Furthermore, five competitions have been held to recruit staff for the labour and social security corps. Only the provincial labour delegates have service vehicles because resources are lacking. In its communication of August 2007, the UGTC again emphasizes the lack of staff and the total absence of material facilities in the premises that house inspectors. The Committee also notes the observations from the CGTL, which raise a matter addressed in 2004 by the Confederation of Public Service Unions (CSP), namely that inspectors’ conditions of service and pay expose them to the influence of employers and weaken their authority to issue injunctions. The Committee hopes that the Government will be in a position in its next report to provide information on progress, particularly regarding the staff and means of action of the inspectorate and the organization and working of the inspection system. Please indicate in particular the measures taken or envisaged to ensure that labour inspectors are independent of all improper external influence.
The Committee also urges the Government to take measures to ensure that an annual report on the work of the labour inspectorate, containing all available information on the subjects listed at Article 21 of the Convention, is published and sent to the ILO, in accordance with Article 20. The Committee would be grateful if, to this end, the Government would take measures without delay for defining a method for uniform collection and processing of relevant information, and keep the ILO informed of progress in this regard.
Lastly, the Government is also asked to provide information on the results of the reading of the text on the supervisory powers of labour inspectors which, according to the Government’s statement in 2005, had been submitted to the National Labour Advisory Committee.
2. Article 5(b). Collaboration between labour inspection officials and the social partners. In its observations sent in August 2007, the UGTC asserts that there is no cooperation at all between labour inspectors, employers and workers. The Committee refers the Government to its previous comment on this matter in which it noted that the Labour Code does not deal with the issue of cooperation in labour inspection, and draws the Government’s attention to Part II of Recommendation No. 81, which provides useful guidelines on the nature and type of measures that might be taken to encourage such collaboration, with the employers too, in the area of occupational safety and health. It would be grateful if, in consultation with the employers and workers, the Government would entertain the possibility of implementing such measures, and asks it to keep the ILO informed of the results of such collaboration.
The Committee notes the Government’s report, its brief reply to the Committee’s previous observation concerning comments made by the Confederation of Public Service Unions (CSP) and the General Union of Cameroon Workers (GUCW) received at the ILO in September 2004. It also takes note of the new observations sent to the ILO by the GUCW dated 30 August 2005 and 30 August 2006.
1. Inadequate resources, ineffectiveness and deterioration of the labour inspection system. In its comments received at the ILO on 22 September 2004, the CSP alleges that certain Articles of the Convention are not properly applied. It notes with regret that there was no cooperation whatsoever between labour inspectors, employers and workers (Article 5 of the Convention); inspectors’ working and pay conditions made them vulnerable and exposed them to influence by employers (Article 6); and this is reflected, inter alia, by the non-application of Article 13 concerning inspectors’ authority to make orders for the elimination of risks to workers’ health and safety. The CSP also asserts that inspections are confined to enterprises in the private sector and never give rise to the application of penalties (Articles 16 and 17).
The same points were made by the GUCW in an observation of 27 August 2004, which also mentioned that local offices were poorly equipped and even lacked a supply of drinking water, and that there were no means of transport (Article 11).
In comments of 29 May 2005, the Government replied to the observations of the abovementioned organizations, stating that it was awaiting proof of the GUCW’s allegations concerning the labour inspectors’ lack of authority and resources. As to the inspectors’ supervisory authority, the Government indicated that the relevant text was to be submitted for examination to the Tripartite Synergy Committee for referral to the officers of the National Labour Advisory Commission, the only body with authority to issue opinions and proposals on labour legislation and regulations.
On 30 August 2005, the GUCW sent further comments to the ILO on the application of the Convention in which it referred to its previous observation and indicated that, in addition, as a result of restructuring, the Ministry of Employment, Labour and Social Insurance had been split into two ministries, with several inspectors being assigned to the new Ministry of Employment and Vocational Training, with the result that “workplace inspection had taken a punishing”.
Under cover of a letter of 29 November 2005, the Government sent to the ILO the GUCW’s reply regarding proof of its allegations, referring the Government to the reports of the annual conferences of officials of the central and external departments of the Ministry of Labour and Social Security.
The Committee further notes that, according to the general and legislative information sent by the Government, effect is given in law to every provision of the Convention. It notes, however, that there are no reports or extracts of reports on the practical working of the labour inspection enabling the Committee to assess its effectiveness or its weaknesses. Yet, in a direct request to the Government in 2002, the Committee noted the information that teams were to be despatched to collect reports from the departmental and provincial inspectorates and that technical assistance was to be sought from the ILO to improve skills in the collection and analysis of the statistics needed to draw up such reports. No such measures appear to have been taken and, according to the Government, it is still difficult to produce a general report on the labour inspection services.
In a new observation dated 30 August 2006, the GUCW reiterates its views on the situation of the labour inspectorate and adds that there is no longer an inspectorate for want of inspectors and resources. It again reports that some labour inspectors are subject to corruption by employers and that inspectors have no authority in the performance of their tasks.
The Committee urges the Government to take steps to ensure that an annual report on the activities of the labour inspectorate, containing all available information on the subjects listed at Article 21 of the Convention, is drawn up, published and sent by the central inspection authority to the ILO, in accordance with Article 20. It would be grateful if the Government would at once take measures to establish a method for uniform collection and processing of the relevant information and to report to the ILO all progress made towards this end.
The Government is also asked to provide information on the text concerning the powers of the labour inspectorate which, the Government says, has been submitted to the National Labour Advisory Commission, and on the outcome of the Commission’s examination of the text.
2. Collaboration between officials of the labour inspectorate and the social partners. The Committee notes that in reply to its direct request of 2004, the Government states that collaboration between officials of the labour inspectorate and workers or their organizations (Article 5(b)) is regulated by Title II of the Labour Code. The Committee notes that these provisions say nothing of collaboration in labour inspection, and draws the Government’s attention to Part II of Recommendation No. 81, which provides useful guidelines on the nature and form of measures that could be taken to encourage such collaboration, with employers as well as workers, in the area of occupational safety and health. It would be grateful if the Government would consider, in consultation with the employers and the workers, the possibility of implementing such measures, and if it would keep the ILO informed of the results of such collaboration.
Referring to its observation and further to its previous comments, the Committee requests the Government to provide detailed additional information on the following provisions.
Article 3, paragraph 2 of the Convention. In connection with the requirements of Article 16.
Article 4. In connection with Articles 19, 20 and 21.
Articles 8 and 10. By stating the geographical distribution and the respective duties of labour administrators, labour controllers and deputy labour controllers, given the functions and areas assigned by the Convention to the labour inspection system.
Article 13. By giving details of the exercise in practice of the power of labour inspectors and medical labour inspectors to order measures with immediate executory force in the event of imminent danger to the health or safety to the workers.
Article 14. By communicating Decree No. 78-546 of 28 December 1978, which is not attached to the report as stated.
Article 18. By referring to relevant developments in relation to paragraph 263 of the 1985 General Survey on labour inspection.
Articles 19, 20 and 21. By indicating any steps taken to obtain technical assistance from the ILO for the purpose of implementing these provisions.
The Committee also notes, in accordance with the information contained on page 38 of a handbook entitled "Labour inspection - Guide for inspection visits", published in 2000, that "the inspector should not fail to advise the head of the enterprise or his representative of the inspection visit". In this regard, the author of the publication also strongly advises that account should be taken not systematically but only exceptionally of the principle of visits without prior notification prescribed by Article 12, paragraph 1, of the Convention. The Committee notes the arguments put forward by the author to support this point of view and observes that they are contrary not only to the Convention but also to section 108(1)(a) of the Labour Code. Under these provisions, it is prior notification which should be the exceptional practice, not an unannounced visit, as emphasized in paragraphs 158 ff. of the abovementioned General Survey. It therefore requests the Government to indicate the legal value of the abovementioned document and the established practice in this matter.
The Committee notes the Government’s report, which responds in part to its previous comment. It also notes that observations were formulated by the General Union of Cameroon Workers (GUCW), dated 27 August 2004, and by the Confederation of Public Service Unions (CSP), dated 2 September 2004, with regard to Articles 5, 6, 11, 13, 16 and 18 of the Convention. The International Labour Office sent these comments to the Government on 8 and 11 October 2004, respectively, in order to invite it to submit any observation which it might wish to make with regard to the points raised. The Committee will examine at its next relevant session the points raised in the abovementioned comments and the information sent in response by the Government.
The Committee is addressing a direct request regarding certain points to the Government.
The Committee notes the Government’s reports and the comments sent by the Federation of Free Trade Unions of Cameroon. It asks the Government to provide additional information on the following points.
Article 3 of the Convention. The Committee asks the Government to indicate whether labour inspectors are responsible for drawing the competent authority’s attention to defects or abuses not specifically covered by existing legal provisions, as required by paragraph 1(c), and to explain how it is ensured that the conciliation duties conferred on inspectors by sections 139 and 158 of the Labour Code with a view to settling social conflicts, do not interfere with the authority and impartiality which inspectors need in their relations with employers and workers (paragraph 2).
Article 4. The Committee notes, that according to Decree No. 98/150 of 24 July 1998 to organize the Ministry of Employment, Labour and Social Welfare, in respect of its supervisory functions the Labour Inspectorate reports to several bodies including the Directorate of Labour, the Directorate of Social Insurance, the Directorate of Occupational Health and Safety, the Provincial Labour Inspection and Social Welfare Brigade, and the Departmental Delegation for Employment, Labour and Social Welfare. It would appear from the information supplied by the Government that the General Inspectorate is the central labour inspection authority. The Committee points out, however, that this is not clear from the terms of the abovementioned Decree. It therefore asks the Government to indicate the central authority responsible for the supervision and control of the labour inspectorate and, in accordance with Article 20, for drawing up an annual inspection report. The Government is asked to send a copy of the organizational chart of the Ministry of Labour and Social Insurance.
Article 7. The Committee notes that CRADAT (African Regional Labour Administration Centre) in Yaoundé is largely responsible for providing continuous training for inspectors. The Committee would be grateful if the Government would provide detailed information on the areas of training covered and the frequency of courses.
Articles 8 and 10. The Committee notes that the labour inspectorate is made up of 34 departmental services and ten provincial services and has 373 technical staff. The Government is asked to provide information on the distribution of the above staff by job category and sex and to indicate whether any special duties are to be assigned to women inspectors.
Article 12. The Committee notes that, according to section 108 of the Labour Code, the authority of labour inspectors extends only to establishments liable to inspection. Referring to paragraph 165 of its General Survey of 1985 on labour inspection, the Committee wishes to draw the Government’s attention to the case of undertakings which are not officially or recognizably subject to inspection but which nonetheless employ workers covered by the labour legislation. Emphasizing that labour inspectors must be authorized to enter these premises by day (paragraph 1(b)), it asks the Government to provide information on the manner in which it is ensured that workers employed in these premises are covered by this provision or, if they are not covered, to take measures to that end and report on them to the ILO.
Article 13, paragraph 2(b). With reference to its previous comments and noting with interest that section 95(3) of Act No. 92/007 of 14 August 1992 issuing the Labour Code authorizes the labour inspector or medical labour inspector to order immediately enforceable measures in the event of imminent danger for the health and safety of workers, the Committee would be grateful if the Government would provide copies of any texts to implement this provision together with information on its effects in practice.
Article 14. The Committee notes that, according to the Government, employers must report within three days to the National Social Security Fund any industrial accidents or cases of occupational disease, a copy of the report being sent to the competent labour inspector who will hold an enquiry if the fund so requests. It also notes that if the employer fails to do so, the worker has three years in which to report. The Committee would be grateful if the Government would provide copies of any texts on the procedure for reporting industrial accidents and cases of occupational disease.
Article 18. The Committee notes that fines for breaches of the legislation covered by the labour inspectorate are set by section 166 to 168 of the Labour Code. It also notes that fines are also imposed for obstructing labour inspectors or medical labour inspectors in the performance of their duties. Referring in this connection to paragraph 263 of its General Survey of 1985 on labour inspection, the Committee draws the Government’s attention to the importance of having a system for reviewing the amounts of fines to ensure that they are sufficiently dissuasive in spite of any monetary fluctuations.
Articles 19, 20 and 21. The Committee notes the difficulties caused by a lack of human and material resources which are preventing the publication of a national general report on the work of the inspection services. The Committee notes that there are plans to send out teams to collect reports from departmental and provincial inspectorates and to request technical assistance from the ILO in order to improve abilities to collect and analyse the statistics needed to produce the reports. The Committee hopes that the request for technical assistance will be favourably received and that the Government will not fail to provide information in its next report on progress made in giving practical effect to the abovementioned Articles of the Convention.
The Committee notes that the Government's report has not been received. It must therefore repeat its previous observation which read as follows:
Article 13, paragraph 2(b), of the Convention. For many years the Committee has been requesting the Government to take the necessary measures to give effect to this Article of the Convention, which provides that labour inspectors shall be empowered to make orders requiring measures to be taken with immediate executory force in the event of imminent danger to the health or safety of the workers. Since 1978, the Government has been indicating that the necessary measures were being taken to amend the law. The Committee notes the Government's indication in its last report that these measures have not yet been taken and expresses the firm hope that the necessary modifications will be adopted in the near future. Articles 16, 20 and 21. The Committee once again notes that no annual inspection report has been provided since those relating to the years 1978 and 1979. It recalls that these reports are an essential means of determining how the inspection system is working in practice and whether workplaces are being inspected as often and as thoroughly as necessary. It once again hopes that the Government will transmit to the Office, within the time-limits set out in the Convention, annual reports on the activities of the inspection services and that they will contain all the information required by the Convention.
The Committee hopes that the Government will make every effort to take the necessary action in the very near future.
Article 13, paragraph 2(b), of the Convention. For many years the Committee has been requesting the Government to take the necessary measures to give effect to this Article of the Convention, which provides that labour inspectors shall be empowered to make orders requiring measures to be taken with immediate executory force in the event of imminent danger to the health or safety of the workers. Since 1978, the Government has been indicating that the necessary measures were being taken to amend the law. The Committee notes the Government's indication in its last report that these measures have not yet been taken and expresses the firm hope that the necessary modifications will be adopted in the near future.
Articles 16, 20 and 21. The Committee once again notes that no annual inspection report has been provided since those relating to the years 1978 and 1979. It recalls that these reports are an essential means of determining how the inspection system is working in practice and whether workplaces are being inspected as often and as thoroughly as necessary. It once again hopes that the Government will transmit to the Office, within the time-limits set out in the Convention, annual reports on the activities of the inspection services and that they will contain all the information required by the Convention.
[The Government is asked to report in detail in 1996.]
The Committee notes the information provided by the Government.
Article 13, paragraph 2(b), of the Convention. For many years the Committee has been asking the Government to take the necessary measures to give effect to this Article of the Convention, which requires that labour inspectors be empowered to make or have made orders requiring measures with immediate executory force in the event of imminent danger to the health or safety of the workers. Since 1978, the Government has been indicating that the necessary measures were being taken to amend the law. The Committee hopes that the Government will soon be able to indicate that the necessary amendment has been made and brought into force.
Articles 16, 20 and 21. The Committee notes that no annual inspection reports have been provided since those for 1978 and 1979. It recalls that such reports are an essential means of determining how the inspection system works in practice and whether it is ensured that workplaces are inspected as often and as thoroughly as necessary. It hopes that the Government will send annual reports on the activities of the inspection service to the Office within the time-limits set by the Convention and that these reports will include all the information required by the Convention.
Article 13, paragraph 2(b), of the Convention. In answer to the Committee's earlier comments, the Government refers to the provisions of Title IV and Annex I of Order No. 039/MTPS/IMT of 26 November 1984, which establish a four-day minimum period for the execution of orders, and considers that these are measures with immediate executory force. The Committee points out that the above provisions give effect to paragraph 2(a) of this Article (under which inspectors must be empowered to order certain alterations to the installation or plant, to be carried out within a specified time-limit) but not to paragraph 2(b) which applies to cases of emergency in which the inspector must be empowered to make orders requiring "measures with immediate executory force in the event of imminent danger to the health or safety of the workers". In such cases (e.g. when there is a danger of asphyxia, explosion, collapse of plant, etc.), the procedure laid down by the provisions of Order No. 039/MTPS/IMT is not adequate to avert the danger, which could materialise before the expiry of the four-day minimum time-limit imposed when an order is issued. The Committee hopes that, bearing these explanations in mind, the Government will take the necessary measures (either as part of the revision of the Labour Code, or by supplementing Order No. 039/MTPS/IMT with an appropriate provision) to confer on labour inspectors the powers laid down by Article 13, paragraph 2(b), of the Convention.
Articles 20 and 21. The Committee notes with regret that, despite the Government's assurances that it would provide regular annual inspection reports, no report has been received by the International Labour Office since 1982. It trusts that the Government will not fail to take the necessary steps to ensure that, in future, these reports, containing information on all the subjects listed at Article 21, are published and transmitted to the International Labour Office within the time-limits laid down by Article 20.