conditions should be conducted by the competent labor authorities under the Labor Inspection Act. However, inspections of labor conditions for foreign fishers on distant water fishing vessels, who are hired through overseas recruitment, are carried out by the Fisheries Agency under Article 26 of the Act for Distant Water Fisheries and its associated regulations. Inspections concerning occupational safety and health on fishing vessels and labor condition inspections for coastal and inshore fisheries remain under the jurisdiction of labor authorities or dedicated labor inspection agencies. Some scholars, however, have raised concerns that the delegation of inspection authority under Article 26 of the Act for Distant Water Fisheries may lack clarity, potentially violating the principle of explicit authorization. Although fisheries workers are protected under the Occupational Safety and Health Act, the act's inspection framework was not explicitly designed for fishing vessels. Agencies responsible for occupational safety and health inspections are typically familiar with factory environments on land but may lack expertise in the unique working conditions aboard fishing vessels. Conversely, while the Fisheries Agency is well-versed in fishing vessel operations, it cannot perform safety and health inspections. Moreover, there is no jurisdiction over inspections of foreign-flagged vessels. These factors highlight the complexity and high degree of specialization required in labor inspection systems, necessitating ongoing interagency coordination. Civil society groups are sometimes invited to participate in onboard visits or labor condition inspections of foreign fishers on distant water fishing vessels conducted by the Fisheries Agency. However, their inability to exercise public authority often relegates them to mere observers, and they may even be denied boarding. The NHRC recommends that participation of civil society organizations during inspections be formalized, enabling these organizations to provide meaningful contributions rather than remaining passive observers. Additionally, the 135

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