22 view of the fact that they have to cover 13 sites that are geographically widely dispersed. 95. The MFHR maintains that in violation of Article 3§2 Greece has also failed to “provide for the enforcement of regulations by measures of supervision”. 96. The MFHR argues that the mines inspectorate lacks the means to carry out sufficiently frequent and thorough checks to avert – as far as possible – occupational accidents and diseases.In support of its allegations it refers to the small number of inspectors (five engineers), in the south of Greece and a decline in the number of visits, from about 780 checks carried out in 2000, to 550 in 2004. 97. It adds that the general labour inspectorate (SEPE) pays very few visits to extraction sites – three in 2005, according to the inspectorate's 2005 report. It considers that the inspection services' oversight has been made even more ineffective by the fact that the DEH sub-contracts a significant proportion of its mining activities and does not exercise sufficient control over its contractors' health and safety policies. 98. As evidence of the inspection services' ineffectiveness, it cites the particularly high number of occupational accidents in Greece, including fatal ones. It also quotes Eurostat statistics, which show that, before enlargement of the European Union, the occupational accident and fatal occupational accident rates in Greece were above the average of the countries of the European Union (EU – 15). It also relies on data produced by the Government on trends in fatal accidents notified to the Institute of Social Insurance (IKA), to show that the number of fatal accidents has recently risen. 99. The MFHR claims that the fines imposed by the SEPE are often the minimum laid down in the legislation - Act 3385/2005, which establishes a scale from €1 000 to 30 000 - and are too light to act as a deterrent: €1 333 on average in 2005, according to the SEPE's 2005 report. It concludes that non-financial penalties, such as suspension of activities, disciplinary measures and criminal proceedings, are seldom if ever applied. B – The Government 100. The Government maintains that it has met all its obligations under Article 3 of the Charter. 101. The Government states that the DEH has an internal directive on the recording of occupational diseases. It acknowledges that there has been a delay in the recording process but hopes that once the recording process is complete, there will be proper provision for recognising and preventing occupational accidents. 102. The Government maintains that the number of occupational physicians is fixed in accordance with Act 1568/85 and that in 2003, 96.3 % of undertakings that were required to employ such doctors were in compliance with their obligations, namely 580 undertakings out of 602, employing 78 016 people. It also argues that the number of hours required to be worked, and thus the number of doctors are laid down in presidential decree 294/88 on the minimum employment time of safety technicians and occupational physicians, in application of Act 1568/85, and that these depend on the number of personnel and the risk category of the undertaking