For around $2 a day some Afghan children as young as 10 work long hours in the country's coal mines with no safety gear and, until now, no government mining policy to protect them.
While national law allows Afghan children to work up to 35 hours a week from the age of 14, they are not allowed to do hazardous jobs such as mining. But after 30 years of conflict and with many children the sole family breadwinners, aid and rights groups say the laws are flouted and not enforced.
As Afghanistan tries to attract foreign investors to develop an estimated $3 trillion worth of untapped mineral deposits, Mines Minister Wahidullah Shahrani has been working to expand and clean up the industry and has drafted a policy officially setting the minimum age for coal mine workers at 18.
"We drafted the first-ever social policy guidelines to make sure that when it comes to the labor force, and when it comes to health and safety, and most importantly on the issue of child labor, we will have some type of standards," he told Reuters.
"Previously we did not have any official policy at the Ministry of Mines."
The guidelines are due to be implemented in the next few months and mining inspectors would be employed to ensure the rules are upheld, Shahrani said. But critics have questioned the government's capacity to manage the mining industry.
Since Shahrani became minister at the start of 2010, he has drawn up the ministry's first business plan and signed Afghanistan to the Extractive Industries Transparency Initiative (EITI) as a candidate country. He was optimistic that by April 2012 Afghanistan would get full EITI compliant status.
Afghanistan's rich mineral deposits have been trumpeted as the key to future prosperity, but experts say the bounty is many years, even decades, away and point to massive security and infrastructure challenges for potential investors.
The country however has already awarded a contract to China's top copper producer, Jiangxi Copper Co, and China Metallurgical Group Corp for the big Aynak mine south of Kabul.
Shahrani is due to award another large contract in November for what the government describes as Asia's largest untapped iron ore deposit, the Hajigak mine, that straddles the provinces of Bamiyan, Parwan and Maidan Wardak.
CHILD LABOR WIDESPREAD
About 200 children were recently found working in coal mines in central Bamiyan province, according to separate studies by the Afghanistan Independent Human Rights Commission and by the Child Protection Action Network, a joint initiative with aid groups including the U.N. Children's Fund (UNICEF).
Afghanistan is one of the poorest countries in the world, where children make up half the population, and a quarter of children die before the age of five.
The Afghanistan Independent Human Rights Commission found that children were working in some mines run by the government, which Shahrani acknowledged, although he said there was "not that many." He blamed 30 years of conflict for pushing impoverished families to allow children to work in mines.
"All those years have been a difficult period for the people," he said.
The U.S. Geological Survey has found Afghanistan has "moderate to potentially abundant" coal resources, although most of it is relatively deep or currently inaccessible.
It is mainly used for powering small industries -- such as cement production, textile manufacturing and food processing -- and as a primary source of household fuel, it said.
Child labor in Afghanistan is not restricted to mining.
There are about 1.2 million Afghan children in part- or full-time work, the government says, in a country where war, poverty, widespread unemployment and a preference for large families have created a huge underage labor market.
A 2010 study by the Afghanistan Independent Human Rights Commission found that an even larger portion of the country's 15 million children -- up to 40 percent -- were likely to be engaged in some sort of paid work.
Abdul Ahad Farzam, head of the commission in Bamiyan, said because many mines were often located in remote areas where children are exposed to the dangers associated with coal mining -- cancer and respiratory illnesses caused by the dust and gases, which can also cause underground explosions.
"We are afraid of child abuse because they stay all night and day there together (at the mines)," he said.