progressive development, which require States to advance as efficiently and expeditiously as possible towards the full realization of those rights. 18 Aside from my deliberations on the regulatory content derived from Article 26, which I believe is limited to the obligation of progressivity, I find it highly problematic that many of the benefits derived from ESCER are consolidated through jurisprudence as immediately enforceable obligations. 5. In the judgment, prior to the analysis of the violations of Article 26 of the Convention, the Court points out that in this specific case it is exclusively appropriate to study the violation of the obligations of immediate enforceability with respect to the right to work in just, equitable and satisfactory conditions that ensure the safety, health and hygiene of the worker, with health and social security, which does not prevent the development of standards in this area. However, in elaborating on this aspect of the decision, the Court reiterates its case law on the aforementioned rights without making any distinction between the obligations of immediate enforceability and those of progressive development, and without specifying the criterion that differentiates one from the other from the point of view of their content. 6. That said, it could be argued that the immediately enforceable obligations referred to in the decision are those associated with the regulation, supervision and oversight of a dangerous activity carried out by individuals - which is how I believe it should be understood- either in terms of the right to work (occupational risks) or social security (labor contracting modalities). Otherwise, the central element of the notion of progressive development obligations, associated with the fact that the benefits derived from ESCER must be guaranteed to the extent of the resources available in each of the member States of the Convention, becomes blurred. In the judgment, the Court identifies as obligations derived from the right to health the provision of specific services for the treatment of certain conditions or the implementation of care centers with particular facilities in a specific region. 19 Although these elements are absolutely reasonable in light of the circumstances of this case, it would be wrong to conclude that the materialization of these benefits should be considered as an obligation of immediate enforceability derived from the ESCER. 7. All of the above without mentioning that the analysis carried out in relation to the right to life could have subsumed, by way of connection, precisely those contents that can be considered immediately enforceable, all reiterated with the same elements when analyzing the violation of the right to work in just, equitable and satisfactory conditions that ensure the safety, health and hygiene of the worker, as well as health and social security. 20 Humberto Antonio Sierra Porto Judge Pablo Saavedra Alessandri Secretary 18 Cf. Case of Muelle Flores v. Peru. Preliminary objections, merits, reparations and costs. Judgment of March 6, 2019. Series C No. 375, para 190, and Advisory Opinion OC-27/21, supra, para. 147. Cf. Case of the Miskito Divers (Lemonth Morris et al.) v. Honduras. Merits, reparations and costs. Judgment of August 31, 2021. Paras. 95-96. 19 20 Cf. Case of the Miskito Divers (Lemonth Morris et al.) v. Honduras. Merits, reparations and costs. Judgment of August 31, 2021. Paras. 78.