The enforcement of Occupational Health and Safety (OHS) legislation varies considerably from country to country. This paper considers the enforcement of OHS legislation through a comparative analysis of eleven countries. The ASSE publication for the international practice specialty, "World Focus", uses the three regional classifications of Europe/Middle East/Africa, Asia/Pacific Rim and the Americas. Those are the regional designations used in this paper. The paper has a brief review of national accident statistics and a review of the enforcement OHS laws.

Incident Statistics Europe/MiddleEast/Africa

The total EUROSTAT statistics for Denmark from 1994 to 2002 are set out below.2 It is important to note that for countries, such as Denmark, where reporting workplace accidents is not required to qualify for treatment under social security or insurance schemes, and therefore the countries do not necessarily report 100% of all accidents.3

Table 1 (available in full paper).


The German Federation of Institutions for Statutory Accident Insurance and Prevention (HVBG) is the organization responsible for the statistics in Germany. It is interesting to note that in Germany statistics on workplace accidents include accidents on the way to and from work.4 The most recent statistics for Germany have been compiled by EUROSTAT, the European Union (EU) organization responsible for compiling data regarding the member states.5

Table 2 (available in full paper).

United Kingdom

RIDDOR 95 (Reporting of Injuries, Diseases and Dangerous Occurances Regulation 1995) came into effect April 1, 1996 and replaced RIDDOR 85. Deaths of all employed people6 arising from work activity are reportable to either HSE or the local authority. There are three categories of reportable injury to workers defined under the regulations: fatal, major and over-3-day injury.7 There were 235 fatal injuries to workers in 2003/04, an increase of 4% on the 2002/03 figure of 227.8 The rate of fatal injury to workers is at a similar level in 2003/04 as it was in the base year. The estimate of the number of working days lost (full day equivalent) due to workplace injury per 100,000 persons was 40,000 days per 100,000 persons in 2003/04 as compared to 35,000 days per 100,000 persons in 2000/02. These figures accounted for an estimated 8.8 million working days lost in 2003/04.

Non-fatal major injuries to all enforcing authorities by industry 1999/00-2003/04 (available in full text)

Fatal injuries reported to all enforcing authorities by industry 1999/00-2003/04 (available in full text)

Asia/Pacific Rim

The most recent year available for industrial accident and injury/illness statistics is 2002. In 2002 1,548 workers were killed in industrial accidents. Further, 125,918 workers suffered work related injuries/illnesses that resulted in lost time. The information provided as Table A is representative of lost time injuries/illnesses that resulted in at least 4 days of lost time. Table B is a representation of the number of work related fatalities among Japanese workers.

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