Occupational safety and health practice vary among nations with different approaches to legislation, regulation, enforcement, and incentives for compliance. In the EU, for example, some member states promote OSH by providing public monies as subsidies, grants or financing, while others have created tax system incentives for OSH investments. A third group of EU member states has experimented with using workplace accident insurance premium discounts for companies or organizations with strong OSH records.
Australia In
Australia, four of the
six states and both territories have enacted and administer harmonized work health and safety legislation in accordance with the Intergovernmental Agreement for Regulatory and Operational Reform in Occupational Health and Safety. Each of these jurisdictions has enacted work health and safety legislation and regulations based on the Commonwealth Work Health and Safety Act 2011 and common codes of practice developed by
Safe Work Australia. Some jurisdictions have also included mine safety under the model approach. However, most have retained separate legislation for the time being. In August 2019,
Western Australia committed to join nearly every other state and territory in implementing the harmonized Model WHS Act, Regulations and other subsidiary legislation.
Victoria has retained its own regime, although the Model WHS laws themselves drew heavily on the Victorian approach.
Safe Work Australia also recognizes the psychosocial dimensions of workplace safety, including risks arising from job demands, poor workplace relationships, low job control, and inadequate support during significant organizational changes such as redundancy and restructuring. Employers covered under the Model WHS Act have a duty to manage pychosocial hazards with the same rigor applied to physical hazards in the workplace.
Canada In
Canada, workers are covered by
provincial or federal labor codes depending on the sector in which they work. Workers covered by federal legislation (including those in mining, transportation, and federal employment) are covered by the
Canada Labour Code; all other workers are covered by the health and safety legislation of the province in which they work. The
Canadian Centre for Occupational Health and Safety (CCOHS), an agency of the Government of Canada, was created in 1978 by an act of parliament. CCOHS is mandated to promote safe and healthy workplaces and help prevent work-related injuries and illnesses. There are significant common elements across relevant provincial OHS legislation. The foundation of each of these legislative frameworks is the belief that all Canadians have "a fundamental right to a healthy and safe working environment." In general, provincial workplace safety laws in Canada are designed to promote shared responsibility, prevent accidents, and ensure accountability at all levels of an organization. Employers, supervisors, and workers are expected to work together to minimize risks. Employers, in particular, are legally obligated to take every reasonable precaution to protect workers. If the workplace has more than a few employees, they are required to develop written health and safety policies and procedures. Employers must also provide and maintain equipment and machinery in a safe working condition. Additionally, employers must inform, instruct, and supervise workers to ensure safe work practices are followed. Employers are also responsible for supplying necessary protective equipment and ensuring it is used correctly, whether it involves
machine guards or
personal protective equipment (PPE). Supervisors have a duty to ensure that workers use all required safety devices and comply with established procedures. They must also communicate information about existing or potential hazards and provide guidance on how to work safely. Workers also have the right to refuse work if they believe it is unsafe and poses a danger to themselves or others. In workplaces with a set minimum number of employees (twenty in the case of workplaces under federal jurisdiction), it is mandatory to have a health and safety committee. This, made up of both worker and management representatives, meets regularly to identify hazards, investigate incidents, and make recommendations to improve workplace safety. These committees are crucial for fostering collaboration and addressing safety concerns in a timely manner. Law also requires employers to take defined steps to prevent
workplace violence and
harassment. They must create a workplace violence policy along with a program that identifies risks and outlines procedures for addressing them. A separate workplace harassment policy must explain how complaints should be reported and investigated. Employers are required to train employees on these policies to ensure awareness and compliance. All incidents involving violence, threats, or persistent harassment must be taken seriously and handled appropriately. In severe cases involving serious injury or death due to negligence, organizations and individuals can be prosecuted under the
Criminal Code of Canada through the provisions introduced by the
Jobs and Growth Act. In some provinces, like
Ontario, this introduces serious criminal consequences for safety violations. Workplaces are also subject to federal regulations under WHMIS, the
Workplace Hazardous Materials Information System. WHMIS governs the labeling, documentation, and communication of hazardous materials. Employers must ensure that all hazardous substances are properly labeled, that
material safety data sheets are readily available, and that workers are trained on how to handle these materials safely. As an example of arrangements at a provincial level, Ontario's primary workplace safety legislation is the
Occupational Health and Safety Act (OHSA). This law sets out the responsibilities of employers, supervisors, and workers to promote a safe and healthy work environment. Ontario's occupational health and safety framework is built around the concept known as the "Internal Responsibility System," which means that everyone in the workplace shares responsibility for recognizing and addressing safety concerns. The OHSA is enforced by Ontario's
Ministry of Labour, Immigration, Training and Skills Development. Ministry inspectors have the authority to visit workplaces, investigate complaints, and issue orders. Failure to comply with the law can lead to substantial fines and penalties, and individual supervisors or managers may also be held personally liable.
China In
China, the
Ministry of Health is responsible for occupational disease prevention and the
State Administration of Work Safety workplace safety issues. The Work Safety Law (安全生产法) was issued on 1 November 2002. The Occupational Disease Control Act came into force on 1 May 2002. In 2018, the
National Health Commission (NHC) was formally established to formulating national health policies. The NHC formulated the "National Occupational Disease Prevention and Control Plan (2021–2025)" in the context of the activities leading to the "Healthy China 2030" initiative.
European Union The
European Agency for Safety and Health at Work was founded in 1994. In the
European Union,
member states have enforcing authorities to ensure that the basic legal requirements relating to occupational health and safety are met. In many EU countries, there is strong cooperation between employer and worker organizations (e.g.,
unions) to ensure good OSH performance, as it is recognized this has benefits for both the worker (through maintenance of health) and the enterprise (through improved
productivity and
quality). Member states have all transposed into their national legislation a series of directives that establish minimum standards on occupational health and safety. These directives (of which there are about 20 on a variety of topics) follow a similar structure requiring the employer to assess workplace risks and put in place preventive measures based on a
hierarchy of hazard control. This hierarchy starts with elimination of the hazard and ends with
personal protective equipment.
Denmark In
Denmark, occupational safety and health is regulated by the Danish Act on Working Environment and Cooperation at the Workplace. The Danish Working Environment Authority (
Arbejdstilsynet) carries out inspections of companies, draws up more detailed rules on health and safety at work and provides information on health and safety at work. The result of each inspection is made public on the web pages of the Danish Working Environment Authority so that the general public, current and prospective employees, customers and other stakeholders can inform themselves about whether a given organization has passed the inspection.
Netherlands In the
Netherlands, the laws for safety and health at work are registered in the Working Conditions Act (
Arbeidsomstandighedenwet and
Arbeidsomstandighedenbeleid). Apart from the direct laws directed to safety and health in working environments, the private domain has added health and safety rules in Working Conditions Policies (
Arbeidsomstandighedenbeleid), which are specified per industry. The
Ministry of Social Affairs and Employment (SZW) monitors adherence to the rules through their inspection service. This inspection service investigates industrial accidents and it can suspend work and impose fines when it deems the Working Conditions Act has been violated. Companies can get certified with a VCA certificate for safety, health and environment performance. All employees have to obtain a VCA certificate too, with which they can prove that they know how to work according to the current and applicable safety and environmental regulations.
Ireland The
Health and Safety Authority, based in
Dublin, is responsible for enforcing health and safety at work legislation in
Ireland. which replaced earlier legislation from 1989. Under the 2005 Act, companies are legally required to prepare a "safety statement" which sets out the hazards identified in the workplace, the risks arising from those hazards, and the measures in place to mitigate those risks and safeguard employee safety, health and welfare.
Spain In
Spain, occupational safety and health is regulated by the Spanish Act on Prevention of Labor Risks. The
Ministry of Labor is the authority responsible for issues relating to labor environment. The
National Institute for Safety and Health at Work (
Instituto Nacional de Seguridad y Salud en el Trabajo, INSST) is the government's scientific and technical organization specialized in occupational safety and health.
Sweden In
Sweden, occupational safety and health is regulated by the Work Environment Act. The
Swedish Work Environment Authority (
Arbetsmiljöverket) is the government agency responsible for issues relating to the working environment. The agency works to disseminate information and furnish advice on OSH, has a mandate to carry out inspections, and a right to issue stipulations and injunctions to any non-compliant employer.
India In
India, the
Ministry of Labour and Employment formulates national policies on occupational safety and health in factories and docks with advice and assistance from its Directorate General Factory Advice Service and Labour Institutes (DGFASLI), and enforces its policies through inspectorates of factories and inspectorates of dock safety. The DGFASLI provides technical support in formulating rules, conducting occupational safety surveys and administering occupational safety training programs.
Indonesia In
Indonesia, the
Ministry of Manpower (
Kementerian Ketenagakerjaan, or Kemnaker) is responsible to ensure the safety, health and welfare of workers. Important OHS acts include the Occupational Safety Act 1970 and the Occupational Health Act 1992. Sanctions, however, are still low (with a maximum of 15 million
rupiahs fine and/or a maximum of one year in prison) and violations are still very frequent.
Japan The Japanese
Ministry of Health, Labor and Welfare (MHLW) is the governmental agency overseeing occupational safety and health in
Japan. The MHLW is responsible for enforcing Industrial Safety and Health Act of 1972 – the key piece of OSH legislation in Japan – setting regulations and guidelines, supervising labor inspectors who monitor workplaces for compliance with safety and health standards, investigating accidents, and issuing orders to improve safety conditions. The Labor Standards Bureau is an arm of MHLW tasked with supervising and guiding businesses, inspecting manufacturing facilities for safety and compliance, investigating accidents, collecting statistics, enforcing regulations and administering fines for safety violations, and paying accident compensation for injured workers. The (JISHA) is a non-profit organization established under the Industrial Safety and Health Act of 1972. It works closely with MHLW, the regulatory body, to promote workplace safety and health. The responsibilities of JISHA include: Providing education and training on occupational safety and health, conducting research and surveys on workplace safety and health issues, offering technical guidance and consultations to businesses, disseminating information and raising awareness about occupational safety and health, and collaborating with international organizations to share best practices and improve global workplace safety standards. The (JNIOSH) conducts research to support governmental policies in occupational safety and health. The organization categorizes its research into project studies, cooperative research, fundamental research, and government-requested research. Each category focuses on specific themes, from preventing accidents and ensuring workers' health, to addressing changes in employment structure. The organization sets clear goals, develops road maps, and collaborates with the Ministry of Health, Labor and Welfare to discuss progress and policy contributions.
Malaysia In
Malaysia, the
Department of Occupational Safety and Health (DOSH) under the
Ministry of Human Resources is responsible to ensure that the safety, health and welfare of workers in both the public and private sector is upheld. DOSH is responsible to enforce the
Factories and Machinery Act 1967 and the
Occupational Safety and Health Act 1994. Malaysia has a statutory mechanism for worker involvement through elected health and safety representatives and health and safety committees. This followed a similar approach originally adopted in Scandinavia.
Saudi Arabia In
Saudi Arabia, the
Ministry of Human Resources and Social Development administrates workers' rights and the labor market as a whole, consistent with human rights rules upheld by the
Human Rights Commission of the kingdom.
Singapore In
Singapore, the
Ministry of Manpower (MOM) is the government agency in charge of OHS policies and enforcement. The key piece of legislation regulating aspects of OHS is the
Workplace Safety and Health Act. The MOM promotes and manages campaigns against unsafe work practices, such as when working at height, operating cranes and in traffic management. Examples include Operation Cormorant and the Falls Prevention Campaign.
South Africa In
South Africa the
Department of Employment and Labour is responsible for occupational health and safety inspection and enforcement in the commercial and industrial sectors, with the exclusion of mining, where the
Department of Mineral Resources is responsible. Regulations implementing the OHS Act include: • General Safety Regulations, 1986 • Environmental Regulations for Workplaces, 1987 • Driven Machinery Regulations, 1988 • General Machinery Regulations, 1988 • Noise Induced Hearing Loss Regulations, 2003 • Pressure Equipment Regulations, 2004 • General Administrative Regulations, 2003 • Diving Regulations, 2009 • Construction Regulations, 2014
Syria In
Syria, health and safety is the responsibility of the
Ministry of Social Affairs and Labor ().
Taiwan In
Taiwan, the of the
Ministry of Labor is in charge of occupational safety and health. The matter is governed under the .
United Arab Emirates In the
United Arab Emirates, national OSH legislation is based on the Federal Law on Labor (1980). Order No. 32 of 1982 on Protection from Hazards and Ministerial Decision No. 37/2 of 1982 are also of importance. The competent authority for safety and health at work at the federal level is the Ministry of Human Resources and Emiratisation (MoHRE).
United Kingdom Health and safety legislation in the UK is drawn up and enforced by the
Health and Safety Executive and local authorities under the
Health and Safety at Work etc. Act 1974 (HASAWA or HSWA). HASAWA introduced (section 2) a general duty on an employer to ensure,
so far as is reasonably practicable, the health, safety and welfare at work of all his employees, with the intention of giving a legal framework supporting codes of practice not in themselves having legal force but establishing a strong presumption as to what was reasonably practicable (deviations from them could be justified by appropriate risk assessment). The previous reliance on detailed prescriptive rule-setting was seen as having failed to respond rapidly enough to technological change, leaving new technologies potentially unregulated or inappropriately regulated. HSE has continued to make some regulations giving absolute duties (where something must be done with no "reasonable practicability" test) but in the UK the regulatory trend is away from prescriptive rules, and toward goal setting and risk assessment. Recent major changes to the laws governing
asbestos and
fire safety management embrace the concept of risk assessment. The other key aspect of the UK legislation is a statutory mechanism for worker involvement through elected health and safety representatives and health and safety committees. This followed a similar approach in Scandinavia, and that approach has since been adopted in countries such as Australia, Canada, New Zealand and Malaysia. The Health and Safety Executive service dealing with occupational medicine has been the
Employment Medical Advisory Service. In 2014 a new occupational health organization, the
Health and Work Service, was created to provide advice and assistance to employers in order to get back to work employees on long-term
sick-leave. The service, funded by the government, offers medical assessments and treatment plans, on a voluntary basis, to people on long-term absence from their employer; in return, the government no longer foots the bill for
statutory sick pay provided by the employer to the individual.
United States In the
United States, President
Richard Nixon signed the
Occupational Safety and Health Act into law on 29 December 1970. The act created the three agencies which administer OSH: the
Occupational Safety and Health Administration (OSHA), the
National Institute for Occupational Safety and Health (NIOSH), and the
Occupational Safety and Health Review Commission (OSHRC). The act authorized OSHA to regulate private employers in the 50 states, the
District of Columbia, and
territories. It includes a
general duty clause (29 U.S.C. §654, 5(a)) requiring an employer to comply with the Act and regulations derived from it, and to provide employees with "employment and a place of employment which are free from recognized hazards that are causing or are likely to cause [them] death or serious physical harm." OSHA was established in 1971 under the
Department of Labor. It has headquarters in Washington, DC, and ten regional offices, further broken down into districts, each organized into three sections: compliance, training, and assistance. Its stated mission is "to ensure safe and healthful working conditions for workers by setting and enforcing standards and by providing training, outreach, education and assistance." Grants focus on small business, hard-to-reach workers and high-hazard industries. The National Institute for Occupational Safety and Health (NIOSH), also created under the Occupational Safety and Health Act, is the federal agency responsible for conducting research and making recommendations for the prevention of work-related injury and illness. NIOSH is part of the
Centers for Disease Control and Prevention (CDC) within the
Department of Health and Human Services. ==Professional roles and responsibilities==