A reference framework for health and safety in the workplace in China and the European Union: A comparative study

Abstract

BACKGROUND: Occupational Health and Safety (OHS) has a direct repercussion on the work, social and economic environments. The regulatory frameworks developed by each country are a basic aspect of OHS action policies. OBJECTIVE: This study analyses and compares the differences in OHS regulations in China and the European Union (EU) to identify weaknesses or gaps in the Chinese regulations. METHODS: Firstly, an overview of the OHS situation in the EU and China is carried out to provide context. Following this, a comparison of OHS regulations is conducted by searching different European and Chinese databases. The comparison focuses on several areas: socio-economic issues, accident rates, and the OHS regulatory framework. RESULTS: Since 1989, the EU has produced a broad and comprehensive OHS regulatory framework. Almost 30 years later, its positive impact can be seen in EU accident rates, indicating that this framework might be used as a reference for other territories or countries. China has a complicated system with over 280 OHS legislative regulations, in the form of laws, regulations, rules, integrated regulations, etc. that lead to a mixture and repetition of contents. CONCLUSIONS: The Chinese OHS legislation is still being constructed and complemented, since the two main Chinese OHS laws were approved during the last decade. This contrasts with the mature European framework, as it has been modified and completed over the years.