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#1 Posted : 24 February 2005 09:12:00(UTC)
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Posted By Rob Diss Hi, I am wondering if there are any H & S practitioners in the following geographical areas, Nordic region, France, Holland, Germany, Copenhagen & Australia. If so, I would like to speak regarding any local H & S laws. As a rule of thumb, am I correct in applying UK laws to ALL my companies overseas offices inorder to secure employees health/safety etc?
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#2 Posted : 24 February 2005 09:17:00(UTC)
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Posted By J Knight No, you are not correct, and you have to be careful. You should of course apply UK standards where it meets or exceeds local ones, but do enure that local standards are not better (or even entirely different) to UK ones. France for example has a very different H&S regime to the UK, and Scandinavian countries sometimes set higher standards than we do, John PS Can't remember right now where the EU directive which will apply source country standards to ex-pat employers got to, but even if it is already law (and I don't think it is) some of the states you mention are not in the EU.
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#3 Posted : 24 February 2005 10:40:00(UTC)
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Posted By Rob T Hi, If you go to the IOSH International specialist group site (see on left specialist groups) you will find some of the legislation concerning some of these countries. As a rule of thumb sticking to the spirit of UK law may help but you really need to use the local criminal H&S laws as a minimum base-line. You mentioned Oz - they have different laws for each state. They also (in NSW at least) have regulations requiring clear plugs just as an example. If you're intending to work in these countries I would suggest that you do look at their laws in some detail. The EU countries are easier as they are all SUPPOSED (yeah yeah!) work to deriritives of the six-pack and other associated directives that we use in the UK. You seem to be working in the International field - have you thought about joining the IOSH International Specialist Group? It is a very proactive group and for the benefit of others - we will have a stand at conference this year - do pop over and have a word. Cheers ROB Todd
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#4 Posted : 24 February 2005 11:04:00(UTC)
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Posted By Adam Jackson My last job was similar, we had sites in the USA, France, UK, Germany, Italy, Poland plus other wider-flung places such as Indonesia, Brazil and Venezuela. I adopted the policy of taking whichever country had the strictest legislation on a particular risk area and using that as the minimum corporate standard. Its not as easy as saying "x country is the strictest so we'll use that" as the leading country changed depending on the issue being looked at. And to complicate it further, there are cases where you need to exercise some judgement and occasionally allow differing standards. I don't mean expose someone to a life threatening situation in one country but not in another, but often smaller issues can hit cultural problems. For example, in the US if you use formaldehyde you have to put a "warning, cancer hazard" sign on the door to the room. If we'd done that in France nobody would have stepped foot in the room. Similarly, in the US if you have a microwave in a staff kitchen, you need to have a "danger, radiation hazard" sign on the canteen door - can you imaging putting that on a canteen door here? (Cue "h&s gone mad comments, etc.). We used the UK scaffolding standards, but oddly enough these didn't cover the Indonesian method of cutting some bamboo from the jungle and making a scaffold out of that - we had to permit that as there was no 'proper' alternative.
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