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Posted By moshe Dyan
What are the main differences between their relevant legislation.
My understanding is that NI (not GB but UK) are only different in so much as EU Regs were implemented at a later date and HSE is HSE NI.
ROI I believe has it's H&S legislation based very closely on GB legislation with it's EU Regs basically being a copy of GB, even to matching their exacting standards.
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Posted By Martin Daly
All countries in the E.U. must comply with EU Directives. Each Country does this by bringing in Regulations that must comply with the Directives.
As all the regulations must comply with the same Directive all the regulations in all EU Countries are simular.
If there is a dispute this is resolved by comparing the different regulations with the original Directive.
About as clear as mud.
Martin Daly
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Posted By J Knight
ROI's getting a new law, which reading May's SHP will differ in some very important respects from UK law. NI, being part of the UK, follows UK law, though like Scotland there are important variations. IOM however is not in the UK, is an associate member of the EU, and when I was visiting on behalf of my previous employer risk assessments were seen as best practice (I think they have their own management regs now)!
John
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Posted By Fred Pratley
Your interpretation of how H&S law is applied is correct, there being abou 2 years time lag between England and NI/ROI implementation.
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Posted By Jay Joshi
ROI legislation, although having some similarities with the GB system is as such independent.
Why not look up at the respective websites of their regulatory bodies to get a feel of it??
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Posted By Karen Todd
Yep, we here in NI wait for GB to make the legislation, then we copy it almost word for word a year or two later.
Go to http://www.hseni.gov.uk and download the .pdf file of current legislation.
Regards,
Karen
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Posted By J Knight
Hi moshe,
Further to my previous post, I have in front of me the SHP article; the new law in ROI will almost certainly include, among other things;
A definition of H&S competence which goes further than that in MHSW
Spot fines for non-compliance
Safety statements
Drug testing
A statutory definition of 'reasonably practicable'
Commercial activities for the HSA in Ireland
The last one looks evry interesting,
John
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Posted By Christopher Kelly
Historically Eire legislation was the same as UK legislation. Since H&S@W Act UK Eire has continued to implement legislation almost exactly the same as UK but has also started to take pointers from US and other European states. Much legislation is still being implemented almost the same as UK. They use mainly UK and their own (Eire) ACOPS and guidance but also expect reference to BS and International Standards. It is a bit confused at that level.
NI is exactly same as UK
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