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Posted By Descarte
I been given the task of producing around 20 global safety guidelines on certain safety topics using our own UK and EU legislation as a background. I do however have to also accomodate USA, Asia, South America, Africa, Middle East and Australasia requirements all into the same topic.
I want to stay away from putting a foot note on all to say "Ensure you abide with all additional local customs, laws and regulations" as they probably wouldn't know themselves as not all sites have dedicated safety advisors, but don't think I could possibly research and read legislation for over 50 different countries on 20 different topics.
I do however guess that EU legislation will be more stingent than most and would encompass most of US legislation in to it as well. Note I am not required to include any exposure limits or details just general requirements and statements.
For example a driving policy - I know from experience that hailing a cab in the UK is not a major safety concern, but in africa, parts of asia and S-America caution should be aired, if not avoided using only preferred transport arranged through local clients or internal flights where required and driving with doors locaked at all times.
So I guess my fairly long winded question would be, has any one got any gems of knowledge and experience of internation law on such topics as: Electricity, Safety Signs, Change Control, COMAH/DSEAR over and above that required here in the UK.
Any snippets of information or direct links to relevent information would be most welcome, instead of just www.osha.gov
Many thanks
Des
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Posted By Kelvin
Des,
Firstly i wouldnt be assuming that any one continent has more stringent legislation than others. From experience i would say they are different and tend to focus on specific areas that the EU may have already considered or may have not.
Secondly, being a H&S Professional from Australia i can tell you that each state and territory in oz implement their own legislation. Thus creating 9 jurisdictions of H&S law. To help you with your queries in this area i would visit www.nohsc.gov.au which is a government funded organisation striving for a national standard. For specific states, that may assist you with you specific requirements you could try www.worksafe.vic.gov.au www.workcover.nsw.gov.au and workcover.wa.gov.au
Hope this helps
Kelvin
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Posted By Descarte
Thank you very much for your prompt response, I will certainly look at the guidance on controlling exposure to UV radiation and sunlight as I am sure AU will probably have best practice here, as well as documents I found on Noise, major hazard facilities, workplace injury and diease reporting and plant design as I am sure there will be some minor discrepancies.
Thanks again
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Posted By David Kimmins
Des
I agree with Kelvin, countries you may perceive to have less developed standards may have the strictest requirements on a particular issue. Again, some countries may have guidelines or requirements that you would find bizarre and refuse to follow. For example in Korea, fire escape routes are up to the roof. In Germany in larger buildings fire escape routes may direct you to the center of the building and then to a stairwell leading to an underground tunnel.
If you want something specific about a particular country please send me an e-mail and if it is one of the 15 countries I have responsibility for I may be able to answer it.
Otherwise on the Inetrnational Specialist group of this site there is a document for traveling safely internationally that is useful.
Here are some English Language sites for various countries HSE or IOSH org Equivalents.
Korea
http://www.kosha.or.kr/english/english.htm
Mexico
http://mhssn.igc.org/
Hong Kong
http://www.hkosha.org.hk/
Canada (you'll have to access each province)
http://www.sdc.gc.ca/en/home.shtml
USA
http://www.osha.gov/
Germany
http://www.hvbg.de/e/pages/
On the documentation you produce you should design it as the minimum standard and state that it is the minimum standard to be followed unless local code or regulations is stricter.
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Posted By Mike Draper
Descarte
I would have to agree with everything that's been said so far. We currently work in a number of countries in Western Europe and the Far East, but in the past have worked in North America, Eastern Europe, the Middle East, etc.
There is nothing so disheartening as thinking you know the requirements for construction, asbestos, fire/explosion, or any other topic you care to pick, especially since "it's all the same across Europe", only to find out that every workplace directive is implemented differently in each member state and that's before you start looking outside of the EC.
Some examples:
To remove asbestos insulation board in the UK you need a licensed contractor, a written method of work and submission to the HSE using form ASB5 with 14 days notice. In Eire, there is no licensing regime and the submission to the HSA needs 28 days notice.
At a construction site in the UK, you need a construction health and safety plan prepared by the Principal Contractor, but neither of these exists in Spain. In Spain each contractor prepares their own Health and Safety at Work Plan, to be checked/approved by the Health and Safety Co-ordinator. Spain is also complicated by it's municiple government structure.
In China you have to have a licence to carry out design work, that is be a local Design Institute. So even if you do all the engineering yourself, it has to be redone by the Chinese, to their standards and codes. Ironically of course, most Chinese standards are British Standards.
So there's a few titbits.
Mike
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Posted By Descarte
Excellent, it's nuggets like these I am after.
Much appreciated
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Posted By Jerry Lucey
Robens might be a good starting point as his report did not just act as a guideline for the Health & Safety at Work Act 1974. I know that Irish and Australian legislation also encompasses this approach.
It might be interesting to look at how Robens was interpreted in different countries/ continents and how the resulting legislation compares.
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Posted By Won
HI Descarte~
In Korea, there are some regulations and act related OSH.
If you come up to following link you can find some OSH Act/Regulations in KOREA.
http://www.kosha.or.kr/english/right2.htm
and, my company is trying to translate some standards related OSH in English, if you want them, I can send you the draft of them.
Have a good day~
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