Jacqui, I'm a German HSW Adviser with experience in the UK Sector. As far as I'm aware there is no documentation available which explains the differences between UK and German Legislation. You will be able to find all of the German Legislation on the following websites: www.dguv.de & www.baua.de Unfortunately most of the information is in German. You will possibly need to utilise a local consultant. Let me know if you would like to discuss offline. Manny

Holmezy's observation chimes with section 6 of the report by Ragnar Loftstedt. He not only confirms the problem of different interpretations but also highlights 2 basis sources worth bearing in mind. These are: a. differences in language - he comments that his own native language, Swedish, has no word for 'risk' and that a survey of German business people indicated that 80% didn't recognise the difference between 'risk' and 'hazard' b. methodological shortcomings in Impact Assessments of regulations His proposed remedy is much more rigorous scientific implementation of regulations. If you wish to consider this approach, the Ergonomic Guidelines published for a modest price by the International Labour Office can help with your enquiry, as ergonomics is simply a science-based method of designing and evaluating work.

Thank you so much to those who have responded, thankfully have a little bit of time but it looks like I'm going to need it to do some reading ! I can't believe we are the only ones coming against this problem when dealing with international companies. Happy Christmas everyone

Jacqui, are your audits going to be looking at legal compliance or at the effectiveness of a H&S regime? If the latter then a wet floor in Germany is not different in outcome to a similar one in France or UK. Likewise, the manual handling of boxes transcends national boundaries. Maybe you could decide on the top few causes of accidents or occ. ill-health in your industry and focus on the way these are managed across your business. You say your audits are to be basic. Given that it seems to me that trying to grasp the subtle (and sometimes glaringly obvious) differences in national interpretation of Directives may not be necessary.