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GeeTee  
#1 Posted : 20 March 2020 15:50:44(UTC)
Rank: New forum user
GeeTee

Afternoon 

I work for a global company and currently deal with H&S for the UK, I need to map legislation across UK, US and Europe to look at standardising our approach to H&S where we operate.

I understand this will take some work but is there a source where I can map them easier, or is it a case of building a register in the UK then looking through the OSHA regs for the US and the EEC dirtectives for Europe?  

Thanks.

Kim Hedges  
#2 Posted : 21 March 2020 13:06:38(UTC)
Rank: Super forum user
Kim Hedges

Basically there isn't and pragmattically there can't be, because OSHA under USA law is a series of directive by the Federal Government.  Whilst EU Law is also Federal and a series of directives, all the the local 26 countries have their own laws and adapt the EU law to their own version (or ignore it - it seems).  UK law is split into Scotish Law, English and Welsh Law and Northern Irish Law.  All these laws are very similar, as you know, but with minor differences.  I think the biggest hurdle is case law, where under English law safety legistlation tends not to be appealed at all, as the court system accepts that the safety law was broken and so a penalty must be made.  Whereas is appears under USA Federal Law and OSHA, companies can and do break the US laws, get prosecuted and are then allowed to appeal the decision of the court and often reduce or walk away without paying reparations to the Country or individuals.  This is why companies operatoring tend to zero in on one type of law.  I used to work for KBR in Iraq, so I was goverened by OSHA laws, even though I am British, working in a war zone in Iraq (who have their own laws) and for an American company.  

Kim Hedges  
#3 Posted : 21 March 2020 13:10:25(UTC)
Rank: Super forum user
Kim Hedges

Incidentally, it is now EEA not EEC, European Economic Area, but commonly talked about as the EU, Economic Union.  

GeeTee  
#4 Posted : 24 March 2020 10:19:56(UTC)
Rank: New forum user
GeeTee

Thanks looks like it will be a task managing it.

I'm thinking of looking at top level investigating the hazards the business has as the work is same in each operating area. Formlating a register of them using the local directives and have the local management deal with the respective law through their legal sections. Does that sound achievable to you?

A Kurdziel  
#5 Posted : 24 March 2020 11:23:16(UTC)
Rank: Super forum user
A Kurdziel

I think that the hazards are the same the world over and the activities’ are similar so are the risks associated with those hazards. You should be able to produce a global risk profile but diferent parts of the world will have different approaches to managing the risk

Look at this article about how the OSHA manage H&S in the US https://www.shponline.co.uk/global-legislation/occupational-health-and-safety-in-the-usa/

It’s very different approach from what is done in Europe. They don’t use risk assessment but rely more on prescriptive advice from OSHA etc.

So in the US it’s about creating the right checklists and making sure that everything is covered while here RAMS are what it is about.  If you were to insist on RAMS in the US, you might be putting your business at a disadvantage with its local competitors, while if you took the American approach in here you might end up being prosecuted.  Trying to make a one size fits all approach might be tricky.

 

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