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#1 Posted : 09 May 2006 15:34:00(UTC)
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Posted By danielmurphy1985 There is a proposed large Rest Home being built and a site has been chosen in the UK, however, there is still a chance that it will be constructed somewhere in Europe. Could anyone tell me the difference between relevant legal principles and requirements & health and safety principles between the UK and Europe. I know there may be many, but i am only interested in the main factors (although any info would be much appreciated). Thankyou in advance D. Murphy
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#2 Posted : 09 May 2006 18:47:00(UTC)
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Posted By Paulo Dinis Hi Murphy, I had to read your post 3 times, "main factors" might be too "macro" for that kind of “benchmarking”. Considering you can have a word to say about the final project location, as for in the “decision making process” my guess it that H&S issues don’t have a huge weight on total cost. I would say that’s mostly secondary, important but not relevant. You need a “micro” approach to considerer the H&S issues, both for the building itself and for worker’s and user’s. Still let me try to give you a quick input. As far as my knowledge there isn’t any European Directive concerning this kind of establishments. There for all legal aspects of H&S are determined by each State Member. In Portugal we have specific legislation concerning the "licensing" of such spaces. Who knows you speak Portuguese so let me post an website here http://www.consumidor.pt...&plingua=1&pmenu_id=1033 That’s a link for a consumer website so you can trust the info there. I´ve done in the past several audit’s and safety inspections to those kinds of establishment, using basic checklist’s (i´m sure you H&S folks also use it in UK) in order to asses the “legal conformity”. Main issues cover physical aspects of buildings, as well as accessibility aspects. All should be covered and taken care in the Project stage. Besides that, there is technical staff that has to be present and to conduct supervising activities. Leisure’s activities should also be planned by law. I´m sure the requirement of 150 lux in bedrooms’ is not too demanding right? “Micro approach” again. As you should be aware, many thousands of French retired are choosing to move to Morocco in order to have better quality of live they couldn’t have in France. The fact most people speak French there also helps. Many retired from North Europe have chosen Spain in the past. There is a famous retired "land" in Spain called "Costa del sol" sea side, with many Rest Homes there but local regulation is very very negative ( people see their lands being ripped off and many UK´s that bought some flat, villa or farm there are now disgusted about this situation ). There even was some media coverage about this issue. Still there are Norwegian Rest Homes supported by Norwegian social welfare in that area of Spain. Just as a suggestion, considerer the state member Portugal for a possible destination. Weather is interesting; cost of live is appealing for English retired, technical staff cost is under UK standards, construction is also under UK price’s, English is spoken here and there is fiscal treat’s between Portugal and UK. Current Government is now taking some measures in order to "capture" this kind of investment’s. We do have exceptional conditions for successful projects in that field. There is however a catch, time to process all legal procedures is very often too high here ( burocratic ). Still the retired community from abroad is increasing here, and places like Alentejo have lot’s oh Dutch, Swiss’s etc that comes here as personal and private projects. As far as health and safety requirements for workers, there is National legislation that arises from the main European H&S Directive. Again that’s not a major “cost aspect” in this kind of project. Hope this help. Paulo Dinis H&S Manager Portugal. www.paulodinis.com www.shstonline.com
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#3 Posted : 10 May 2006 09:38:00(UTC)
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Posted By Jerry Lucey Goodmorning Daniel, Legislation is very similar throughout the EU, however there are subtle differences in how Directives are enacted by member states. Looking at CDM and the Irish Construction Regulations is the allocation of duties i.e. between the Planning Supervisor and Principle Contractor in the UK and the Project Supervisors Construction and Design Stages in Ireland. The duties are the same, just allocated differently. The main thing is not to be phased by different legislation as when you delve deeper the similiarities will become apparant.
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#4 Posted : 10 May 2006 10:00:00(UTC)
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Posted By Mike Draper Daniel Good luck. Seriously though, the main H&S legal principles are the same across Europe. Sticking to the "vanilla" Framework Directive and then moving through the various workplace directives you won't go far wrong with compliance anywhere in Europe, including construction. The tricking bit is picking up on some of the nuances. Notifications vary depending on the local government structure and aside from the local cultural differences, there will always be little surprises in store like the trend in some countries to insist on particular qualifications or comeptencies for certain tasks. E.g. the asbestos licensing regime in the UK or the safety practitioner requirements of Spain. I suggest looking at http://osha.europa.eu/OSHA This provides a useful resource to check out the different regimes across Europe. Mike
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#5 Posted : 10 May 2006 23:48:00(UTC)
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Posted By Paulo Dinis Wow ! Am i that off the discussion ? Where you asking about the construction stage or in the utilization stage ? When only covering the Construction phase there is the Council Directive 92/57/EEC of 24 June 1992 on the implementation of minimum safety and health requirements at temporary or mobile construction sites (eighth individual Directive within the meaning of Article 16 (1) of Directive 89/391/EEC) Maybe my english is not god enought to understand the true scope of the question asked.... Paulo Dinis H&S Manager Portugal
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