Hi Safe AS

Five nations, three legislative regimes for occupational health and safety.

So, one for Great Britain.

One for Northern Ireland

One for the Republic

Until such time as some in the Conservative Party get their way with a "bonfire" of health and safety regulations, the practical implications of the three regimes are largely the same.

Great Britain has a much larger population than NI or the Republic so each tends to let the big brother take the lead in developing new legislation.

So, if there are new Regulations, NI usually follows a few months later and the Republic does the same though generally giving the Regulations a different title where the word Safety precedes Health in line with the European model.

But the overall content of those Regulations is generally largely the same with the odd exception e.g. where the Republic's method for tranposing the EC Temporary or Mobile Construction Sites Directive remains closer to the wording of the Directive than the way GB and NI have transposed TMCSD via CDM and CDM NI.

But as regards your new premises in or near Dublin if you apply the requirements of e.g. the Workplace (Health, Safety and Welfare) Regulations 1998 you won't go far wrong. One thing that WILl be different is incident reporting requirements, partly due to a previous bonfire in the UK.

But each of three legislative regimes has primary legislation - Acts in GB and the Republic and an Order in NI (enabled by HSWA) which introduced three enforcing authorities - HSE, HSE NI and HSA - and provided for regulations to be made under the primary legislation.

Most recent regulations have been driven by EC Directives.

Personally I doubt that there will be much of a bonfire in the UK - the Working Time Regulations 1998 will probably go, partly as the UK was strongly opposed to the parent Directive and transposed the Directive by means other than HSWA. Also I suspect that CDM might go.

P