Posted By BOD HI All, Would anyone have a definitive list of key differences in the UK and Irish legislations. I appreciate that this may not be that many but it would be a handy thing to have. Thanks

Posted By Bob Shillabeer Have you tried looking at the Irish web pages

Posted By anon1234 Are you refering to Northern Ireland or Eire?

Posted By DRB if it's H&S law your after try the HSA website

Posted By Tracey Kelly There aren't many real differences in the content of the Regulations - they are mostly derived from the same EU Directives and best practice, anyway. As a gross generalisation and simplification, the UK brings an EU Directive into law, with Guidelines and a handy acronym. A year or so later, Ireland brings in almost-identical regulations, with minor changes for local palates - and a different name. This isn't really surprising, given the relative sizes and budgets of the HSA and HSE. Where there isn't clear guidance or standards within Ireland, you should use the British or other European standards (or even American in the case of some technical safety issues such as relief valve sizing). An example would be the Seveso Regulations in Ireland, and the CoMAH Regulations in the UK. In the UK (as with about half of the EU member states) the CoMAH regulations are risk-based, whereas Ireland chose to go along the consequence-based route. However, you are still expected to be up to date with the HSE guidance and approaches to particular issues such as bund over-topping and Buncefield. Also, sometimes Irish courts will look to British case law when considering new issues (such as stress), as their size tends to mean that problems are tackled in the UK before they become an issue here. You really need to read the relevant Irish legislation to find out the detail and spot any particular differences (or vice versa). The Irish statute book http://www.irishstatutebook.ie/front.html is a good source of current Regulations and Acts, but it isn't always up to date. The HSA web site http://www.HSA.ie is also useful. You need to be careful, though, as the regulations aren't always exact equivalents - e.g. the six-pack in the UK, and the General Application Regulations in Ireland, or CoSHH & DSEAR in the UK and the Chemical Agents Regulations / Biological Agents Regulations / Carcinogen Regulations in Ireland. Another word of caution- where there is a difference between Scottish and English/Welsh Regulations(such as building standards), the Irish version will tend to be the same as the English version. Which leads me on to the next caveat - Irish Law is similar to English Law, and not Scottish Law - worth remembering if you are used to the Scottish system. My final word - remember that although there are many similarities, it's a different country, with different laws and attitudes and different ways of applying the same rules - although best practice remains best practice wherever you are.

Posted By thomas satelle There are a lot of major differences in relation to UK and irish legislation UK 1974 Safety act ( from ruebens commission ) IRL 1989 Safety act ( from barrington commission ) now 2005 act EU Framework directive 89 / 389 Transposed into irish law with a plethora of regulations- such as S.I.299 ( applications regulations) S.I. 504 construction regulations S.I 218 confined space regs- UK management of health and safety regs ( 6 pack) similiar to our regs Visit the The irish health and safety website WWW.HSA.ie- similiar to HSE site tom

Posted By Ian Mitchell Hi Tracey, Can't speak for Bod, but my reason was to make life easier. We are the UK arm of an Irish company. The Irish company have an Integrated Management System for the three ISO's that is very good. However, it is set up for RoI (not Eire- sorry!) terminology and we basically 'piggy back' it over here. Rather than have two parallel management system documents with therefore twice the work I suggested we leave the Irish stuff in and have a reference table for the differences. As has been said, it is mostly terminology as they all come from the same place (Brussels!). Something along the lines of 'Irish Regulation' 'English equivalent' and 'Notable differences'. So, it does serve a purpose and is not just an academic exercise. Regards

Posted By Tracey Kelly I agree with BOD, I would have two sets of documentation - one for each jurisdiction. It shouldn't take much time for someone with an understanding of each to go through the Irish version and amend it for UK use, and it will be easier to maintain each independently of the other as regulations are amended. It may also be possible to "sanitise" the Irish SMS to refer generically to the requirements without being specific about the particular Regulation name/number/requirement. Each version would need regular review for regulatory changes, anyway. If necessary, checklists, permits, forms etc. can be particular to each jurisdiction rather than the main body of the SMS. Some large multinationals maintain databases of all EHS legislation in each jurisdiction, but these are expensive to set up and maintain. They can also be bought in. I also agree that some HSA inspectors can, without irony, get upset about references to CoSHH, for example, then in the next breath tell you that they expect you to use the HSE web site and the BSI for reference.