No health & safety regime is quite like Great Britain’s – but around the world, you’ll find a few unexpected rules to deal with. And if your company is operating there, they’re rules you need to know.
From the sensible to the simply strange, here are seven surprising ways that other countries’ health & safety laws differ from ours in the UK. For more, see our full guides to international health & safety.
1. American health & safety isn’t for everyone
Federal H&S law in the USA doesn’t cover everyone (though many state laws do).
Most surprisingly, it doesn’t apply to the public sector or to domestic workers – unlike in the UK, where it applies to just about all of us.
2. Human life has a set price in the UAE
If your company causes a serious health & safety error in the United Arab Emirates, be prepared to get your wallet out.
Unlike the UK, the UAE has the concept of diya, or blood money, baked into its H&S legislation. The cost of a human life is set at DH200,000 (around £43,500) – and a workplace fatality could mean the employer is liable to pay that out. Likewise, a smaller arsh is paid out for the loss of an organ, body part, or its functions.
You might also have to pay the cost of…
- treatment for work-related injuries and occupational diseases
- compensation to families of a deceased worker, equal to the worker’s basic wage for 24 months
3. You can’t work outside when the UAE is at its hottest
The UAE also has a midday break rule, which prohibits anyone from working directly under the sun between 12.30pm – 3pm during its blazing hot summers. It’s strict on working hours at that time of year too.
It’s not particularly surprising that the UAE has special summertime rules and the UK doesn’t… though perhaps we could have used them in 2018.
4. China has period drama
Here’s a rule we certainly don’t have in the UK: in China, women cannot be asked to work under certain conditions when they’re menstruating. Those conditions include working high above the ground, at low temperatures or in cold water, or anything involving hard physical labour.
5. Bullying is a health & safety issue on the continent
The UK recognises bullying and harassment as a serious issue in our employment law – but in a number of countries across Europe, it’s considered a health & safety issue too.
- In France, health & safety committees must propose actions to prevent bullying and sexual harassment
- In the Netherlands, bullying is considered a psychosocial hazard, due to the dangerous effects it can have on mental health
- The Republic of Ireland also identifies it as hazardous and dangerous in its H&S legislation
6. German companies aren’t liable
In German law, there’s no such thing as corporate liability. Companies generally aren’t prosecuted for health & safety breaches, and there’s no concept of corporate manslaughter.
However, businesses operating in Germany do have to answer to Betriebsrat, or works councils – elected bodies of workers’ representatives in companies. There’s no real equivalent in the UK. Betriebsrat have a say in all kinds of things (including the power to veto a worker getting fired), and look out for employees’ health & safety.
7. Spain’s a bit specific
Spain has specific occupational health & safety decrees that deal with particular industries or sectors. They include the national police, fishing vessels, electrical risks… and recruitment agencies.
For more in-depth guidance to H&S around the world, take a look inside the International Health and Safety topic in Croner-i Health & Safety. It offers a detailed look at the regimes in Australia, China, France, Germany, Ireland, Netherlands, Spain, UAE, and the USA, with more on the way from Canada, Hungary, India, Italy, Mexico, and Russia.