Every month, when I read the OSHA QuickTakes newsletter, there is one section that always stands out to me. Beneath the news of successful safety programs, training opportunities, and partnerships, there is a section titled Enforcement. OSHA publicly announces when they have levied a large fine or won a big settlement, making sure this is communicated to their audience of safety professionals.

Contrarily, OSHA's European counterpart, the European Agency for Safety and Health at Work (EU-OSHA) has a monthly newsletter that typically leaves out any similar enforcement section. They instead only include news about research they've conducted, awards for exemplary leaders, and information on continuous improvement of safety programs. While this is just one difference of a simple monthly communication, it is symbolic of the differences of how workplace safety is addressed in the United States versus Europe. US safety focuses on enforcement and compliance whereas European safety has equipping, educating, and empowering at its core.

Understandably, countries have diverse approaches to different safety problems. Climates, infrastructure, and demographics in each country are too diverse to have one standard that encompasses all. For example, based on some of these differences, the UK has a greater need to place their attention on work-related illnesses, whereas the United States deems it fit to put more emphasis on making sure management is aware of safety issues and their repercussions (Paton 2008).

At the same time, some other areas of Europe might benefit from this US approach. According to a 2008 article in Occupational Health, approximately "half of senior managers and company directors do not have an up-to-date understanding of their health and safety-related duties and responsibilities" (Paton 2008). It's safe to say that, despite our geographical and demographic differences, the US and the EU states could learn from each other when it comes to worker safety systems.

US Safety Standards

The Occupational Safety and Health Act was signed into law near the end of 1970 and created the Occupational Safety and Health Administration. OSHA covers almost all private sector employers and employees within the 50 states and other territories. In order to align with their mission of assuring safe and healthful working conditions for all people, OSHA focuses on three strategies:

• strong, fair, and effective enforcement
• education and compliance assistance
• partnerships and alliances with local governments and private sector (OSHA 2006) 

Per the 1970 act, OSHA has the power to both set and enforce health and safety standards (Ashford 1976). Beyond their public announcements of violators, they have had a reputation as an authoritative enforcement agency since its early life. For example, their "Safety and Health Management Guidelines" was initially written with an authoritative and compliance-based approach. As of this year, they have made strides to mimic similar guidelines from other countries as an information-based toolkit designed to educate and empower, rather than alarm and enforce.

European Safety Standards

Founded in 1994, EU-OSHA's main goal is to collect, analyze, and distribute information to those involved in occupational safety and health. They have a diverse amount of campaigns that enable them to research and raise awareness for different workplace health initiatives. EU-OSHA is an agency of the European Union. 

US vs. EU: Worker Fatalities

There is not always a definitive answer to what region is more effective at keeping their workers safe. One measurement often looked to as a baseline is the fatality rate of workers in the two different areas. According to a 2010 U.S. Bureau of Labor (BLS) study, the worker fatality rate in the U.S. is 3.1 fatalities per 100,000 workers. The same study indicated that the EU fatality rate is 2.8 fatalities per 100,000 workers (BLS 2014).

In the table below from the same BLS survey, we can see how different industries compare for this same metric.

 *Per 100,000 workers

Notice that the US doubles the EU's fatality rate for the agriculture, water supply, and transportation industries, and has a higher rate across the board aside from the professional and financial industries.

Due to the vast amount of tangible and intangible differences between these two regions, as well as the way the government agencies are structured and allocated enforcement power, it's difficult to pinpoint any specific reasons for the EU's lower worker fatality rate. However we can say that the approach of empowering workers with education and information is a viable way to address certain safety issues.

As you implement and improve the safety program at your workplace, keep this article in mind. Educating your workers on the hazards they are working with and giving them a sense of ownership of their coworkers' safety is a great way to receive buy-in at all levels. For help in creating a safety program that fits your workplace, visit our corporate accounts page to learn how we work with companies to keep their workers safe.

References

Ashford, Nicholas (1976) Crisis in the Workplace: Occupational Disease and Injury. Retrieved from https://books.google.com/books/about/Crisis_in_the_Workplace.html?id=fmuophZlMtgC

BLS (2014) Comparing fatal work injuries in the United States and the European Union. Retrieved from: https://www.bls.gov/opub/mlr/2014/article/pdf/comparing-fatal-work-injuries-us-eu.pdf

Paton, Nic (2008) Senior Managers Fail to Show Competence in Health and Safety. Occupational Health, Vol. 60, Iss. 3; pg. 6. Retrieved from http://connection.ebscohost.com/c/articles/31776188/senior-managers-fail-show-competence-health-safety

OSHA 2006 https://www.osha.gov/Publications/about-osha/3302-06N-2006-English.html

US Bureau of Labor Statistics 2014 https://www.bls.gov/opub/mlr/2014/article/pdf/comparing-fatal-work-injuries-us-eu.pdf