Abstract: The development and application of health and safety laws in a country depend on several aspects including, in particular, the historical development of the legal system and laws in the country concerned and the impact of the international and supranational laws and regulations. Since the European Community has a common legal framework, it is tempting to conclude that health and safety laws in the Member States should be the same. However, there are some significant differences in the application of the law. For example, the enforcement practices vary from country to country and different liabilities can be imposed on the employer for breach of the statutory requirements. Four areas of health and safety law, that is employer’s duties and responsibilities, enforcement, liability and sanctions will be considered in this article in three Member States: Germany, Sweden and Finland, with a comparative perspective in relation to the United Kingdom.
International Journal of Comparative Labour Law and Industrial Relations