A reference framework for health and safety in the workplace in China and the European Union: A comparative study

Abstract

BACKGROUND:

Occupational Health and Safety (OHS) has a direct repercussion on the work, social and economic environments. The regulatory frameworks developed by each country are a basic aspect of OHS action policies.

OBJECTIVE:

This study analyses and compares the differences in OHS regulations in China and the European Union (EU) to identify weaknesses or gaps in the Chinese regulations.

METHODS:

Firstly, an overview of the OHS situation in the EU and China is carried out to provide context. Following this, a comparison of OHS regulations is conducted by searching different European and Chinese databases. The comparison focuses on several areas: socio-economic issues, accident rates, and the OHS regulatory framework.

RESULTS:

Since 1989, the EU has produced a broad and comprehensive OHS regulatory framework. Almost 30 years later, its positive impact can be seen in EU accident rates, indicating that this framework might be used as a reference for other territories or countries. China has a complicated system with over 280 OHS legislative regulations, in the form of laws, regulations, rules, integrated regulations, etc. that lead to a mixture and repetition of contents.

CONCLUSIONS:

The Chinese OHS legislation is still being constructed and complemented, since the two main Chinese OHS laws were approved during the last decade. This contrasts with the mature European framework, as it has been modified and completed over the years.

Keywords

Occupational health and safety UE comparison regulatory frameworks

1 Introduction

Occupational Health and Safety is an important goal for countries, given its direct repercussion on work, social and economic environments. According to the International Labour Organization [1] each year approximately 2.02 million people die from work-related diseases and 321.000 die in workplace accidents. A worker dies from a work-related accident or disease every 15 seconds. The same source indicates that four percent of the world’s gross domestic product (US$ 1,251,353 million) is lost due to injury, death and disease. This estimate includes absence from work, healthcare treatment, disability and survivor benefits.

The regulatory frameworks in each country are extremely important when managing the basic principles of a society, including the physical well-being of its workers. According to McKinlay [2], in the area of Occupational Health and Safety (OHS), one piece of effective health legislation is equal to many separate health interventions and the cumulative efforts of innumerable health workers over long periods of time. However, OHS laws cover only about 10 percent of the population in developing countries [3].

Pybus’ model [4] postulates that safety culture starts with a traditional phase where rules dominate, although they have limited effectiveness. However, a well-developed and solid regulatory body is necessary to reach the transitional phase, where there is an emphasis on the importance of engineering controls and safety management systems. Lastly, the innovative phase is reached where people are key elements and their behaviours become crucial to improve safety performance.

For many years, the European Union (EU-28 1 ) has been drawing up a regulatory framework and creating management tools to reduce accidents in the workplace in all of the member countries. The European Framework Directive on Safety and Health at Work was published over 30 years ago and the EU now has a mature regulatory system. This framework has contributed to instilling a culture of prevention throughout the EU that could be a model for other countries. In contrast, China has a regulatory framework that is barely known in the Western world due to its different social system, the language barrier and large cultural differences. The system has undergone broad changes, but not all OHS issues have been sufficiently regulated. Moreover, when regulations do exist they are often not followed [5]. Chang et al. [6] indicate that 80%of workplace accidents are caused by infringing regulations or work rules. Investigations and the subsequent administrative and judicial penalties are significantly affected by legal, business and industry pressure, as well as media attention [7].

However, given the high costs of workplace accidents, and after some significant incidents in recent years, the Chinese government has shifted its focus to safety management [8]. Proof of this is China’s Thirteenth Five-Year Plan (13th FYP - 2016–2020) [9], which includes targets for analysing current safety conditions in the workplace.

This work briefly analyses workplace accident rates in the EU and China to identify the regulatory framework for Occupational Risk Prevention (ORP) in both communities. It analyses, classifies and compares regulations to raise awareness regarding the Chinese OHS regulatory framework and to identify possible weaknesses in the Chinese regulatory systems. Finally, this work is a source of OHS regulatory information in both China and the EU that can be used by international companies.

2 Methodology

Firstly, context is provided for the situation in the EU and China and two important aspects are highlighted. On the one hand, an analysis is conducted of workplace accidents in the EU and China and the problems they present. On the other, the importance of migrant workers and their impact on OHS in a globalized world is examined. Subsequently, the OHS regulatory frameworks are studied after performing extensive searches in European and Chinese databases.

Examples of EU websites included in the searches are:

Eur_Lex, European Union Law [10].

Harmonised standards. European [11].

In the case of China, a large number of websites have been searched:

Chinese Laws and Regulations on work safety and occupational health [12].

Construction industrial standards (JGJ) [13].

National standards (GB) and recommendatory standards (GB/T) [14].

National standards specifically on occupational health (GBZ) [15].

Work safety industrial standards (AQ) [16].

The regulations were identified, classified and analysed to detect possible equivalences. The issues not addressed in those regulations considered equivalent have been identified to highlight any gaps.

3 Context

3.1 The current occupational health and safety situation in the EU and China

Comparing accident rates in the EU and China is a complicated task. Due to the enormous difference in population –in 2015 [17], there were 1376.0 million people in China and 505.2 million in the EU–it has been necessary to use statistical indicators for the at-risk population (normally Incidence Rate, rate per 100.000 workers). In international databases [18, 19] these values are not available for all countries and international criteria have not been defined to compile accident rate data to permit objective comparisons [20 –22]. The description of the statistical systems for each country provided by the International Labour Organization [23] shows that many factors influence the data provided on workplace accidents. For example, the source of the data my vary from country to country (private insurers, public services, etc.), not all countries include occupational illnesses or accidents that take place on the way to and from work, there are variations in the maximum deadline for reporting an accident-related death, etc.

The EU provides harmonised data - correcting the differences in the accident register in each member country [24] –both for fatal accidents and non-fatal accidents at work from all professional activities. The Incidence Rate values can be consulted [25] and comparisons can be made that consider how the active population is changing. This official data indicates that the EU accident rate has been falling over the last few decades [25 –27]. A downward trend of 25%in work accidents was observed between 2000 and 2006 according to the harmonised data on workplace accidents [28].

In China, the National Economic and Social Development Statistics Bulletin 2008–2017 [29] does not provide data on non-fatal work accidents despite the fact that light injuries are a cause of concern and are very frequent and costly [30, 31]. In addition, the available Incident Rate for fatal accidents only refers to accidents in mining and trading and does not include fires in the areas of production and operation, roads, water and rail transportation, civil aviation, agricultural machinery, fishing vessels, etc.

On the other hand, some authors highlight the low reliability and transparency of the Chinese statistics [22, 32]. They also indicate the poor suitability of the statistical indicator system, the data sources, and the poor auditing and organisation of the processes used to report and present accidents, or to collect and process the data [30 , 34].

Despite the above, recent studies do analyse workplace accident data in China, although they do not provide absolute values for accidents, and variations in the active population are not considered. Wang et al. [35] show how the number of accidents and deaths in China has dropped between 2001 and 2015, with 72.57%fewer accidental deaths and 49.28%fewer non-fatal accidents. Along these lines, Ma & Zhao [8] state that the frequency of workplace accidents in China is much lower than in the past, although it is still higher compared to many other countries.

Despite these limitations, it can be generally stated that accidents in the workplace have fallen in both China and the EU.

3.2 Migrant workers (rural workers vs immigrant workers)

Globalisation has brought with it a rise in immigrant workers and poses a special challenge for OHS throughout the world that requires special attention [36, 37]. Not only is it difficult to incorporate into the job market massive numbers of immigrant workers with inappropriate skills and a poor knowledge of preventive measures [38], but a large cultural and social divide [39, 40] and even linguistic barriers [41] must be addressed. Furthermore, the number of undocumented workers is high and records are scarce [42, 43]. Their dire economic situation, illegal status and limited knowledge of their rights forces workers to accept jobs that endanger their welfare [43, 44].

In China, migrant workers do not come from other countries but from the least developed and industrialised areas of the country, particularly rural areas. Most of them do not have the urban Hukou 2 in their host city, which can make it difficult for them to attain the same rights to employment, education, housing, healthcare, and social services as local workers [45].

Between 1949 and 1978, rural areas received a great deal of attention, with a focus on health issues as this represented a serious threat to the health system. For example, mosquitoes could transmit malaria and contaminated food and water could cause cholera, typhoid and diarrhoea [46]. At present, the problem is the large rural population that is moving to urban areas. These people receive low wages in lower-status jobs that require less technological knowledge and a high level of physical effort [47, 48]. In addition, this separates families, which causes discrepancies between expectations and reality [49] and results in both physical and mental problems that lead to poor living conditions [45, 50].

In 2015, the working population in China was estimated to be almost 775 million people [51], including 277 million migrant workers [52] that shared characteristics such as poor educational level and insufficient work qualifications, training and experience [53]. According to the Migrant workers survey research of China [54], 76.4%of the rural workforce has not received any type of professional training. The same source indicates that migrant worker are involved in more than 80%of the fatal accidents each year.

The Chinese government pays a lot of attention to migrant workers and their situation but there is still no focus on OHS.

4 Results

4.1 Comparison of the OHS legal framework for China and EU-28

Over the last 20 years, industrialisation in China has been on the rise, along with its associated risks. China’s OHS regulatory system has been trying to make suitable adjustments and even reforms to deal with these changes [55].

The government has passed a range of laws, regulations, and decrees that regulate workers’ rights and health and safety (H&S) protection [56], with the understanding that a well-structured regulatory system will have a positive effect on reducing the occupational accident rate as concluded by a variety of authors [26 , 57].

Chinese authors have looked at the Chinese OHS regulatory system and have compared it with other countries (i.e. [58 –61]). Many of these studies have focussed on the mining sector, for both coal and other materials (i.e. [62 –64]).

The international literature comparing regulations in China and other countries is, however, very limited. Studies can be found that compare the laws and administrative structures for occupational safety and health between the United States and China [65] and comparative studies that also focus on mining safety [66, 67]. A variety of authors have made comparisons of some specific aspects in the OHS field, such as risk assessment, compliance with regulations, OHS training, occupational exposure limits, etc. [68 –70]. Recently, Liu [71] compared the characteristics of legislation from a few selected countries (EU, China, The Netherlands, Norway and United Kingdom), the main methods for regulating OHS in the workplace and the role of the different stakeholders. However, no detailed comparisons exist of OHS regulations in the EU and China that could be used to provide feedback regarding the Chinese regulatory framework.

The EU’s general strategy has consisted of drawing up legal-technical regulations, known as Directives, that the Member States must transpose into national legal rulings. The impact of this legal framework on accident rates in EU countries has differed, but in general it has been positive [26].

The EU’s current OHS legislation is contained in:

Council Directive 89/391/EEC of 12 June 1989 on introducing measures to encourage improvements in workers’ health and safety in the workplace (Framework Legislation, modified by Directive 2007/30/CE). This directive has been completed with twenty Individual Directives (see Table 1).

Other Directives that contain detailed OHS provisions relating to professional activities (healthcare on ships) or specific groups of vulnerable persons (temporary workers or young workers).

Table 1
Twenty individual directives

Year Number Individual directive

1989 1st Workplace

1989 2nd Equipment by workers at work

1989 3rd Personal protective equipment

1990 4th Manual handling of loads: back injury to workers

1990 5th Requirements for work with display screen equipment

1990 6th Exposure to carcinogens at work

1990 7th Exposure to biological agents at work

1992 8th Temporary or mobile construction site

1992 9th Signs at work

1992 10th Pregnant workers. Workers who have recently given birth

1992 11th Mineral-extracting industries through drilling

1992 12th Surface and underground mineral-extracting industries

1993 13th Board fishing vessels

1998 14th Exposure to chemical agents at work

1999 15th Explosive atmospheres

2002 16th Physical agents (vibration)

2003 17th Physical agents (noise)

2004 18th Physical agents (electromagnetic fields)

2006 19th Physical agents (artificial optical radiation)

2013 20th Physical agents (electromagnetic fields)

Year	Number	Individual directive
1989	1st	Workplace
1989	2nd	Equipment by workers at work
1989	3rd	Personal protective equipment
1990	4th	Manual handling of loads: back injury to workers
1990	5th	Requirements for work with display screen equipment
1990	6th	Exposure to carcinogens at work
1990	7th	Exposure to biological agents at work
1992	8th	Temporary or mobile construction site
1992	9th	Signs at work
1992	10th	Pregnant workers. Workers who have recently given birth
1992	11th	Mineral-extracting industries through drilling
1992	12th	Surface and underground mineral-extracting industries
1993	13th	Board fishing vessels
1998	14th	Exposure to chemical agents at work
1999	15th	Explosive atmospheres
2002	16th	Physical agents (vibration)
2003	17th	Physical agents (noise)
2004	18th	Physical agents (electromagnetic fields)
2006	19th	Physical agents (artificial optical radiation)
2013	20th	Physical agents (electromagnetic fields)

In addition to these specific regulations, the European Commission publishes Harmonised Standards. Manufacturers, other economic operators, or conformity assessment bodies can use harmonised standards to demonstrate that products, services or processes comply with the relevant EU legislation. Although standards as such are voluntary, complying with them proves that your products and services have attained a certain level of quality, safety and reliability [11].

Finally, it should be highlighted that many products require the CE marking to be sold in the European Economic Space (EEE), which is made up of the EU, Iceland, Liechtenstein and Norway. The CE marking is an indicator that the product has been assessed and meets all EU health, safety and environmental protection requirements. The CE marking should be used for machinery, electrical equipment, collective job site protection and even personal protective equipment, even if it was not manufactured in the EEE. In the same way, there are EU regulations for manufacturing or importing certain chemical substances in quantities equal to or greater than one tonne per year. These substances should be recorded in the REACH database [Registration, Evaluation, Authorisation and Restriction of Chemicals) [72].

In China, according to an article from the Chinese Association of Work Safety [73], since the foundation of the People’s Republic of China 50 years ago, over 150 legislative OHS or related laws, regulations and rules have been published and are in force (not counting regional regulations). At the same time, hundreds of OHS standards have been formulated and officially published.

The Chinese OHS regulatory framework is made up of:

Two main laws: 1) the Law of the People’s Republic of China on Prevention and Control of Occupational Diseases [74], modified in 2011 and 2016, regulating safeguards for work safety of business entities, the rights and obligations of employees in work safety, the supervision and administration of work safety, emergency rescue, the investigation and handling of work safety accidents and legal liabilities, etc., and 2) the Law of the People’s Republic of China on Work Safety [75], modified in 2009 and 2014, regulating early prevention, protection and management during the labour process, occupational disease diagnosis and safeguards for occupational disease patients, supervision and inspection and legal liability.

Specific OHS laws for certain sectors: the Mining Safety Law (1992), the Fire Control Law (1998), modified in 28/10/2008), the Road Safety Law and the Emergency Response Law (2007);

OHS administrative regulations: Regulation on Work Safety Licenses (2004, modified on 29/07/2014), Regulations on the Administration of Safety production in Construction projects (2003), Regulations on Labour Protection in Workplaces Where Toxic Substances are used (2002), etc.;

Departmental rules regarding OHS: i.e. Provisions on the Supervision and Administration of Occupational Health in the Workplace (2012), Administrative Measures for Fishery Seamen (2014), etc.

The OHS compulsory standards. There are also voluntary standards recommended by the state.

The regulations for the Implementation of the Standardization Law [76] provide detailed regulations on compliance with the standards and the field of application for compulsory standards, including OHS standards. According to the document Measures for the Administration of National Occupational Health Standards [77], the standards are divided into 9 categories, with 5 of them being compulsory: 1) workplace conditions; 2) occupational exposure limits for industrial toxicants, dust from production, and physical factors; 3) occupational disease diagnosis; 4) occupational radiation protection; 5) occupational protection products. The mandatory standards can also be classified into two groups: provisional mandatory standards, in which only some clauses are mandatory and full text mandatory standards that are completely compulsory. Both of them are considered as mandatory standards in the Chinese legal system.

With regard to the field of application, both the Standardization Law [78] and Regulations for the Implementation of the Standardization Law [76] point out that the standards can also be divided into national, industrial, provincial and business standards 3 . Compulsory standards play an important role in the regulation system and stakeholders are legally liable in case of non-compliance. Furthermore, the 17th article of the Work Safety Law [75] and the 14th article of the Law on Prevention and Control of Occupational Diseases [74] also specify compulsory compliance of relevant national and industrial standards for work safety and occupational health, respectively.

In 2017, China proposed a bill to modify the Standardisation Law, taking into account the excessive number of standards. When searching for standards, it was found that all EU standards are on one website [11], whilst the Chinese standards mentioned in this article mainly come from four websites [13 –16] and some are even repeated on different sites.

This paper will only include national standards that are completely or partially compulsory.

4.2 Comparison of specific OHS regulations

As we mentioned in section 3.2, the specific OHS regulations in the EU are contained in a Framework Legislation and twenty Individual Directives. Table 2 shows their equivalence with Chinese standards.

Table 2
Framework legislation

EU Council Directive 89/391/EEC of 12 June 1989 on the introduction of measures to encourage improvements in the safety and health of workers at work.

China Work Safety Law (2002). Modified by the National People’s Congress Standing Committee in 27/08/2009 and 31/08/2014.

Law on the Prevention and Control of Occupational Diseases (2001). Modified in 31/12/2011 and 02/07/2016.

Both in the EU and in China, the approach to H&S in the workplace is primarily preventive and is the responsibility of the employer, with a balanced participation by the workers.

On the other hand, EU regulations define a series of general prevention principles including: avoiding risks, evaluating risks that cannot be avoided, combating risks at the source, adapting to technical progress, replacing the dangerous with the non-dangerous or the less dangerous and giving appropriate instructions to workers. As mentioned by Liu [71] the major difference is that while the Chinese system also adopts the principle of risk prevention, it does not have supporting principles and instruments.

The individual directives can be placed in six groups according to their goal:

Requirements for the workplace (section 4.1)

Personal protective equipment (section 4.2)

Work equipment (section 4.3)

Specific activities (section 4.4)

Special collectives of workers (section 4.5)

Exposure to toxic agents (section 4.6)

In China, given the large number of regulations, rules, etc. as described above, only the most representative have been selected, and they are always compulsory.

4.2.1 Requirements for the workplace

In the EU, there are six Directives related to the workplace (see Table 3). T3.1 is far-reaching and detailed and applicable in all workplaces, unless there is a specific regulation (means of transport used outside the work site or workplaces situated inside means of transport; temporary or mobile work sites; mining industries; fishing boats; fields, woods and other land situated away from the buildings of an agricultural or forestry site). It defines the employers’ obligation: emergency exits are kept clear and can be used at all times; good technical maintenance of the workplace, equipment and devices, and quick rectification of defective elements that may present a risk; appropriate hygiene conditions; regular maintenance and checks of safety equipment to prevent and eliminate hazards.

Table 3
Summary of regulations dealing with requirements for the workplace in China and the EU

EU China

T3.1. Council Directive 89/654/EEC of 30 November 1989 concerning the minimum safety and health (S&H) requirements for the workplace (1st individual directive). T3.2. Provisions on the Supervision and Administration of Occupational Health at Workplace, 2012.

T3.3. Measures for Occupational Hazardous Agents Reporting, 2012.

T3.4. GBZ 1-2010: Hygienic Standards for the Design of Industrial Enterprises, 2010.

T3.5. Council Directive 92/58/EEC of 24 June 1992 on the minimum requirements for the provision of safety and/or health signs at work (9th individual Directive). Amendment: Directive 2014/27/EU. T3.6. GB 2894-2008: Safety signs and guideline for the use, 2008.

T3.7. GBZ 158-2003: Warning Signs for Occupational Hazards in the Workplace, 2003.

T3.8. Council Directive 92/57/EEC of 24 June 1992 on the implementation of minimum S&H requirements at temporary or mobile construction sites (8th individual Directive). T3.9. Regulations on the Administration of Safety Production in Construction Projects, 2003.

Standards:

T3.10. GB 50656-2011: Construction company safety manage criterion, 2011.

T3.11. GB 50720-2011: Technical code for fire safety of construction site, 2011.

T3.12. Council Directive 92/91/EEC of 3 November 1992 concerning the minimum requirements for improving the S&H protection of workers in the mineral-extracting industries through drilling (11th individual Directive).

T3.13. Council Directive 92/104/EEC of 3 December 1992 on the minimum requirements for improving the S&H protection of workers in surface and underground mineral-extracting industries (12th individual Directive). T3.14. Mine Safety Law, 1992. Modified by decision on 27/08/2009.

T3.15. Regulations for the Implementation of the Mine Safety Law, 1996.

T3.16. GB 16423-2006: Safety Regulations for Metal and Non-metal Mines, 2006.

T3.17. Council Directive 93/103/EC of 23 November 1993 concerning the minimum S&H requirements for work on board fishing vessels (13th individual Directive). T3.18. Regulations on Fishery Vessel Inspection, 2003.

T3.19. Provisions on Reporting and Investigation of Marine Safety Incidents on Fishery Vessels, 2012.

T3.20. Measures for the Administration of Fishery Seamen, 2014.

EU	China
T3.1. Council Directive 89/654/EEC of 30 November 1989 concerning the minimum safety and health (S&H) requirements for the workplace (1st individual directive).	T3.2. Provisions on the Supervision and Administration of Occupational Health at Workplace, 2012.
	T3.3. Measures for Occupational Hazardous Agents Reporting, 2012.
	T3.4. GBZ 1-2010: Hygienic Standards for the Design of Industrial Enterprises, 2010.
T3.5. Council Directive 92/58/EEC of 24 June 1992 on the minimum requirements for the provision of safety and/or health signs at work (9th individual Directive). Amendment: Directive 2014/27/EU.	T3.6. GB 2894-2008: Safety signs and guideline for the use, 2008.
	T3.7. GBZ 158-2003: Warning Signs for Occupational Hazards in the Workplace, 2003.
T3.8. Council Directive 92/57/EEC of 24 June 1992 on the implementation of minimum S&H requirements at temporary or mobile construction sites (8th individual Directive).	T3.9. Regulations on the Administration of Safety Production in Construction Projects, 2003.
Standards:
	T3.10. GB 50656-2011: Construction company safety manage criterion, 2011.
	T3.11. GB 50720-2011: Technical code for fire safety of construction site, 2011.
T3.12. Council Directive 92/91/EEC of 3 November 1992 concerning the minimum requirements for improving the S&H protection of workers in the mineral-extracting industries through drilling (11th individual Directive).
T3.13. Council Directive 92/104/EEC of 3 December 1992 on the minimum requirements for improving the S&H protection of workers in surface and underground mineral-extracting industries (12th individual Directive).	T3.14. Mine Safety Law, 1992. Modified by decision on 27/08/2009.
	T3.15. Regulations for the Implementation of the Mine Safety Law, 1996.
	T3.16. GB 16423-2006: Safety Regulations for Metal and Non-metal Mines, 2006.
T3.17. Council Directive 93/103/EC of 23 November 1993 concerning the minimum S&H requirements for work on board fishing vessels (13th individual Directive).	T3.18. Regulations on Fishery Vessel Inspection, 2003.
	T3.19. Provisions on Reporting and Investigation of Marine Safety Incidents on Fishery Vessels, 2012.
	T3.20. Measures for the Administration of Fishery Seamen, 2014.

T3.5. focuses on signs at work that identify the location and identification of containers and pipes, fire-fighting equipment, certain traffic routes, illuminated and acoustic signs, as well as the introduction of appropriate verbal communications and hand signals.

The other four Individual Directives (T3.8, T3.12, T3.13 and T3.17) have been created for jobs requiring a specific regulation due to the hazards involved: temporary or mobile construction sites, drilling, surface and underground mineral-extracting industries, and work on board fishing vessels (see Table 3).

In China there are three regulations that are applicable to all workplaces. T3.2. emphasises the main body of responsibilities for employers regarding occupational health and safety by specifying things such as: setting up occupational health management institutions and training personnel, drafting rules and regulations, management of operating environment, workers, files and materials, management of both safety and work equipment, facilities and devices, monitoring occupational health and so on. There is also a compulsory standard providing basic hygiene requirements for the location and overall layout of industrial enterprises, workplaces, auxiliary rooms and emergency rescue.

With regard to safety and/or health signs at work, there are no regulations at a higher level than standards. T3.6 deals with safety signs not only in workplaces but also in public places and other sites where people need be reminded of safety. T3.7. focuses on signs only for occupational hazards at work in all workplaces, in all entities, to make workers aware of those hazards, and take appropriate protective measures.

For construction sites, T3.9 specifies safety responsibilities for all stakeholders, and includes information on emergency rescue, investigation of work accidents and other content similar to T3.8. However, although the Chinese full-time personnel and the EU H&S coordinator have similar duties, differences do exist. The Chinese safety coordinator is appointed by the constructor, but in the case of the H&S coordinator this is done by the project supervisor or the client. Additionally, the Chinese safety coordinator can only be appointed if they have passed the appropriate administrative department exams. Furthermore, safety management for construction companies is specified by T3.10 and fire safety is specified by 3.11.

With regard to T3.12, there are indeed regulations on drilling or prospective engineering in China. Unfortunately, they are not specific for the mineral-extracting industries, so they have not been included in the table. With respect to T3.13, the corresponding regulations in China are T3.14, T3.15 and T3.16. The aim of T3.14 is to ensure safety in mining production, with T3.15 including the details of how T3.14 should be implemented and T3.16 specifying safety requirements in mining design, construction and exploration processes.

T3.18. deals with issues concerning inspection of fisheries and T3.19 regulates crew management on board fishing vessels including training, health standards, certification, examination, assessment, personnel structure and workers’ responsibilities, etc. Finally, T3.20 sets down standards for reporting and investigating work safety-related accidents on fishing vessels.

Table 3, shows that the aspects included in the EU laws are also in the Chinese regulatory framework, but the number of regulations is greater. It should be highlighted that China has paid great attention to mining safety and it has set up its own comparatively complete OHS system in mining, with over 100 regulations if we consider all of the different levels.

4.2.2 Personal protective equipment (PPE)

Directive T4.1. Compiles employers’ obligations (see Table 4), PPE assessment, rules for use and information, and the consultation and participation of workers. It is supplemented by T4.2, which includes the essential requirements, Declaration of Conformity and the CE mark for PPE. In order to obtain this marking, the product must meet technical requirements described in the Harmonised Standards for each PPE [11]. These technical specifications are considered appropriate or sufficient to meet European legal requirements.

Table 4
Summary of regulations on personal protective equipment

EU T4.1. Council Directive 89/656/EEC of 30 November 1989 on the minimum H&S requirements for the use by workers of PPE at the workplace (3rd individual Directive).

T4.2. Council Directive 89/686/EEC of 21 December 1989 on the approximation of the laws of the Member States relating to PEE. Regulation (EU) 2016/425 of the European Parliament and of the Council of 9 March 2016 on PEE and repealing Council Directive 89/686/EEC.

China T4.3. Provisions for management of labour protection articles of employers, 2015. Modified on 15/01/2018.

T4.4. GB 2626-2006 Respiratory protective equipment –non-powered air-purifying particle respirator.

T4.5. GB 6095-2009 Personal fall protection systems.

T4.6. GB 2811-2007 Safety helmet.

In China, T4.3 compiles rules for selection, purchase, delivery, use, maintenance, substitution and ineffectiveness for PPE and collective equipment. This regulation mentions 11 standards, including 3 compulsory standards related to personal protective equipment: T4.4, T4.5 and T4.6.

4.2.3 Work equipment

T5.1, which deals with the minimum health and safety requirements for the use of work equipment by workers at work, encompasses the characteristics of all work equipment, not only machines (see Table 5). It defines the obligations for business owners when choosing work equipment and establishes the need to provide training and inspect work equipment, both upon installation and each time it is reassembled. This directive has been modified several times. For example, minimum requirements were introduced to improve H&S for persons working at height (ladders, scaffolding and ropes), thus helping to significantly lower the number of falls. Similarly to the rules for Personal Protective Equipment, the EU defines complementary regulations regarding CE marking or technical requirements to market the different pieces of work equipment and a large number of harmonised European standards for each product [11].

Table 5
Summary of regulations on work equipment

EU T5.1. Council Directive 89/655/EEC of 30 November 1989 concerning the minimum safety and health requirements for the use of work equipment by workers at work (2nd individual Directive). Amendments: 95/63/EC, 2001/45/EC and 2007/30/EC. Codified version: 2009/104/EC.

China T5.2. Special Equipment Safety Law, 2013.

T5.3. Regulations on Safety Supervision of Special Equipment, 2003. Amended 2009.

T5.4. Provisions on reporting and investigation handling for special equipment accidents, 2009.

T5.5. GB 5083-1999: General rules for designing the production facilities in accordance with safety and health requirements, 1999.

T5.6. GB 4053-2009: Safety requirements for fixed Steel ladders and platform.

T5.7. GB 5144-2006: Safety code for tower cranes.

Table 6

Summary of regulations on specific activities

EU	T6.1. Council Directive 90/269/EEC of 29 May 1990 on the minimum H&S requirements for the manual handling of loads where there is a risk particularly of back injury to workers (4th individual Directive).
	T6.2. Council Directive 90/270/EEC of 29 May 1990 on the minimum safety and health requirements for work with display screen equipment (5th individual Directive).
China	N/A

Due to the enormous number of regulations in China, only the most relevant have been included. T5.2 is a legal system that only focuses on special equipment that could pose a severe hazard to personal and property safety, but not all work equipment. The safety law rules provide guidelines in the following areas regarding special equipment: appropriate training for production workers, management (sales, rent, import and export of equipment), equipment operation, testing and inspection, supervision and management by the governing department, emergency rescue and accident investigation and disposition, liability of all special equipment-related parties. T5.2 is implemented by T5.3, T5.4 and a series of regulations for safety management and supervision of specific types of special equipment such as boilers and pressure vessels, pressure pipelines, pressure vessels, gas cylinder, etc., which have not been included in the table. At the same time, there are some standards on this issue. T5.5 specifies the basic principles, and the general and special requirements of H&S design for all types of work equipment in addition to air and water transport vehicles, water facilities, electrical equipment and nuclear energy equipment. T5.6 and T5.7 outline safety specifications for specific equipment.

On the other hand, there are several regulations not included in Table 5, i.e. provisions and measures on management for work equipment in specific types of enterprises, such as electronics and machinery. However, this does not only concern equipment safety requirements, but also technical or economic aspects.

4.2.4 Specific activities

Directive T6.1, which provides the minimum H&S requirements for handling loads manually where there is a particular risk of back injury for workers, reflects concern for workers’ muscular and skeletal health. In China, although handling loads is considered to entail risks, no mandatory regulation exists. There are a few recommended standards that specify aspects such as the measurement and classification of physical work intensity in the workplace (GBZ/T 189.10-2007) and the ergonomic requirements of lifting and carrying in manual handling (GB/T 31002.1-2014), etc.

Similarly, a compulsory regulation analogous to T6.2 does not exist concerning minimum H&S requirements for work with display screen equipment. This Directive does not apply to workstations and computer systems on board means of transport; computer systems mainly intended for public use; portable systems, except when used as a workstation for an extended period; equipment with a small display (calculators, cash registers, etc.); traditional typewriters. There are only a few recommended standards for similar content from the EU directive, such as ergonomic requirements for office work with visual display terminal (VDTs) (GB/T 18978) and work seats/chairs (GB/T 14774), ergonomic principles for the design of control centres, especially visual display terminal workstations (DL/T 373.12), etc. Finally, T5.9. mentions the correct angle and distance between the display screen and the operators, but it does not refer to risks that people might suffer when working permanently with this equipment.

4.2.5 Special collectives of workers

T7.1 sets out the basic rights of all women before and after pregnancy in the EU. It is the only Individual Directive that refers to a specific group of workers (see Table 7). In China, T7.2. specifies employers’ obligations including improving occupational safety and hygiene conditions, providing training on occupational safety and hygiene, guaranteeing their rights at work and limiting the scope of work allowed for female employees not only before, during or after pregnancy, but also at other times and during menstruation.

Table 7
Summary of regulations on special collectives of workers

EU T7.1. Council Directive 92/85/EEC of 19 October 1992 on the introduction of measures to encourage improvements in the safety and health at work of pregnant workers and workers who have recently given birth or are breastfeeding (10th individual Directive). Amendment: Directive 2014/27/EU.

China T7.2. Special Rules on the Labour Protection of Female Employees, 2012.

There are other European directives that are not considered Individual Directives, including:

Council Directive 94/33/EC (1994) on protecting young people at work.

Council Directive 91/383/EEC (1991) supplementing measures to encourage improvements in occupational health and safety for workers with a fixed- duration employment relationship or a temporary employment relationship.

Council Recommendation 2003/134/EC (2003) concerning improvements to occupational health and safety protection for self-employed workers.

In China, there are regulations for young people, which in this case means under age workers: Regulations for Special Protection of Minor Workers (1994) and Provisions on prohibition of child-labour (2002).

However, there is no specific regulation for health and safety protection of temporary workers. In addition, Labour Law [79] and Labour Contract Law [80] stipulate that temporary workers have the same rights and obligations as permanent staff. Moreover, all Occupational Health and Safety regulations can be applied to temporary and self-employed workers.

Finally, it should be highlighted that both China and the EU pay close attention to workers who are exposed to radiation. In China, Measures for Management of Occupational Health of Radiological Workers (2007), and in the EU, Directive 89/618/Euratom, modified most recently in 2013 (Directive 2013/59/Euratom - protection against ionising radiation).

4.2.6 Exposure to toxic agents

The EU has developed 9 specific directives to address this issue. Each one respectively regulates protection of workers from different types of agents: carcinogens, biological agents, physical agents (see Table 8: vibration, noise, electromagnetic fields, artificial optical radiation and electromagnetic fields), chemical agents (see Table 9) and explosive atmospheres (see Table 10). The Directive lays down exposure limit values and exposure “action” values (above which employers must apply protective measures). It also includes worker information and training and employers’ obligations.

Table 8
Summary of regulations on exposure to physical agents

EU T8.1. Directive 2002/44/EC of the European Parliament and of the Council of 25 June 2002 on the minimum H&S requirements regarding the exposure of workers to the risks arising from physical agents (vibration) (16th individual Directive).

T8.2. Directive 2003/10/EC of the European Parliament and of the Council of 6 February 2003 on the minimum H&S requirements regarding the exposure of workers to the risks arising from physical agents (noise) (17th individual Directive).

T8.3. Directive 2004/40/EC of the European Parliament and of the Council of 29 April 2004 on the minimum H&S requirements regarding the exposure of workers to the risks arising from physical agents (electromagnetic fields) (18th individual Directive). Amendments: Directive 2008/46/EC, 2012/11/EU and repealed by 2013/35/EU.

T8.4. Directive 2006/25/EC of the European Parliament and of the Council of 5 April 2006 on the minimum H&S requirements regarding the exposure of workers to risks arising from physical agents (artificial optical radiation) (19th individual Directive).

T8.5. Directive 2013/35/EU of the European Parliament and of the Council of 26 June 2013 on the minimum H&S requirements regarding the exposure of workers to the risks arising from physical agents (electromagnetic fields) (20th individual Directive).

China T8.6. Heatstroke Prevention Measures Management Approach, 2012.

T8.7. Occupational exposure limits for hazardous agents in the workplace: Physical agents, (GBZ 2.2-2007).

Table 9

Summary of regulations on exposure to chemical agents

EU	T9.1. Council Directive 98/24/EC of 7 April 1998 on the protection of the H&S of workers from the risks related to chemical agents at work (14th individual Directive). Amendments: Directive 83/477/EEC and Directive 2014/27/EU, Directive 2006/15/EC.
China	T9.2. Regulations on Labour Protection in Workplaces Where Toxic Substances Are Used, 2002.
	T9.3. Catalogue of General Toxic Substances, 2002.
	T9.4. Catalogue of Highly Toxic Substances, 2003.
	T9.5. Provision on the Safe Use of Chemicals in the Workplace, 1996.
	T9.6. List of Hazard Chemicals, 2015.
	T9.7. Trial Guidelines for Safety Assessment of Hazardous Chemical Production Enterprises, 2004.
	T9.8. Occupational exposure limits for hazardous agents in the workplace Chemical hazardous agents (GBZ 2.1-2007).
	T9.9. Regulations for the Prevention and Control of Pneumoconiosis. 1987.
	T9.10. Provision on Supervision and Inspection of Hazard Degree Classification of Dust, 1991.
	T9.11. Decision of the State Council on Strengthening Dust and Toxicant Prevention, 1984.
	T9.12. Notice on Special Action for the Governance of Hazards of Dust and Highly Toxic Substances, 2009.

Table 10

Summary of regulations on exposure to explosive atmospheres

EU	T10.1. Directive 1999/92/EC of the European Parliament and of the Council of 16 December 1999 on minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres (15th individual Directive).
China	T10.2. Safety Regulation for Explosion Endangered Places, 1995.
	T10.3. Trial Electrical Safety Regulations for Explosion Endangered Places, 1987.
	T10.4. Explosive Atmospheres (GB 3836-2010).
	T10.5. General Guidelines on prevention of static accidents (GB 12158-2006.)

In China, occupational hazard agents are divided into 6 groups according to the Classification of Occupational Hazards [81]: 1. dust; 2. chemical; 3. physical (including noise, high temperature, low pressure, high pressure, high altitude hypoxia, vibration, laser, low temperature, microwave, ultraviolet, infra-red, power frequency electromagnetic field, high-frequency electromagnetic field, UHF electromagnetic field and others not mentioned that cause occupational diseases); 4. radioactive; 5. biological (including AIDS virus, brucella, borrelia burgdorferi, forest encephalitis virus, bacillus anthracis and other biological agents not mentioned that can lead to occupational diseases); 6. others (including metal fumes, due to underground operating conditions and jobs that require scraping operations).

There is no direct correspondence in China for the following two Individual Directives:

Council Directive 90/394/EEC of 28 June 1990 on the protection of workers from risks related to exposure to carcinogens at work (6th individual Directive). Amendments: Directive 2004/37/EEC and Directive 2009/148/EC

Council Directive 90/679/EEC of 26 November 1990 on the protection of workers for risks related to exposure to biological agents at work (7th individual Directive). Amendments: Directive 97/59/EEC, Directive 97/65/EEC, Directive 93/88/EC and Directive 95/30/EC. Codified version: 2000/54/EC.

Although COH [80] defines the biological agents, there is no specific regulation, except one standard (T9.8. see Table 9) regulating exposure limit values of two biological agents: Beauveria bassiana and Subtilisins.

The European regulations dealing with exposure to physical agents stipulate detailed limit values for each agent (see Table 8): vibration, noise, electromagnetic fields, artificial optical radiation, and electromagnetic fields. In China, high temperatures are regulated (T8.6) and we found standard T8.7 that specifies occupational exposure limits for ultra-high frequency radiation, high frequency electromagnetic fields, power frequency electric fields, laser radiation, microwave radiation, ultraviolet radiation, heat stress work, noise, hand-transmitted vibration and 3 other agents that are not considered physical agents in European regulations: meteorological requirements in the underground workplace or coal mine, physical workload, and heart rate and energy consumption during physical work

As far as chemical agents are concerned, in addition to directive T9.1, the EU have The European Chemicals Agency (ECHA), which is responsible for updating the REACH database [72] and the specific regulations for classification, labelling and packaging of substances and mixtures. In addition, there is also a variety of compulsory standards to assess exposure to chemical agents by inhalation for comparison with limit values and measurement strategies.

Finally, we should mention Directive 2009/148/EC (2009) on protecting workers from asbestos exposure at work. In China, the term “chemical agents” generally includes chemical and dust agents. However, occasionally, in addition to dust, the term also includes biological agents (T9.8) and they are sometimes included under the expression “toxic agents” along with some kinds of dust, such as asbestos (T9.2). All of this is according to the Catalogue of general toxic substances (T9.3) and highly toxic substances (T9.4) mentioned in the same regulation.

As far as chemical agents are concerned, T9.2 specifies employers’ obligations in workplaces using any of the toxic substances included in these two catalogues. These include preventive measures, protection in the work process including assignment of occupational doctors and nurses, information, protective measures and welfare, occupational health training before and during the work process, protective equipment and emergency rescue facilities, occupational health surveillance, rights and obligations of workers, supervision and administration by the relative governmental department and penalty provisions for any violations. There are also various departmental regulations on the safe use of chemicals in workplaces (T9.5) and guidelines to assess risks and in companies that produce hazardous chemicals, including the surrounding environment, natural conditions, production processes and conditions (T9.7). In addition, the occupational exposure limits for dust, chemical and biological agents in the workplace are also regulated (T9.8). There are still more than 20 regulations and compulsory standards, plus some recommended standards, concerning chemical substances, such as the Regulation on Control over the Safety of Hazardous Chemicals [82], the Provisional Rules of Supervision and Management of Major Dangerous Sources of Hazardous Chemicals [83], etc. These not only tackle protecting workers from risks related to exposure to chemicals at work, but also focus on public, society and environmental safety, so they are not included in Table 9. With regard to dust, apart from the limit value specified in T9.8, T9.9 stipulates how to prevent pneumoconiosis by providing dustproof facilities, protective equipment and training, in addition to controlling exposure, etc. In addition, T9.10 provides a hazardous dust classification. Furthermore, T9.11 and T9.12 regulate prevention and control of both dust and toxicants at the same time. There are also some recommended standards, such as GBZ/T 193-2007, which focuses on specific occupational hazards in processing asbestos, and GB/T 5817-2009, which requires companies to conduct an annual productive dust classification test.

Regarding explosive atmospheres, the EU has T10.1 that obliges employers to take technical and organisational measures to prevent the formation of explosive atmospheres. It includes a classification of areas where explosive atmospheres can form, and the minimum provisions intended to improve safety and protect the health of workers who are potentially exposed to explosive atmospheres. In regulation T10.2, China provides a hazard classification, technology safety and safety management in hazardous areas, and penalties to protect workers’ health and safety, while guaranteeing public, social and environmental security to some degree. Moreover, T10.3 provides greater details regarding explosive substances, classification of explosive hazardous sites, electrical explosion-proof security technology and management. T10.4. specifies the general requirements of equipment in explosive atmospheres and various types of special equipment protection, electrical installation and so on. In particular, section 14 of this standard specifies safety requirements in explosive gas atmospheres. In addition, static accidents are always linked to explosive atmospheres, so T10.5 can also be mentioned.

5 Conclusions

After analysing the EU’s regulation structure, it can be seen that the Framework Legislation defines minimum safety and health requirements that are applicable in all fields of work. Article 16 of the Framework Legislation regulates aspects that should be dealt with in the Individual Directives, clearly defining the structure of the EU OHS regulations. They all make up a complete regulation system where all the work sectors, work teams, specific risks, etc. are regulated by defining minimum H&S parameters.

China has a complicated, disorganised system made up of over 280 OHS legislative regulations, in the form of laws, regulations, rules, integrated regulations, etc. that lead to a mixture and repetition of contents. In addition, there are also hundreds of OHS standards that are compulsory, with requirements on the same level as some of the EU Individual Directives.

It can be seen that a large number of Chinese regulations at several legislative levels and from several state departments are required to cover the minimum H&S content of each Individual Directive.

Moreover, China has not comprehensively regulated activities that expose workers to special risks, e.g. no specific attention is paid to handling loads, working with data display screens, etc. We should also highlight the lack of specific regulation for biological agents, within the category of hazardous agents.

In addition, it should be highlighted that the focus of the OHS regulation is different. The European regulatory framework is concerned with prevention, whilst China is still in a phase where rules are not preventive but drafted to correct problems that have been detected.

It should be highlighted that both the Chinese and EU regulation system emphasise the need for workers to be correctly trained in OHS, which should be the business owner’s responsibility. One of the problems in China associated with training is the high number of workers moving to the cities from the countryside, called “migrant” workers in this study.

In conclusion, the Chinese OHS legislation is still being drawn up and completed, considering that the two Chinese OHS laws were approved over the last decade. This contrasts with the mature European framework set up in 1989, although it is still evolving and being updated.

Finally, it should be noted that this study has had limited access to data on accidents and occupational illness in China, in addition to the difficulty of uncovering China’s complex regulation system,

Conflict of interest

None to report.

Funding

This work was supported by the Project of National Natural Science Foundation of China, “The prevention control and release of unsafe emotion for high-risk industry employees” under grant no. 71573086; and the Department of Building Construction of University of Granada (Spain).

Footnotes

Overview of present EU Member States (EU-28): Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, The Netherlands, Poland, Portugal, Rumania, Slovenia, Slovakia, Spain, Sweden and United Kingdom.

Hukou is the Chinese household registration system that restricts geographical mobility among the population.

The number of a standard consists of the standard code, the serial number issued by the standard, and the number for the release year. In general, the standard codes are: GB (national standard), GBZ (national standards specifically on occupational health), AQ (work safety industrial standards), JGJ (construction industrial standards). GB is the code number for mandatory national standards and GB/T is the code for recommended standards.

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EU	Council Directive 89/391/EEC of 12 June 1989 on the introduction of measures to encourage improvements in the safety and health of workers at work.
China	Work Safety Law (2002). Modified by the National People’s Congress Standing Committee in 27/08/2009 and 31/08/2014.
	Law on the Prevention and Control of Occupational Diseases (2001). Modified in 31/12/2011 and 02/07/2016.

EU	T4.1. Council Directive 89/656/EEC of 30 November 1989 on the minimum H&S requirements for the use by workers of PPE at the workplace (3rd individual Directive).
	T4.2. Council Directive 89/686/EEC of 21 December 1989 on the approximation of the laws of the Member States relating to PEE. Regulation (EU) 2016/425 of the European Parliament and of the Council of 9 March 2016 on PEE and repealing Council Directive 89/686/EEC.
China	T4.3. Provisions for management of labour protection articles of employers, 2015. Modified on 15/01/2018.
	T4.4. GB 2626-2006 Respiratory protective equipment –non-powered air-purifying particle respirator.
	T4.5. GB 6095-2009 Personal fall protection systems.
	T4.6. GB 2811-2007 Safety helmet.

EU	T5.1. Council Directive 89/655/EEC of 30 November 1989 concerning the minimum safety and health requirements for the use of work equipment by workers at work (2nd individual Directive). Amendments: 95/63/EC, 2001/45/EC and 2007/30/EC. Codified version: 2009/104/EC.
China	T5.2. Special Equipment Safety Law, 2013.
	T5.3. Regulations on Safety Supervision of Special Equipment, 2003. Amended 2009.
	T5.4. Provisions on reporting and investigation handling for special equipment accidents, 2009.
	T5.5. GB 5083-1999: General rules for designing the production facilities in accordance with safety and health requirements, 1999.
	T5.6. GB 4053-2009: Safety requirements for fixed Steel ladders and platform.
	T5.7. GB 5144-2006: Safety code for tower cranes.

EU	T7.1. Council Directive 92/85/EEC of 19 October 1992 on the introduction of measures to encourage improvements in the safety and health at work of pregnant workers and workers who have recently given birth or are breastfeeding (10th individual Directive). Amendment: Directive 2014/27/EU.
China	T7.2. Special Rules on the Labour Protection of Female Employees, 2012.

EU	T8.1. Directive 2002/44/EC of the European Parliament and of the Council of 25 June 2002 on the minimum H&S requirements regarding the exposure of workers to the risks arising from physical agents (vibration) (16th individual Directive).
	T8.2. Directive 2003/10/EC of the European Parliament and of the Council of 6 February 2003 on the minimum H&S requirements regarding the exposure of workers to the risks arising from physical agents (noise) (17th individual Directive).
	T8.3. Directive 2004/40/EC of the European Parliament and of the Council of 29 April 2004 on the minimum H&S requirements regarding the exposure of workers to the risks arising from physical agents (electromagnetic fields) (18th individual Directive). Amendments: Directive 2008/46/EC, 2012/11/EU and repealed by 2013/35/EU.
	T8.4. Directive 2006/25/EC of the European Parliament and of the Council of 5 April 2006 on the minimum H&S requirements regarding the exposure of workers to risks arising from physical agents (artificial optical radiation) (19th individual Directive).
	T8.5. Directive 2013/35/EU of the European Parliament and of the Council of 26 June 2013 on the minimum H&S requirements regarding the exposure of workers to the risks arising from physical agents (electromagnetic fields) (20th individual Directive).
China	T8.6. Heatstroke Prevention Measures Management Approach, 2012.
	T8.7. Occupational exposure limits for hazardous agents in the workplace: Physical agents, (GBZ 2.2-2007).