Introduction
OSH is a crucial indicator of the social development and well-being of society. It is aimed at performing work duties that are safe for the life and health of an employee. The importance of OSH cannot be neglected by the leading countries of this world, and their approaches to its implementation seem to be a relevant topic to discuss. Germany demonstrates many significant aspects in this regard, and these aspects, in comparison with some other European countries – France and Sweden – will be explored below.
German OSH Approach
The primary method of increasing the level of labor protection is technical progress, through the invention of new machines and tools, when working with which, the likelihood of harm to the employee decreases, as well as the development of more and more advanced protective equipment that ensure human safety during work. Also, an important factor is the training of people working in hazardous production, safe working methods, and the correct use of protective equipment (Lenhardt & Beck, 2016). The main goal of improving working conditions in production is to reduce diseases and accidents at work, to preserve the life and health of workers.
In addition to the social effect of a high level of labor protection, there is also an economic result. For example, there is a decrease in the costs of paying compensation after accidents, again due to the increased working conditions, its productivity increases. In accordance with German law, all entrepreneurs are united in professional societies (Berufsgenossenschaft), which are divided according to the territorial and sectoral lines. There are 35 such communities in total, and more than 20 thousand people are employed in them (Diettrich, Becker, & Luders, 2018).
Funding for professional communities comes only from the insurance premiums of organizations. Industries where the risk of injury is especially high pay large insurance premiums, but even more, are paid by those enterprises where work is not carried out to reduce production risks (Sun, et al., 2018). This indicator is monitored using statistics on accidents at work, and if this figure rises, then so does the premium. This encourages employers to reduce the risks of injury at work and occupational diseases. A striking proof of the creation of such a system is that over the past 30 years, the number of accidents in the workplace has decreased by half as a result of which there has been a decrease in insurance premiums (Diettrich, Becker, & Luders, 2018).
The basic concept of occupational safety and health in Germany is not to detect accidents at work but to prevent them. For this, professional communities carry out their activities in the following areas:
- Supervision over the state of labor protection in the organization;
- Medical support;
- Social assistance;
- Research work to improve the level of labor safety;
- Insurance coverage (Zwetsloot et al., 2020).
But these are not all areas of their activity. It is also important to note the following.
First, Employees of the technical supervision service are engaged not only in compliance with labor protection standards but also widely cooperate with enterprises, provide consultations when purchasing or modernizing equipment and technologies or, if necessary, changing the technological process (Diettrich, Becker, & Luders, 2018). They also participate in testing new equipment for compliance with the safety level.
Second, since an important task of the professional communities is the prevention of accidents, they pay great attention to training personnel in safe working practices. About four hundred thousand people are trained in professional communities. Particular attention to this training is not only to teach to avoid risks but to motivate the employee in order to comply with safety rules (Federal Ministry of Labour and Social Affairs, 2011). Since it is impossible to train all multimillion-dollar employees, first of all, they teach the persons on whom labor safety depends most of all, for example, the employer or the person, the management company, etc. Third, the communities have their own medical network, which includes all clinics and ambulance centers throughout Germany. This network is equipped with the latest equipment, ambulances, and even rescue helicopters. Fourth, professional communities conduct research work, which is carried out by twenty research institutions (Diettrich, Becker, & Luders, 2018).
Professional communities are self-regulatory, non-profit corporations. All areas of activity are financed only through insurance premiums. The state does not participate in the management of these communities but only exercises legal supervision. Since professional communities are not-for-profit organizations, they can set the premiums paid by companies only to those that will be necessary to support all the functions performed by the communities (Diettrich, Becker, & Luders, 2018). In order to implement the principle of social partnership, the board of the professional community is elected every six years and consists of employers and workers from various industries.
Also, professional communities are united in the association of professional associations in Germany (HVBG), which ensures the activities of the communities, respects their interests, and contains commissions that develop measures to reduce injuries and harm to health at work (Diettrich, Becker, & Luders, 2018). The Association is engaged in labor safety control, international cooperation in the field of labor protection, training of employees of professional communities, and also solves general issues of labor safety and medicine.
The association includes expert commissions that are engaged in the development of instructions, rules, directives, and basic provisions on occupational safety and health protection of workers (Reinert, 2016). A special place is occupied by the Committee on Occupational Medicine, which develops instructions and rules for the prevention of industrial injuries. The Association also houses the Occupational Safety Institute (BIA), which studies various factors that affect worker health through measuring laboratories. In addition, the institute examines the safety of building structures, personal protective equipment, workplaces, etc. The Association also includes another Scientific Research Institute of Occupational Medicine, which is engaged in the study of various diseases and the consequences of working at a particular enterprise. At this institute, there is a clinic in which occupational pathologists of multiple specialties work.
The Association of Trade Associations annually publishes the directory Statistics of Professional Social Insurance Associations. Figures and Long-Term Trends. Since 1993, this guide has been published in English translation, which helps to get acquainted with its content in a wide range of different countries. The materials posted in it are based on data collected by trade associations. The handbook provides information on the enterprises and companies included in the system, data on accidents reported by trade associations with disability for more than three days, including fatal accidents at work, as well as on the way to and from work home. This information is given in absolute numbers and coefficients both for the country as a whole and for individual industries. Industries include mining, mines and quarries, gas, heating and water supply, metalworking, light engineering and electrical engineering, chemical, forestry, paper and printing, food, construction, transportation, and much more.
At the end of this section, it should be noted that the labor protection system in Germany is one of the most advanced in Europe. It has undergone a long development over hundreds of years, which has made it possible to increase the life expectancy of workers, its quality, as well as achieve tremendous results in the economic development of the country and enterprises (Ertel & Formazin, 2019). That is why most of the leading experts in the field of labor protection believe that the experience of Germany can help improve the labor protection system in almost any country.
Comparison of German OSH Approach to France and Sweden
France OSH Approach
In France, OSH legislation is a large structure, but the bodies that have a real impact on employers are the Labor Inspectorate and the Committee on Health, Safety, and Working Conditions. As such, there is no special assessment of working conditions in France, but legislation requires entrepreneurs to provide labor protection services, using specialized doctors for this (Ncube & Kanda, 2018). Then, France has a very developed system of occupational safety training. Training takes place at the National Institute for Labor Protection. In addition to students, it trains teachers who train employees specifically at the workplace.
France strives to ensure that the number of injuries and occupational risks become isolated. Companies with more than 50 employees must form their own committee for work safety, working conditions, and hygiene (INRS, 2017). Its main function is to protect the rights of workers to decent and safe working conditions. Enterprises employing more than 250 people are required to have their own labor service. It is engaged not only in monitoring compliance with labor safety rules but also in ensuring a favorable psychological climate in the team (Worker-participation.eu, 2016). The personnel of the service pays special attention to the most vulnerable categories of workers, such as persons with disabilities, senior citizens, etc.
The personnel of the labor service is appointed jointly by the employer and the labor safety committee: in some cases, the labor inspectorate may interfere with the staffing of the service. Service specialists undergo special training at the National Institute for Labor Protection (Guarnieri, 2010). It is funded primarily by the National Insurance Fund for employees. Classes are held in a full-time format. In addition, there is the possibility of distance learning based on a course developed by the National Institute for Research and Security. The basic principle of all training programs implemented in France is an integrated approach to ensuring occupational safety. It presupposes, among other things, the development of a corporate culture in which employees feel a personal responsibility for the state of labor protection at the enterprise.
Sweden OSH Approach
The Swedish legislation addresses the central issue in relation to labor, and more specifically, what rights and obligations the employer have and what the worker has. Then, this includes issues related to those responsible for the equipment (compliance with safety measures when working with machines, machine tools, etc.), preventive measures to protect against occupational diseases and accidents at the workplace (ILO, n.d.). Another important feature of Sweden legislation in this regard is the creation of a good atmosphere in the workplace. The protection of favorable working conditions is taking care of absolutely everything – starting from surrounding objects and ending with a collective (Berthelsen et al, 2019; SWEA, 2020). In addition to the labor law, there are also many rules at specific enterprises that set a huge number of restrictions regarding safety, technical and legal standards, the premises in which they work, the presence of fuses on machines and machines that set the level of noise, vibration, and even stress levels.
If a worker has complaints about the safety conditions at his or her workplace, their unsatisfactory situation, this employee must contact the safety officer with his or her complaint. Such an authorized person must be in every enterprise with a staff of at least five employees – the minimum number of such employees is one (Vinberg, Markussen, & Landstad, 2017). This person in charge bears the burden of the interests of employees and monitors the proper observance of safety measures. It is also worth noting one interesting fact. The fact is that, although the employer must be fully responsible for maintaining the creation of a favorable atmosphere at the enterprise, the employee must also participate in this.
Comparison
It should be emphasized that German peculiarities in terms of OSH are generally justified by this country’s federal organization. The federal states are free to choose the administrative structure of their law enforcement system – this creates a number of problems. The latter ones are due to the fact that the Federal Ministry has little influence over the respective regional ministries, which is not a characteristic of France and Sweden.
The organizational structure of the labor inspectorate may vary in each federal state. For example, in the federal government of Saxony, the state labor inspectorate is represented in the form of the Occupational Safety, Health, and Safety Unit, which is part of the Labor Department of the Saxon Ministry of Economy, Labor, and Transport. The Ministry administers and supervises the activities of the Saxon Regional Office for Occupational Safety and Health and its divisions.
German law regulates the representation of workers in the form of a workers’ council through their participation in the resolution of labor disputes. The Workers’ Council provides assistance in the field of labor protection, can take the initiative to improve working conditions, and apply to the state labor inspectorate with complaints about the actions of the employer, as well as for advice. To inform employees, industry insurance companies issue brochures, guidelines, and booklets explaining labor legislation, safety precautions and send them to their enterprises directly to managers. Under national laws, it is employers who are obliged to inform their employees – it is common for the mentioned countries. There are also massive information campaigns for the general population. One of the key goals of these activities is to show that all investments in accident prevention, safety, and health at work pay off. It might be summarized that the discussed OSH approaches of Germany, France, and Sweden tend to follow the best practices in this regard. The authorities make the necessary emphasis on OSH – starting from educational and ending with encouraging activities and policies.
The Extent of OSH Inclusion in School Curriculum in Germany in Comparison with France and Sweden
The way country pays attention to OSH education at schools may be the setting point of facilitating OSH issues in pupils’ future careers. Curricula and syllabuses in German primary schools refer to the responsibilities of the Ministries of Education and Cultural Affairs in the Länder. A syllabus specifies both the course contents and the course aims and teaching methodology. These are obligatory for the teachers. Within the scope of the primary school, or Grundschule, environmental and health-related issues, are significantly being included as subjects in the syllabuses. Among these subjects, “An introduction to the professional and working world is a compulsory component of every course of education and is provided either in a special subject such as Arbeitslehre (pre-vocational studies) or as part of the material covered in other subjects” (EU-OSHA, 2009, p. 62).
Then, general health education is being conducted in primary and secondary schools. This implies that a pupil learns the essentials of health and hygiene, as well as the appropriacy and importance of environment-friendly actions. However, it should be noted, “while OSH is not a specific part of the general curriculum, various Federal States have OSH-related educational programmes and projects”. On the other hand, according to EU-OSHA (2009), “It is, however, up to the individual school and its teachers whether they participate in these activities” (p.62).
In France, the education ministry sets the school’s curricula and learning objectives. A teacher is able to choose their particular teaching methodology and textbooks. “The obligation to teach safety at school in primary school and the collèges includes three significant areas: road safety, safety at home, and major natural and technological risks”. Moreover, according to EU-OSHA (2009), the French educational system has adopted a holistic approach to safety education, and it is taught in a cross-cutting and interdisciplinary manner (p. 59).
The notable point in the Swedish educational framework is that pupils are perceived and defined as employees of a school. This means that the pupils get used to the importance and conditions of OSH from the very first steps of their educational journey. They are involved in OSH management to an exact extent and take part in various related activities. However, there is no separate discipline on OSH in the curricula, but it is implied that several “subjects have goals related to lifestyle and safety and health at work” (EU-OSHA, 2009, p. 112). The comparative table of the extent of OSH inclusion in the school curriculum in Germany, in comparison with France and Sweden, is presented below.
Table 1. The Extent of OSH Inclusion in School Curriculum in Germany in Comparison with France and Sweden.
Conclusion
In conclusion, it seems reasonable to state that Germany has developed an effective approach to OSH implementation. In comparison with France and Sweden, it has a number of visible differences that are mostly justified by the federal governmental organization. It was found that Germany and the compared countries tend to follow the best European practices regarding OSH. On the other hand, the comparative analysis in the framework of the extent to which OSH is implemented in school curricula showed that Germany seems to demonstrate less significant achievements than France and Sweden. It might be assumed that the inclusion of a separate OSH discipline in the general curriculum in Germany will contribute to even better OSH indicators in the nearest future in this country.
References
Berthelsen, H., Ertel, M., Geisler, M., & Muhonen, T. (2019). Validating the psychosocial safety climate questionnaire – integration of findings from cognitive interviews in Germany and Sweden.Scandinavian Journal of Work and Organizational Psychology, 4(1), Web.
Diettrich, A., Becker, A., & Luders, S. (2018). POOSH – Occupational Safety and Health of Posted Workers: Depicting the existing and future challenges in assuring decent working conditions and wellbeing of workers in hazardous sectors. Lkv.uni. Web.
Ertel, M., & Formazin, M. (2019). An approach to the further development and application of the PSC tool by applying cognitive interviewing in Germany. In: Dollard M., Dormann C., Awang Idris M. (eds) Psychosocial Safety Climate. Springer, Cham. Web.
EU-OSHA (2009). OSH in the school curriculum: requirements and activities in the EU Member States. Web.
Federal Ministry of Labour and Social Affairs. (2011). European and international occupational safety and health. Web.
Guarnieri, F. (2010). Occupational safety and health in France: Practitioners and policy – AFNOR Report. Researchgate. Web.
ILO. (n.d.). Occupational safety and health country profile: Sweden. Web.
INRS. (2017). OSH system in France. Web.
Lenhardt, U., & Beck, D. (2016). Prevalence and quality of workplace risk assessments – Findings from a representative company survey in Germany. Safety Science, 86(1), 48–56.
Ncube, F. & Kanda, A. (2018). Current Status and the Future of Occupational Safety and Health Legislation in Low- and Middle-Income Countries. Safety and Health at Work 9(4), 365–371.
Reinert, D. (2016). The future of OSH: a wealth of chances and risks. Industrial Health, 54(5), 387–388.
Sun, Y., Arning, M., Bochmann, F., Borger, J., & Heitmann, T. (2018). Development and validation of a practical instrument for injury prevention: The occupational safety and health monitoring and assessment tool (OSH-MAT). Safety and Health at Work, 9(2), 140-143.
SWEA. (2020).Acts and regulations about work environment. Web.
Vinberg, S., Markussen, L. T., & Landstad, B. J. (2017). Cooperation between occupational health services and small-scale enterprises in Norway and Sweden: A provider perspective. Workplace Health and Safety, 65(8), 355–364.
Worker-participation.eu. (2016). Health and Safety in France. Web.
Zwetsloot, G., Schmitt-Howe, B., & Nielsen, K. Y. (2020). Success factors for OSH implementation. Opening the black box of OSH realisation. Policy and Practice in Health and Safety, 18(2), 196–210.