The European Union does not have an agency called "OSHA EU." EU-OSHA is an information agency, not the EU equivalent of the enforcement authority US OSHA. EU directives are implemented through each Member State's national law and enforced by national authorities. This course is general education, not legal advice, a compliance determination or accredited certification. Before acting, identify the country, US state, sector, worker status and current law, then obtain competent legal and HSE advice where consequences are material.
Two systems, not two equivalent agencies
United States: the OSH Act and OSHA
In the United States, the Occupational Safety and Health Act of 1970 created the federal Occupational Safety and Health Administration. Federal OSHA sets and enforces workplace safety and health standards for much of the private sector. Some workplaces fall under an OSHA-approved State Plan. Those state programmes must be at least as effective as the federal programme and may use different or stricter requirements.
European Union: treaties, directives and national law
In the European Union, occupational safety and health law begins with EU treaties and directives. Framework Directive 89/391/EEC establishes broad minimum principles. Additional directives address particular risks and groups. Member States transpose directives into national legislation and may maintain or introduce more protective measures. National labour inspectorates or other national authorities enforce that national law. EU-OSHA supplies information, research and tools; it does not inspect workplaces or issue penalties.
| Question | United States | European Union |
|---|---|---|
| Central legal instrument | OSH Act and applicable federal or State Plan standards | EU directives plus national transposing legislation |
| Primary enforcement | Federal OSHA or the applicable State Plan agency | Authorities designated by each Member State |
| EU-OSHA role | Not applicable | Information and research agency, not inspectorate |