Legal frameworkSource verified

US OSHA and EU occupational safety law

The major legal differences, who enforces the rules, and how to determine which requirements apply to a workplace.

6 modules + assessment60–75 minutesReviewed 4 August 2026
International HSE professionals comparing United States and European occupational safety legal frameworks
Language
Module 1

Two systems, not two equivalent agencies

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.

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.

QuestionUnited StatesEuropean Union
Central legal instrumentOSH Act and applicable federal or State Plan standardsEU directives plus national transposing legislation
Primary enforcementFederal OSHA or the applicable State Plan agencyAuthorities designated by each Member State
EU-OSHA roleNot applicableInformation and research agency, not inspectorate
Sources

Primary sources and further reading

  1. US OSHA, Occupational Safety and Health Act of 1970
  2. US OSHA, Laws and Regulations
  3. US OSHA, State Plans
  4. EUR-Lex, Framework Directive 89/391/EEC
  5. EU-OSHA, About EU-OSHA
  6. German Federal Ministry of Justice, Arbeitsschutzgesetz translation

Editorial owner: Myaser HSE Hub Editorial

Last verified: 4 August 2026

Review trigger: Review immediately after a material change to cited legislation, jurisdiction or agency role, and at least annually.

Professional boundary: General education only. Do not use this course as the sole basis for a legal, engineering or operational safety decision.