The OSHA UK Equivalent: What It Actually Is

The answer: the UK is not OSHA

OSHA is the US — the Occupational Safety and Health Administration, the 29 CFR, the standard and the citation. The UK is different: the UK equivalent of OSHA is the HSE (the Health and Safety Executive) and the HSWA 1974 (the Health and Safety at Work Act) — the law, and the enforcement behind it.

The difference is the system, not the name: the US writes the standard (the 29 CFR, the citation, the fine), and the UK enforces the law (the HSWA, the regulation, the prosecution). The US inspector is the OSHA compliance officer who cites; the UK counterpart is the HSE enforcing officer who can prosecute.

The regulator: the HSE, and the local authority

The UK regulator is the HSE (the Health and Safety Executive), and the HSE takes the high-risk industry: construction, oil and gas, chemicals, manufacturing, transport. The HSE sends the enforcing officers who inspect and enforce, and it publishes the research and the guidance (the HSG, the L-Eg) that the rest of the system works to.

The local authority is the low-risk regulator: the office, the shop, the restaurant, the school. The local authority enforcing officer inspects and enforces the same law for the premises the HSE does not cover. The two together are the UK regulator — and together they are the UK equivalent of OSHA.

The law: the HSWA 1974, and the regulation

The UK law is the HSWA 1974 (the Health and Safety at Work Act 1974) — the parent. The HSWA sets the general duties: the duty of the employer, the duty of the employee, the duty of the self-employed. The test is so far as is reasonably practicable — the UK standard for every duty that follows.

The regulation is the detail: the MHSWR 1999 (the risk assessment), the COSHH 2002 (the chemical), the RIDDOR 2013 (the report), the CDM 2015 (the construction), the Work at Height Regulations 2005, the LOLER 1998 (the lifting), the PUWER 1998 (the equipment), the DSE Regulations 1993 (the screen), the Management of Health and Safety at Work. The parent act plus the regulation is the UK law — and that is the UK equivalent of OSHA.

The enforcement: the prosecution, and the fine

The UK enforcement is the prosecution. The HSE prosecutes — the employer and, where the case shows it, the director — in the court, and the fine is unlimited. That is the UK answer to the OSHA citation.

The US enforcement is the citation: the OSHA compliance officer cites, and the citation is graded (other-than-serious, serious, repeated, willful) with the fine attached. The two are different machines for the same job: the UK prosecutes, the US cites.

The comparison: the UK vs the US, side by side

The two systems, side by side:

• The regulator: the UK — the HSE (the high-risk) + the local authority (the low-risk); the US — OSHA (the federal) + the state plan.
• The law: the UK — the HSWA 1974 + the regulation; the US — the OSH Act 1970 + the 29 CFR.
• The standard: the UK — the law (the regulation); the US — the standard (the 29 CFR).
• The enforcement: the UK — the prosecution (the court, the unlimited fine); the US — the citation (the administrative, the fine).
• The risk: the UK — the MHSWR (the 5-step); the US — the general duty + the standard.
• The chemical: the UK — the COSHH 2002; the US — the HazCom 2012 (the GHS).
• The report: the UK — the RIDDOR 2013; the US — the OSHA 300 log.
• The construction: the UK — the CDM 2015; the US — the 29 CFR 1926.
• The worker: the UK — the safety representative (the elected); the US — the OSHA committee (the voluntary).

What Is the UK Equivalent of OSHA? (the Direct Answer)

The UK has no OSHA. The UK equivalent of OSHA is the HSE — the Health and Safety Executive — for the high-risk industry, and the local authority environmental health for the rest, both enforcing the Health and Safety at Work Act 1974 and the regulations underneath it. The OSHA is one federal agency; the UK is the HSE plus the local authority plus the law. The comparison on this page runs the two side by side — the regulator, the law, the enforcement, the number, the deadline — and the answer for the expat and the site is: the UK is stricter on the assessment and the consultation, and the OSHA is stricter on the penalty and the record.