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US vs. UK: Who Is Safer and Why?
By Scott Schneider
A recent study from the Rand Center for Safety and Health in the Workplace concludes that construction work in Britain is much safer than in America.
In the U.S., now, about eight construction workers out of every 100,000 die on the job each year. In Britain, the rate is about two per 100,000. This gap has grown larger since the 1990s when the British rate was half of the U.S. rate. Other European Union countries (Finland, France, Sweden, Germany) also have much lower workplace fatality rates than the U.S.
In their analysis, the researchers screened the data by excluding homicides in the workplace (which are exceedingly rare in the U.K. because of strict gun laws) and traffic related deaths (since those are not counted in the U.K. statistics). Leaving aside these kinds of fatalities, if the death rate in construction in the U.S. were as low as Britain’s, over 300 lives would be saved each year.
How can the differences be explained? Why is construction work safer in the U.K.? Several explanations are offered:
- Britain has significant rules that do not exist in the U.S., such as the Construction Design and Management Regulations which place obligations on designers and architects to include safety in a project's design stage.
- European regulations require each company to do a safety and health risk assessment and address those risks (similar to the Injury and Illness Prevention Programs OSHA has been proposing).
- Britain is more highly unionized than the U.S. (though its unionization rate has been declining as well) with a quarter of the workforce unionized.
- Britain requires “safety reps,” workers hired by the company just to enforce safety on sites, for all worksites (more information on safety reps is here).
- The construction workforce in Britain is claimed to be more stable, more experienced and less risk taking.
- Britain has tougher fall protection rules than the U.S., and falls account for a large percentage of construction fatalities.
- Government-funded construction, which may be safer and may better follow safety regulations, is a larger share of construction in Britain than in the U.S. (the recent Olympic construction in Britain was one of the safest projects ever).
What can we learn from this study? Can we make construction in the U.S. as safe as in Britain?
Given the rulemaking paralysis in the U.S., it would be difficult for OSHA to match the rules in place in Britain, even though they could have a big impact on safety. Unionization rates are unlikely to grow in the near-term. U.S. government-funded construction is often safer than privateconstruction (sites run by the Army Corps of Engineers have much lower injury rates than private projects in general), but the mix of public- versus Private-funded construction is unlikely to change. If anything, more projects traditionally funded by government are now being funded by public- private partnerships (P3).
So while it is worthwhile noting that construction is safer in Britain and showing it is possible to save hundreds of lives each year, the U.S. is probably not going to match the British record anytime soon. Nevertheless, seeing the potential, we may be inspired and challenged to keep up the work for on-the-job safety and health in the U.S.
The UK has just released its latest statistics for 2013, which show continued improvement. Thirty-nine construction workers died in the UK in the past year.
[Scott Schneider is the LHSFNA's Director of Occupational Safety and Health.]