National Styles of Worker Protection in the United States and Japan: The Case of the Automotive Industry

This paper compares and contrasts the national styles or approaches to the regulation and management of occupational safety and health distinctive of the United States and Japan within the context of the automotive industries of these two countries. Referring to comparative workplace injury and illness experience and data on safety and health regulatory activities, strengths and weaknesses of the two approaches are considered. It is suggested that an optimal strategy would contain elements of both approaches. Elements of the two approaches that might be adapted cross-nationally are identified and discussed.