Legislating on occupational safety and health: a comparison of the British and American experience

Abstract. In the early 1970s both the United Kingdom and the United States legislated new occupational safety regulations. Enforcement strategies varied considerably: the British chose a persuasive, the Americans a coercive approach. The legislative process was characterized by consensus in the first case, by conflict in the second. Consequentially the UK regulation appears to have been quite effective, while the US one led only to negligible results. This difference can be mainly explained by the different strength of the interest groups involved in the regulation's implementation.