In 1989, the Member States of the European Union set minimum rules on how prevention in the workplace was to be organized. It was a unanimous decision of the EU Council of Ministers. But would it turn governments into more preventively-minded employers?

One singular fact about the Framework Directive is that it does not distinguish between private sector workers and the different categories of public and civil service employees - an entirely new approach to some States.

This report is looking at what effects the Framework Directive 1989 had produced in the central civil service of four countries - Austria, Spain, France and United Kingdom - through a comparative study of selected aspects. It focuses on three aspects in particular:

  • worker representation;
  • the operation of preventive services;
  • training.

The first thing we found is that, in four countries, the State is still inclined to see itself as a case apart, standing selectively outside the rules of ordinary law.

This report shows how this outlook has led to various failings and delays in transposing the Framework Directive. But it is practical implementation that is most fraught with problems, with glaring shortcomings in the inspection and enforcement machinery, and inadequate arrangements for preventive services and staff representation provision.