An Overview of the Occupational Safety and Health Systems of Nigeria, UK, USA, Australia and China: Nigeria Being the Reference Case Study

Abstract

This paper reviews the Occupational Safety and Health (OSH) frameworks of Nigeria, UK, USA, Australia and China considering Nigeria as a representative developing country. The study looks at each of the five OSH regulatory and enforcement models against a range of performance themes with a view to uncovering strategic lessons for Nigeria and other developing nations. The study identifies some of the potential drivers behind the developments of the different OSH management frameworks. These drivers include robustness of the OSH laws, efficiency of the judicial system, degree of independence of the OSH enforcement agency, adequacy of financial budgets, good workforce-inspector ratio, accident history and activities of the civil/human right groups. Even though Nigeria is used as a reference case study, the observations and conclusions drawn are generic and applicable to typical developing countries. The paper may also be found beneficial by researchers looking to have a high level view of the OSH management frameworks of Nigeria, UK, USA, Australia and China. Although Nigeria is working to implement a new and more comprehensive OSH law, i.e. the Labour, Safety, Health and Welfare (LSHW) Bill (2012), this paper does not assess Nigeria’s current OSH standing against the provisions of LSHW Bill which is yet to be rolled out. (The second part of this bipartite series will address some of the key structural and potential implementation issues surrounding LSHW Bill).