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evaluation of the european strategy on safety and health at work ...

evaluation of the european strategy on safety and health at work ...

EVALUATION OF THE

EVALUATION OF THE EUROPEAN STRATEGY ON SAFETY AND HEALTH AT WORK 2007-2012149wellbeing ong>ofong> workers so that ong>theong>y stay at work longer. However, it isremarkable that in ong>theong> Council’s Joint Employment Report ong>ofong> 2011, ong>theong>re is nomention ong>ofong> OSH as a key policy to ensure higher employment rates, indicatinga clear lack ong>ofong> integration ong>ofong> OSH-related issues in employment policies at EUlevel.› Collaboration between DG EMPL and DG MARKT has resulted in ong>theong>production ong>ofong> a useful guide to encourage public authorities to promote goodworking conditions through ong>theong>ir public procurements.Oong>theong>r policy areas have been identified as being relevant when it comes to OSHrelatedissues, even though ong>theong>y were not mentioned in ong>theong> ong>strategyong>. In particular,synergies with environmental policies (and in particular REACH) should beexploited much more than ong>theong>y are now. The policy agenda related to fisheries hasbeen very active in terms ong>ofong> promotion ong>ofong> better working conditions and effortsshould continue in this direction in ong>theong> upcoming strategic cycle. However, ong>theong> lackong>ofong> initiatives in ong>theong> areas ong>ofong> research, education, migration, agriculture andstandardisation is particularly concerning and seems to demonstrate a need forgreater coordination between ong>theong> relevant institutional actors (i.e. between DGEmployment and ong>theong> relevant directorate-generals).5.6 CoherenceCoherence deals with ong>theong> internal logic ong>ofong> ong>theong> ong>strategyong> and ong>theong> consistency betweenintended outputs, results, outcomes and impacts.Evaluation question:Q7: To what extent are ong>theong> actions promoted by ong>theong> ong>strategyong> coherent and correspondentto a non-contradictory intervention logic? If ong>theong>y are not, why?As part ong>ofong> ong>theong> desk study ong>ofong> ong>theong> European ong>strategyong>, we developed an overview ong>ofong>ong>theong> ong>strategyong> in an intervention logic format (included in Appendix F). Thisoverview and ong>theong> analysis ong>ofong> ong>theong> six objectives in chapter 4 gave rise to ong>theong>following findings:› The ong>theong>ory ong>ofong> change underlying ong>theong> ong>strategyong> is not completely evident. Thereare a number ong>ofong> assumptions about outcomes and ong>theong> results ong>ofong> certain actionswhich are not stated in ong>theong> ong>strategyong> (shown in italics in ong>theong> logical frameworkoverview). The ong>strategyong> thus does not present a full logical chain ong>ofong> expectedactions, results, outcomes and impacts. There is an increased focus onobjectives and actions, but less focus on ong>theong> steps in between.› There are no major contradictions in ong>theong> design ong>ofong> ong>theong> ong>strategyong>: The sixpriority areas (which could also be seen as intermediate objectives) are areas,which are supportive ong>ofong> ong>theong> goal to reduce ong>theong> number ong>ofong> occupationalaccidents and diseases. The specific areas ong>ofong> intervention and actionshighlighted under ong>theong> six priority areas are also supportive ong>ofong> ong>theong> intermediateobjective inherent in ong>theong> priority area. The weakest link is ong>theong> link betweenhttp://projects.cowiportal.com/ps/A019055/Documents/3 Project documents/Interim and final report/Final report October 2012/OSH ong>evaluationong>-report_Final_submitted 14 March2013.docx

150 EVALUATION OF THE EUREVALUATION OF THE EUROPEAN STRATEGY ON SAFETY AND HEALTH AT WORK 2007-2012150intermediate objective 6 on international cooperation and ong>theong> overall goal. It isnot completely evident how international action will contribute to reducing ong>theong>incidence ong>ofong> accidents and diseases within ong>theong> EU, except in ong>theong> obvious caseong>ofong> assisting candidate countries.› Several ong>ofong> ong>theong> six intermediate objectives are not objectives in ong>theong> strict senseong>ofong> ong>theong> word. Raong>theong>r, ong>theong>y can be regarded as means to achieve certainobjectives. The most obvious example is ong>theong> first objective ong>ofong> 'putting in placeand modern and effective legislative framework'. Having this as an objectiveimplies a risk ong>ofong> undue focus on legislation raong>theong>r than ong>theong> end-results, whichlegislation should contribute to achieve.As presented in section 5.1, workers' and employers' representatives havepointed to inconsistencies under ong>theong> priority area ong>ofong> a modernised legalframework. Workers' representatives generally acknowledge ong>theong> need to easeong>theong> administrative burdens on SMEs, but are sceptical about simplification ong>ofong>ong>theong> legal framework as ong>theong>y fear this will reduce ong>theong> level ong>ofong> protection.Hence, ong>theong>y point to an inconsistency between ong>theong> action area ong>ofong> simplificationand ong>theong> objective ong>ofong> a modern legal framework. On ong>theong> oong>theong>r hand, ong>theong>employers' representatives are generally much in favour ong>ofong> simplification butsceptical about additional regulatory requirements (action area ong>ofong> updating ong>theong>legal framework), hence also pointing to an inconsistency (but between actionareas ong>ofong> updating ong>theong> legal framework and simplifying it). This, ong>ofong> course,reflects a genuine dilemma between ensuring a high level ong>ofong> protection and atong>theong> same time devising legislation, which is suited for implementation at ong>theong>local level. However, organising ong>theong> ong>strategyong> according to a logic whereby'legislation' is not formulated as an end in itself could perhaps serve as astarting point for a meaningful dialogue on ong>theong> areas ong>ofong> intervention andpotentials for adaptation and simplification.› The links and hierarchy ong>ofong> ong>theong> intermediate objectives and ong>theong> headings/areasong>ofong> action listed under each intermediate objective are not clear in all cases.One example is ong>theong> second objective relating to national strategies, whichincludes a sub-heading ong>ofong> 'improving ong>theong> preventive effectiveness ong>ofong> healthsurveillance'. Here, it would seem that ong>theong> national strategies would be ong>theong>means to achieve this end, contrary to how it is presented in ong>theong> ong>strategyong>.› Some areas for action are mentioned in various places in ong>theong> ong>strategyong>. Thismay serve to underline ong>theong>ir importance, but on ong>theong> oong>theong>r hand, it is alsosomewhat confusing and obscuring ong>theong> priority. A key example is ong>theong> area ong>ofong>promotion ong>ofong> mental health at ong>theong> workplace, which is mentioned withdifferent emphasis/actions under objective 2. National strategies, objective 3.Prevention, and objective 4. Risks. This is related with anoong>theong>r keyobservation that ong>theong> crucial area ong>ofong> better implementation ong>ofong> OSH regulation ismentioned as a sub-objective under Objective 1, but at ong>theong> same time anumber ong>ofong> oong>theong>r objectives and areas mentioned elsewhere in ong>theong> ong>strategyong>actually support this objective.› A ong>strategyong> period ong>ofong> 5-6 years is a long period and this calls for a ong>strategyong>,which provides an overall framework for action, but does not specify eachhttp://projects.cowiportal.com/ps/A019055/Documents/3 Project documents/Interim and final report/Final report October 2012/OSH ong>evaluationong>report_Final_submitted14 March 2013.docx

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