한국과 아시아 4개국에 글로벌 기업 진출을 위한 산업안전보건에 관한 근로자 보호규정 비교

Abstract

We compared Korea with the four Asian countries (China, Thailand, Vietnam and Philippines) on five parts of regulations of occupational safety and health: regulations for employee protection, measurement of working environments, occupational health care, occupational diseases, and punishment. The main subjects of measuring the working environment of the five Asian countries, including South Korea, was the same as the employer, but there were slight differences in measurement timing, but at least once every year. In the case of the qualification of the work environment, the general public shall not be allowed to perform and obtain permission from the departments and heads of the departments and agencies of each country. In the report, South Korea, China, Thailand and Vietnam should report the results of measurement to the designated institutions in each country, but in the Philippines, there is obligation to measure the work environment, but there is no obligation to report. In the four countries excluding Thailand, it is stated that the medical institution needs to undergo a medical checkup, which stipulates that the medical institution carries out a medical checkup for the workers in accordance with the law. In the case of working hours, it is possible to see that all five countries’ working hours are similar or equal. Female workers in all the five countries can have the maternity leave and menstruation leave. In Vietnam, there are slightly more detailed welfare regulations for female workers than other four countries country.