comparative study of health and safety between canada-china
DESCRIPTION
A comparative study of health and safety regulation, as well as the application of said regulations and the legal measures associated with breaches, in the field of construction between Canada and the People's Republic of China. Conducted in 2013 during a month long interenship with the Erjian Construction group.TRANSCRIPT
Comparative Study of Health and Safety on Construction Sites in Canada and China
ByGabriel Lavoie
1st Cohort: 2011-2013
Table of Contents
I. Introduction ............................................................................................................................... 3
II. Methodology .............................................................................................................................
6
III. Comparison of Theoretical Norms in Construction Health and Safety ……………....................... 7
III.1 Governing Bodies ....................................................................................................... 7
III.2 Safety Training ........................................................................................................... 8
III.3 Inspection .................................................................................................................. 9
III.4 Enforcement ........................................................................................................... 10
III.5 Standards ..................................................................................................... ............ 11
IV. Comparison of Practical Observations on Construction Health and Safety .......................... 12
IV.1 Safety Training ……………........................................................................................... 12
IV.2 Heights Safety .......................................................................................................... 14
IV.3 Environmental Safety ...............................................................................................
16
IV.4 Safety Equipment .....................................................................................................
19
IV.5 Inspections and Corruption ..................................................................................... 22
V. Summary of Findings .............................................................................................................. 23
References .................................................................................................................................. 25
Annex 1: Sample Interview Sheet ………………………….................................................................... 27
Annex 2: Sample Observation Checklist ………………….................................................................. 29
Be they houses, temples or palaces, buildings are one of the fundamental expressions of
civilization. Requiring cooperation among many to achieve a common goal, they are, in and of
themselves, a testimony to human ingenuity and cooperation.
However, when one walks through the dome of a cathedral, stands atop a tall skyscraper, or
walks besides a ruined fortification, it is easy to be so amazed by the scale of the building, by the genius
of the engineering that went into the structure, that one forgets about the humans behind it, the
dozens, hundreds or ever thousands who labored, bled and sometimes even died to achieve what we
see before us.
Throughout the ages, the value of human life has varied greatly, from nearly worthless to having
immeasurable value. Despite this, loss of human life is rarely beneficial; after all, loss of experienced and
qualified labor is never good for either productivity or for the final quality of a work. As such, for as long
as humans have been putting their lives in danger to build things, they have been trying to ensure that
they survive the experience. However, it is not until the rise of syndication in the West that a
generalized movement towards ensuring worker safety appeared. This movement, originally based
around the syndicates themselves, was, in many states, eventually absorbed into the state's health
policies, leading to the present day structure of national and even international regulations on health in
safety on construction sites.
Indeed, today in the West, ensuring the continued health and safety of the workforce is one of
the primary concerns of most corporations. Although it could be said that this is mostly the result of the
growing concern for human life that began in Occident during the Enlightenment, simple economics, as
well as basic human nature, seems to point to a rather more mundane motivation, profit. As could be
expected, the unplanned reduction of the qualified workforce through accidents is not profitable for any
corporation, as it results in a loss of productivity and, often, other associated consequences such as
disability pay, lawsuits and bad publicity. This is the primary reason for safety measures within the
corporate environment itself, particularly for any safety measures going beyond what is dictated by the
state. Indeed, at least in the West, the moral imperative behind ensuring health and safety falls mostly
upon the state itself, whose values, including the preservation of human life and the elimination of
needless suffering, are those shared, at least theoretically, by a majority of the population due to
widespread education based on a post-Enlightenment, Christian valued system. Public pressure is
therefore the primary motivation behind the creation of state based regulation on health and safety.
From a Western point of view, it is therefore easy to think that developing countries, which, on
average, have less stringent safety norms, also attribute less value to human life than developed ones.
Although this might be true, as in many of them there was no major social revolution which drastically
increased the perceived value of human life amongst the general population, this would be dismissing
the most probable reason for this discrepancy: the relatively small size of the educated labour force.
Indeed, as was the case during the Industrial Revolution in the West, the value of uneducated and
unqualified labour is relatively unimportant; accidents cause little loss in productivity, as the labour can
easily be replaced, and minimal monetary loss, as the individuals are either too poor or lack sufficient
education to conduct legal action against the corporation. Furthermore, the uneducated proletariat is
often ineffective as political forces due to its inability to critically evaluate information provided to it and
to organise itself into effective pressure groups, and is therefore more or less powerless to force their
governments to create new legal norms, and even more so when contrasted to the large socio-economic
influence the corporations they oppose exert on the governments.
Because of this, the worksite health and safety of workers only improves when doing so results
in an increase in profit for the corporations, including when striking and other forms of protest result in
too large a loss of productivity, or when a third party becomes involved in the situation, be it local
intellectuals or foreign influence. With the rise of an educated middle class in the developing world,
resulting in the increase of costs associated with accident and an increase in the socio-political influence
of the workforce, as well as the globalisation of the economy and the growing social awareness in most
of the world (resulting in loss of profit when customers refuse to associate with corporations who
mistreat their employees), it is probable that a dramatic increase in the stringency of security norms will
soon be observed in the developing world, and this tendency is already evident in places such as China,
where many corporations are actively enforcing stricter regulations than the national ones in an effort to
improve their image and limit bad press associated with worksite accidents. Indeed, although there is
room for improvement, the situation is often not as bad as what is believed in the Western world, which
is an image influenced solely by the worst cases, which are the only ones of sufficient magnitude to be
publicized outside of China.
With that said, accidents still happen. Indeed, in both nations, construction remains one of the
most accident prone industries, with construction being the industry with the largest proportion of
worksite accidents in Canada with around 24.4 accidents per 1000 workers per year (slightly more than
manufacturing sector with 24/1000 workers) and second most in China based on governmental
evaluation, with the only industry having a worst ratio being manufacturing, largely due to the public
nature of the former making accidents all the more evident in the public eye, and therefore, all the more
damaging for a company’s image.
The purpose of the present document will therefore be to provide a summary and comparison
of the state of health and safety on construction sites in Canada and the People’s Republic of China. This
analysis will be conducted in two segments: first, an analysis of the norms and regulations in place in
both nations forming the groundwork of worksite health and safety, and second, an analysis of the
practical application of these norms, based on practical observations and interviews with local experts in
the field of health and safety.
II. Methodology
This analysis and comparison of health and safety within the construction industries of Canada
and China is divided into two segments, a theoretical and a practical one. In both cases, the relevant
information was obtained through three processes, namely analysis of theoretical documents,
interviews with experts within the field and practical observations on construction sites.
First, to find the basic information required for the theoretical analysis, the primary documents
from both nations, including their respective labour codes and occupational safety regulations where
analysed, thereby providing basic information relative to the governing bodies, the enforcement
methods, the legal obligations of employers and employees and the various standards in each nation.
Furthermore, this was complemented by analysis of said standards, including those related to the
various specifications of protective equipment, fire and electrical safety as well as scaffold assembly.
Moreover, information relating to the different health impacts of hazards found in construction,
including sound, asbestos and volatile solvents, was obtained from the websites of the World Health
Organisation and the Environmental Protection Agency, as well as from other published articles. Finally,
some information that proved difficult to find through written sources, such as the manner in which
safety inspections and training were conducted in each state, as well as how different groups in each
nation influenced the creation of regulations, were obtained through interviewing experts in both
nations. An example of the set of questions asked during these interviews is presented in Annex 1.
Second, to conduct the practical comparison, factual evidence from different sites was obtained
primarily through direct observations of different construction sites in each nation. Most of these were
conducted on a formal basis, using the observation checklist presented in Annex 2, allowing for
observation of the application of the different standards, especially those relating to the wear of safety
equipment and to ensuring a safe working environment through building safe structures (including
scaffolding) and limiting potential exposure to dangers including fire, electric and chemical hazards.
Additionally, some observations were conducted informally, without use of a full checklist, because the
conditions did not allow for a full observation of a site, often because only a few tasks were being
conducted or could be observed on said site. However, taken as a whole, the sum of these observations
allowed for the practical analysis of the application of health and safety norms on the smaller types of
sites, including renovation and rural project. Finally, when practical information could not be observed,
such as that related to the relative frequency of corruption amongst the inspectors or to the actual
quality of the safety equipment used, it was obtained during the interviews with each nation’s experts.
III. Comparison of Theoretical Norms in Construction Health and Safety
As in all things relating to legal matters, there is, in construction health and safety, a distinction
between what should theoretically be done, and what is actually done in reality. Indeed, no matter what
the actual state of health and safety in either nation is in practice, the system of rules and regulations
which codifies and enforces it remains an integral part of the health and safety system, representing in a
way the ultimate objective that the nation sets for itself, and therefore, a global comparison between
states must include discussion on this aspect. Thus, this section represents a rapid comparison of the
primary theoretical elements for health and safety in construction in both Canada and China.
III.1 Governing Bodies
To begin, before concrete analysis of health and safety standards on construction sites and
Canada and China can be conducted, it is important to note what group, or series of groups, are
responsible for these policies in both nations. Indeed, in both states, worksite health and safety are
state based concerns, and, as such, ultimately under jurisdiction of their respective governments, which
are the primary source of regulations and the final arbitrator and enforcer of said regulations within
their borders. However, distinctions exist in how the regulation system is structured, as well as in how
the responsibility is shared between the different levels of government in each nation.
Indeed, in China, rather distinctively to most other state, there is no single central database for
the regulation system, and no general background law to support the regulations themselves, as the
China Workplace Safety Law only deals with the general and legal aspects of health and safety in every
industry, and the Construction Law of the People’s Republic of China mostly only covers the safety of a
building after it has been built as well as regulations regarding the elimination of the possible health
impacts of building on the surrounding populations, while only mentioning that the corporations are
responsible for the health and lives of the employees on their sites, and that said employees are allowed
to make suggestions for improvements and to press charges in the event of an accident.
Due to this, ensuring proper health and safety on construction sites in China is therefore based
solely on the application of individual standards, which are approved by the Ministry of Construction.
These standards are often inspired by, or taken wholly, from the standards of other states, and can be
further modified or clarified in their application by policy announcements. However, due to the
structure of the Chinese government, more than a dozen governmental agencies (including the
overarching State Council as well as the provincial and city governments and their individual
Construction Committees) can make these modifications on any single standard and, due to the
impossibility of maintaining perfect communication in such a large bureaucracy, these modifications can
sometimes be contradictory or remain largely unpublicized even within the same city.
This structure is in direct contrast to that of Canada, where the primary document for health
and safety in construction (and in any other field) is a single, formal document, known as the Canada
Occupational Health and Safety Regulation (OHSR). This document, published by the government of
Canada and regularly updated, provides both the basic health and safety regulations on any given field,
such as the minimal equipment or conditions required for conducting various operations, as well as
basic regulations on first-aid in industry in addition to providing a list of what standards and regulations
apply for each sector of industry. It does not, however, contain information pertaining to the legal
aspect of worksite incidents, which is itself described under part II of the Canada Labour Code (CLC),
which pertains to the legal obligations of both employees and employers relative to health and safety,
and any legal sanctions that may come from breaching said obligations. However, because health and
labour are both provincial concerns, every province can add to any federal document, creating their own
set of regulations, such as the Occupational Health and Safety Act of Ontario and the Loi sur la Santé et
Sécurité au Travail of Quebec.
As for the standards used in Canada, they are, similarly to China, usually adopted on the national
level, and tend to closely model those used in the United-States. However, some aspects of the
standards used in construction (and therefore, health and safety in said field) can vary between
provinces, as the building code is also unique to each of them, and although the differences are usually
minimal, some oddities can appear, such as the fact that Quebec’s regulation on the maximal sound
intensity one is allowed to be exposed to for a period of 8 hours (85 db) is lower than the Canadian
federal standard (87 db), itself being lower than the standard of all other provinces (90 db). Due to this,
safety equipment is often rated to the highest standard across the nation.
Moreover, in both states, pressure groups, including industrial lobbies and worker groups or
unions (of which there is only one in China, the All-China Federation of Trade Unions) also exert
considerable influence on the adoption of new policies, both through direct pressure on the State and
through influencing the public opinion. As could be expected, the actual influence wielded by each of
these groups varies immensely, but, taken as a whole, they represent one of the primary factors
influencing how governments shape their health and safety policies.
III.2 Safety Training
The basis of any functioning legal system is circulation of information; if individuals are to follow
norms, they must first learn what behaviours they have to avoid or favor to respect it. As such, training
is a central pillar of health and safety, and the principal manner in which prevention is conducted.
In China, officials are obligated to follow regular training course to keep up to date on evolving
regulations, and to inform workers under them of any relevant information. Furthermore, workers have
to be trained in the safe use of any equipment they are expected to use in their work, and any employer
is forced to divulge any and all probable hazards that a worker may face when on a site, as well as to
provide information relative to preventive and emergency measures. The situation is similar in Canada,
where employers are forced to provide complete safety training for any task carried out by their
employees, as well as to inform them of any potential hazards to their health. However, only field
supervisors are required to follow safety training, with higher executives not needing to follow any kind
of safety training unless they intend to inspect or work on a construction site. Furthermore, employers
in both nations are obligated by law to freely provide (and enforce the wear of) any required safety
equipment for their workers, and this safety equipment must conform to the standards in place.
III.3 Inspection
Next, in both states, the primary, and arguably most efficient, method of enforcing the
regulations is inspection, and although both states have had scandals in the past related to the quality of
said inspections, the overall importance of inspection remains unchanged, and it is still an important
factor in preventing incidents and injuries, both for the workers and future users of a building.
In China, inspections are conducted at three different levels. First, the corporations themselves
maintain inspectors within their personnel, who inspect the worksites daily or weekly to ensure that the
work is being conducted adequately and safely for the rest of the personnel. They generally remain on a
single large site and keep records of every inspection, to facilitate tracking the evolution of issues and to
identify recurring problems for future training needs. As could be expected, these individuals do not
issue fines to their own corporations, but simply make recommendations to solve issues. Second,
regional inspectors intermittently visit the sites under their jurisdiction, conducting a general inspection
of the sites and penalizing breaches in the regulations, usually by giving an ultimatum to solve the issue
before giving the corporation a fine. Finally, national inspectors go around the country, doing surprise
visits of sites more or less at random (corporations with a history of bad practices tend to be visited
more often than others), and although they wield the same legal power as the regional inspectors, they
represent the ultimate authority on the matter.
Canada follows a similar system, although construction inspection is mostly a provincial matter.
Indeed, although federal regulation forms the basis, as each province maintains its own construction
and labour code, the highest level of enforcement is provincial. As in China, inspectors visit corporations
mostly at random, and enforce the regulations through fines and ultimatums. Moreover, city inspectors
in Canada fulfill much the same role as regional inspectors in China, having the right to suspend the
construction permit for any worksite under their jurisdiction, and to levy fines in the event of non-
compliance with the law. Finally, unlike China, very few construction corporations in Canada maintain a
detachment of trained inspectors, relying more on the expertise of the trained personnel on each site.
III.4 Enforcement
As mentioned above, enforcement of health and safety (as well as general construction
regulations) is done in an identical manner in both states, through stopping work on a site and the use of
ultimatums and fines until matters are resolved, as well as with direct fines in the event of accidents.
However, the subjects, as well as the amount, of the fines differ in both states, and ever within them.
Indeed, in Canada, although removal of the construction permit until matters are solved is often
the preferred course of action, fines can also be levied, both for actions that contravene the health and
safety regulations and for actions that directly endanger the health or lives of individuals, with the latter
being subject to harsher fines. Moreover, Canada distinguishes between a physical person and a moral
person, with the latter being subject to larger fines. Finally, although the CLC prescribes maximal fines
and sentences ($1,000,000 and/or two years of imprisonment) that can be levied for failure to respect
health and safety norms, the fines themselves are a provincial matter, and so vary across Canada.
China, on the other hand, usually only fines employers (but does not distinguish between
individuals and corporations), although some infractions, such as refusing to provide funds for ensuring
safety or signing a contract exempting the employer from liability in the event of an accident, may result
in fines to the corporation as well as all investors on a given project, regardless of their knowledge or
approval of the actions. However, the fines themselves tend to be much smaller in China, with fines
ranging from 20,000¥ to 200,000¥ (the exchange rate from the Renminbi to the Canadian dollar is
around 6:1), and although individuals may be forced to step down from their positions, they cannot be
imprisoned unless their actions also constitute a criminal act.
III.5 Standards
As for the standards and regulations themselves, in theory, the standards in China are often
quite similar to those in place in Canada. This could come as a surprise, seeing as the accident rate
(especially for fatal ones) is greater in China, but the latter is due more to differences in how they are
enforced than to any real difference in standards, which have improved dramatically in China in the last
years as public pressure, both internal and foreign, has forced industries and the government to bring
them up to international levels.
Indeed, from the standpoint of construction, the basic standards related to health and safety,
including the obligation of employers to provide adequate protective equipment whose rating matches
or exceeds that demanded by the standards, are similar in both nations. Therefore, helmets, work boots
(usually with steel toe and sole protectors) and work gloves are required in most construction work in
both states, with China being slightly less stringent on who needs to wear certain pieces of equipment,
notably protective footwear, which is only required for some trades, including bricklaying, masonry, iron
working and steel fixing, rather than for everyone on a construction site.
Moreover, more specialised pieces of equipment, including air filters, eye protection, insulated
clothing as well as hearing protection are required in both states for specialized tasks involving exposure
to noise, flying debris, high temperature or high concentrations of airborne particles, such as
jackhammering, indoor painting, sanding and welding. However, here again, China is slightly less
demanding: hearing protection is never a required piece of equipment for any task in China (although
noise exposure regulations make it required for some tasks), and insulated welding equipment is only
required for arc welding rather than for all types. The safety standards the equipment are required to
meet are also similar, with only some small differences in the magnitude of the forces the equipment
needs to be able to safely absorb.
Furthermore, other basic safety norms, such as requiring railing and toe boards on scaffolding
over a certain height (2m in China and 3m in Canada), requiring safety nets on construction sites at a set
interval (no more than 4.6 or 30 m under a construction level for most of Canada and China respectively)
as well as requiring the indication of possible environmental hazards through clear and evident signage,
are similar in both nations, and it is evident that the purpose of these regulations is the same in both
cases, with only some differences in the specific requirements of the law.
IV. Comparison of Practical Observations on Construction Health and Safety
Although it can be said that in theory the legislation for health and safety regulations of Canada
and China are quite similar, their actual application often differs greatly, and is far from consistent even
within the same nation. Indeed, most serious work accidents are the result of a dramatic increase in the
consequences of otherwise benign human accidents due to improper application of the safety
regulations in place. As such, serious work accidents tend to be more common and more severe on sites
where either the work itself is willingly conducted in an unsafe manner, or the inspections are not
carried out adequately, thereby allowing involuntary breaches in the safety regulations to persist.
Because of this, although analysis of the theoretical laws in regulations in place in both nations
can provide some information about the relative state of health and safety in both nations, they cannot,
by themself, provide a complete comparison on the status of health and safety on construction sites in
both nations. It is therefore logical that another point of comparison between both states concern how
health and safety regulations are followed in practice rather than on the regulations themselves. The
primary practical elements of comparison between health and safety in the Chinese and Canadian
construction industries will therefore be the practical application of the most important areas of
regulation, namely the nature of the safety training given to employees, the application of heights safety
and protective equipment regulations, the presence of environmental dangers and the quality of
inspections. Please note however that this comparison is a generalisation based solely upon anecdotal
evidence collected from my observations as well as those of health and safety experts and other
individuals of the construction industry from both China and Canada, and therefore only represents a
rough indicator of the relative health and safety practices of both nations.
IV.1 Safety Training
As was mentioned earlier, one of the primary tasks of employers in both nations is providing
safety training for their employees. In Canada, the great majority of construction corporations provide
training for their employees, to ensure proper use of safety equipment and adequate knowledge of
potential dangers on a construction site. This training mostly concerns safety from the standpoint of the
tasks conducted by a given employee as well as general construction site safety norms, and is often
done in an unofficial manner through pairing and communication with more experienced workers or
supervisors, and, although the training can be inconsistent at times, it is for the most part effective in
limiting accidents, as the practical context facilitates integration of knowledge and techniques and the
mentor role encourages experienced workers to work in a safer manner to be good models. In addition
to this, larger corporations in Canada also hold training seminars for employees to ensure that they
remain up to date on safety practices, especially if the regulations have changed, and to provide safety
information on unusual scenarios that employees may not have experience facing, including safety
protocols for working (or ceasing work) in dangerous weather including high winds, hail or freezing rain.
Large corporations in China follow a similar method, with employees being trained on-site based
on the needs of their specific work as well as on basic safety regulations relative to the construction site
environment. However, in China, as the law requires that employees be trained by safety experts, the
training tends to be of a more theoretical than practical nature, although the latter is often gained over-
time through working with more experienced workers. Nevertheless, because this practical training is
entirely informal, young workers often also perpetuate bad habits taken from older workers, who do not
feel they are responsible for the training. Interestingly, many large Chinese corporations also regularly
test the basic safety knowledge of all their workers through written exams, with individuals failing said
exams being forbidden from working on a construction site until they obtain additional safety training
and pass the test again.
However, in China, smaller corporations, especially those operating in rural areas, tend not to
provide any safety training to their employees. This is further compounded by the relative lack of
education amongst the rural and migrant workers that compose a large segment of the workforce of
smaller corporations, which reduces both their awareness to potential dangers and their willingness to
seek training. As could be expected, this often leads to disproportionately high rates of accidents.
Another element of general safety on construction site is the creation and communication of
emergency plans. Indeed, both in Canada and in China, the great majority of construction corporations
establish at least a single, but usually a few to account for different events, basic emergency plans for
their worksites, which include standard emergency measures such as evacuation planning and
containment protocol for any potentially dangerous compounds stored or used on site, and these plans
are then taught to every worker on any given site. In addition, most corporations ensure that at least
some individuals on each worksite are trained in first aid to provide basic assistance in the event of an
accident. However, here again, smaller corporations in China tend to not invest as much into emergency
planning, which, combined with the lack of safety training, results in relatively minor incidents such as
small fires having disproportionately large consequences.
IV.2 Heights Safety
Both in Canada and in China, the primary source of accidents on construction sites are falls from
elevated positions and impacts from falling objects, with the great majority of these occurring either
when working on or erecting scaffolds or when conducting roofing work. Indeed, although both nations
have extensive regulations on the safe erection and use of construction scaffolds, including standards for
everything from the minimal height of toe boards to the maximal amount of mass that can be supported
by a standard sized wooden board, scaffolding remains one of the segments of construction work with
the greatest proportion of infractions, possibly due to their ubiquitous nature on construction sites,
although it is important to note that there is a clear difference in the quality (and safety) of scaffold
work based on the nature of the company which conducts it and on the scale of the work, with major
construction companies and larger sites often having safer installations.
Indeed, in China, most large construction corporations, especially those working on sky scrapers
and other forms of very large urban installations, tend to take heights safety very seriously, as these
construction sites, and therefore the corporations working on them, are often in the eyes of the media
and the population, making any accidents (and especially avoidable ones) or delays due to inspectors
finding procedural errors particularly bad for their reputation. Due to this, scaffolding on these sites is
usually made of good material, almost always metal (bamboo scaffolding is legal in China, and is
cheaper, although it is harder to install correctly), and properly maintained, in contrast to rural areas
and renovation projects in which the scaffolds are either made of hastily assembled bamboo or old
material bought off from larger corporations, making their solidity inconsistent and therefore prone to
unexpected material failures. Scaffold walkways in China are uniformly made of weaved bamboo fibres,
whose quality varies but is usually decent to good on all but the most unsafe sites. Furthermore, the
scaffold installations themselves on large sites almost universally follow the prescribed standards as far
as form and presence of reinforcement components including interior and exterior bracing, while those
on smaller sites tend to forgo most of the unnecessary bracing and reinforcements to cut costs, thereby
weakening the structure, especially in the event of partial failure, in which case the remaining structure
often becomes inadequate to support the stress placed on it, and, in turn, eventually collapses.
As far as safety devices present on the scaffolds and buildings themselves, most large
corporations again follow the established regulations for installing railing on all levels that are being
worked on and properly maintained safety netting at regular intervals, while smaller sites tend to forgo
railing and netting on many sites, or include netting that provides inadequate protection, either because
it is damaged or poorly installed, hampering the even distribution of stress loads. However, strangely
enough, although all other forms of safety measures are at least present in some form on most larger
sites, toe boards, despite being mandatory on any scaffolding or working level over 8m in height, are
conspicuously absent from the great majority of sites, including world class construction projects such as
the Shanghai Tower, and although the presence of safety nets does make them more or less redundant,
the fact remains that falling objects can be extremely deadly, especially considering that horizontal
safety netting is only required every 30m in China. For instance, a standard concrete block, of a nominal
size of 8" by 8" by 16", weighs about 30 lbs.; if it falls 15 m, the impact energy is 2.0 kJ, more than the
energy of a 0.223 caliber bullet (the standard round for NATO assault rifles, with around 1.7 kJ of
energy), a painful, and probably deadly impact even if a helmet is worn due to spinal or cerebral trauma.
As for Canada, similarly to those of larger firms in China, the great majority of construction sites
maintain scaffolding of at least adequate quality, almost universally made of steel, although lighter
aluminium scaffolding is gaining in popularity amongst smaller firms. The material itself is largely made
of good quality and well maintained steel, normally of a single grade to limit miscalculations, and the
installation is at minimum up to the established standards. Indeed, the primary difference between
Canadian and Chinese scaffolds is the flooring material of choice; the Canadian construction industry
favors wood for platforms, either as timber planks or plywood, as they are relatively cheap, require little
maintenance, and give good indication of degradation (wood will visibly, and often also audibly, warp or
crack before failure). The wood essences of choice are softwoods of the spruce, pine or fir families as
well as the Douglas fir, due to their high strength to mass ratio and relatively affordable cost.
Concerning additional safety equipment, most Canadian construction sites maintain railing on all
exterior faces of worked on levels or on the adjoining scaffolding, and this railing usually integrates a toe
board at the bottom to stop unattended objects from falling onto lower levels. The exception to this are
renovation or personal work sites, which often forgo some of the railing, and rarely include a toe board
unless masonry work is being conducted. Construction sites of sufficient size also maintain safety netting
within 15 ft. of the bottom of any worked on floor, to further limit the damage caused by falling objects
and to prevent injuries in the case of falls. As could be expected, due to the much smaller maximal
distance between a work floor and a safety net, the danger posed by falling objects in Canada tends to
be lessened; for instance, using the same concrete block as the previous example, even at the maximal
possible height, the impact energy would only be 0.6 kJ, an assuredly unpleasant impact, but
nonetheless survivable with little to no long-term consequences if a helmet is worn.
IV.3 Environmental Safety
Another primary source of worksite incidents in construction is the literal mass of possible
environmental dangers, both natural and artificial, that are present on a construction site. These
represent a truly immense variety of hazards which include everything from live electrical wires, to
aerosolised dust, to dangerous chemicals, and even reckless drivers. As accounting for all these
elements is both impossible and ultimately unimportant, this document will focus on the most
important ones and the ones on which there is a clear distinction between Canada and China. Namely,
these include fire hazards, electrical hazards, dangerous atmosphere and hazardous conduct.
First, as could be expected from an industry that often deals with both flammable material and
multiple, often unsupervised, ignition sources, fires have always been, and still are, a very serious threat
in the construction industry. However, for the most part, construction sites in China and Canada apply
fire prevention norms well enough, ensuring some protection from accidental fires and greatly reducing
the consequences of such an event, both in terms of material and human costs. Indeed, on the vast
majority of sites, most flammable material is kept stored away from the general construction site until
its use is required (although this is usually due to its sensitivity to the elements in general), and any
debris is kept separate from the rest of the site, often in specially made metallic bins for ease of
disposal. Additionally, any flammable or explosive compounds (such as acetylene in welding tanks) are
usually kept away from the main construction zones, and, in larger sites in China, are even kept locked in
specially made sheds that are off the premises of the construction site itself when not in use. Moreover,
for the most part, smoking is forbidden inside any building in construction both in Canada and in China,
and these regulations are followed on the great majority of sites. The primary difference is that although
most Canadian provinces permit smoking while outside of buildings or on buildings that are not yet
enclosed (the notable exception being Prince-Edward Island), most sites in China forbid smoking not
only while on or near a building under construction, but also while anywhere on the construction site
proper. The only major exceptions to this are small construction corporations in rural areas, which tend
to permit smoking nearly everywhere, even in clearly dangerous circumstances such as while welding or
painting. In Canada, possible sources of ignition, including sparks from welding or cutting metal, are kept
under control by limiting them to controlled environments usually devoid of exposed combustible
materials. However, this is often not the case in China, where welding is often done without covering
any potentially flammable material underneath, and, worse, sometimes over other workers not
protected against the shower of superheated metal.
Next, electrical hazards represent one of the more insidious threats on constructions sites,
which inevitably have to deal with the dangers of partially exposed (and possibly damaged) wiring and
large concentration of both manpower and conductive elements including tools, scaffolds and structural
elements. To limit the probability of accidental damage to the main electrical systems, the majority of
large construction sites in Canada and China maintain temporary electrical boxes on the periphery of
construction sites with easy access to power cut-offs, and keep the primary wiring away from heavy
circulation. Furthermore, in China, many sites keep all outside electrical wiring elevated on poles to keep
it from coming in contact with most machinery, although this makes maintenance more difficult and
facilitates accidental contacts with machinery too large to fit underneath, as workers pay little attention
to the presence of the wires, leading to accidental electrocutions, which, due to the large amperage
needed on construction sites, are often fatal. Additionally, inside construction sites, electrical work is
only conducted by, or under supervision of, trained electricians wearing appropriate safety equipment,
and the majority of potentially live wires are regularly inspected and kept insulated from conductive
surfaces through capping. The notable exceptions are smaller sites in both nations, which often conduct
electrical work without a trained electrician and often skimp on conducting full inspections of the wiring.
Another frequent source of hazards on construction sites are dangerous compounds present in
the atmosphere. The most common of these are the many types of volatile organic solvents found in
paint, varnishes and many other chemical products, mostly cyclical hydrocarbons such as xylene,
toluene and benzene, that can cause irritation of the eyes and respiratory systems as well as serious
damage to the nervous system including polyneuropathy (peripheral nerves malfunction), atrophy of the
optical nerve (causing progressive loss of sight), dysfunction of the pyramidal and cerebellar brain cells
as well as other forms of brain lesions if inhaled in large quantities. Indeed, due to their volatile nature,
these compounds can accumulate in rooms during and after work, and remain there for long periods of
time if the environment is poorly aerated. Therefore, in China and in Canada, most construction projects
require that any worker doing extensive paint work inside a structure be equipped with an air filter and
sealed protective glasses to limit exposure, and that the environment be well aerated. However, on
smaller sites, particularly private home construction or renovation projects in both nations as well as on
rural construction sites in China, protective equipment is rarely available, and although the small scale of
the work limits the exposure, long term consequences can still occur, especially if paint work is
conducted regularly. To prevent this, some corporations as well as many independent individuals in
Canada are beginning to favor VOC-free paints, to limit the danger from any accidental exposure.
Other forms of airborne contaminants include asbestos, which can cause hardening of the
pleura, scarring and thickening of the pulmonary alveoli (reducing the elasticity of the lungs, and
therefore, the volume of inhalations), as well as cancer in most types of lung cells due to the size of the
asbestos particles being similar to that of human chromosomes, hampering mitosis. Although its use is
now entirely illegal in Canada, and severely regulated in China, it is still found in older construction
projects and can be exposed during renovations. To limit its danger, in both nations, asbestos is usually
manipulated with care and only in well aerated environments while wearing air filters and eye
protection. Finally, even something as simple as concrete dust, generated during demolition operations,
can have serious health impact if inhaled, causing inflammation of the respiratory system and, if it
contains silica, silicosis, leading to serious inflammation and scarring of the upper pulmonary lobes. In
Canada, most workers dealing with large amounts of dust usually wear enclosed safety glasses and air
filters, while in China, it is very rare for additional protection to be worn when working in environments
filled with dust, despite the fact that state regulation requires both eye protection and air filters.
Finally, the last major source of safety hazards on constructions sites, reckless conduct, is
common in both nations, although some acts are much more common in China than in Canada. In
Canada, the most common types of reckless conduct are not using available movement restricting or fall
arrest systems when working at heights without the benefits of railings (such as when an individual is
installing the railing on a given level), and leaving equipment and material unattended, especially when
at heights. China faces similar issues, with workers often ignoring available safety harnesses when in a
rush or when dexterity is required and leaving many unattended objects when departing a site,
especially for the morning break. Indeed, despite efforts by the respective governments of each nation
and multiple deaths each year, these reckless habits remain relatively common as, for the most part,
they make life easier for the workers. Furthermore, China also faces an additional safety issue, caused
by that nation’s drivers. Indeed, while truck and machinery drivers on construction sites in Canada
usually drive carefully, and with the aid of signalers to avoid hazards, their Chinese homologues favor a
more aggressive style of driving. Namely, although they do not drive extremely fast, they do not tend to
adapt their driving to the characteristics of the road, resulting in frequent skidding and loss of control on
wet or icy roads. Moreover, as indicating one’s intents when driving a motor vehicle is all but unheard of
in China, it is difficult for pedestrians to anticipate how vehicles around them will be moving, a danger
further compounded by the general disregard for pedestrians in groups of less than five exhibited by
most Chinese drivers, including heavy machinery operators.
IV.4 Safety Equipment
No matter the amount of precautions taken, accidents are bound to happen in any industry
where a human element remains present. The construction industry is definitely not exempt from this,
and the even-changing nature of the work environment within the industry, combined with the
omnipresence of multiple sources of distraction and the physically demanding nature of the work, make
accidents in the construction industry particularly frequent and dangerous. In light of this, it is
understandable that the wear of adequate protective equipment be one of the primary elements of
health and safety regulation. However, inadequate protective equipment is also one of the primary
causes of serious injuries in accidents, as otherwise minor incidents become much more severe. Again,
as there are dozens of different pieces of protective equipment, each regulated by their own set of
standards, this comparison will focus on the most common ones.
Before we start however, it is important to note that the quality of the protective equipment in
Canada and in China, although usually adequate by itself, is by no means always so. Although this is
infrequent in Canada, as the North-American equipment industry is made up of a few larger
corporations, with very little import of cheap imitations, and so the product quality can easily be
controlled by the industry and the government both during production and field use, it is a major
problem in China, where cheap knock-offs providing inadequate protection represent a large segment of
all safety equipment sold and worn, as they are usually available at a much cheaper price, making them
a compelling choice for unscrupulous corporations, although large enterprises often favor quality
equipment to ensure conformity with regulations. This issue is further worsened by the lack of quality
testing in China; there are more than a thousand legal equipment producers, and untold more that
operate outside governmental control, but only 15 institutes authorized to conduct safety testing.
Verification of all, or even most, commercial products on the market is therefore impossible, and testing
of equipment used on actual construction sites is all but unheard of except amongst the largest
corporations who send in samples for testing in order to conform to the law.
On to the actual equipment itself, assuredly the most ubiquitous piece of protective equipment
in the construction industry in China and Canada is the safety helmet, or hard hat, whose wear is all but
compulsory in both nations. Indeed, in China, despite only being mandatory for individuals working on
the outside of structures, safety helmets, almost universally of the front-brimmed variety, are worn on
larger sites by nearly everyone from the moment they step onto a construction site to the moment they
leave it. The only major exceptions are workers on smaller renovation sites, who tend to forgo helmets
due to working almost exclusively indoors where they are not required, and corporate executives
viewing construction sites from afar, although the latter group usually takes to wearing hard hats when
doing close-up inspections. The situation is similar in Canada, although it is even rarer for individuals on
a construction site to be found without a helmet, with the only major exception being individuals
conducting finishing work on the inside of structures after exterior construction is complete. As always
however, some cases of negligence do happen, and, in both nations, it is not unheard of for individuals
to enter construction sites without helmets when not actively working on it, be it to communicate with
individuals on the site or simply to cross through it, sometimes resulting in fatal incidents.
Nearly as ubiquitous as helmets and just as important in protecting the health of workers in the
construction industry, work boots are another universal piece of protective equipment in Canada.
Indeed, regulation approved steel-toed boots with both toe and sole protection are universally worn by
the great majority of individuals within the construction industry in Canada from the moment they step
on any construction site, regardless of size or importance. Moreover, in difficult working conditions,
including frigid weather and floods, reinforced work boots, albeit specially adapted to these conditions,
are still worn. In China however, this is not the case; work boots incorporating steel protection are very
rarely worn, even on larger sites, despite being part of the mandatory equipment for many trades.
Indeed, workers, no matter the specific requirements of their trades, tend to favor either normal shoes
or rubberized boots if the working conditions are wet. Inspectors are amongst the only segments of the
worker population who regularly wear protective boots, although even amongst them it is not a
universal practice. This practice, combined with the lack of toe boards on most Chinese structures,
results in a dramatic increase in the amount of feet injury, including broken bones and amputated toes,
while also increasing the frequency of other types of leg injuries, such as sprained ankles, due to poor
ankle support when working in potentially slippery and uneven terrain.
Another important element of basic safety in the construction industry are work gloves. As could
be expected, their primary function is twofold: to protect workers against minor cuts and abrasions as
well as against harmful compounds in the environment, and to improve the worker’s grip on tools and
material. Nearly as universal as work boots in Canada, they are worn by almost all individuals conducting
some form of physical work on construction sites, with some variations based on the needs of specific
trades (some are water resistant, some are heavily insulated against heat or electricity, etc.). There is
however a minority of individuals who work without gloves, especially amongst trades requiring good
manual dexterity, as gloves do hamper fine motor control and reduce manual feedback. The situation on
larger sites in China is similar, with most workers wearing gloves when doing physical labour, particularly
when doing work that frequently exposes the hands to danger such as welding. Despite this, the gloves
themselves are rarely specifically made for the task at hands, reducing their effectiveness against some
hazards. Furthermore, individuals on smaller sites are often not provided with gloves, and so must make
do without them or acquire a pair on their own.
In addition to the basic security equipment, many trades in construction require additional
protective equipment. Most frequently, this is to ensure protection of the essential organs on the face,
which are not otherwise protected. As such, in Canada, protective glasses and air filters are worn by the
great majority workers doing work with any kind of chemicals (including painting) or in an environment
where they are exposed to large concentrations of suspended dust, such as concrete mixing and
demolition. Moreover, welders universally wear at least protective welding glasses, if not full welding
masks. This is in contrast with China, where, although the general population is often seen wearing cloth
masks to prevent contamination by disease and overexposure to the polluted air in cities, the majority
of construction workers do not wear them, even if their task requires it. For instance, despite
governmental regulations, workers will jackhammer concrete for extended periods of time without
wearing a mask or protective glasses (or any safety equipment beyond a helmet for that matter),
exposing both their eyes and lungs to particles of dust. The notable exceptions are the welders, who
almost universally wear welding masks, with some favouring smaller goggles instead.
Finally, a last set of important pieces of safety equipment are fall arrest and movement limiting
systems, intended to protect wearers from falls when railing is impossible or impractical to install. Here,
the situation is nearly identical in Canada and in China, and so, on larger sites, individuals doing early
structural work, both on primary structures and on scaffoldings, rarely tie themselves despite it being
mandatory in both states (anyone who is standing on a platform more than 3 m off the ground lacking
railing must be tied down to prevent dangerous falls), and although this enables them to have more
manoeuvrability while working (and is a tradition amongst most ironworkers), it exposes them to
additional dangers. Furthermore, individuals rapidly moving to and from the edges of buildings, without
stopping to conduct any extensive work, including inspectors, rarely tie themselves down, as it would
not be time efficient. Interestingly however, most individuals doing later work, including structural
welders, often tie themselves down. Despite this, on smaller sites and renovation projects, it remain
extremely rare for individuals in either nations to tie themselves down, as the expenses associated with
most suspension or fall arrest systems usually make them economically unviable on smaller sites.
IV.5 Inspections and Corruption
The final point of comparison for health and safety in the construction industries of Canada and
China is the quality and reliability of the inspections conducted in both nations. Indeed, although they
may still respect most, if not all, safety regulations, many corporations in both these nations conduct
acts of dubious legality to influence any inspector visiting their sites or inspection their equipment, in an
effort to have them be more lenient in their evaluation, thereby allowing the corporations to bypass
fines and the loss of public image associated with them. This, in turns, reduces the reliability of the
inspections, which do not necessarily reflect the actual quality and safety of the work conducted.
In China, corruption is very widespread amongst construction industry inspectors. Indeed, as
many corporations do not respect at least some of the health and safety or construction regulations in
place, and so often pay off inspectors to ignore infractions, with direct monetary payments, almost
universally in cash, being by far the most frequent method. This is so common that some corporations
go even further, bribing inspectors as a matter of fact, without even waiting for them to detect issues.
This not only results in unsafe buildings that are poorly constructed, but also in more accidents that tend
to be more severe, as inadequate safety equipment is not reported. Moreover, this travesty also
extends to the inspectors inside the corporations themselves, which often falsify inspection reports or
fail to report incidents in order to make it seem that their sites are safer than they are, both in the eyes
of the public and those of their foreign investors. Furthermore, the quality of the inspections in China is
further reduced by the general lack of competence of the inspectors themselves, who are often not
qualified to make comprehensive evaluations of all practices and safety equipment observed on a site.
The situation in Canada is similar, with non-negligible segments of the construction industry
routinely bribing inspectors to ignore breaches in regulations. However, this is often to disguise small
breaches to the construction code made to save costs, rather than major structural dangers or serious
health and safety infractions, for which bribes are rarely accepted, although the later certainly does
happen on larger sites. Moreover, due to the difficulty of moving large sums of money for illegal
purposes without leaving an obvious trail, payments in Canada, especially minor ones, are often made
through indirect and often perishable means such as hockey tickets, although the traditional direct
transfer of cash remains popular. Furthermore, the quality of the inspections in Canada tends to be high,
with inspectors being for the most part qualified and up to date on pertinent regulations. This means
that although there are some infractions to the regulations that are discovered and remain unpunished,
these are mostly minor ones, with the more severe ones usually being found and corrected.
V. Summary of Findings
Upon analysis of the information gathered through the research conducted on the state of
health and safety in the construction industry of China and Canada, a few conclusions can be made
about its relative state in both nations. Indeed, although the two states are theoretically similar on this
matter, there exists a noticeable distinction in practice due to poor enforcement in China.
As such, if only analysed from a theoretical standpoint, China and Canada have, at the
fundamental level, very similar health and safety systems. Indeed, in both nations, the basis of the
system rests on a series of standards that are approved by a central state authority and, if needed, latter
modified to conform to progressively more stringent norms as the organisational scale goes from the
general to the specific. Moreover, the standards themselves are often quite similar, and although there
are still some areas, most notably on the topic of minimal requirements for safety equipment, where the
Chinese standards remain less stringent than those in Canada, the intent behind the regulations is the
same. The primary distinction as far as the standards are concerned reside in how they are enforced; in
China, the fines for non-compliance tend to be proportionately much smaller than in Canada, and can
usually only be levied against corporate entities rather than particular individuals. Despite this, there
also remain some important distinctions between the organisation of health and safety in both states;
the most important ones being the differences in the organisational structure behind the creation and
enforcement of regulations. Indeed, the Chinese state is much more centralised than the Canadian one,
in which the provinces are mostly independent in their application and enforcement of regulations,
mostly due to the fact that the construction industry is a provincial concern in Canada rather than a
national one as is the case in China. In the end however, although the centralised nature of the Chinese
system does lend itself to loss of productivity and additional corruption through bureaucratic red tape,
the structural differences between the two systems do not modify in any great way the manner in which
the system should work in theory.
However, as it happens in many things, reality does not conform itself to theory, and so despite
being theoretically similar, the practical application of the health and safety norms in Canada and China
differ somewhat in practice. Indeed, despite the regulations being similar, they are important
differences in how they are applied by the construction industry in both nations. Most importantly, the
frequency with which standards are entirely ignored, both from a personal and corporative level, is
much greater within the Chinese industry, with some regulations being all but inexistent in practice,
leading to an increase in both the frequency and severity of accidents on constructions sites.
Furthermore, even when the standards and proper practices appear to be applied correctly, the
equipment used in China may be inadequate due to poor quality control. Finally, although corruption is
present (and even frequent) in the construction industry of both states, it is more common and more
flagrant in China, which further hampers the application of the health and safety regulations. In
conclusion, despite being similar in theory, it can be observed that in practice, the state of health and
safety within the construction industry in China is worse than that in Canada due to inadequate
enforcement and quality control, which leads to disregard for the regulations, both amongst the
workers and the employers.
With this being said, it is important to note that the state of health and safety in the
construction industry in China has progressed immensely within the last few years, and its progression
could best be likened to that seen at the start of the 20th century in the West following the rise of
unionization. Indeed, due to the growing pressure from both worker groups within the industry and
foreign influence, the gap between the theoretical norms and what is seen in reality is steadily
diminishing. Of course, it is likely that the norms will never be fully applied, but it is probable that major
progress will continue to be made in the next decades.
References
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---. Z89.1-2009 – Safety Requirements for Industrial Head Protection. 2009. Print.
Centre canadien d'hygiène et de sécurité au travail. "Limites d'exposition au bruit au Canada." 07 April 2011. Web. 01 May 2013. <http://www.cchst.ca/oshanswers/phys_agents/exposure_can.html>.
Canada. Ministry of Justice. Canada Labour Code. 2013. Web. <http://laws-lois.justice.gc.ca/eng/acts/L-2/>.
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---. Z195-M1984 - Protective Footwear. March 1984. Print.
Other Canadian standards in print or electronic form
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IHLO. "Health and Safety in China: Hats, shoes, gloves and masks….." IHLO. International Trade Union Confederation Hong Kong Liaison Office. Jan 2007. Web. 3 May 2013. <http://www.ihlo.org/LRC/WC/300107.html>.
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Annex 1: Sample Interview Sheet
Please note that indented lines are additional questions, to be asked based on the answer to the earlier
question, and usually represent additional precisions.
Questions Interview Health and Safety
State:
What regulates health and safety?
Are there any official documents?
What organisation is responsible for creating the regulations on health and safety in worksites?
Is regulation created on a general (or national) basis, or is it industry or corporation based?
Is there an organisation responsible for ensuring the regulations are upheld?
Are worker unions allowed to demand modifications in the application of regulations regarding health and safety?
Are the regulations followed on most sites?
Are the regulations followed to the minimal acceptable level or to a higher standard?
When the regulations are not followed, is the responsibility normally on the employee’s or the employer’s part?
Are the employees trained in the proper use of protective equipment?
Are employers forced to inform the employees of any and all dangers they may be exposed to while working on a site?
Are there legal measures on both sides to ensure respect of health and safety measures?
Are there any legal measures for compensation in the case of accidents related to health and safety incidents?
Questions about specific health and safety measures to compare
Annex 2: Sample Observations Checklist
Please note that again, indented lines are additional questions, to be asked based on the answer to the
earlier question, and usually represent additional precisions.
Observations Checklist
Site:
Theoretical:
Training on safety protocols
Training on emergency procedures
Employees up to date
Presence of an emergency plan
Up to date
Known by the workers
Presence of safety personnel
Not reachable in adequate delay
Environmental:
Presence of direct physical danger (fire, live wire, rock avalanche, etc.)
Non-indicated
Workers not/inadequately protected
Presence of hazardous materials (toxic, corrosive, radioactive)
Non-indicated
Workers not/inadequately protected
Presence of dangerous atmosphere (gas composition, particles in suspension)
Non-indicated
Workers not/inadequately protected
Presence of indirect environmental dangers (high winds, wet or icy surface, etc.)
Non-indicated/unknown to workers
Workers not adequately equipped
Human:
Dangerous practices (ignored safety equipment, reckless driving, unattended objects, etc.)
Ordered by the administration
Unhealthy work environment (work hours, psychological and social environment, stress)
Created by the administration