Different ways of implementing Directives across Europe

Here at Laidler, we're preparing for an exhibition in Dublin which is taking place on November 16th and 17th. As is often the case, we've also got a speaking slot at the show and we'd decided to talk about practical machinery safety risk assessments, introducing the requirements of PUWER, (Provsion and Use of Work Equipment Regulations). PUWER implements the Amended Work Equipment Directive in the UK which would be fine for Northern Ireland but not for Dublin in the South. A little research brought to light the different ways in which countries implement Directives and why, if you are working across Europe, you need to be aware of these differences.

In the UK, we have Regulations such as PUWER, Display Screen Equipment, LOLER (Lifting Operations and Lifting Equipment) and others. Each are implementations of a European Directive. When you look at Ireland, you have the General Application Regulations which includes chapters for the individual Directives. 2 completely different approaches, but covering all the same information. it's relatively straight forward to compare the 2, but it's worth knowing for the future that if you have responsibilities across Europe, what should be a straight forward process, i.e. dealing with European legislation, may be a little trickier than you first imagined due to the different approaches used.