海峡两岸职业安全卫生法制比较

The Comparative Study of the Cross-Straits Occupation Safety and Health Legal Systems

职业安全卫生法是劳动基准法的重要组成部分,并因其涉及面广、内容庞杂而渐自成体系。由于法制背景的不同,两岸的职业安全卫生立法在体例结构、适用范围以及具体制度内容等方面存在诸多差异。在当前,两岸事实上面临着同样的问题,即要将先进理念与现行立法相结合,从根本上带动整个职业安全卫生立法的革新。

The legislation of occupation safety and health in China's Mainland is still at the starting stage, backward nearly 30 years when compared with Taiwan. Because of their different legal system backgrounds, a great deal of differences in such aspects as style structure, applicable scope and concrete system content, etc. exist in the legislation of cross-straits occupation safety and health. At present, the two sides of the Straits face a common problem, which is how to combine advanced ideas and current legislation in order to drive the innovation of the legislation for the whole occupation safety and health.