工伤保险伤残待遇国际比较——以德国、英国、美国、日本和中国为例

International Comparison of Work-related Injury Insurance Benefits——Case Study of Germany,Britain,America,Japan and China

通过详细介绍德、英、美、日和中国五国的工伤保险伤残待遇项目,纵向比较五国十多年的工伤保险伤残待遇的变迁,运用待遇收入替代率横向比较五国的工伤保险伤残待遇水平。研究结果表明:我国的工伤保险整体伤残待遇水平最高,日本、德国和美国紧随其后,英国排名末尾;我国的工伤保险伤残待遇补偿模式与德国、美国和日本的较为相似,以德、美和日三国的补偿经验为例,以本人工资的80%~90%作为暂时性伤残待遇的基数,稍微降低伤残待遇收入替代率;通过细化伤残等级或者将伤残等级转化为致残程度,更加细化永久性伤残待遇;在因工死亡待遇方面应相应降低一次性工亡补助金待遇,细化遗属待遇、扩大遗属范围来弥补因工死亡待遇的降低。

This article introduces the work-related injury insurance benefits of Germany,Britain, America, Japan and China in detail, and compares the changes of more than 10 years longitudinally. It uses income replacement rate of di-sability benefits to measure the level of work-related injury insurance benefits in the five countries. The results show that China has the highest overall level of disability benefits,followed by Japan,Germany and America, and Britain has the lowest overall level of disability benefits. The compensation mode of work-related injury insurance in China is relatively similar to that in Germany,America and Japan. Learning compensation experience from Gennany,America and Japan, China slightly lowers income replacement rate of disability benefits with 80-90 percent of individual wage as the base. By classifying the degree of disability,China can determine permanent disability benefits more detailedly. It’s necessary to lower the one-time work-related death benefits, classify the benefits of family dependents of the deceased, and increase family dependents of the deceased to make up for the reduced benefits due to work-related death.