Factors influencing the transferability of occupational safety and health economic incentive schemes between different countries
研究了影响职业安全健康经济激励计划在不同国家间转移的法律、政治和文化因素，基于欧盟27国的调查，发现各国系统设计高度相似，但保险市场结构差异是关键障碍。
OBJECTIVES: This article looks at the factors that influence the transferability of different types of occupational safety and health (OSH) economic incentives from one country to another. METHODS: To review the legal, political, and cultural framework conditions for economic incentive schemes in the European Union (EU), the European Agency for Safety and Health at Work (EU-OSHA) surveyed EU member states about the state of such schemes in their countries. In addition to the survey responses, relevant information on existing schemes and their national context within the 27 EU member states was gathered through reports, articles, and databases. Following this, countries were clustered according to cross-cultural differences. RESULTS: Despite the apparent variations in Europe's social security systems, there is a high degree of similarity between the countries regarding the basic criteria of design of the system. In addition, different kinds of incentives are used in different member states regardless of the social insurance system. When it comes to insurance incentive schemes, the fundamental difference between countries is whether the workers' compensation scheme is based on a competitive market between private insurance companies or a kind of monopoly structure, where the employers do not have the choice between several insurance companies. A clear majority of 19 of the 27 EU member states have a monopoly system. CONCLUSIONS: Subsidy systems, tax incentives, and insurance-based "experience rating" are theoretically -possible in all EU countries. In competitive insurance markets, effort-based incentives are more difficult to achieve. A possible solution could be the introduction of long-term contracts or the creation of a common prevention fund, financed equally by all insurers.