OSHA
U.S. federal regulation for workplace safety standards
GDPR UK
UK regulation for personal data protection and privacy.
Quick Verdict
OSHA ensures US workplace safety through standards and inspections, while GDPR UK mandates personal data protection with rights and fines. Companies adopt OSHA to prevent injuries and comply federally; GDPR UK to safeguard privacy and avoid massive penalties.
OSHA
Occupational Safety and Health Act of 1970
Key Features
- Enforces General Duty Clause for recognized hazards
- Mandates hierarchy of controls prioritizing engineering
- Codifies detailed standards in 29 CFR 1910
- Imposes risk-prioritized inspections and penalties
- Requires electronic injury recordkeeping and reporting
GDPR UK
UK General Data Protection Regulation (UK GDPR)
Key Features
- Accountability principle requiring demonstrable compliance
- Seven core data processing principles
- Extra-territorial scope targeting UK individuals
- 72-hour ICO breach notification requirement
- Mandatory DPIAs for high-risk processing
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
OSHA Details
What It Is
Occupational Safety and Health Administration (OSHA), established by the Occupational Safety and Health Act of 1970, is a U.S. federal regulation enforcing workplace safety. Its primary purpose is assuring safe conditions via standards in 29 CFR Parts 1910-1928. It uses a performance-based approach with the General Duty Clause for uncodified hazards.
Key Components
- Subparts covering walking surfaces, PPE, HazCom, LOTO, toxic substances.
- **Hierarchy of controlselimination, substitution, engineering, administrative, PPE.
- Recordkeeping (OSHA 300/300A/301), inspections, penalties up to $165,514.
- No certification; compliance via enforcement and state plans.
Why Organizations Use It
Mandated for most U.S. employers; reduces injuries, penalties, insurance costs. Enhances reputation, productivity; aligns with ESG. Mitigates legal risks from citations.
Implementation Overview
Phased: gap analysis, written programs (IIPP), training, audits. Applies to general industry, construction; all sizes. Ongoing via inspections, no formal certification.
GDPR UK Details
What It Is
UK General Data Protection Regulation (UK GDPR) is the UK's post-Brexit data protection law, adapting EU GDPR with the Data Protection Act 2018. It is a binding regulation enforcing risk-based accountability for personal data processing by the Information Commissioner's Office (ICO).
Key Components
- Seven core principles: lawfulness, purpose limitation, data minimisation, accuracy, storage limitation, integrity/confidentiality, accountability.
- Individual rights (access, rectification, erasure, portability, objection).
- Controller/processor obligations, DPIAs, breach notifications, lawful bases.
- No certification; compliance via demonstrable records (RoPA), audits.
Why Organizations Use It
- Legal mandate for UK-established or targeting entities.
- Mitigates fines up to 4% global turnover or £17.5M.
- Builds trust, reduces breach risks, enables cross-border operations.
Implementation Overview
- Phased: gap analysis, RoPA, policies, training, DPIAs, vendor contracts.
- Applies to all sizes handling UK personal data; ongoing governance, ICO audits.
Key Differences
| Aspect | OSHA | GDPR UK |
|---|---|---|
| Scope | Workplace safety, health hazards, recordkeeping | Personal data processing, privacy rights, security |
| Industry | All US industries, general/construction/agriculture | All UK sectors handling personal data |
| Nature | Mandatory US federal regulation with inspections | Mandatory UK regulation with ICO fines |
| Testing | Inspections, recordkeeping audits, no certification | DPIAs, audits, no mandatory certification |
| Penalties | Civil fines up to $165k per willful violation | Fines up to £17.5M or 4% global turnover |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about OSHA and GDPR UK
OSHA FAQ
GDPR UK FAQ
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