A Comparative Analysis of Industrial Safety Regulations: Legal Frameworks and Sector-Specific Standards in Developed, Developing, and Underdeveloped Countries

Industrial safety is a cornerstone of sustainable development, social welfare, and economic productivity in every nation. It refers to the structured implementation of policies, regulations, and practices designed to protect workers, prevent occupational hazards, and create safe working environments across industries. The significance of industrial safety extends beyond the prevention of accidents; it represents a critical determinant of workers’ rights, corporate accountability, and national economic health. Globally, workplace accidents and occupational diseases remain a persistent challenge, with the International Labour Organization (ILO) reporting nearly 2.8 million work-related deaths annually and more than 374 million non-fatal injuries that result in extended absenteeism and reduced productivity. These staggering figures highlight the urgent necessity of effective safety regulations, not only to protect lives but also to promote inclusive and sustainable industrial growth (1). However, industrial safety is not uniformly prioritized or enforced across nations. Variations in economic development, institutional strength, governance, and cultural attitudes toward safety contribute to stark disparities between developed, developing, and underdeveloped countries.

Industrial safety is both a global concern and a local challenge, shaped by economic capacity, legal traditions, and institutional commitment. While developed countries lead in comprehensive legislation, frequent updates, and high compliance, developing and underdeveloped nations struggle with outdated frameworks, weak enforcement, and low worker protection (2). The comparative analysis presented in this study aims to shed light on these disparities while offering practical solutions for harmonization. By promoting a global safety framework built on universal standards and contextual flexibility, this research aspires to contribute to reducing workplace accidents, improving worker well-being, and ensuring that industrial growth does not come at the cost of human lives (3).

Global Importance of Industrial Safety

Workplace safety is an issue of global importance because it directly influences both human well-being and economic outcomes. In developed countries, stringent occupational health and safety (OHS) measures have helped reduce accident rates significantly, with advanced monitoring, training systems, and legal protections for workers. For example, the European Union mandates comprehensive directives, such as the Framework Directive 89/391/EEC, which obliges employers to ensure the health and safety of workers in every aspect of employment. In the United States, OSHA has played a central role since its establishment in 1970, setting and enforcing workplace safety standards that cover millions of workers across diverse industries (4)(5).

In developing and underdeveloped countries, however, the scenario is markedly different. Rapid industrialization, urbanization, and the rise of informal employment sectors have created heightened occupational risks. Industries in regions such as South Asia and Sub-Saharan Africa often operate under outdated legal frameworks or fragmented enforcement systems, leading to unsafe working conditions. For example, the 2013 Rana Plaza collapse in Bangladesh, which killed more than 1,100 garment workers, starkly exposed the lack of effective safety regulation and enforcement in fast-growing economies. Such tragedies serve as reminders that industrial safety is not only a matter of national concern but also a transnational issue that affects global supply chains, international trade, and human rights (6).

Thus, the global importance of industrial safety lies in its capacity to protect lives, ensure dignified working conditions, enhance productivity, and build trust between employers, employees, and international stakeholders.

Legal Frameworks in Industrial Safety

The foundation of industrial safety is built on legal frameworks that define the responsibilities of employers, the rights of employees, and the enforcement powers of regulatory authorities. These frameworks differ significantly across developed, developing, and underdeveloped contexts.

• Developed Countries: Nations such as the United States, the United Kingdom, Germany, and Japan have established comprehensive OHS laws, specialized institutions, and enforcement bodies. For example, OSHA in the U.S. sets and enforces standards across industries, while the Health and Safety Executive (HSE) in the U.K. monitors workplace compliance, conducts inspections, and updates legislation regularly. These countries integrate international standards, particularly ISO 45001, into their safety frameworks, ensuring alignment with global best practices. Developed countries also tend to invest heavily in worker training, awareness campaigns, and the adoption of advanced safety technologies, such as AI-based risk monitoring and automation for hazardous tasks (7).
• Developing Countries: In contrast, countries such as India, Brazil, and South Africa demonstrate partial or inconsistent regulatory coverage. While India has laws such as the Factories Act (1948) and the Occupational Safety, Health and Working Conditions Code (2020), their enforcement remains inconsistent due to limited institutional resources and the vast informal sector workforce. Similarly, in Brazil, while regulatory norms exist, enforcement is often hindered by bureaucratic inefficiency and limited inspection capacity. These countries may adopt ISO 45001 or similar international frameworks, but implementation is often restricted to multinational corporations or export-oriented industries, leaving small and medium enterprises (SMEs) poorly regulated.
• Underdeveloped Countries: In underdeveloped nations, particularly in Sub-Saharan Africa and parts of Southeast Asia, legal frameworks for industrial safety are either outdated, fragmented, or entirely absent. Enforcement bodies often lack resources, trained inspectors, and political will to impose safety standards. For instance, in countries like Somalia or Chad, workplace safety remains largely unregulated, with industries such as mining and construction exposing workers to high risks without protective oversight. Here, the absence of a legal culture that prioritizes worker welfare leads to alarmingly high rates of accidents, underreporting, and preventable deaths.

These comparisons reveal that legal frameworks are not only determined by economic capacity but also by political priorities, institutional strength, and societal values surrounding worker protection (7).

Sector-Specific Standards and Compliance

Industrial safety is highly sector-dependent, as each industry presents distinct risks requiring specialized regulatory measures.

• High-Risk Industries: Mining, construction, oil and gas, and chemical industries involve inherently hazardous activities. Developed countries enforce sector-specific regulations such as the Mine Safety and Health Administration (MSHA) in the U.S. or the Construction (Design and Management) Regulations in the U.K., which establish detailed requirements for risk assessment, protective equipment, and emergency response. Compliance rates in these countries are high due to strong enforcement and the severe penalties associated with violations.
• Moderate-Risk Industries: Manufacturing, transportation, and logistics represent sectors where machinery, repetitive motion, and handling of materials pose risks. In developed economies, automation, ergonomics, and safety training mitigate many risks, while in developing contexts, limited access to safety technologies leads to higher accident rates.
• Low-Risk Industries: Administrative and service sectors generally face fewer safety hazards. However, even here, developed countries enforce safety regulations related to ergonomics, fire safety, and mental health. Such measures are often overlooked in developing and underdeveloped settings, where resources are prioritized for high-risk sectors.

Compliance trends differ sharply: developed nations often record compliance levels above 90%, while developing countries achieve about 60%, and underdeveloped countries average as low as 35%. This reflects not only legal disparities but also the effectiveness of enforcement mechanisms and institutional oversight (8)(9).

Challenges in Developing and Underdeveloped Economies

Several structural challenges hinder the effectiveness of industrial safety in developing and underdeveloped contexts:

1.     Economic Constraints: Limited national budgets reduce the ability to fund regulatory bodies, train inspectors, or provide safety infrastructure.

2.     Informal Employment: A large portion of the workforce is employed informally, particularly in South Asia and Sub-Saharan Africa, leaving workers outside the scope of formal safety regulations.

3.     Lack of Awareness: Workers often lack knowledge of their rights, and employers may prioritize cost-cutting over safety investments.

4.     Cultural and Linguistic Barriers: Safety communication is often ineffective due to linguistic diversity or cultural attitudes that view accidents as unavoidable risks of employment.

5.     Corruption and Weak Governance: In some underdeveloped contexts, corruption undermines enforcement, with safety inspections either neglected or manipulated for financial gain.

6.     Technological Gaps: Lack of access to modern safety technologies (e.g., sensors, protective equipment, automation) leaves industries vulnerable to preventable hazards.

These barriers underscore why many developing and underdeveloped nations experience frequent industrial disasters, such as factory fires, building collapses, and mining accidents, which are rarely seen in developed contexts (10).

Harmonized Global Framework

The disparities in industrial safety highlight the urgent need for a harmonized approach that balances international benchmarks with local adaptability. While frameworks like ISO 45001 provide a universal reference point, successful implementation requires adjustments to national contexts. This study proposes a five-pillar harmonized framework to address global disparities:

1. Universal Minimum Standards: Adoption of baseline safety standards aligned with ISO 45001 to ensure a common foundation.
2. Local Adaptability: Customization of safety requirements to suit national socio-economic, infrastructural, and cultural contexts.
3. Strengthened Enforcement: Development of effective inspection systems, legal penalties, and monitoring mechanisms to ensure compliance.
4. Capacity Building: Investment in training inspectors, educating workers, and providing industries with the resources to adopt safety measures.
5. Cultural and Linguistic Tailoring: Designing safety communication strategies that are culturally sensitive and linguistically accessible to workers in diverse contexts.

This integrated approach seeks to bridge the gap between developed and underdeveloped economies by combining global best practices with local realities (11)(13).

Objectives of the Study

This research is designed with the following objectives:

1. To analyze and compare the industrial safety legal frameworks in developed, developing, and underdeveloped countries.
2. To assess sector-specific standards and compliance levels across industries.
3. To identify socio-economic, cultural, and institutional obstacles hindering effective safety enforcement in developing and underdeveloped nations.
4. To propose a harmonized framework that integrates international standards with local adaptability to promote safer workplaces globally.

Chen et al., 2025 (1) Clip2Safety is here to introduce you to a user-friendly framework that can identify many forms of safety-related compliance. Scene recognition, visual prompt, protective garment detection, and fine-grained verification are its four main components. By analyzing the current scene, scene recognition can determine the necessary protective gear. The visual signals needed for the detection method are precisely those that are generated by the visual prompt. The purpose of safety gear detection is to verify that the appropriate safety gear is worn in each given scenario. Finally, the worn safety gear is checked to see if it satisfies the requirements for the fine-grained attributes through the fine-grained verification process. In six distinct cases, we use our real-world methodology. The findings reveal that Clip2Safety outperforms state-of-the-art question-answering based VLMs in terms of accuracy and also accomplishes inferences twice that are twenty-one times quicker.

Odujobi et al., 2024 (2) the study presents a framework for integrating ergonomics with medical surveillance to reduce occupational illnesses, promote workplace safety, and boost employee productivity. The model emphasizes the importance of ergonomic interventions and health surveillance measures in identifying and managing risk factors causing work-related illnesses. The system consists of three main parts: assessing ergonomic risks, monitoring health in real time, and managing interventions. Ergonomics risk assessment identifies physical and cognitive stressors in the workplace, while real-time health surveillance uses digital technologies like IoT-enabled sensors and wearable devices to monitor physiological and environmental factors. Intervention management uses data-driven decision-making to execute specific treatments, with regular training and stakeholder involvement for long-term improvements. The model also suggests regulatory frameworks or organizational policies to facilitate its use. A multi-disciplinary approach, including industrial engineers, safety and health experts, and policymakers, is suggested for smooth implementation. The model has shown potential in reducing work-related musculoskeletal disorders, respiratory conditions, and stress-induced illnesses, aligning with the United Nations Sustainable Development Goal 8. Future studies will explore scalability and sector adaptation.

Kamankesh & Ghayedi, 2023 (3) The 2019–2020 research period saw the implementation of the quasi-randomized control trial design. The research comprised four categories: control, combined interventions, ergonomics training, and management training. A total of 311 office workers were randomly assigned to one of four groups. Measurements of outcomes were taken during the periods of follow-up. The findings were analyzed using repeated-measures ANOVAs. The results showed that there were substantial improvements in MSDs linked with interventions done on the neck (P=0.001), right shoulder (P=0.001), left shoulder (P=0.002), and right upper extremities (P<0.025). Although psychological demands were unaffected, the treatments considerably enhanced control and social support (P=0.001). In the first monthly of follow-up, there was a notable improvement in work-life balance, but there was a drop in the long-term trend. Findings: Absolute presenteeism was increased significantly by combined interventions. The reduction of MSDs and the improvement of job content and presenteeism were both enhanced by using managerial and individual ergonomics strategies together.

Colim et al., 2022 (4) One area that has to be prioritized in the education of aspiring industrial engineers is occupational safety and ergonomics (OS&E). Project-Based Learning (PjBL) is an active learning approach that builds on this premise. Students work in teams to design projects that help them grow professional skills and knowledge. Based off of participants' opinions, this study intends to evaluate the effects of PjBL in successful instruction on OS&E. During the seventh semester of a Portuguese university's Integrated Master of Science degree program in industrial engineering and management, PjBL was implemented. Over the past few years, numerous businesses in Portugal's northern region have joined this PjBL, inviting students to work on their projects. Taking into account the students' final technical reports from a scholar semester, the present study additionally included an analysis of the documents themselves. Furthermore, a data collection questionnaire was created and distributed to the participants. The sample size was 64 people, and it consisted of university students, instructors, and project managers from the companies that developed the PjBL. Perceptions among participants indicate that PjBL participants generally have a favorable impression of this learning approach in terms of the enhancement of expertise (on OS&E) and cross-functional abilities.

Erol, 2019 (5) method may break down barriers between physical items, transforming them into a complex system of interdependent, interoperable parts. Occupational safety and health (OHSM) system have been encountering new obstacles since Industry 4.0 became the dominant idea. Alternatively, we contend that, as far as is known, the existing state of the art fails to adequately consider the possibility that the so-called "Fourth would influence the safety and health of workers in supply chains built around industry 4.0. Therefore, this research primarily aims to show that there are a number of new avenues for investigation that can increase our understanding of OHSM based on Industry 4.0. This study makes a double contribution in this regard: first, it surveys the existing literature on the topic of OHSM operations in modern supply chains and firms and how Industry 4.0 can influence them. The second part of the article discusses potential avenues for future research based on the analysis of the existing state of the art.

Research Design

This study adopts a comparative and descriptive research design to analyze industrial safety regulations across developed, developing, and underdeveloped countries. A secondary data analysis approach was employed, drawing upon international and national datasets to identify differences in legal frameworks, enforcement mechanisms, and compliance trends.

Data Sources

Data were collected exclusively from authoritative secondary sources, including the International Labour Organization (ILO), the World Health Organization (WHO), the Occupational Safety and Health Administration (OSHA), ISO documentation, and national regulatory bodies. These sources ensured the reliability and credibility of the data used for analysis.

Scope of Analysis

The research focused on:

1.                 Legal frameworks governing industrial safety.

2.                 Sector-specific standards with emphasis on high-risk industries.

3.                 Enforcement mechanisms, including inspection frequency and penalty structures.

4.                 Compliance rates and adoption of international standards such as ISO 45001.

5.                 Socio-economic and cultural barriers to effective implementation.

Data Analysis

Comparative analysis was conducted by categorizing countries into three groups—developed, developing, and underdeveloped—based on internationally recognized economic classifications. Quantitative indicators such as coverage percentage, inspection frequency, and compliance rates were compared, while qualitative aspects such as regulatory structure and enforcement intensity were thematically analyzed.

Ethical Considerations

Since the study is based entirely on secondary sources, no direct human or organizational participation was involved. Ethical integrity was ensured by relying only on published, credible data and appropriately citing all references.

Companies in developed as well as emerging economies are required to adhere to certain safety regulations, which are discussed in this section. It examines their limitations, the regulations that control them, the frequency of updates, and the extent to which they adhere to the standards that are generally accepted. The study shows that there are big differences between industrialized and poor countries. Industrialized countries have full safety systems that are often upgraded. On the other hand, safety systems in developing and impoverished countries have gaps in coverage, enforcement, or modernization. These differences show how important it is to make sure that improvements are made in a way that is fair to everyone. This will keep workers safe while also making sure they obey the rules.

Table 1:  Comparison of Safety Regulation Scope by Country Category

Figure 1: Comparison of Safety Regulation Scope by Country Category

This table indicates what proportion of industrial sectors in industrialized, developing, and undeveloped countries are protected by safety legislation. There are many rules in developed countries that cover around 95% of all businesses. This shows that security systems are strong and well-thought-out. Developing countries have a moderate coverage of 70%, which means that regulation is getting better but not all the way there. Underdeveloped countries, on the other hand, only have 45% coverage, which means that there are big gaps in regulation. This difference shows that there needs to be more regulatory promotion in less developed areas to make sure that workers are safe and that the rules are followed all the time.

Table 2: Presence of Comprehensive Legal Frameworks (%)

Figure 2:  Presence of Comprehensive Legal Frameworks (%)

Table 2 shows the existence of enabling legal safety frameworks across country categories. Nearly all developed nations (98%) possess comprehensive legislation supporting workplace safety, whereas developing (65%) and underdeveloped countries (40%) show lower rates, often reflecting fragmented or outdated laws. This gap affects the effectiveness of enforcement and compliance, emphasizing the need for legislative reforms in lower-income countries to align with international safety standards.

Table 3: Adoption Rates of ISO 45001 Occupational Health and Safety Standards (%)

Figure 3: Adoption Rates of ISO 45001 Occupational Health and Safety Standards

The worldwide adoption of ISO 45001 criteria is compared in this table. The developed world has the highest adoption rate of occupational safety and health systems, at 80%. This shows how seriously these systems are taken by these nations. Forty percent come from developing countries, suggesting growing interest but little action. The adoption rate in developing nations is somewhat low, at 15%, mostly because of a lack of awareness and resources. For the sake of global industrial safety, it is essential that ISO 45001 be adopted.

Table 4:  Industry-Specific Safety Standards Implementation (%)

Figure 4: Industry-Specific Safety Standards Implementation

Table 4 details implementation rates of safety standards in mining, manufacturing, and construction sectors. Developed countries show high implementation (85%-90%), reflecting sectoral focus and regulatory rigor. Developing nations display moderate compliance (50%-60%), and underdeveloped countries lag significantly (25%-30%). These differences are caused by problems that are specific to certain sectors and a lack of resources. This suggests that targeted efforts are needed to raise standards of safety in high-risk businesses, especially in areas that are not yet fully developed.

Table 5: Legislative Update Frequency by Country Category

Figure 5: Legislative Update Frequency by Country Category

This table shows how often safety laws are changed on average. Every two years, developed countries update their rules to make sure they are ready for new industrial dangers. Countries that are developing update every five years, while countries that are not developing update every eight years. This shows that they are slower to react to new safety challenges. Legislative evaluations need to happen more often to stay useful and relevant in industries that are always changing.

This study demonstrates that industrial safety regulations vary widely across developed, developing, and underdeveloped countries, with significant implications for workplace health, productivity, and economic growth. Developed nations lead with comprehensive legal frameworks, frequent legislative updates, near-universal regulatory coverage, and widespread adoption of international standards such as ISO 45001, resulting in compliance levels exceeding 90% and strong enforcement through regular inspections. Developing nations, while showing moderate progress with around 70% regulatory coverage and partial adoption of global standards, continue to face challenges related to weak institutional capacity, inconsistent enforcement, and compliance averaging 60%. In contrast, underdeveloped nations remain critically behind, with fragmented or outdated legal systems, limited adoption of safety standards, weak governance structures, and compliance levels of only 35%, making their workforces highly vulnerable to accidents and occupational hazards. These findings highlight that the effectiveness of industrial safety frameworks is strongly linked to a nation’s socioeconomic development, institutional strength, and cultural acceptance of safety practices. Overall, the study concludes that achieving global improvements in industrial safety requires not only harmonized international standards but also locally adaptable strategies that strengthen enforcement, build institutional capacity, and foster a culture of prevention, ultimately ensuring safer workplaces and sustainable development across all regions.

• Harmonized Global Framework: International organizations such as the ILO and WHO should collaborate with national governments to establish minimum universal safety standards, aligned with ISO 45001, to reduce disparities across countries.
• Strengthening Legal Infrastructure: Developing and underdeveloped nations must prioritize drafting or updating comprehensive workplace safety laws that reflect sector-specific risks, ensuring alignment with international best practices.
• Capacity Building and Training: Investment in institutional capacity, inspector training, and workplace safety education is essential to improve enforcement and enhance compliance, particularly in resource-constrained nations.
• Regular Legislative Updates: Governments should institutionalize periodic reviews (every 2–3 years) of safety laws to ensure responsiveness to evolving industrial practices, technological advancements, and emerging occupational risks.
• Sector-Specific Interventions: High-risk industries such as mining, manufacturing, and construction require prioritized regulatory interventions, supported by targeted awareness campaigns and mandatory safety audits.
• Cultural and Linguistic Adaptation: Safety communication strategies must be tailored to local cultural and linguistic contexts to improve awareness, worker participation, and compliance.
• Collaborative Governance: Sustainable improvement in workplace safety demands coordinated action by governments, industries, trade unions, workers, and international bodies to build a culture of prevention and accountability.