Comparative Study of Health and Safety on Construction Sites in Canada and

China

By
Gabriel Lavoie

1st Cohort: 2011-2013

Table of Contents
I.
Introduction ......................................................................................................
......................... 3
II.
Methodology .....................................................................................................
........................ 6
III. Comparison of Theoretical Norms in Construction Health and Safety
....................... 7
III.1 Governing
Bodies ....................................................................................................... 7
III.2 Safety
Training ...........................................................................................................
8
III.3
Inspection .........................................................................................................
......... 9
III.4
Enforcement ....................................................................................................
....... 10
III.5
Standards .........................................................................................................
........ 11
IV. Comparison of Practical Observations on Construction Health and
Safety .......................... 12

IV.1 Safety Training

........................................................................................... 12
IV.2 Heights
Safety .......................................................................................................... 14
IV.3 Environmental
Safety ............................................................................................... 16
IV.4 Safety
Equipment .....................................................................................................
19
IV.5 Inspections and
Corruption ..................................................................................... 22
V. Summary of
Findings ............................................................................................................
.. 23
References ........................................................................................................
.......................... 25
Annex 1: Sample Interview Sheet
.................................................................... 27
Annex 2: Sample Observation Checklist
.................................................................. 29

Be they houses, temples or palaces, buildings are one of the fundamental

expressions of civilization. Requiring cooperation among many to achieve a
common goal, they are, in and of themselves, a testimony to human ingenuity and
cooperation.
However, when one walks through the dome of a cathedral, stands atop a tall
skyscraper, or walks besides a ruined fortification, it is easy to be so amazed by the
scale of the building, by the genius of the engineering that went into the structure,
that one forgets about the humans behind it, the dozens, hundreds or ever
thousands who labored, bled and sometimes even died to achieve what we see
before us.
Throughout the ages, the value of human life has varied greatly, from nearly
worthless to having immeasurable value. Despite this, loss of human life is rarely
beneficial; after all, loss of experienced and qualified labor is never good for either
productivity or for the final quality of a work. As such, for as long as humans have
been putting their lives in danger to build things, they have been trying to ensure
that they survive the experience. However, it is not until the rise of syndication in
the West that a generalized movement towards ensuring worker safety appeared.
This movement, originally based around the syndicates themselves, was, in many
states, eventually absorbed into the state's health policies, leading to the present
day structure of national and even international regulations on health in safety on
construction sites.
Indeed, today in the West, ensuring the continued health and safety of the
workforce is one of the primary concerns of most corporations. Although it could be
said that this is mostly the result of the growing concern for human life that began
in Occident during the Enlightenment, simple economics, as well as basic human
nature, seems to point to a rather more mundane motivation, profit. As could be
expected, the unplanned reduction of the qualified workforce through accidents is
not profitable for any corporation, as it results in a loss of productivity and, often,
other associated consequences such as disability pay, lawsuits and bad publicity.
This is the primary reason for safety measures within the corporate environment
itself, particularly for any safety measures going beyond what is dictated by the
state. Indeed, at least in the West, the moral imperative behind ensuring health and

safety falls mostly upon the state itself, whose values, including the preservation of
human life and the elimination of needless suffering, are those shared, at least
theoretically, by a majority of the population due to widespread education based on
a post-Enlightenment, Christian valued system. Public pressure is therefore the
primary motivation behind the creation of state based regulation on health and
safety.
From a Western point of view, it is therefore easy to think that developing
countries, which, on average, have less stringent safety norms, also attribute less
value to human life than developed ones. Although this might be true, as in many of
them there was no major social revolution which drastically increased the perceived
value of human life amongst the general population, this would be dismissing the
most probable reason for this discrepancy: the relatively small size of the educated
labour force. Indeed, as was the case during the Industrial Revolution in the West,
the value of uneducated and unqualified labour is relatively unimportant; accidents
cause little loss in productivity, as the labour can easily be replaced, and minimal
monetary loss, as the individuals are either too poor or lack sufficient education to
conduct legal action against the corporation. Furthermore, the uneducated
proletariat is often ineffective as political forces due to its inability to critically
evaluate information provided to it and to organise itself into effective pressure
groups, and is therefore more or less powerless to force their governments to create
new legal norms, and even more so when contrasted to the large socio-economic
influence the corporations they oppose exert on the governments.
Because of this, the worksite health and safety of workers only improves
when doing so results in an increase in profit for the corporations, including when
striking and other forms of protest result in too large a loss of productivity, or when
a third party becomes involved in the situation, be it local intellectuals or foreign
influence. With the rise of an educated middle class in the developing world,
resulting in the increase of costs associated with accident and an increase in the
socio-political influence of the workforce, as well as the globalisation of the
economy and the growing social awareness in most of the world (resulting in loss of
profit when customers refuse to associate with corporations who mistreat their
employees), it is probable that a dramatic increase in the stringency of security
norms will soon be observed in the developing world, and this tendency is already

evident in places such as China, where many corporations are actively enforcing
stricter regulations than the national ones in an effort to improve their image and
limit bad press associated with worksite accidents. Indeed, although there is room
for improvement, the situation is often not as bad as what is believed in the Western
world, which is an image influenced solely by the worst cases, which are the only
ones of sufficient magnitude to be publicized outside of China.
With that said, accidents still happen. Indeed, in both nations, construction
remains one of the most accident prone industries, with construction being the
industry with the largest proportion of worksite accidents in Canada with around
24.4 accidents per 1000 workers per year (slightly more than manufacturing sector
with 24/1000 workers) and second most in China based on governmental
evaluation, with the only industry having a worst ratio being manufacturing, largely
due to the public nature of the former making accidents all the more evident in the
public eye, and therefore, all the more damaging for a companys image.
The purpose of the present document will therefore be to provide a summary
and comparison of the state of health and safety on construction sites in Canada
and the Peoples Republic of China. This analysis will be conducted in two segments:
first, an analysis of the norms and regulations in place in both nations forming the
groundwork of worksite health and safety, and second, an analysis of the practical
application of these norms, based on practical observations and interviews with
local experts in the field of health and safety.

II. Methodology
This analysis and comparison of health and safety within the construction
industries of Canada and China is divided into two segments, a theoretical and a
practical one. In both cases, the relevant information was obtained through three
processes, namely analysis of theoretical documents, interviews with experts within
the field and practical observations on construction sites.
First, to find the basic information required for the theoretical analysis, the
primary documents from both nations, including their respective labour codes and
occupational safety regulations where analysed, thereby providing basic information
relative to the governing bodies, the enforcement methods, the legal obligations of
employers and employees and the various standards in each nation. Furthermore,
this was complemented by analysis of said standards, including those related to the
various specifications of protective equipment, fire and electrical safety as well as
scaffold assembly. Moreover, information relating to the different health impacts of
hazards found in construction, including sound, asbestos and volatile solvents, was
obtained from the websites of the World Health Organisation and the Environmental
Protection Agency, as well as from other published articles. Finally, some
information that proved difficult to find through written sources, such as the manner
in which safety inspections and training were conducted in each state, as well as
how different groups in each nation influenced the creation of regulations, were
obtained through interviewing experts in both nations. An example of the set of
questions asked during these interviews is presented in Annex 1.
Second, to conduct the practical comparison, factual evidence from different
sites was obtained primarily through direct observations of different construction
sites in each nation. Most of these were conducted on a formal basis, using the
observation checklist presented in Annex 2, allowing for observation of the
application of the different standards, especially those relating to the wear of safety
equipment and to ensuring a safe working environment through building safe
structures (including scaffolding) and limiting potential exposure to dangers
including fire, electric and chemical hazards. Additionally, some observations were
conducted informally, without use of a full checklist, because the conditions did not
allow for a full observation of a site, often because only a few tasks were being

conducted or could be observed on said site. However, taken as a whole, the sum of
these observations allowed for the practical analysis of the application of health and
safety norms on the smaller types of sites, including renovation and rural project.
Finally, when practical information could not be observed, such as that related to
the relative frequency of corruption amongst the inspectors or to the actual quality
of the safety equipment used, it was obtained during the interviews with each
nations experts.

III. Comparison of Theoretical Norms in Construction Health and Safety

As in all things relating to legal matters, there is, in construction health and
safety, a distinction between what should theoretically be done, and what is actually
done in reality. Indeed, no matter what the actual state of health and safety in
either nation is in practice, the system of rules and regulations which codifies and
enforces it remains an integral part of the health and safety system, representing in
a way the ultimate objective that the nation sets for itself, and therefore, a global
comparison between states must include discussion on this aspect. Thus, this
section represents a rapid comparison of the primary theoretical elements for health
and safety in construction in both Canada and China.
III.1 Governing Bodies
To begin, before concrete analysis of health and safety standards on
construction sites and Canada and China can be conducted, it is important to note
what group, or series of groups, are responsible for these policies in both nations.
Indeed, in both states, worksite health and safety are state based concerns, and, as
such, ultimately under jurisdiction of their respective governments, which are the
primary source of regulations and the final arbitrator and enforcer of said
regulations within their borders. However, distinctions exist in how the regulation
system is structured, as well as in how the responsibility is shared between the
different levels of government in each nation.
Indeed, in China, rather distinctively to most other state, there is no single
central database for the regulation system, and no general background law to
support the regulations themselves, as the China Workplace Safety Law only deals
with the general and legal aspects of health and safety in every industry, and the
Construction Law of the Peoples Republic of China mostly only covers the safety of
a building after it has been built as well as regulations regarding the elimination of
the possible health impacts of building on the surrounding populations, while only
mentioning that the corporations are responsible for the health and lives of the
employees on their sites, and that said employees are allowed to make suggestions
for improvements and to press charges in the event of an accident.

Due to this, ensuring proper health and safety on construction sites in China
is therefore based solely on the application of individual standards, which are
approved by the Ministry of Construction. These standards are often inspired by, or
taken wholly, from the standards of other states, and can be further modified or
clarified in their application by policy announcements. However, due to the
structure of the Chinese government, more than a dozen governmental agencies
(including the overarching State Council as well as the provincial and city
governments and their individual Construction Committees) can make these
modifications on any single standard and, due to the impossibility of maintaining
perfect communication in such a large bureaucracy, these modifications can
sometimes be contradictory or remain largely unpublicized even within the same
city.
This structure is in direct contrast to that of Canada, where the primary
document for health and safety in construction (and in any other field) is a single,
formal document, known as the Canada Occupational Health and Safety Regulation
(OHSR). This document, published by the government of Canada and regularly
updated, provides both the basic health and safety regulations on any given field,
such as the minimal equipment or conditions required for conducting various
operations, as well as basic regulations on first-aid in industry in addition to
providing a list of what standards and regulations apply for each sector of industry.
It does not, however, contain information pertaining to the legal aspect of worksite
incidents, which is itself described under part II of the Canada Labour Code (CLC),
which pertains to the legal obligations of both employees and employers relative to
health and safety, and any legal sanctions that may come from breaching said
obligations. However, because health and labour are both provincial concerns, every
province can add to any federal document, creating their own set of regulations,
such as the Occupational Health and Safety Act of Ontario and the Loi sur la Sant
et Scurit au Travail of Quebec.
As for the standards used in Canada, they are, similarly to China, usually
adopted on the national level, and tend to closely model those used in the UnitedStates. However, some aspects of the standards used in construction (and
therefore, health and safety in said field) can vary between provinces, as the
building code is also unique to each of them, and although the differences are

usually minimal, some oddities can appear, such as the fact that Quebecs
regulation on the maximal sound intensity one is allowed to be exposed to for a
period of 8 hours (85 db) is lower than the Canadian federal standard (87 db), itself
being lower than the standard of all other provinces (90 db). Due to this, safety
equipment is often rated to the highest standard across the nation.
Moreover, in both states, pressure groups, including industrial lobbies and
worker groups or unions (of which there is only one in China, the All-China
Federation of Trade Unions) also exert considerable influence on the adoption of
new policies, both through direct pressure on the State and through influencing the
public opinion. As could be expected, the actual influence wielded by each of these
groups varies immensely, but, taken as a whole, they represent one of the primary
factors influencing how governments shape their health and safety policies.

III.2 Safety Training

The basis of any functioning legal system is circulation of information; if
individuals are to follow norms, they must first learn what behaviours they have to
avoid or favor to respect it. As such, training is a central pillar of health and safety,
and the principal manner in which prevention is conducted.
In China, officials are obligated to follow regular training course to keep up to
date on evolving regulations, and to inform workers under them of any relevant
information. Furthermore, workers have to be trained in the safe use of any
equipment they are expected to use in their work, and any employer is forced to
divulge any and all probable hazards that a worker may face when on a site, as well
as to provide information relative to preventive and emergency measures. The
situation is similar in Canada, where employers are forced to provide complete
safety training for any task carried out by their employees, as well as to inform
them of any potential hazards to their health. However, only field supervisors are
required to follow safety training, with higher executives not needing to follow any
kind of safety training unless they intend to inspect or work on a construction site.
Furthermore, employers in both nations are obligated by law to freely provide (and
enforce the wear of) any required safety equipment for their workers, and this
safety equipment must conform to the standards in place.
III.3 Inspection
Next, in both states, the primary, and arguably most efficient, method of
enforcing the regulations is inspection, and although both states have had scandals
in the past related to the quality of said inspections, the overall importance of
inspection remains unchanged, and it is still an important factor in preventing
incidents and injuries, both for the workers and future users of a building.
In China, inspections are conducted at three different levels. First, the
corporations themselves maintain inspectors within their personnel, who inspect the
worksites daily or weekly to ensure that the work is being conducted adequately
and safely for the rest of the personnel. They generally remain on a single large site
and keep records of every inspection, to facilitate tracking the evolution of issues
and to identify recurring problems for future training needs. As could be expected,

these individuals do not issue fines to their own corporations, but simply make
recommendations to solve issues. Second, regional inspectors intermittently visit
the sites under their jurisdiction, conducting a general inspection of the sites and
penalizing breaches in the regulations, usually by giving an ultimatum to solve the
issue before giving the corporation a fine. Finally, national inspectors go around the
country, doing surprise visits of sites more or less at random (corporations with a
history of bad practices tend to be visited more often than others), and although
they wield the same legal power as the regional inspectors, they represent the
ultimate authority on the matter.
Canada follows a similar system, although construction inspection is mostly a
provincial matter. Indeed, although federal regulation forms the basis, as each
province maintains its own construction and labour code, the highest level of
enforcement is provincial. As in China, inspectors visit corporations mostly at
random, and enforce the regulations through fines and ultimatums. Moreover, city
inspectors in Canada fulfill much the same role as regional inspectors in China,
having the right to suspend the construction permit for any worksite under their
jurisdiction, and to levy fines in the event of non-compliance with the law. Finally,
unlike China, very few construction corporations in Canada maintain a detachment
of trained inspectors, relying more on the expertise of the trained personnel on each
site.
III.4 Enforcement
As mentioned above, enforcement of health and safety (as well as general
construction regulations) is done in an identical manner in both states, through
stopping work on a site and the use of ultimatums and fines until matters are
resolved, as well as with direct fines in the event of accidents. However, the
subjects, as well as the amount, of the fines differ in both states, and ever within
them.
Indeed, in Canada, although removal of the construction permit until matters
are solved is often the preferred course of action, fines can also be levied, both for
actions that contravene the health and safety regulations and for actions that
directly endanger the health or lives of individuals, with the latter being subject to
harsher fines. Moreover, Canada distinguishes between a physical person and a

moral person, with the latter being subject to larger fines. Finally, although the CLC
prescribes maximal fines and sentences ($1,000,000 and/or two years of
imprisonment) that can be levied for failure to respect health and safety norms, the
fines themselves are a provincial matter, and so vary across Canada.
China, on the other hand, usually only fines employers (but does not
distinguish between individuals and corporations), although some infractions, such
as refusing to provide funds for ensuring safety or signing a contract exempting the
employer from liability in the event of an accident, may result in fines to the
corporation as well as all investors on a given project, regardless of their knowledge
or approval of the actions. However, the fines themselves tend to be much smaller
in China, with fines ranging from 20,000 to 200,000 (the exchange rate from the
Renminbi to the Canadian dollar is around 6:1), and although individuals may be
forced to step down from their positions, they cannot be imprisoned unless their
actions also constitute a criminal act.

III.5 Standards
As for the standards and regulations themselves, in theory, the standards in
China are often quite similar to those in place in Canada. This could come as a
surprise, seeing as the accident rate (especially for fatal ones) is greater in China,
but the latter is due more to differences in how they are enforced than to any real
difference in standards, which have improved dramatically in China in the last years
as public pressure, both internal and foreign, has forced industries and the
government to bring them up to international levels.
Indeed, from the standpoint of construction, the basic standards related to
health and safety, including the obligation of employers to provide adequate
protective equipment whose rating matches or exceeds that demanded by the
standards, are similar in both nations. Therefore, helmets, work boots (usually with
steel toe and sole protectors) and work gloves are required in most construction
work in both states, with China being slightly less stringent on who needs to wear
certain pieces of equipment, notably protective footwear, which is only required for
some trades, including bricklaying, masonry, iron working and steel fixing, rather
than for everyone on a construction site.
Moreover, more specialised pieces of equipment, including air filters, eye
protection, insulated clothing as well as hearing protection are required in both
states for specialized tasks involving exposure to noise, flying debris, high
temperature or high concentrations of airborne particles, such as jackhammering,
indoor painting, sanding and welding. However, here again, China is slightly less
demanding: hearing protection is never a required piece of equipment for any task
in China (although noise exposure regulations make it required for some tasks), and
insulated welding equipment is only required for arc welding rather than for all
types. The safety standards the equipment are required to meet are also similar,
with only some small differences in the magnitude of the forces the equipment
needs to be able to safely absorb.
Furthermore, other basic safety norms, such as requiring railing and toe
boards on scaffolding over a certain height (2m in China and 3m in Canada),
requiring safety nets on construction sites at a set interval (no more than 4.6 or 30
m under a construction level for most of Canada and China respectively) as well as

requiring the indication of possible environmental hazards through clear and evident
signage, are similar in both nations, and it is evident that the purpose of these
regulations is the same in both cases, with only some differences in the specific
requirements of the law.

IV. Comparison of Practical Observations on Construction Health and Safety

Although it can be said that in theory the legislation for health and safety
regulations of Canada and China are quite similar, their actual application often
differs greatly, and is far from consistent even within the same nation. Indeed, most
serious work accidents are the result of a dramatic increase in the consequences of
otherwise benign human accidents due to improper application of the safety
regulations in place. As such, serious work accidents tend to be more common and
more severe on sites where either the work itself is willingly conducted in an unsafe
manner, or the inspections are not carried out adequately, thereby allowing
involuntary breaches in the safety regulations to persist.
Because of this, although analysis of the theoretical laws in regulations in
place in both nations can provide some information about the relative state of
health and safety in both nations, they cannot, by themself, provide a complete
comparison on the status of health and safety on construction sites in both nations.
It is therefore logical that another point of comparison between both states concern
how health and safety regulations are followed in practice rather than on the
regulations themselves. The primary practical elements of comparison between
health and safety in the Chinese and Canadian construction industries will therefore
be the practical application of the most important areas of regulation, namely the
nature of the safety training given to employees, the application of heights safety
and protective equipment regulations, the presence of environmental dangers and
the quality of inspections. Please note however that this comparison is a
generalisation

based

solely

upon

anecdotal

evidence

collected

from

my

observations as well as those of health and safety experts and other individuals of
the construction industry from both China and Canada, and therefore only
represents a rough indicator of the relative health and safety practices of both
nations.
IV.1 Safety Training
As was mentioned earlier, one of the primary tasks of employers in both
nations is providing safety training for their employees. In Canada, the great
majority of construction corporations provide training for their employees, to ensure
proper use of safety equipment and adequate knowledge of potential dangers on a

construction site. This training mostly concerns safety from the standpoint of the
tasks conducted by a given employee as well as general construction site safety
norms,

and

is

often

done

in

an

unofficial

manner

through

pairing

and

communication with more experienced workers or supervisors, and, although the

training can be inconsistent at times, it is for the most part effective in limiting
accidents, as the practical context facilitates integration of knowledge and
techniques and the mentor role encourages experienced workers to work in a safer
manner to be good models. In addition to this, larger corporations in Canada also
hold training seminars for employees to ensure that they remain up to date on
safety practices, especially if the regulations have changed, and to provide safety
information on unusual scenarios that employees may not have experience facing,
including safety protocols for working (or ceasing work) in dangerous weather
including high winds, hail or freezing rain.
Large corporations in China follow a similar method, with employees being
trained on-site based on the needs of their specific work as well as on basic safety
regulations relative to the construction site environment. However, in China, as the
law requires that employees be trained by safety experts, the training tends to be of
a more theoretical than practical nature, although the latter is often gained overtime through working with more experienced workers. Nevertheless, because this
practical training is entirely informal, young workers often also perpetuate bad
habits taken from older workers, who do not feel they are responsible for the
training. Interestingly, many large Chinese corporations also regularly test the basic
safety knowledge of all their workers through written exams, with individuals failing
said exams being forbidden from working on a construction site until they obtain
additional safety training and pass the test again.
However, in China, smaller corporations, especially those operating in rural
areas, tend not to provide any safety training to their employees. This is further
compounded by the relative lack of education amongst the rural and migrant
workers that compose a large segment of the workforce of smaller corporations,
which reduces both their awareness to potential dangers and their willingness to
seek training. As could be expected, this often leads to disproportionately high rates
of accidents.

Another element of general safety on construction site is the creation and

communication of emergency plans. Indeed, both in Canada and in China, the great
majority of construction corporations establish at least a single, but usually a few to
account for different events, basic emergency plans for their worksites, which
include

standard

emergency

measures

such

as

evacuation

planning

and

containment protocol for any potentially dangerous compounds stored or used on

site, and these plans are then taught to every worker on any given site. In addition,
most corporations ensure that at least some individuals on each worksite are
trained in first aid to provide basic assistance in the event of an accident. However,
here again, smaller corporations in China tend to not invest as much into
emergency planning, which, combined with the lack of safety training, results in
relatively minor incidents such as small fires having disproportionately large
consequences.

IV.2 Heights Safety

Both in Canada and in China, the primary source of accidents on construction
sites are falls from elevated positions and impacts from falling objects, with the
great majority of these occurring either when working on or erecting scaffolds or
when conducting roofing work. Indeed, although both nations have extensive
regulations on the safe erection and use of construction scaffolds, including
standards for everything from the minimal height of toe boards to the maximal
amount of mass that can be supported by a standard sized wooden board,
scaffolding remains one of the segments of construction work with the greatest
proportion of infractions, possibly due to their ubiquitous nature on construction
sites, although it is important to note that there is a clear difference in the quality
(and safety) of scaffold work based on the nature of the company which conducts it
and on the scale of the work, with major construction companies and larger sites
often having safer installations.
Indeed, in China, most large construction corporations, especially those
working on sky scrapers and other forms of very large urban installations, tend to
take heights safety very seriously, as these construction sites, and therefore the
corporations working on them, are often in the eyes of the media and the
population, making any accidents (and especially avoidable ones) or delays due to
inspectors finding procedural errors particularly bad for their reputation. Due to this,
scaffolding on these sites is usually made of good material, almost always metal
(bamboo scaffolding is legal in China, and is cheaper, although it is harder to install
correctly), and properly maintained, in contrast to rural areas and renovation
projects in which the scaffolds are either made of hastily assembled bamboo or old
material bought off from larger corporations, making their solidity inconsistent and
therefore prone to unexpected material failures. Scaffold walkways in China are
uniformly made of weaved bamboo fibres, whose quality varies but is usually
decent to good on all but the most unsafe sites. Furthermore, the scaffold
installations themselves on large sites almost universally follow the prescribed
standards as far as form and presence of reinforcement components including
interior and exterior bracing, while those on smaller sites tend to forgo most of the
unnecessary bracing and reinforcements to cut costs, thereby weakening the
structure, especially in the event of partial failure, in which case the remaining

structure often becomes inadequate to support the stress placed on it, and, in turn,
eventually collapses.
As far as safety devices present on the scaffolds and buildings themselves,
most large corporations again follow the established regulations for installing railing
on all levels that are being worked on and properly maintained safety netting at
regular intervals, while smaller sites tend to forgo railing and netting on many sites,
or include netting that provides inadequate protection, either because it is damaged
or poorly installed, hampering the even distribution of stress loads. However,
strangely enough, although all other forms of safety measures are at least present
in some form on most larger sites, toe boards, despite being mandatory on any
scaffolding or working level over 8m in height, are conspicuously absent from the
great majority of sites, including world class construction projects such as the
Shanghai Tower, and although the presence of safety nets does make them more or
less redundant, the fact remains that falling objects can be extremely deadly,
especially considering that horizontal safety netting is only required every 30m in
China. For instance, a standard concrete block, of a nominal size of 8" by 8" by 16",
weighs about 30 lbs.; if it falls 15 m, the impact energy is 2.0 kJ, more than the
energy of a 0.223 caliber bullet (the standard round for NATO assault rifles, with
around 1.7 kJ of energy), a painful, and probably deadly impact even if a helmet is
worn due to spinal or cerebral trauma.
As for Canada, similarly to those of larger firms in China, the great majority of
construction sites maintain scaffolding of at least adequate quality, almost
universally made of steel, although lighter aluminium scaffolding is gaining in
popularity amongst smaller firms. The material itself is largely made of good quality
and well maintained steel, normally of a single grade to limit miscalculations, and
the installation is at minimum up to the established standards. Indeed, the primary
difference between Canadian and Chinese scaffolds is the flooring material of
choice; the Canadian construction industry favors wood for platforms, either as
timber planks or plywood, as they are relatively cheap, require little maintenance,
and give good indication of degradation (wood will visibly, and often also audibly,
warp or crack before failure). The wood essences of choice are softwoods of the
spruce, pine or fir families as well as the Douglas fir, due to their high strength to
mass ratio and relatively affordable cost.

Concerning additional safety equipment, most Canadian construction sites

maintain railing on all exterior faces of worked on levels or on the adjoining
scaffolding, and this railing usually integrates a toe board at the bottom to stop
unattended objects from falling onto lower levels. The exception to this are
renovation or personal work sites, which often forgo some of the railing, and rarely
include a toe board unless masonry work is being conducted. Construction sites of
sufficient size also maintain safety netting within 15 ft. of the bottom of any worked
on floor, to further limit the damage caused by falling objects and to prevent injuries
in the case of falls. As could be expected, due to the much smaller maximal
distance between a work floor and a safety net, the danger posed by falling objects
in Canada tends to be lessened; for instance, using the same concrete block as the
previous example, even at the maximal possible height, the impact energy would
only be 0.6 kJ, an assuredly unpleasant impact, but nonetheless survivable with
little to no long-term consequences if a helmet is worn.

IV.3 Environmental Safety

Another primary source of worksite incidents in construction is the literal
mass of possible environmental dangers, both natural and artificial, that are present
on a construction site. These represent a truly immense variety of hazards which
include everything from live electrical wires, to aerosolised dust, to dangerous
chemicals, and even reckless drivers. As accounting for all these elements is both
impossible and ultimately unimportant, this document will focus on the most
important ones and the ones on which there is a clear distinction between Canada
and China. Namely, these include fire hazards, electrical hazards, dangerous
atmosphere and hazardous conduct.
First, as could be expected from an industry that often deals with both
flammable material and multiple, often unsupervised, ignition sources, fires have
always been, and still are, a very serious threat in the construction industry.
However, for the most part, construction sites in China and Canada apply fire
prevention norms well enough, ensuring some protection from accidental fires and
greatly reducing the consequences of such an event, both in terms of material and
human costs. Indeed, on the vast majority of sites, most flammable material is kept
stored away from the general construction site until its use is required (although
this is usually due to its sensitivity to the elements in general), and any debris is
kept separate from the rest of the site, often in specially made metallic bins for ease
of disposal. Additionally, any flammable or explosive compounds (such as acetylene
in welding tanks) are usually kept away from the main construction zones, and, in
larger sites in China, are even kept locked in specially made sheds that are off the
premises of the construction site itself when not in use. Moreover, for the most part,
smoking is forbidden inside any building in construction both in Canada and in
China, and these regulations are followed on the great majority of sites. The primary
difference is that although most Canadian provinces permit smoking while outside
of buildings or on buildings that are not yet enclosed (the notable exception being
Prince-Edward Island), most sites in China forbid smoking not only while on or near
a building under construction, but also while anywhere on the construction site
proper. The only major exceptions to this are small construction corporations in rural
areas, which tend to permit smoking nearly everywhere, even in clearly dangerous
circumstances such as while welding or painting. In Canada, possible sources of

ignition, including sparks from welding or cutting metal, are kept under control by
limiting them to controlled environments usually devoid of exposed combustible
materials. However, this is often not the case in China, where welding is often done
without covering any potentially flammable material underneath, and, worse,
sometimes over other workers not protected against the shower of superheated
metal.
Next, electrical hazards represent one of the more insidious threats on
constructions sites, which inevitably have to deal with the dangers of partially
exposed (and possibly damaged) wiring and large concentration of both manpower
and conductive elements including tools, scaffolds and structural elements. To limit
the probability of accidental damage to the main electrical systems, the majority of
large construction sites in Canada and China maintain temporary electrical boxes on
the periphery of construction sites with easy access to power cut-offs, and keep the
primary wiring away from heavy circulation. Furthermore, in China, many sites keep
all outside electrical wiring elevated on poles to keep it from coming in contact with
most machinery, although this makes maintenance more difficult and facilitates
accidental contacts with machinery too large to fit underneath, as workers pay little
attention to the presence of the wires, leading to accidental electrocutions, which,
due to the large amperage needed on construction sites, are often fatal.
Additionally, inside construction sites, electrical work is only conducted by, or under
supervision of, trained electricians wearing appropriate safety equipment, and the
majority of potentially live wires are regularly inspected and kept insulated from
conductive surfaces through capping. The notable exceptions are smaller sites in
both nations, which often conduct electrical work without a trained electrician and
often skimp on conducting full inspections of the wiring.
Another frequent source of hazards on construction sites are dangerous
compounds present in the atmosphere. The most common of these are the many
types of volatile organic solvents found in paint, varnishes and many other chemical
products, mostly cyclical hydrocarbons such as xylene, toluene and benzene, that
can cause irritation of the eyes and respiratory systems as well as serious damage
to the nervous system including polyneuropathy (peripheral nerves malfunction),
atrophy of the optical nerve (causing progressive loss of sight), dysfunction of the
pyramidal and cerebellar brain cells as well as other forms of brain lesions if inhaled

in large quantities. Indeed, due to their volatile nature, these compounds can
accumulate in rooms during and after work, and remain there for long periods of
time if the environment is poorly aerated. Therefore, in China and in Canada, most
construction projects require that any worker doing extensive paint work inside a
structure be equipped with an air filter and sealed protective glasses to limit
exposure, and that the environment be well aerated. However, on smaller sites,
particularly private home construction or renovation projects in both nations as well
as on rural construction sites in China, protective equipment is rarely available, and
although the small scale of the work limits the exposure, long term consequences
can still occur, especially if paint work is conducted regularly. To prevent this, some
corporations as well as many independent individuals in Canada are beginning to
favor VOC-free paints, to limit the danger from any accidental exposure.
Other forms of airborne contaminants include asbestos, which can cause
hardening of the pleura, scarring and thickening of the pulmonary alveoli (reducing
the elasticity of the lungs, and therefore, the volume of inhalations), as well as
cancer in most types of lung cells due to the size of the asbestos particles being
similar to that of human chromosomes, hampering mitosis. Although its use is now
entirely illegal in Canada, and severely regulated in China, it is still found in older
construction projects and can be exposed during renovations. To limit its danger, in
both nations, asbestos is usually manipulated with care and only in well aerated
environments while wearing air filters and eye protection. Finally, even something
as simple as concrete dust, generated during demolition operations, can have
serious health impact if inhaled, causing inflammation of the respiratory system
and, if it contains silica, silicosis, leading to serious inflammation and scarring of the
upper pulmonary lobes. In Canada, most workers dealing with large amounts of dust
usually wear enclosed safety glasses and air filters, while in China, it is very rare for
additional protection to be worn when working in environments filled with dust,
despite the fact that state regulation requires both eye protection and air filters.
Finally, the last major source of safety hazards on constructions sites,
reckless conduct, is common in both nations, although some acts are much more
common in China than in Canada. In Canada, the most common types of reckless
conduct are not using available movement restricting or fall arrest systems when
working at heights without the benefits of railings (such as when an individual is

installing the railing on a given level), and leaving equipment and material
unattended, especially when at heights. China faces similar issues, with workers
often ignoring available safety harnesses when in a rush or when dexterity is
required and leaving many unattended objects when departing a site, especially for
the morning break. Indeed, despite efforts by the respective governments of each
nation and multiple deaths each year, these reckless habits remain relatively
common as, for the most part, they make life easier for the workers. Furthermore,
China also faces an additional safety issue, caused by that nations drivers. Indeed,
while truck and machinery drivers on construction sites in Canada usually drive
carefully, and with the aid of signalers to avoid hazards, their Chinese homologues
favor a more aggressive style of driving. Namely, although they do not drive
extremely fast, they do not tend to adapt their driving to the characteristics of the
road, resulting in frequent skidding and loss of control on wet or icy roads.
Moreover, as indicating ones intents when driving a motor vehicle is all but unheard
of in China, it is difficult for pedestrians to anticipate how vehicles around them will
be moving, a danger further compounded by the general disregard for pedestrians
in groups of less than five exhibited by most Chinese drivers, including heavy
machinery operators.

IV.4 Safety Equipment

No matter the amount of precautions taken, accidents are bound to happen in
any industry where a human element remains present. The construction industry is
definitely not exempt from this, and the even-changing nature of the work
environment within the industry, combined with the omnipresence of multiple
sources of distraction and the physically demanding nature of the work, make
accidents in the construction industry particularly frequent and dangerous. In light
of this, it is understandable that the wear of adequate protective equipment be one
of the primary elements of health and safety regulation. However, inadequate
protective equipment is also one of the primary causes of serious injuries in
accidents, as otherwise minor incidents become much more severe. Again, as there
are dozens of different pieces of protective equipment, each regulated by their own
set of standards, this comparison will focus on the most common ones.
Before we start however, it is important to note that the quality of the
protective equipment in Canada and in China, although usually adequate by itself, is
by no means always so. Although this is infrequent in Canada, as the NorthAmerican equipment industry is made up of a few larger corporations, with very
little import of cheap imitations, and so the product quality can easily be controlled
by the industry and the government both during production and field use, it is a
major problem in China, where cheap knock-offs providing inadequate protection
represent a large segment of all safety equipment sold and worn, as they are
usually available at a much cheaper price, making them a compelling choice for
unscrupulous corporations, although large enterprises often favor quality equipment
to ensure conformity with regulations. This issue is further worsened by the lack of
quality testing in China; there are more than a thousand legal equipment producers,
and untold more that operate outside governmental control, but only 15 institutes
authorized to conduct safety testing. Verification of all, or even most, commercial
products on the market is therefore impossible, and testing of equipment used on
actual construction sites is all but unheard of except amongst the largest
corporations who send in samples for testing in order to conform to the law.
On to the actual equipment itself, assuredly the most ubiquitous piece of
protective equipment in the construction industry in China and Canada is the safety

helmet, or hard hat, whose wear is all but compulsory in both nations. Indeed, in
China, despite only being mandatory for individuals working on the outside of
structures, safety helmets, almost universally of the front-brimmed variety, are
worn on larger sites by nearly everyone from the moment they step onto a
construction site to the moment they leave it. The only major exceptions are
workers on smaller renovation sites, who tend to forgo helmets due to working
almost exclusively indoors where they are not required, and corporate executives
viewing construction sites from afar, although the latter group usually takes to
wearing hard hats when doing close-up inspections. The situation is similar in
Canada, although it is even rarer for individuals on a construction site to be found
without a helmet, with the only major exception being individuals conducting
finishing work on the inside of structures after exterior construction is complete. As
always however, some cases of negligence do happen, and, in both nations, it is not
unheard of for individuals to enter construction sites without helmets when not
actively working on it, be it to communicate with individuals on the site or simply to
cross through it, sometimes resulting in fatal incidents.
Nearly as ubiquitous as helmets and just as important in protecting the health
of workers in the construction industry, work boots are another universal piece of
protective equipment in Canada. Indeed, regulation approved steel-toed boots with
both toe and sole protection are universally worn by the great majority of
individuals within the construction industry in Canada from the moment they step
on any construction site, regardless of size or importance. Moreover, in difficult
working conditions, including frigid weather and floods, reinforced work boots, albeit
specially adapted to these conditions, are still worn. In China however, this is not
the case; work boots incorporating steel protection are very rarely worn, even on
larger sites, despite being part of the mandatory equipment for many trades.
Indeed, workers, no matter the specific requirements of their trades, tend to favor
either normal shoes or rubberized boots if the working conditions are wet.
Inspectors are amongst the only segments of the worker population who regularly
wear protective boots, although even amongst them it is not a universal practice.
This practice, combined with the lack of toe boards on most Chinese structures,
results in a dramatic increase in the amount of feet injury, including broken bones
and amputated toes, while also increasing the frequency of other types of leg

injuries, such as sprained ankles, due to poor ankle support when working in
potentially slippery and uneven terrain.
Another important element of basic safety in the construction industry are
work gloves. As could be expected, their primary function is twofold: to protect
workers against minor cuts and abrasions as well as against harmful compounds in
the environment, and to improve the workers grip on tools and material. Nearly as
universal as work boots in Canada, they are worn by almost all individuals
conducting some form of physical work on construction sites, with some variations
based on the needs of specific trades (some are water resistant, some are heavily
insulated against heat or electricity, etc.). There is however a minority of individuals
who work without gloves, especially amongst trades requiring good manual
dexterity, as gloves do hamper fine motor control and reduce manual feedback. The
situation on larger sites in China is similar, with most workers wearing gloves when
doing physical labour, particularly when doing work that frequently exposes the
hands to danger such as welding. Despite this, the gloves themselves are rarely
specifically made for the task at hands, reducing their effectiveness against some
hazards. Furthermore, individuals on smaller sites are often not provided with
gloves, and so must make do without them or acquire a pair on their own.
In addition to the basic security equipment, many trades in construction
require additional protective equipment. Most frequently, this is to ensure protection
of the essential organs on the face, which are not otherwise protected. As such, in
Canada, protective glasses and air filters are worn by the great majority workers
doing work with any kind of chemicals (including painting) or in an environment
where they are exposed to large concentrations of suspended dust, such as
concrete mixing and demolition. Moreover, welders universally wear at least
protective welding glasses, if not full welding masks. This is in contrast with China,
where, although the general population is often seen wearing cloth masks to
prevent contamination by disease and overexposure to the polluted air in cities, the
majority of construction workers do not wear them, even if their task requires it. For
instance, despite governmental regulations, workers will jackhammer concrete for
extended periods of time without wearing a mask or protective glasses (or any
safety equipment beyond a helmet for that matter), exposing both their eyes and

lungs to particles of dust. The notable exceptions are the welders, who almost
universally wear welding masks, with some favouring smaller goggles instead.
Finally, a last set of important pieces of safety equipment are fall arrest and
movement limiting systems, intended to protect wearers from falls when railing is
impossible or impractical to install. Here, the situation is nearly identical in Canada
and in China, and so, on larger sites, individuals doing early structural work, both on
primary structures and on scaffoldings, rarely tie themselves despite it being
mandatory in both states (anyone who is standing on a platform more than 3 m off
the ground lacking railing must be tied down to prevent dangerous falls), and
although this enables them to have more manoeuvrability while working (and is a
tradition amongst most ironworkers), it exposes them to additional dangers.
Furthermore, individuals rapidly moving to and from the edges of buildings, without
stopping to conduct any extensive work, including inspectors, rarely tie themselves
down, as it would not be time efficient. Interestingly however, most individuals
doing later work, including structural welders, often tie themselves down. Despite
this, on smaller sites and renovation projects, it remain extremely rare for
individuals in either nations to tie themselves down, as the expenses associated
with most suspension or fall arrest systems usually make them economically
unviable on smaller sites.
IV.5 Inspections and Corruption
The final point of comparison for health and safety in the construction
industries of Canada and China is the quality and reliability of the inspections
conducted in both nations. Indeed, although they may still respect most, if not all,
safety regulations, many corporations in both these nations conduct acts of dubious
legality to influence any inspector visiting their sites or inspection their equipment,
in an effort to have them be more lenient in their evaluation, thereby allowing the
corporations to bypass fines and the loss of public image associated with them.
This, in turns, reduces the reliability of the inspections, which do not necessarily
reflect the actual quality and safety of the work conducted.
In China, corruption is very widespread amongst construction industry
inspectors. Indeed, as many corporations do not respect at least some of the health
and safety or construction regulations in place, and so often pay off inspectors to

ignore infractions, with direct monetary payments, almost universally in cash, being
by far the most frequent method. This is so common that some corporations go
even further, bribing inspectors as a matter of fact, without even waiting for them
to detect issues. This not only results in unsafe buildings that are poorly
constructed, but also in more accidents that tend to be more severe, as inadequate
safety equipment is not reported. Moreover, this travesty also extends to the
inspectors inside the corporations themselves, which often falsify inspection reports
or fail to report incidents in order to make it seem that their sites are safer than
they are, both in the eyes of the public and those of their foreign investors.
Furthermore, the quality of the inspections in China is further reduced by the
general lack of competence of the inspectors themselves, who are often not
qualified to make comprehensive evaluations of all practices and safety equipment
observed on a site.
The situation in Canada is similar, with non-negligible segments of the
construction industry routinely bribing inspectors to ignore breaches in regulations.
However, this is often to disguise small breaches to the construction code made to
save costs, rather than major structural dangers or serious

health and safety

infractions, for which bribes are rarely accepted, although the later certainly does
happen on larger sites. Moreover, due to the difficulty of moving large sums of
money for illegal purposes without leaving an obvious trail, payments in Canada,
especially minor ones, are often made through indirect and often perishable means
such as hockey tickets, although the traditional direct transfer of cash remains
popular. Furthermore, the quality of the inspections in Canada tends to be high, with
inspectors being for the most part qualified and up to date on pertinent regulations.
This means that although there are some infractions to the regulations that are
discovered and remain unpunished, these are mostly minor ones, with the more
severe ones usually being found and corrected.
V. Summary of Findings
Upon analysis of the information gathered through the research conducted on
the state of health and safety in the construction industry of China and Canada, a
few conclusions can be made about its relative state in both nations. Indeed,

although the two states are theoretically similar on this matter, there exists a
noticeable distinction in practice due to poor enforcement in China.
As such, if only analysed from a theoretical standpoint, China and Canada
have, at the fundamental level, very similar health and safety systems. Indeed, in
both nations, the basis of the system rests on a series of standards that are
approved by a central state authority and, if needed, latter modified to conform to
progressively more stringent norms as the organisational scale goes from the
general to the specific. Moreover, the standards themselves are often quite similar,
and although there are still some areas, most notably on the topic of minimal
requirements for safety equipment, where the Chinese standards remain less
stringent than those in Canada, the intent behind the regulations is the same. The
primary distinction as far as the standards are concerned reside in how they are
enforced; in China, the fines for non-compliance tend to be proportionately much
smaller than in Canada, and can usually only be levied against corporate entities
rather than particular individuals. Despite this, there also remain some important
distinctions between the organisation of health and safety in both states; the most
important ones being the differences in the organisational structure behind the
creation and enforcement of regulations. Indeed, the Chinese state is much more
centralised than the Canadian one, in which the provinces are mostly independent
in their application and enforcement of regulations, mostly due to the fact that the
construction industry is a provincial concern in Canada rather than a national one as
is the case in China. In the end however, although the centralised nature of the
Chinese system does lend itself to loss of productivity and additional corruption
through bureaucratic red tape, the structural differences between the two systems
do not modify in any great way the manner in which the system should work in
theory.
However, as it happens in many things, reality does not conform itself to
theory, and so despite being theoretically similar, the practical application of the
health and safety norms in Canada and China differ somewhat in practice. Indeed,
despite the regulations being similar, they are important differences in how they are
applied by the construction industry in both nations. Most importantly, the
frequency with which standards are entirely ignored, both from a personal and
corporative level, is much greater within the Chinese industry, with some

regulations being all but inexistent in practice, leading to an increase in both the
frequency and severity of accidents on constructions sites. Furthermore, even when
the standards and proper practices appear to be applied correctly, the equipment
used in China may be inadequate due to poor quality control. Finally, although
corruption is present (and even frequent) in the construction industry of both states,
it is more common and more flagrant in China, which further hampers the
application of the health and safety regulations. In conclusion, despite being similar
in theory, it can be observed that in practice, the state of health and safety within
the construction industry in China is worse than that in Canada due to inadequate
enforcement and quality control, which leads to disregard for the regulations, both
amongst the workers and the employers.
With this being said, it is important to note that the state of health and safety
in the construction industry in China has progressed immensely within the last few
years, and its progression could best be likened to that seen at the start of the 20 th
century in the West following the rise of unionization. Indeed, due to the growing
pressure from both worker groups within the industry and foreign influence, the gap
between the theoretical norms and what is seen in reality is steadily diminishing. Of
course, it is likely that the norms will never be fully applied, but it is probable that
major progress will continue to be made in the next decades.

References
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for Safety Nets Used During Construction, Repair and Demolition Operations.
Aug 7 1979. Print.
---. Z89.1-2009 Safety Requirements for Industrial Head Protection. 2009. Print.
Centre canadien d'hygine et de scurit au travail. "Limites d'exposition au bruit
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---. Z195-M1984 - Protective Footwear. March 1984. Print.
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Ontario. Ministry of Labour. Occupational Health and Safety Act. 2011. Web.
<http://www.elaws.gov.on.ca/html/statutes/english/elaws_statutes_90o01_e.htm>.
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Annex 1: Sample Interview Sheet

Please note that indented lines are additional questions, to be asked based on the
answer to the earlier question, and usually represent additional precisions.
Questions Interview Health and Safety
State:
What regulates health and safety?
Are there any official documents?
What organisation is responsible for creating the regulations on health and
safety in worksites?
Is regulation created on a general (or national) basis, or is it industry or
corporation based?
Is there an organisation responsible for ensuring the regulations are upheld?
Are worker unions allowed to demand modifications in the application of
regulations regarding health and safety?
Are the regulations followed on most sites?
Are the regulations followed to the minimal acceptable level or to a higher
standard?
When the regulations are not followed, is the responsibility normally on the
employees or the employers part?
Are the employees trained in the proper use of protective equipment?
Are employers forced to inform the employees of any and all dangers they may be
exposed to while working on a site?
Are there legal measures on both sides to ensure respect of health and safety
measures?
Are there any legal measures for compensation in the case of accidents
related to health and safety incidents?

Questions about specific health and safety measures to compare

Annex 2: Sample Observations Checklist

Please note that again, indented lines are additional questions, to be asked based
on the answer to the earlier question, and usually represent additional precisions.
Observations Checklist
Site:
Theoretical:
Training on safety protocols
Training on emergency procedures
Employees up to date
Presence of an emergency plan
Up to date
Known by the workers
Presence of safety personnel
Not reachable in adequate delay
Environmental:
Presence of direct physical danger (fire, live wire, rock avalanche, etc.)
Non-indicated
Workers not/inadequately protected
Presence of hazardous materials (toxic, corrosive, radioactive)
Non-indicated
Workers not/inadequately protected
Presence of dangerous atmosphere (gas composition, particles in suspension)
Non-indicated
Workers not/inadequately protected
Presence of indirect environmental dangers (high winds, wet or icy surface,
etc.)

Non-indicated/unknown to workers
Workers not adequately equipped
Human:
Dangerous practices (ignored safety equipment, reckless driving, unattended
objects, etc.)
Ordered by the administration
Unhealthy work environment (work hours, psychological and social
environment, stress)
Created by the administration