COMMISSION STAFF WORKING DOCUMENT STAKEHOLDER CONSULTATION - SYNOPSIS REPORT Accompanying the Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of Regions EU strategic framework on health and safety at work 2021-2027 Occupational safety and health in a changing world of work
Date: 2021-06-28
Institutions: Directorate-General for Employment, Social Affairs and Inclusion, European Commission
Subjects: EU strategy, incapacity for work, labour law, occupational accident, occupational disease, occupational health, workplace

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 28.6.2021  SWD(2021) 149 final  COMMISSION STAFF WORKING DOCUMENT  STAKEHOLDER CONSULTATION - SYNOPSIS REPORT    Accompanying the Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of Regions EU strategic framework on health and safety at work 2021-2027     Occupational safety and health in a changing world of work      {COM(2021) 323 final} - {SWD(2021) 148 final}  
 
 
SYNOPSIS REPORT 

1. 

INTRODUCTION  

This report covers feedback and input from the public, administrations, associations and other 
organisations (‘stakeholders’) on the previous EU strategic framework on health and safety at 
work (2014-2020) (‘the previous framework’). It also covers input for the new EU strategic 
framework on health and safety at work (2021-2027) (‘the new framework’). 

A consultation strategy was designed to enable a wide consultation capturing the views and 
opinions  of  the  public  and  all  relevant  stakeholders  in  different  fora,  including  through  an 
open public consultation (OPC). The aim of the consultation was to take stock of the quality 
and implementation of the previous strategic framework and to support the new framework 
by  providing  input  to  the  EU  strategic  orientations  for  the  period  2021-2027  in  this  policy 
area.  The  consultation  process  drew  on  the  stakeholder  mapping  that  identified  the 
following relevant stakeholders: 

the Advisory Committee on Safety and Health at Work (ACSH); 
the Senior Labour Inspectors Committee (SLIC); 

 
 
  national  authorities  (ministries  of  employment/social  affairs,  national  institutes  for 

occupational safety and health, labour inspectorates, etc.); 

  social partners at Member-State and EU levels; 
  employers, including micro, small and medium enterprises and workers; 
  academic/research institutes; 
  occupational  safety  and  health  (OSH)  professionals  (private  experts/consultants, 

external OSH protective and preventive services, OSH networks, etc.); 

  other groups, such as public insurance organisations.  

The  consultation  strategy  was  aimed  at  gathering  input  through  various  consultation 
methods and tools, notably: 

 

the  opinions  and  positions  of  the  main  OSH  stakeholders  (such  as  the  ACSH,  the 
SLIC, and EU employers’ and workers’ representatives) as well as the opinion of the 
EU institutions (Council and European Parliament);  
  an external study to take stock of the previous framework1; 
 
 
 

the results of the OPC2; 
feedback on the published roadmap; 
regular exchanges with – and ad hoc contributions from – stakeholders. 

The contributions received confirmed strong support from the public and stakeholders for a new 
framework.  The  contributions  also  confirmed  the  importance  of  common  objectives  and 
coordinated action to mobilise all actors around the same goal – the improvement of occupational 

1 A separate staff working document presenting, among others, the results of the study will be published in 

parallel: https://ec.europa.eu/social/BlobServlet?docId=24123&langId=en 

2 A separate consultation report as part of the above-mentioned study, will be published. It will offer a 
more comprehensive overview of the contributions received within the OPC.  

1 

 
 
 
 
 
 
                                                           
health and safety. In the communication3 that  this report accompanies, these contributions have 
been  taken  into  account.  The  communication  identifies  the  main  priority  issues  as  well  as 
concrete  actions  that  could  be  taken.  Contributions  that  went  beyond  the  scope  of  the  EU’s 
powers were not taken into account. 

2.  METHODOLOGY  

Stakeholders  had  the  opportunity  to  provide  online  feedback  on  the  roadmap4  for  the  new 
framework using an open-text field. They also had the opportunity to participate in an OPC 
by  submitting  their  feedback  through  an  online  questionnaire.  In  addition,  the  Commission 
received contributions from stakeholders through regular exchanges and ad hoc submissions. 
On  behalf  of  DG  Employment,  Social  Affairs  and  Inclusion  (DG  EMPL),  an  external 
contractor carried out some of the consultation activities. 

The  OPC  combined  a  mixture  of  ‘closed’  questions  (where  respondents  chose  from  a  pre-
determined  selection  of  answers)  and  ‘open’  questions  (where  they  were  free  to  write  any 
response  they  chose).  Participants  were  given  a  500-character  limit  for  all  questions  except 
questions 23 and 25. For these two questions, responses of 2 500 characters were allowed.  

The  OPC  results,  the  feedback  on  the  roadmap,  and  other  contributions  were  analysed 
quantitatively  and  qualitatively.  For  the  roadmap  feedback  and  other  contributions,  only 
issues mentioned at least twice by stakeholders have been considered in the analysis for this 
report.  Where  no  reference  to  a  particular  stakeholder  group  was  made,  this  means  that 
various  stakeholder  groups  –  not  constituting  a  majority  of  stakeholder  groups  –  raised  the 
issues mentioned. 

To  identify  themes/issues  of  relevance  for  the  new  framework,  MS  Excel  and  text-analysis 
tools were used for the OPC, while manual analysis was used for the roadmap feedback and 
other contributions. Where relevant, thematic grouping was applied to free-text responses to 
determine approximate frequencies of issues raised in these responses. This involved a degree 
of interpretation. 

3.  CONTRIBUTIONS RECEIVED THROUGH REGULAR EXCHANGES WITH 

KEY STAKEHOLDERS OR ON AN AD HOC BASIS  

Between  June  2019  and  February  2021,  over  20  contributions  were  received  on  the  new 
framework through regular exchanges or ad hoc submissions. The European Parliament (EP) 
and  the  Council  provided  25%  of  contributions,  while  individual  Member  States  and  trade 
unions/trade  union  associations  provided  17%  each.  Contributions  were  also  provided  by 
companies/business associations (13% of all contributions), non-governmental organisations 
(NGOs)  (8%),  and  EU  OSH  consultative  bodies  (the  ACSH  and  SLIC)  (8%).  International 

3 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions: “EU strategic framework on health and safety at work 
2021-2027 – Occupational safety and health in a changing world of work”  

4  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12673-EU-Strategic-Framework-on-

Health-and-Safety-at-Work-2021-2027 

2 

 
 
 
 
 
 
 
 
 
 
                                                           
organisations,  national 
accounted for 4% of contributions. 

labour 

inspectorates,  and  academic/research 

institutions  each 

Stakeholder type - regular exchanges and ad hoc contributions 

EU institution

Trade union/trade union association

Member State

NGO

Company/business association/business organisation

EU OSH consultative bodies (SLIC, ACSH)

Academic/research institution

National labour inspectorate

International organisation

4%  4% 

4% 

8% 

13% 

8% 

17% 

25% 

17% 

The issue most frequently raised in the stakeholder contributions was that of the changes in 
the world of work caused by the combined effects of technological progress, demographic 
change,  climate change  and  globalisation. Most contributions  in  this context  referred to  the 
rapid  ageing  of  the  EU  population  and  the  need  to  integrate  older  workers  to  ensure  that 
they  lived  a  productive,  healthy  and  long  working  life.  Many  of  these  contributions  also 
discussed effective return-to-work policies for people who had been out of work for some 
time.  Other  contributions  on  this  subject  discussed  the  increased  risks  arising  from  rapid 
digitalisation and new forms of work, two trends that have been accelerated by the pandemic. 
These  risks  include  ergonomic  and  psychosocial  risks,  OSH  risks  in  non-standard 
employment forms, and the risks of working from home.  

Most  stakeholders  also  referred  to  the  need  to  support  the  application  of  OSH  rules, 
particularly  in  micro,  small  and  medium  enterprises,  and  the  need  to  improve  the 
enforcement  of  these  rules.  In  this  area,  the  issue  most  frequently  raised  in  stakeholder 
consultations was the need to ensure OSH protection for vulnerable groups.  

Another  issue  that  stakeholders  considered  to  be  important  was  the  prevention  of  work-
related diseases (in particular cancer and the need to continuously update legislation in this 
field) and accidents at work.  

Stakeholders also  pointed to  the need to  support the implementation  of OSH rules with: (i) 
social dialogue; (ii) awareness-raising; (iii) EU and national funding; and (iv) improving 
synergies  with  other  policy  areas  (especially  chemicals  legislation).  They  also  referred  to 
the  need  to  improve  OSH  statistical  data  and  the  OSH  evidence  base,  building  more  on 
science and research.  

Non-business  stakeholders  also  said  it  was  important  to  learn  lessons  from  the  current 
pandemic  and  to  improve  OSH  around  the  world.  Several  stakeholders  also  pointed  to 
specific  OSH  risks  in  some  professions  or  economic  sectors,  as  well  as  the  need  to 
strengthen capacities for OSH on various levels. 

3 

 
 
 
 
 
 
 
 
70

60

50

40

30

20

10

0

Issues raised by stakeholders -  
- regular exchanges and ad hoc contributions 

61 

30 

27 

17 

12 

10 

6 

4 

Changes in the context of the digital transition (e.g. psychosocial risk, ergonomics, non-
standard employment forms, ageing)

Application and enforcement of OSH rules, with special focus on vulnerable groups and MSMEs

Prevention of work-related diseases (e.g. cancer, chemicals, mental health, musculoskeletal
diseases) and accidents

Social dialogue, awareness-raising, funding, synergies with other policy area

Evidence-based policy/data collection

Preparedness/lessons learned from COVID-19

OSH in the world

Other issues

4.  FEEDBACK ON THE ROADMAP  

Between 29 October and 26 November 2020, 49 stakeholders submitted online feedback on 
the  Commission  roadmap.  These  stakeholders  represented  a  variety  of  sectors.  Most 
responses came from companies and business associations (33%), followed by NGOs and the 
public  (19%  each),  other  stakeholder  types  (15%),  trade  unions/trade  union  associations 
(12%) and academic/research institutions (2%).  

4 

 
 
 
 
 
 
Stakeholder type - roadmap feedback 

Company/business association/business organisation

NGO

EU Citizen

Other

Trade union/trade union association

Academic/research institution

Non-EU citizen

2%  2% 

12% 

15% 

33% 

17% 

19% 

The issues most frequently raised by stakeholders were: (i) the prevention of work-related 
diseases and accidents at work; and (ii) the request to address work-related diseases (cancer 
in particular) and accidents at work in the new framework. Several non-business stakeholders 
stressed the importance of: (i) continuously updating binding occupational exposure limits 
(BOELs); and (ii) supplementing the Carcinogens and Mutagens Directive (CMD), including 
for nanomaterials and reprotoxic substances. On the other hand, several industry stakeholders 
asked  for:  (i)  activities  and  facilities  to  help  businesses  adapt  to  stricter  BOELs;  and  (ii)  a 
moratorium  on  stricter  BOELs  until  2022  due  to  the  pandemic.  Another  important  issue 
raised  by  stakeholders  in  this  context  (mentioned  mostly  by  trade  unions)  is  the  need  to 
combat  violence  as  well  as  sexual  and  psychological  harassment  at  work.  As  part  of  a 
focus on accidents at work and work-related diseases, several stakeholders proposed linking 
the new framework with the global ‘vision zero’5 campaign aiming at achieving zero work-
related deaths in the EU.  

Stakeholders were also greatly concerned about the changes in the world of work caused by 
the rapid uptake of new technologies, demographic changes, new ways of organising work, 
and climate change. Most contributions in this area referred to ergonomic and psychosocial 
risks. Many stakeholders asked for musculoskeletal diseases to be tackled urgently due to the 
rise of teleworking. These stakeholders asked for the response to musculoskeletal diseases to 
focus  on  prevention  and  adapted  policies.  Some  stakeholders  asked  for  appropriate  legal 
instruments  to  address  psychosocial  risks  at  work.  In  addition,  several  stakeholders  raised 
concerns  related  to  old-age,  including:  (i)  the  need  for  improved  return-to-work  policies; 
and (ii) OSH risks in non-standard forms of employment.  

Most  stakeholders  mentioned  the  importance  of  supporting  the  application  of  OSH  rules 
(especially  in  micro,  small  and  medium  enterprises)  and  improving  enforcement  by 
strengthening the resources of labour inspectorates. In this context, non-business stakeholders 
stressed the need to ensure that OSH rules were also applied to vulnerable groups, such as: 
(i) younger, female, seasonal and migrant workers; (ii) workers with disabilities/illnesses; and 
(iii) frontline (e.g. healthcare) workers.  

Many stakeholders also mentioned the importance of social dialogue, awareness-raising and 
improving  synergies  with  other  policy  areas  (especially  the  areas  of  chemicals, 
environment  and  public  health).  Stakeholders  also  stressed  the  importance  of  integrating  in 

5 http://visionzero.global/ 

5 

 
 
 
 
 
 
 
                                                           
the  new  framework  lessons  learned  from  the  pandemic  –  especially  lessons  related  to 
musculoskeletal  diseases,  non-standard  forms  of  employment  and  the  increase  of  mental 
health problems. Some stakeholders asked for COVID-19 to be recognised as an occupational 
disease.  

Another  important  issue  raised  by  stakeholders  was  the  need  to  improve  OSH  statistical 
data  and  the  OSH  evidence  base.  Several  stakeholders  also  mentioned  the  need  to 
strengthen international cooperation in OSH and to set EU-wide and global minimum OSH 
requirements and objectives. 

Issues raised by stakeholders - roadmap 

80

70

60

50

40

30

20

10

0

68 

41 

35 

21 

17 

13 

7 

3 

Prevention of work-related diseases (e.g. cancer, chemicals, mental health, musculoskeletal diseases)
and accidents
Changes in the context of the digital transition (e.g. psychosocial risk, ergonomics, non-standard
employment forms, ageing)
Application and enforcement of OSH rules, with special focus on MSMEs and vulnerable groups

Social dialogue, awareness-raising, synergies with other policy areas

Preparedness/lessons learned from COVID-19

Other issues

Evidence-based policy/data collection

OSH in the world

5.  FEEDBACK FROM THE OPC 

The OPC6 took place from 7 December 2020 to 1 March 2021, with 355 respondents replying 
to the questionnaire on the previous and future EU strategic frameworks. Respondents to the 
OPC came from 26 EU Member States and 7 non-EU countries. 

6 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12673-EU-Strategic-Framework-on 

Health-and-Safety-at-Work-2021-2027-/public-consultation 

6 

 
 
 
 
 
 
 
                                                           
Stakeholder type - open public consultation 

Company/business association/business organisation

EU Citizen

Trade union/trade union association

Public authority

Other

NGO

Academic/research institution

Non-EU citizen

6% 

3% 

1% 

9% 

11% 

12% 

35% 

23% 

Of the OPC respondents, 64% strongly agreed or agreed that workplace safety and health in 
their  country/the  EU  had  improved  overall  since  2014.  This  view  was  more  prevalent  for 
respondents  representing  employers  and  employers’  associations  (83%  of  whom  agreed  or 
strongly agreed) and lower for respondents representing workers’ associations (48% of whom 
agreed or strongly agreed). 

Most  respondents  felt  that  the  previous  framework  contributed  either  ‘to  a  great  extent’ 
(15%)  or  ‘somewhat’  (54%)  to  improved  health  and  safety  at  work  at  EU  level.  Slightly 
fewer  respondents  felt  that  the  previous  framework  contributed  ‘to  a  great  extent’  (9%)  or 
‘somewhat’ (54%) to improved health and safety at work at national level. Less than half of 
respondents  felt  that  the  framework  contributed  ‘to  a  great  extent’  (6%),  or  ‘somewhat’ 
(43%)  to  improved  health  and  safety  at  regional  level,  and  ‘to  a  great  extent’  (8%)  or 
‘somewhat’ (43%) to improved health and safety at workplace level. 

Respondents  considered  that the highest  priority  in  the previous framework was addressing 
issues  such  as  the  ageing  of  the  workforce  and  emerging  new  risks.  Of  respondents,  90% 
stated that this was very important or important.  

Opinions  were  divided  on  whether  progress  had  been  made  in  the  actions  under  the  seven 
strategic objectives in the previous framework. For each strategic objective, half or less than 
half of respondents agreed: (i) that good progress had been made against each action; (ii) that 
the action had led to tangible results; (iii) that the actions were relevant to the priorities in the 
area of OSH; and (iv) that the appropriate stakeholders had been involved in developing the 
action. In most cases, more respondents agreed than disagreed that progress had been made in 
these areas. 

When comparing responses on each of the seven strategic objectives, respondents were most 
positive  about  the  progress  made  under  the  first  strategic  objective  (review  national  OSH 
strategies)  and  the  second  strategic  objective  (facilitate  compliance  with  OSH  legislation). 
Respondents  appeared  to  find  the  fifth  objective  (addressing  the  ageing  of  the  workforce, 
emerging  new  risks  and  work-related  and  occupational  diseases)  to  be  the  most  relevant  of 
the  strategic  objectives,  followed  by  the  first  objective,  the  second  objective,  and  the  sixth 
objective (improve data collection). The first, second and fifth objectives were perceived to 
have produced the most tangible results. 

7 

 
 
 
Respondents reported the least progress and least evidence of tangible results under the fourth 
objective (simplify legislation) and the seventh objective (improve international cooperation). 
It is notable that these two objectives were also perceived to be the least relevant. 

On  the  first  strategic  objective,  approximately  half  of  OPC  respondents  (53%)  said  good 
progress  had  been  made,  while  20%  disagreed.  The  same  proportion  (53%)  agreed  that  the 
actions under the first strategic objective were relevant to the priorities in the area of OSH, 
while 39% agreed that these actions involved the appropriate stakeholders, and 41% agreed 
that they led to tangible results. 

Of respondents to the OPC, 35% felt that employers were involved ‘too little’ in the design of 
the previous framework, whereas 33% felt workers’ organisations were involved too little. A 
further  33%  felt  OSH  professionals  were  involved  too  little,  and  31%  felt  employers’ 
organisations were involved too little.   

Respondents mentioned the following key barriers to fulfilling the objectives of the previous 
framework:  (i)  limited  staff  and  money  (mentioned  by  41%);  (ii)  lack  of  interest  among 
employers  (mentioned  by  35%);  and  (iii)  lack  of  awareness/understanding  of  OSH  among 
key stakeholders (mentioned by 34%). 

Most respondents (68%) supported an updated or adapted framework, while 11% felt that a 
successor framework should remain largely the same as the 2014-2020 iteration. A very small 
number  of  respondents  (<1%)  were  in  favour  of  discarding  the  framework,  while  14% 
believed the framework’s current model needed to be fundamentally altered.  

Respondents felt that the two most important OSH challenges that needed to be addressed in 
the next 7 years were psychosocial risks and the trend of increased working from home.  

Key challenges common across the EU that require further OSH policy action 

All respondents (n=349) 
Source: Consultation report from external study  

8 

Thinking ahead to the next 7 years, what are the key challenges that are common across the EU and require further OSH policy action? 16%11%10%10%9%9%8%6%6%4%4%3%2%Psychosocial risks (increased work intensity, blurring of work-private life, etc.)Increased working from home / teleworkingErgonomic risks and musculoskeletal disorders (MSDs)OSH risks emerging from ICT/digitalisation (increased digitalisation, AI, workers' surveillance,…Risks from dangerous substances (e.g. chemicals / carcinogens)Preparedness for future threats to workers’ health and safety (e.g. infectious diseases)OSH risks emerging from the rise of platform economy (gig-work, increased precarious and…OSH risks emerging from climate and environmental change (such as infectious diseases)OSH risks emerging from robotics/automation/new technologiesPromotion of international OSH policy collaboration dimensionOSH risks to specific socio-demographic groups (women, migrants, etc.)OSH risks emerging from nanotechnology/nanomaterialsOther 
 
 
 
OPC  respondents  also  suggested  the  following  main  areas  of  focus  for  the  future 
framework: 

  effective application of OSH legislation; 
  development  and  dissemination  of  OSH  guidance,  good  practices  and  other 

awareness-raising activities; 

  promoting cooperation and coordination of OSH policies across policy areas, such as 

health, education, environment, chemicals, etc. 

Main areas of OSH policy and action at EU level to be included in the future framework 

Figures below 5% not displayed. 
All respondents (n=342-346) 
Source: Consultation report from external study 

9 

81%77%72%68%68%68%57%17%20%23%29%27%26%37%Effective application of OSH legislationDevelopment and dissemination of OSH guidance, good practicesand other awareness raising activitiesPromoting cooperation and coordination of OSH policies acrosspolicy areas, such as health, education, environment, chemicals…Updating and adaptation of OSH related legislationPromoting social dialogueSupporting enforcement activitiesInternational cooperation and coordination of OSH policyImportantSlightly ImportantNot ImportantDon’t knowThinking ahead to the next 7 years (2021-2027), how important do you think the following will be in terms of OSH policy and action at EU level to be included in a Strategic Framework?