GREECE: EWCO comparative analytical report on Information, consultation and participation of workers concerning health and safety

  • Observatory: EurWORK
  • Topic:
  • Health and well-being at work,
  • Working conditions,
  • Published on: 21 Deireadh Fómhair 2010


Disclaimer: This information is made available as a service to the public but has not been edited or approved by the European Foundation for the Improvement of Living and Working Conditions. The content is the responsibility of the authors.

In general, the laws in Greece regarding information, consultation and participation of SME workers in health and safety issues are deemed adequate. Nevertheless, difficulties are encountered in the application of the measures provided for by laws, with the result of Greece still holding one of the highest occupational accident rates in the European Union despite the decrease of such in the country over time.

Background information

The general issue

According to several studies (Walters, 2002, HSE, 2005), Health and Safety management shows significant differences between large companies and SMEs. In these latter, especially among micro-enterprises (less than 10 employees) and small ones (10-49 employees), H&S regulation is a lot of times perceived more as a burden to comply rather than a competitive opportunity because of stronger pressure over costs, company struggle for survival, lack of both financial and human resources. Further, in micro and small firms employers do not always own adequate OSH managerial skills and knowledge and they often see with suspicious the support offered by public agencies.

The extent of workers’ involvement is ambiguous: on the one hand could be easier because of direct relationship with ownership, while lower skills and shorter average tenure and the lack of OSH workplace representatives, due to legal threshold and/or non-unionization, make workers less involved in taking care of H&S on the other.

Regulatory Framework

The Health and Safety at work Framework Council Directive 89/391 introduces general prevention principles applicable to all occupational risks, aimed to ensure a higher degree of protection of workers at work through the implementation of preventive measures to guard against accidents at work and occupational diseases. The directive establishes the obligation on employers to adequately inform (art. 10) and to consult his/her employees and their representatives (art.11) by allowing them “to take part in discussions on all questions relating to safety and health at work”, thus including their right to make proposals and to a balanced participation. Finally, the directive sets an obligation on the employer to adequately train at his expenses his/her employees (art. 12) and their representatives, with regular repeals in order to take into account of technological and organizational changes and to the insurgence or changes of new risks.

The H&S at work strategy 2007-2013 stresses the importance of SMEs, high-risk sectors and subcontracting in achieving the target of a 25% cut of work accidents within 2013: in particular, SMEs are seen as more vulnerable since they have “fewer resources to put complex systems of protection in place, while some of them tend to be more affected by the negative impact of health and safety problems”.

The strategy envisages a simplification and adaptation of the existing legislation to SMEs and various forms of support in its implementation, such as dissemination of good practices, training of employees, development of simple risk assessment tools and guidelines, access to affordable and good quality prevention services, and economic incentives. Labour inspectors should play a twofold role both “as intermediaries to promote better compliance with the legislation in SMEs, primarily through education, persuasion and encouragement” and “when necessary, through coercive means”,

Member States are invited to “take steps to facilitate access to good quality prevention services” particularly in favour of SMEs, to improve health surveillance of workers while avoiding inflating the formal requirements, to incorporate into their national strategies specific measures (financial assistance, training tailored to individual needs, etc.). Further, Member States and the social partners are encouraged to promote “the practical, rapid implementation of the results of basic research by making simple preventive instruments available to enterprises and in particular to SMEs”.

The second programme of Community action in the field of health (2008–2013) and the 2008 "European Pact for Mental Health and Well-being" , together with framework agreements on work-related stress (2004) and violence, bullying and harassment at workplace (2007) show both an important shift from the original notion of H&S, as stated by the 1989 directive, towards a more general “well-being” approach, and the prominent role played by social dialogue in its advance.

Figures and trends

Eurostat figures over work accidents (2002-2006) show the highest incidence rates in medium companies (50-249 employees), while micro-entreprises (1-9 employees) show the highest rates over fatal accidents. These trends seem to depend on the impact of manufacturing, construction and transports, while in the other services industries trends are not so clear-cut. However, Eurostat figures by industry and company size are not complete in order to provide an adequate assessment over time. Further, new risks emerge and work-related diseases (WRDs) evolve from the so-called “hygienic” risk factors towards “psychosocial” ones reflecting changes in working conditions.

Similarly Eurofound 4th EWCS does not show a clear-cut relationship between work accidents, risks for health and work-related diseases with company size. When asked “Do you think your health or safety is at risk because of your work?” (question 32) and “Does your work affect your health, or not?” (question 33), respondents working in small companies (10-49 employees) report the lowest scores. However, the share of respondents not well informed on H&S (question 12) declines from 15.3% in companies with 2 to 9 employees to 11.2% in companies over 250 employees: on average, such a share tend to increase since 1995 (see the full descriptive report). Similarly, both training and involvement over organizational issues are positively correlated with company size and could display indirectly a positive effect on H&S. Composition effects with respect to age (small companies show younger population), and industry (wider proportion of SMEs in services) should be taken into account.


1. National settings and regulatory framework

- How is the 1989 Framework directive on H / S and in particular information / consultation practically implemented in SMEs? Any data available? Do administrative reports exist in particular from the Labour Inspectorate?

Based on presidential decree (PD) 17/1996 which introduces regulations of community directive 89/391 to the greek law system, one of its goals refers to the information, consultation and training of workers and their representatives in health and safety issues. According to the provisions of the above PD, in any undertakings employing less than 50 persons - these accounting for more than 90% of Greek enterprises - employees have the right to choose by majority one representative (selected for a 2-year period) on the health and safety at work. As for enterprises employing

  • 51-100 persons, these have the right to choose 2 representatives ,

  • 101-300 persons, 3 representatives,

  • 301-600 persons, 4 representatives,

  • 601-1,000 persons, 5 representatives,

  • 1,001-2,000 persons, 6 representatives,

  • More than 2,000 persons, 7 representatives.

  • addition, as for enterprises with more than 50 persons, these are obliged to have an occupational physician and safety technician.

Based on the provisions of PD 17/1996, employers are obliged to consult with employees while workers and their representatives have the right to submit proposals aiming at the improvement of health and safety conditions. In addition, employers should inform workers in good time so that the latter or their representatives submit proposals on the design and organization of health and safety training, the establishment of the health and safety regulation and generally to submit proposals on any action that could have substantial effects on their health and safety. Moreover, workers and their representatives have the right to refer to the competent Labour Inspectorate (Σώμα Επιθεώρησης Εργασίας, SEPE) if they believe that the steps taken and the means provided by the respective employer do not suffice to ensure health and safety at work.

Every year SEPE, which falls under the Ministry of Employment and Social Protection (Υπουργείο Απασχόλησης και Κοινωνικής Προστασίας, YPAKP), makes reference in its Annual Report to the controls of enterprises regarding the implementation of health and safety provisions, the sanctions they imposed, the suggestions they put forward on the improvement of working conditions and any subsequent controls of enterprises controlled in the past. Nevertheless, there are no specific particulars on small and medium-sized enterprises because any statistics made available by the European Union are analyzed based on the sector of the enterprise’s economic activity rather than its size.

In 2008, SEPE’s technical and hygiene department investigated the causes of 6,657 workplace accidents, up from 6,561 accidents in 2007 and 6,255 in 2006. The total number of inspection carried out by the technical and hygiene department of SΕPΕ with the purpose of preventing and reducing workplace accidents and occupational diseases stood at 24,600 in 2008, as against 27,895 in 2007 and 27,857 in 2006. Fines imposed on businesses for not observing the rules in relation to hygiene and work safety rose to € 3,354,900 in 2008 from 3,028,500 in 2007 and €2,949,100 in 2006. The number of fatal workplace accidents raised to 142 in 2008 from 114 in 2007 and 128 in 2006. The sector where the most accidents occurred is the construction sector, although there was an important drop in comparison to previous years. In particular, in the construction sector there were recorded 48 accidents in 2008, 59 in 2007 and 56 in 2006.

- Does its implementation in micro and small companies follow similar patterns than in medium ones?

Apart from the division into enterprises having more than 20 employees and those employing less than 20 persons, the provisions on health and safety make no distinction between small and medium-sized enterprises as regards the presence of any representative(s) in a health and safety committee and the presence of an occupational physician in enterprises having more than 50 employees.

- Is H&S the current focus of legislation or did it evolve by incorporating “well-being at work” as the basic concept?

According to the annual reports of the Social Insurance Institute (Ινστιτούτο Κοινωνικής Ασφάλισης, ΙΚΑ), based on the fact that the accident rate (number of accidents per 1,000 insured persons) in Greece in all sectors has fallen from 7.82 in 2003 to 6.32 in 2006, health and safety issues are a specific part of the Greek Labour Law. According to SEPE, the decrease in the accident rate is a sign of the positive results generated by the auditing and information actions of its bodies. Moreover, in order to improve health and safety conditions at work, social partners have established the Hellenic Institute of Occupational Health and Saferty (Ελληνικό Ινστιτούτο Υγιεινής και Ασφάλειας της Εργασίας, ELINYAE) which, among others, aims to provide expert services for these issues.

- The Community strategy health and safety at work for 2007-2012 calls upon the member states to work out and implement strategies to reduce the number of industrial accidents and occupational diseases; are the SMEs specially singled out in the national strategies and cooperation between social partners underlined / foreseen / called for?

The greek micro enterprises are represented in the consultation procedures by the respective employers' organisation, i.e. the General Confederation of Greek Small Businesses and Trades (Γενική Συνομοσπονδία Επαγγελματιών Βιοτεχνών Εμπόρων Ελλάδας, GSEVEE).

2. The micro-level settings: the role of H&S representatives

- From what level onwards / number of employees onwards, is it legally binding to establish an H&S Committee in the companies? What’s its role and function?

Health & Safety Committees are established in enterprises with more than 20 employees. The number of Committee members depends on the number of the enterprise's employees with their term of office set at two years. The committee has an advisory role and is competent to: a) study working conditions so as to propose steps for their improvement; b) monitor the implementation of health and safety measures; c) participate in the elaboration of the enterprise’s policy to prevent occupational risks; d) in case of imminent and serious danger, they ask the employer concerned to take the necessary steps including interruption of production process. Finally, they are entitled to have recourse to the SEPE if they find that the steps taken by the employer are inadequate.

- From what level onwards / number of employees onwards are risk prevention representatives elected? Are they distinct representatives from H&S Committee and work councils?

There are no distinct committees of occupational risk assessment but this duty falls under the auditing powers of Health and Safety Committees. As regards occupational risk assessment, employers are obliged to draw up a written assessment of all the sources that could have an adverse effect on the health of employees. Such written assessment of occupational risks could be made by the enterprise’s safety technician or the occupational physician or it could be assigned to an external legal entity, which provides the services of safety technician and occupational physician, the “External Protection and Prevention Services”, and is hired by employers with respect to health and safety issues.

- Does the H&S Committee deal with individual health related complaints? Does it have the right to initiate action?

Employees may refer to the Health & Safety Committee if they are faced with problems at their work. Subsequently, the committee may refer to the employer to give a solution to the problem but if the latter persists they may turn to the Labour Inspectorate.

- Do regional/territorial risk prevention representatives exist, covering several small SME’s?


- Is there special H&S training foreseen for OSH representatives/committees? Is it adequate in order to cope with both emerging risks and legislative and technological changes in SMEs?

ELINYAE and accredited training centres provide training to safety technicians, occupational physicians and the elected representatives of employees. The bodies carrying out training programmes are obliged to submit the recommended programmes to the General Directorate of the YPAKP together with the qualifications of trainees and trainers. Decisions of the Minister of Employment regulate the organization, operation, duration and curriculum of training programmes. Ministerial decisions also regulate programme implementation expenses, which, however, are not charged to employees.

- In order to carry out prevention policies, does a right exist for the H&S Committee to carry out surveys, call in outside independent experts? Who finances the costs of the operations / expertise? Does this right exist also in SMEs?

See answer to the next question.

- Does the H&S Committee have the right to consult the Labour Inspectorate?

The Health and Safety Committee of an enterprise may refer to the SEPE if they establish that the occupational risk prevention policy on the part of the employer and, generally, all the steps taken by the latter do not suffice to ensure health and safety at work. It is the employer who undertakes the costs of occupational risk assessment, health and safety training of employees and the improvement of working conditions following suggestions of experts (e.g. Labour Inspectorate).

- Does regular reporting, annual reports exist which describe enterprises occupational diseases, assess the occupational risks at the workplace and present prevention policies? Are they submitted to the H&S Committee for discussion before publication?

An enterprise should have a written assessment of the hazards arising against health and safety at the workplace. This assessment is undertaken by the enterprise’s safety technician or the occupational physician or by the “External Protection and Prevention Services” (EPPS). The enterprise’s occupational physician keeps the relevant medical file for each employee. In addition, an individual card of occupational risk is established and included in the medical file, which sets out the results of medical and laboratory exams wherever the employee is subject to exams. The health inspectors of the competent labour inspectorate and the doctors of the insurance organization under which the employee falls and the employee him/herself are entitled to take cognizance of the file and the individual card.

EPPS are obliged to keep files for each enterprise with which they enter into an agreement. Copies of each recommendation, survey, measurement or inspection related to the enterprise are recorded in such files. These entries should also be recorded by EPPS in the books enterprises must keep. The above documents are confidential and apart from the written occupational risk assessment and the different measurements also delivered to the Health and Safety Committee so that the latter submits its remarks, individual cards and individual files are delivered solely to executives of specific bodies and the employees themselves.

- Is the H&S Committee, when providing a high standard of working conditions and of occupational health and safety seen as a positive competition factor? Can the image of the companies be regarded as important in the context for winning major contracts? Do companies refer to the activities of the H&S Committee in their Annual report of activities, to the existence of day-to-day bargaining and the management of working conditions by the H&S Committee? Do and how differ the approaches between micro/small, medium and large companies?

The positive situation in terms of health and safety is taken into account when considering awarding projects to enterprises. Nevertheless, any positive health and safety conditions are not usually disclosed in the annual reports of enterprises but fall under the wider context of human resources management on its part and the satisfactory working conditions offered to its employees. This practice does not vary depending on an enterprise’s size.

3. Social partners and the role of collective bargaining (max 300 words)

Please summarize specific arrangements on H&S for SMEs and SME-dominated industries, and how territorial OSH representatives could intervene at workplace.

What is the role of Social partners in drawing guidelines and implementing H&S and work organization intervention aimed to prevent work accidents and WRDs? What is the role of labour inspectorates, social security institutions, OSH services and national agencies in promoting local-level experiences in SMEs? Please summarize, if there exist, the extent of the cooperation between these latter and social partners.

  • The social partners set up ELINYAE, which is the first institution of social dialogue in this sector that has ever appeared in Greek labour relations. The main purpose of the Institute is to provide scientific and technical support and serve the policy designed for safety, hygiene and health at work in Greece. Its resources derive mainly from a part of employer’s contributions for vocational training, from amounts arranged to be paid by social partners and from EU resources.

  • One of the main objectives of the SEPE is to prevent and reduce continuously industrial accidents and occupational diseases, to improve working conditions and the workplace and to promote measures enhancing the health of workers. Note that the social audit of the activity of the Labour Inspectorate is ensured through the operation of the Labour Inspectorate Social Audit Council (Τμήμα Κοινωνικής Επιθεώρησης), which includes representatives of the main employer associations and trade unions.

  • Through the activity of the SEPE that falls under the YPAKP, the ministry’s General Directorate of Health and Safety Conditions at Work collected and published a volume laying down good practices on safe work within SMEs. The volume was published in 2002 and the survey focuses on the following sectors:

  • arrangement of workplaces (lighting, noise, fire protection, emergency exits, etc);

  • arrangement of workstations (work in seating position, lifting weights etc);

  • equipment;

  • special works;

  • personal protective equipment; and

  • special categories of employees (pregnant women and young people).

Moreover, in 1998 the same Directorate issued a brochure referring to practical guidelines on the preparation of risk assessments within small enterprises. In addition, ELINYAE in cooperation with the Hellenic National Committee “Europe on health and safety at the workplace” issued a volume in 1995 relating to the health and safety at work within SMEs. Finally, ELINYAE created a CD-ROM based training package for safety technicians of small and medium-sized enterprises.

4. Figures, quantitative and qualitative studies.

Are there specific surveys which prove that standards of working conditions, health and safety within small enterprises as compared to larger ones are significant lagging behind?

Do these surveys also investigate the impact of training, information and consultation over working conditions also in SMEs?

When surveys lack, are there qualitative studies investigating the impact of involvement and training on working conditions and health in SMEs?

Develop on the findings / results. Please mention / enumerate / give links.

No survey was found. Nevertheless, a publication of the YPAKP issued in 2002 with respect to good practices for safety at work within SMEs makes reference in the volume’s introduction to the reasons having supported such initiative. According to the authors, it is established that the decrease of industrial accidents and occupational diseases within SMEs encounters many difficulties. Some of these are the following:

  • Given that they do not employ specialized executives, employers do not have the necessary support to deal with problems such as occupational risks.

  • The extended mobility of labour force and the employment of unskilled workers entail the loss of skills, which included safe methods of work.

  • Lack of appropriate information, briefing or training that could convince employers that the improvement of working conditions could benefit the performance of their enterprises is often lacking.

However, in the authors' opinion, a small enterprise does not have the luxury to have some workers absent, to stop or delay production due to accidents. In addition, in small enterprises, employers develop close personal relationships with employees and as a result the aid offered in the case of industrial accidents or occupational diseases usually exceeds by far what is specified by the formal obligations of an employer.

5. Good practices for SMEs: company/territorial level

Are there well known examples for specific collective agreements in a given sector covering working conditions, H&S in particular in SME’s which go far beyond legislation? Are they exceptions or the rule? Please report at least one example at national level and at least two at territorial/company level.

In sectors presenting great hazard such as construction, where a high incidence of accidents is recorded (almost 46.1% of deadly accidents in 2008 were in the construction sector. The respective percentage for 2007 was 62.7% and for 2006, 53.3%), the respective collective agreements describe in detail the rules of protection and the equipment that should be made available to workers. Nevertheless, there is no distinction based on the size of enterprises in these sectors. In general, all collective agreements make reference to health and safety issues without, however, clarifying in detail any specific measures that should be taken.

Based on a good practice awarded by EUOSHA and the YPAKP in the context of good practices implementation within SMEs, namely “Aquasafe” programme which refers to H&S-related prevention in the sector of aquaculture, the respective collective agreement sets out regulations on health and safety that are supported by good practice recommendations.

Given the relatively small number of business labour agreements that are signed, this explained by the fact that there should be at least 21 members to set up a trade union, which signifies that a business union can be set up in a few enterprises in Greece, no business agreements appear within SMEs that lay down more favourable regulations on health and safety issues compared to the applicable laws. It is collective agreements that usually regulate health and safety issues.


  • HSE (2005), Obstacles preventing worker involvement in health and safety. Research Report 296.

  • Walters D. (2002), Regulating health and safety in small enterprises. PIE, Peter Lang, Brussels

Stathis Tikos, Labour Institute of Greek General Confederation of Labour (INE/GSEE)

[1] Question 28a_1 “Have you undergone: Training paid for or provided by your employer, or by yourself if you are self-employed?”; Question 28a_2: “Training paid for or provided by your employer, or by yourself if you are self-employed - number of days”; question 28b_1. “Have you undergone: Training paid for by yourself?”; question 28b_2. “Training paid for by yourself - number of days”; question 28c: “Have you undergone: On-the-job training?”; question 28d. “Have you undergone: Other forms of on-site training and learning?”

[2] Question 30b: “Over the past 12 months have you been consulted about changes in the organisation of work and / or your working conditions?”; question 30d. “Over the past 12 months have you discussed work-related problems with your boss?”

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