Employment Injury Assistance International Comparisons Subgroup minutes: March 2026

Attendees and apologies

• Co-chair: Elma Murray CBE, Chair, Young Scot
• Rachel Gallagher, Strategy and Development Manager, Clydebank Asbestos Group 
• Ian Tasker, CEO, Scottish Hazards 
• Sholen Macpherson, Policy and Research Officer, Coalition for Racial Equality and Rights (CRER) 

Apologies

• Professor Ewan Macdonald OBE, Consultant Occupational Physician

Scottish Government officials present

• Matthew Duff, Social Security Policy
• Risga Summers, Social Security Policy
• Shelley Smith, Social Security Policy
• Daniel Rennie, Social Security Policy
   

Items and actions

Welcome and Introductions

The Co-chair welcomed members to the first meeting of the Employment Injury Assistance (EIA) International Comparisons Subgroup.

The Group had agreed to review a paper previously shared with the Steering Group, entitled ‘International comparison of occupational injury and disease compensation and social security’. 

The Group went through each section of the paper and discussed each example country one at a time. They considered whether there were any ideas or themes worth exploring further while noting the different wider social security systems within which schemes operated and how this might impact the design and delivery of each scheme.

Republic of Ireland

The Group agreed that there were not aspects of this scheme which they wanted to explore further with respect to EIA.

Spain

Members noted the high frequency of updates to the prescription list, noting that this was more responsive than the UK system. They agreed to consider this in more detail for EIA.

There does not appear to be a legal prerequisite to prove certain groups of workers are more exposed than the wider population before consideration by the advisory body. Members asked for more data and research about how this works in practice.

Sweden

Sweden has a system which has no prescriptive list of occupational diseases or injuries, and every application is managed on a case-by-case basis.

Members questioned whether this could lead to a ‘postcode lottery’ and had concerns about the use of regional agencies resulting in extra bureaucracy. As a result, the Group decided that they would not want to replicate this for EIA.

Germany 

In Germany, occupational diseases are listed in the Occupational Disease Regulation. Members noted interest in how the contents of this list compare to the UK’s.

Germany considers diseases outside of the prescribed list and a decision would be given if medical or scientific studies indicate that it should be included in the list. Members questioned how this is considered and whether this could feed into future decision making for prescription for EIA.

The German system pays for medically prescribed rehabilitation following an industrial injury. Members were interested in finding out the costs of this and how they compare to rehabilitation services in the UK.

Domestic Care occupations are included within the German occupation list. Members were keen to explore this further in relation to EIA as it could help address gender inequality within the current UK scheme.

France

As with Germany, members thought that it could be helpful to compare the French prescription list with the UK list. Specifically, members are interested in how France determines the criteria without the same requirement for proof as in the UK.

Members noted that rehabilitation has a strong focus in the French system and discussed whether EIA could passport to further support such as rehabilitation services.

Finland

The Group noted that the Finnish system is a mixed system, with a prescribed list of occupational diseases and an obligation to consider applications outside of this list. Members again expressed interest in how conditions not included on the prescribed list are considered for eligibility and whether there is learning from this approach for EIA.

Members noted that Finland is world-leading for Occupational Health services.

New Zealand

New Zealand has been identified by the Group as a system that they would like to consider further.

The Group requested a 1 page note on how this system works.

International Labour Organization standards

The Group noted that Convention C121 from the ILO standards has not been ratified by the UK and that only 24 countries out of over 100 have signed up to this. The Convention considers the adoption of certain proposals with regard to benefits in the case of industrial accidents and occupational diseases.

Members noted that you do not need to be signed up to this convention to include rehabilitation as part of any scheme and noted the potential for onward referral to rehabilitation to be considered as an option for longer-term reform of EIA.

The Group also discussed how businesses could bear greater responsibility for rehabilitation and play a role in providing this service to their employees, but noted that business regulation and law is a reserved matter.

There was a view that businesses in relevant industries should take more responsibility for rehabilitation and that this could tie into ongoing policy programme around Fair Work in Scotland. The previous iteration of the Healthy Working Lives scheme was raised as a positive example and the Group questioned whether a similar programme should be reintroduced to support employees and employers to access these services. Members were keen to find out the costs of the previous Healthy Working Lives scheme and what the costs would be to reintroduce this.

The Group asked officials to look into whether the UK has accepted ILO recommendations R121 which adopt certain proposals with regard to benefits in the case of industrial accidents and occupational diseases, and R194 which strengthens identification, recording and notification procedures for occupational accidents and diseases, with the aim of identifying their causes, establishing preventive measures.

Self-Employment

Members noted that some of the international systems considered cover self-employment. The current UK scheme excludes people who are self-employed.

AOB and next meeting

Members will feed back key points from the discussion at this meeting to the wider Group at the next meeting of the EIA Steering Group on 24 March 2026.

The next meeting of the Subgroup will be held at a future date after discussion with the wider Group.

The Co-chair thanked members for their time and closed the meeting.

Actions

• to find out whether R121 and R194 of the ILO Standards have been accepted by the UK
• to seek more data and research about the Spanish system, specifically the lack of a prerequisite to prove that certain groups of workers are more exposed than the wider population
• to undertake a more detailed comparison of the prescribed lists in Germany and France and identify any conditions not included in the UK system
• to research the costs of rehabilitation services in Germany and how this compares to the UK
• to find out the costs of the previous Healthy Working Lives scheme and what it might cost to reintroduce a similar model, taking inflation into account
• to provide a 1-page summary of the industrial injury scheme in New Zealand
• to decide the date and time of the next meeting after discussion with the wider EIA Steering Group