Abstract

Background
Although most countries maintain occupational safety and health (OSH) legislation to prevent occupational diseases, the legal codification and integration of occupational health risk assessment (HRA), exposure monitoring, and medical surveillance vary substantially across jurisdictions; therefore, this study compared the legal frameworks of Korea, the United Kingdom (UK), the European Union (EU) and United States (US) to examine the linkage among these elements, assess whether they support estimation of individual cumulative past exposure, and derive implications for improving occupational disease prevention in Korea.
Methods
This qualitative comparative legal analysis examined employer obligations related to quantitative exposure monitoring, HRA, and medical surveillance under the OSH systems of the UK, the EU, the US, and Korea. Primary statutes and subordinate regulations were systematically reviewed to assess how these elements are mandated, linked, and supported by record-keeping provisions enabling cumulative exposure estimation.
Results
The UK and the EU explicitly require HRA as a regulatory starting point and link exposure monitoring and medical surveillance to the outcomes of risk assessment, with targeted hazard-based provisions for intrinsically high-risk agents. The US adopts a hybrid approach, imposing mandatory monitoring and medical surveillance for high-hazard substances under 29 Code of Federal Regulations 1910 Subpart Z while relying on general statutory duties elsewhere. Korea applies broad list-based requirements for exposure monitoring and medical surveillance that are largely independent of HRA outcomes and do not include legally mandated variables necessary for systematic cumulative exposure estimation. In contrast, the UK, the EU, and partially the US provide legal mechanisms, including long-term record-keeping provisions, that enable reconstruction of individual cumulative occupational exposure.
Conclusions
Strengthening the integration of HRA, exposure monitoring, and medical surveillance—together with improved record-keeping structures that support cumulative exposure reconstruction—may contribute to more effective occupational disease prevention and long-term medical surveillance in Korea.

• Keywords: health risk assessment (HRA); exposure monitoring; medical surveillance; individual cumulative exposure