산업안전보건법상 알 권리에 관한 비교법적 연구

Employees’ right to know can be classified into two distinct domains. As a direct legislative measure, first, occupational safety and health law provides employees with right to know, Second, employees’ right to know are given in the process of regulating employers who violate duties on private law such as the duty of reasonable care of safety. The purpose of this thesis is to examine how Germany, the United States and Korea regulate employees’ right to know and how it differs from each other from a comparative law perspective. In Germany, occupational safety and health law provides employees with right to know and occupational safety and health regulations, if they become the content of employment contracts, materialize employers’ duty of reasonable care of safety. If employers violate the duty of reasonable care of safety, employees may have a right to know. In the United States, Employees' right to know is not only a passive right created by imposed obligations on employers, but also an active one granted directly to employees by OSH-Act. Except in the United State, in Germany and Korea, right to know is stipulated not only as the duty by the positive(public) law but also as the duty by the contracts. Employees’ right to know is very important on occupational safety and health, but it is not guaranteed sufficiently in Korea. It is necessary to strengthen and enlarge right to know both on public law and private law.