아픔이 길이 되게 하는 산업재해 정보공개: 미국·영국·프랑스·일본과 한국의 제도 비교

This study examines information disclosure systems in which the results and lessons of accident investigations are shared socially to propose a Korean-style system to prevent industrial accident recurrences and introduce effective preventive measures. The study conducted an in-depth comparative analysis of industrial accident information disclosure systems in major advanced countries, including the United States (OSHA, NIOSH, CSB), the United Kingdom (HSE), France (INRS), the European Union (eMARS), and Japan (JOHAS/JNIOSH). The results revealed that these countries prioritize identifying causes and preventing similar accidents rather than punishment. The systems in these countries disclose detailed accident circumstances, technical causes, and preventive measures through a database accessible to anyone. In contrast, Korea manages accident information confidentially under the pretext of investigation. Additionally, Korea’s system includes punishment-centered practices and the protection of personal information and corporate trade secrets, resulting in insufficient social learning and feedback functions. Accordingly, through this study, the author suggests concrete policy implications for introducing a Korean-style serious accident information disclosure system. The proposal includes the establishment of an independent accident investigation body, standardization and mandatory disclosure of accident investigation reports, and construction of an archive to manage disclosures in an integrated manner.