This paper considers the implementation and operation of provisions for employee representation in health and safety in a number of member states of the European Union. It describes the results of two studies undertaken in seven European countries, including the UK, between 1989 and 1993. These studies compared legislative provisions for employee representation in health and safety in different countries and analysed the information available on the implementation and operation of these provisions. With regard to the coverage and implementation of legislation, the research found a similar pattern in all of the countries studied, with Britain distinguished by a number of features, most notably the very specific rights on this subject given to trade unions. However, analysis of information on operation of the provisions in all of the countries studied pointed to the strong association between trade union workplace organization and support as a powerful influence and determinant of the effectiveness of employee representation in health and safety. Taking this finding into account, the paper discusses the present and future situation in Britain with special reference to the implications of the provisions on employee representation found in the CEC Framework Directive 89/391.