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Preventive Health at Work: A Comparative Approach

46 Pages Posted: 4 Jun 2011 Last revised: 19 Dec 2011

Julie C. Suk

Yeshiva University - Benjamin N. Cardozo School of Law


In the United States, the prevention of costly chronic diseases is an important ambition of healthcare reform. In many European countries, preventive health services are widely distributed in the workplace, through the complex infrastructure of occupational safety and health law. European and national laws impose on employers the duty to prevent risks to workers’ health. In France, as in many European countries, workplace doctors specializing in preventive medicine enable the employer to fulfill the prevention duty. The law requires employers to provide regular preventive checkups to all employees. Occupational physicians monitor employees’ health and engage in workplace policymaking to minimize environmental factors that can exacerbate employees’ chronic diseases. In the United States, employers are increasingly taking an interest in providing onsite preventive health services in order to cut healthcare costs. To identify and understand some of the challenges for integrating preventive health into the American workplace, this Article explores why and how American company clinics function so differently from French workplace health services. The workplace clinics in the two countries are governed by two fundamentally different employment law regimes, which have significant consequences for their ability to optimize employees’ health and pursue public health goals.

Suggested Citation

Suk, Julie C., Preventive Health at Work: A Comparative Approach. American Journal of Comparative Law, Vol. 59, No. 4, 2011; Cardozo Legal Studies Research Paper No. 342. Available at SSRN:

Julie C. Suk (Contact Author)

Yeshiva University - Benjamin N. Cardozo School of Law ( email )

55 Fifth Ave.
New York, NY 10003
United States

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