COMPARATIVE LEGAL STUDY OF THE NORMS ON LIABILITY FOR VIOLATION OF LABOR PROTECTION REQUIREMENTS IN THE CRIMINAL LAW OF FOREIGN COUNTRIES
Introduction: Criminalization of acts that violate the requirements of labor protection is socially conditioned both in Russia and abroad. The norms on criminal liability for violation of labor protection requirements in domestic criminal legislation and foreign legislation are somewhat similar, but at the same time they have significant differences. A comparative analysis of the similarities and differences in the structures of the compositions of such criminal law norms will allow us to use the positive experience of designing and applying the norms on liability for violation of labor protection requirements in Russia. Aim: to make a comparative study of the norms on criminal liability for violation of labor protection requirements in foreign criminal legislation. Methods: The methodological basis of the conducted research is made up of comparative legal and formal legal methods. Results: In the course of the conducted research, taking into account his own vision, the author identified the following positive features of the norms on criminal liability for violation of labor protection requirements in foreign criminal legislation: the formality of the compositions for violation of labor protection requirements (with an intentional form of guilt); the uniform arrangement of such norms (criminal violation of workers' rights); the presence of separate regulatory legal acts regulating the issues of employers' obligations to perform labor protection measures; a crime-forming factor in the form of the onset of an occupational disease as a result of violation of labor protection requirements. Conclusions: The considered domestic criminal law norm has enough controversial points, but it can be improved by borrowing the normative provisions of criminal and labor legislation (in the field of labor protection) of foreign countries.