Countries seek to control exposure to hazardous substances and environments by the enactment of legislation. In the past thirty years, two major different approaches to occupational health and safety legislation have been devleoped by countries around the world. The performance-based legislative approach has been linked with the emergence of occupational health and safety management systems but no research has previously been done to determine whether or not the legislative approach taken by government influences the introduction or form of occupational health and safety management systems used by organisations. Similarly, although the reasons why Australia and other countries have moved to performance-based legislation have been explained in terms of social, political and economic factors that influenced the change, little research has been done on the effectiveness of this approach compared with the prescriptive approach of countries such as Korea. -I- The overall aim of this research is to develop a conprehensive understanding of the management of expusre to heavy metals in selected industries in Korea and Australia. The specific objectives of the study are to determine: The effectiveness of heavy metal exposure management in the fluorescent lamp manufacturing industry in Korea, and an Oral Health Service, and lead-risk workplaces in Queensland, Australia; The management of the legislative arrangements for health surveillance in Korea and Queensland, Australia; The characteristics of the occupational health and safety management systems that are in use in the heavy metal industries in Korea in Australia; and The effectiveness of prescriptive and performance based legislative systems in protecting the health and safety of workers in heavy metal based industries. Secondary analysis of biological monitoring data from 6 fluorescent lamp manufacturing companies (8 workplaces) in Korea was used to examine the extent of mercury exposure and the effectiveness of the health surveillance system in that country. A survey of dental workers in an oral health service in Queensland provided data on the extent of mercury exposure to the workforce and workers' attitudes to the management of occupational risks. The efficiency of the lead health surveillance in Queensland was examined by way of a questionnaire survey of lead designated doctors in the state. A survey of registered lead-risk companies and the oral health servies in Queensland, and 5 of the fluorescent lamp manufacturing companies in Korea provided data on the occupational health and safety management systems in place in these organisations. The health surveillance system for mercury exposed workers in Korea was found to have reduced the incidence of workers with biological levels of mercury above the Baseline Level from 14% in 1994 to 7% in 1999. Bilogical testing of dental workers in Queensland discovered no workers with biological levels of mercury approaching the Baseline Level and air monitoring failed to locate any areas where workers were likely to be exposed to levels approaching the Workplace Exposure Standard. The staff of the Oral Health Service were generally aware of the occupational health and safety management systems in place but only 43% felt that mercury management in the workplace effectively prevented exposure. The lead surveillance system in Queensland was found to be inadequately managed with approximately 37% of registered doctors no longer practicing in the field and their being no way for the government to collect reliable data on the extent of lead exposure in workplaces. The occupational health and safety management systems in the companies surveyed in Queensland and Korea were found to be influenced by the legislative arrangements in place in each of the locations. The Korean systems were more geared to meeting the regulatory requirements whereas the Queensland systems were geared more towards a risk management approach. However substantial differences were also noted depending on the size of the organisation in each case. Legislative arrangements in Korea and Queensland were found to provide reasonable protection from heavy metal exposure to workers however improvements in both systems are needed. The legislation was also found to influence the occupational health and safety management systems in place with performance-based legislation producing systems having a wide risk management focus while a narrower regulatory based focus was noted in Korea where more prescriptive legislation is in force. A confounding factor in the nature of the occupational health and safety management system in place is the size of the organisation and particular attention needs to be paid to this when legislative approaches are considered.