COMPARATIVE ANALYSIS OF THE LEGISLATION OF KAZAKHSTAN AND GEORGIA IN THE FIELD OF OCCUPATIONAL SAFETY IN HARMFUL AND DANGEROUS INDUSTRIES

Occupational safety at enterprises with harmful and dangerous conditions is a key priority of state policy in protecting workers' rights. Effective legislative regulation helps reduce occupational risks, improve working conditions, and ensure social guarantees. This article provides a comparative analysis of the labor protection legislation of Kazakhstan and Georgia, incorporating empirical observations from a foreign scientific internship. The study aims to identify similarities and differences in regulating working conditions, safety measures, and compensation mechanisms. It examines employer obligations, state control, and social guarantees, including occupational risk insurance, benefits, and early retirement. Additionally, compensation mechanisms for workplace accidents and legal accountability for labor protection violations are analyzed. The study's scientific significance lies in comparing legal norms, assessing compliance with international standards, and identifying areas for legislative improvement. The practical significance is in applying findings to modernize Kazakhstan's labor protection system and enhance social protection mechanisms. The study employed the comparative legal method, analysis of regulatory acts, as well as systemic and structural analysis. Differences were identified in the degree of state control, the level of employer responsibility, and the procedures for investigating occupational accidents. Prospective directions for modernizing Kazakhstan’s legislation were defined, taking into account the positive reform trends implemented in Georgia since 2018, such as the introduction of a risk-based approach, strengthening the role of employers, and harmonizing national legislation with European standards. The results of the study may be useful for lawyers, occupational safety specialists, trade unions, employers, and government authorities involved in labor law and social policy. The conclusions and proposals formulated in the