ISO 45001 in Construction: An Integrative Comparative Review of Implementation Drivers, Barriers, and Reported Outcomes in the European Union, United States, and Canada

This hypothesis-generating integrative comparative review examines how ISO 45001:2018 is interpreted and implemented in construction safety management across the European Union (EU), the United States, and Canada. Drawing on 35 sources—including peer-reviewed studies, regulatory documents, institutional guidance, and selected practitioner literature—it compares implementation drivers, regulatory alignment, reported benefits, persistent barriers, and supply-chain governance using an analytical framework organized around six thematic dimensions. The synthesis suggests a convergence–divergence pattern: firms across the three jurisdictions pursue certification for broadly similar reported benefits and encounter similar barriers rooted in worksite dynamism, subcontractor complexity, and workforce transience. Institutional drivers, however, appear to diverge along a spectrum of regulatory emphasis: in the EU, the standard often functions synergistically with directive-based prevention duties as an integrated compliance mechanism, whereas in the United States and Canada it more commonly operates as a voluntary strategic overlay upon detailed regulatory baselines, driven mainly by market differentiation and liability management. These interpretations are propositions inferred from regulatory structures, certification statistics, and practitioner literature rather than conclusions demonstrated by primary causal studies. A mapping of ISO 45001 clauses to construction-specific challenges and a comparative propositions matrix are developed. The evidence base remains uneven—particularly for Canada, which contributes primarily regulatory and institutional evidence—and construction-specific empirical outcome evidence for ISO 45001 is limited. The paper proposes a research agenda for comparative, evidence-based evaluation of occupational health and safety management systems (OHSMS) in global construction.