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SOURCE: Organization for Economic Co-operation and Development (OECD), The State of the Environment 1985. Paris OECD, 1985, p. 242.

a Some federal countries such as Australia and Austria have laws at state level.

b Law on the general control of chemicals.

c Law on compensation.

d Law on nature conservancy.

e Law on public health.

f Law on protection of forests and forest areas.

g Law on noise and air pollution from motor vehicles.

h Law on nuclear energy.

i Law on soil.

j Law on noise.

k Law on territory planning.

l Essentially a specific administrative procedure.

Given the similarity of the problems and the symmetry of responses, it might be expected that environmental management is essentially the same in industrialized countries. In fact, it is difficult to compare environmental policies between countries because newly emerging environmental policies did not develop in a void. A number of important factors have created a framework that contributes to the specificity of responses.

Existing Related Legislation

In most countries, legislation concerning water supply and quality dates to the 19th century.2 Initiated at widely differing times, ranging from the earliest such legislation in the Netherlands where water management represents an existential need, to the United Kingdom in the 19th century, to the United States, which—blessed with abundant resources—felt compelled to address this issue at a relatively late date. Similarly the regulation of industrial nuisances, essentially the impact of industries on their neighborhoods, follows the pattern of industrialization itself. The United Kingdom, having been the first to industrialize, first confronted industrial pollution. Germany followed at some distance, and many countries did not address this issue until the early 20th century. Countries also began to address issues of workplace safety and health. In the United States these issues were not tackled until a relatively late date.

Despite these differences, early linkages already existed between countries regarding these newly emerging policy areas, particularly through trade. Indeed, the United States first moved on pesticide safety in response to a trade ban for reasons of environment and public health: a British embargo imposed in 1925 on apples from the United States. Forced to comply with British requirements concerning arsenical residues on apples or lose an important export market, the United



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