What is the difference between OHSA and UK HSE?

OSHA (Occupational Safety and Health Administration) in the U.S., the U.K. has an HSE (Health and Safety Executive) which enforces a legal requirement that :

“Every employer shall ensure that his employees are provided with adequate health and safety training…” – The Management of Health and Safety at Work Regulations 1999

And in the U.K. preparation of our training program of over 700 “toolbox talks” training safety meetings which have been successful in the United States and Canada, I was reminded of one quote relating to how our common language has diverged over the centuries.

OSHA “Occupational Safety and Health Administration”

OSHA is a regulatory and compliance body of health and safety in the United States of America in which offers a 10 hour and 30 hour awareness classes for workers on OSHA regulations and standards related to different jobs at the workplace. For example excavations, working at height and other related matters. OSHA issues a wallet size card to all participants such as workers, supervisors, etc. OSHA is no longer issuing any cards to any trainees outside the United States of America since 2010.

OSHA training programs are intended for workers within the agency's geographic jurisdiction. These locations include the 50 U.S. States, the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, American Samoa, Guam, the Trust Territory of the Pacific Islands, Wake Island, Outer Continental Shelf Lands defined in the Outer Continental Shelf Lands Act, and Johnston Island. For this reason,

Although trainers may provide safety and health training to workers outside the OSHA's geographic jurisdiction, it must be done outside of the Outreach Training Program and without OSHA's involvement. Under such a plan, trainers may design and issue their own certificates, cards, badges, stickers, etc. as long as they do not indicate that the program is supported by OSHA or is a part of the OSHA Outreach Training Program.

The Health and Safety Executive (HSE) is the body responsible for the encouragement, regulation and enforcement of workplace health, safety and welfare, and for research into occupational risks in Great Britain. It is a non-departmental public body of the United Kingdom with its headquarters in Liverpool, England. In Northern Ireland, these duties lie with the Health and Safety Executive for Northern Ireland. The HSE was created by the Health and Safety at Work etc. Act 1974, and has since absorbed earlier regulatory bodies such as the Factory Inspectorate and the Railway Inspectorate though the Railway Inspectorate was transferred to the Office of Rail Regulation in April 2006. The HSE is sponsored by the Department for Work and Pensions. As part of its work HSE investigates industrial accidents, small and large, including major incidents such as the explosion and fire at Buncefield in 2005. Though it formerly reported to the Health and Safety Commission, on 1 April 2008, the two bodies merged