In China’s legal system of safety production, the Law of PRC on Safe Production is the first comprehensive safe production law in China, which defines the basic requirements for safety production [6]. The Law of PRC on Fire Prevention Regulation, the Law of PRC on road traffic safety, The Law of PRC on special equipment safety and other professional laws and regulations regulate the work of production safety in various industries. In accordance with Chinese laws and regulations, safety production supervision departments are responsible for comprehensive supervision of work safety, the public security, transportation, housing, urban-rural construction, quality and technical supervision departments and other relevant departments are responsible for professional supervision of safety production in accordance with their professional safety laws and regulations in the industry [6].

Based on the industry regulation, China has implemented a national supervisory system in some specific industry field, such as civil aviation, railways, shipping, electric power, coal, etc., in order to improve the professional level of supervision, China has set up a number of professional safety supervision institutions, which are basically vertically managed and have no relationship with local governments. In terms of personnel and business, they are independent from local leaders and can minimize the interference of local governments [6].

The supervision of Chinese government mainly includes: the work safety supervision department and other departments responsible for the supervision and administration of safety production [7]. At the same time, China also actively encourage others to participate in production safety supervision, for example, encouraging the masses inform against hidden danger and accident, organizing workers to participate in and supervise the work of production safety of enterprises with the advantages of trade unions, giving full play to the supervision role of news media by public opinion, and supporting intermediary institutions to provide technical services for work safety etc. [8].

As of 2014, China has over 400 major laws and regulations concerning production safety, occupational health and labor protection, which include more than 50 administrative regulations, more than 30 state council notices on production safety, and more than 100 departmental rules and regulations, in addition, there are hundreds of national standards, industrial standards and local regulations on production safety [3]. However, there are some conflicts between various legal provisions, which restrict the supervision and law enforcement of work safety in China. For example, after implementing the regulations on the reporting, investigation and handling of production safety accidents in China, the investigation and punishment of production safety liability accidents shall be jointly completed by a joint investigation team composed of the national government and the functional department of supervision and administration of production safety, those two subjects have overlapping and overlapping functions in the work of accident investigation and administrative punishment, and it may be difficult for them to investigate and deal with the accident [9].

At present, the restraint of safety supervision personnel in China is more than the incentive, and the absence of incentive mechanism makes it difficult to mobilize the work enthusiasm of safety supervision personnel [10]. On the spiritual level, once a safety production accident occurs, no matter how hard the work of the early safety supervisors is, in the case of strict accountability, the accident prevention work done by the safety supervisors may be ignored or less proposed, making the safety production supervision has become a high-risk occupation, which has certainly hampered the work enthusiasm of safety supervisors, and indirectly caused it to be difficult for safety regulators to absorb and retain outstanding talents [11].

The issue of safety production is not a single issue of government regulation. It also requires the organization of social organizations to play its role in the supervision and management of production safety. The organizations in these social groups include: trade unions, non-governmental organizations and insurance institutions. However, the Chinese social supervision force has not been fully utilized. The main reason is that the participation mechanism is not perfect, which has affected the enthusiasm of social forces to participate. For example, the China Safety and Health Industry Association and other non-government organizations are still in the development stage of safeguarding the interests of the industry [12]. The role of safety production supervision has not been fully paid attention to and developed; the mandatory work injury insurance system has been guaranteed to a certain extent. Workers can obtain certain economic compensation after being injured by accidents and suffering from occupational diseases [8]. However, at present, China’s insurance system is “heavy compensation and light prevention”, and the industrial injury insurance institutions have not better played their role in accident prevention.

Germany is an industrial power and an economic powerhouse, and its annual number of safe production accidents is one of the lowest countries in the world. Germany’s safety production work is at the forefront, thanks to its complete legal system, strict law enforcement supervision, good safety awareness and working environment, and a reliable accident insurance system [5]. In addition, Germany’s safety production supervision and management adopts a “dual track system” supervision system: the national labor protection work and labor supervision carried out by the state labor protection agencies are under the responsibility of the state, federal states and state ministries and commissions; the labor protection activities and supervision carried out by the statutory accident insurance institutions are organized by the Industrial Accident Insurance Association and the Accident Insurance Company [13], both of them have the responsibility of setting labor safety standards, conducting consultation and prevention, implementing supervision and monitoring, and conducting accident investigation. Moreover, the Industrial Accident Insurance Association is not a part of the federal government and the state government, nor does it belong to any government department. However, it has the statutory nature of labor protection supervision and management, and is a self-managed public law entity that is not for profit [14].

Canada is a federal state with a three-tiered federal, provincial, and administrative system. It includes 1 federal government, 10 provincial governments and 3 provincial administrative regions. As one of the largest economies in the world, Canada is rich in natural resources, developed in manufacturing and high-tech industries, and primary manufacturing and agriculture are also the main pillars of the national economy [14]. The federal government is responsible for the formulation of labor security, working conditions, occupational health and safety regulations; the provincial government is responsible for formulating labor standards for minimum wages, compensation for work-related injuries, vacations, and overtime; provincial administrative district governments focus on providing employment assistance and social protection assistance to vulnerable groups [14]. In addition, strengthening the national safety awareness is another important part of the Canadian government to ensure the continuous and stable improvement of the production safety situation. Moreover, Canada holds a national occupational safety and health “safety week” in the first week of June each year, for example, posting “safety and health week” posters, distributing and showing free information and videos on safety and health; inviting security experts to present security knowledge to the enterprise; organizing seminars; announcing the list of workers, departments and leaders who have made outstanding achievements in safety and health work [15].

An important duty of safety production supervision is to supervise enterprises according to laws and regulations, departmental rules and regulations. The legal provisions are the basis for the establishment of the regulatory body, and it is the guarantee that the regulatory agency performs its duties and exercises its rights. Although there are many laws and regulations on production safety in China, there are ambiguous definitions of duties and contradictions between legal provisions. According to the research, German industry associations develop safety standards based on the current state of the industry to promote safe production [5], therefore, to learn from foreign advanced experience, China should gradually implement the principles of institutional setting and legislative advancement, conduct in-depth investigations into the safety production work of enterprises, and introduce a safety production legal system suitable for China’s national conditions.

According to the characteristics of China’s market economy, China should continuously improve the safety management system adapted to the market economy in view of the emerging new situations and problems; governments at all levels have set up work safety supervision and administration organizations and staffed them with professional and full-time supervisors to improve their professional quality and law enforcement ability, clarify the scope and responsibilities of supervision, and form and improve safety supervision networks; in addition, the work safety work pattern of “unified government leadership, supervision by departments in accordance with the law, overall responsibility of enterprises, participation of the masses in supervision, and broad support of the whole society” should be established, and their respective safety responsibilities and obligations should be defined in more detail, so as to ensure that each party’s main responsibility for safety is implemented in place.

In China, there may still be “laws that are not law-abiding and law enforcement is not strict”, enterprises and employees violate the laws, regulations and systems of production safety, which hinders the implementation of the enterprise production safety responsibility system, and causes various types of production safety accidents to occur frequently due to improper rectification of hidden accidents [11]. However, in economically developed countries, for example, “heavy penalty mechanism” is one of the important means for the Canadian government to supervise production safety. Under the effect of “heavy penalty”, Canadian enterprises and their bosses, managers and employees dare not take legal risks with their economic interests due to the high cost of breaking the law [7]. Therefore, the Chinese government can learn from foreign experience to strengthen administrative law enforcement. The responsible units and responsible persons responsible for the safety accidents shall be imposed high fines, and those responsible for serious violations of the law shall be investigated for criminal responsibility according to law, so that those enterprises and individuals who have the chance to survive will not dare to try their own methods and truly play a warning role.