Abstract

Purpose: Despite the enactment of the Risk Assessment System (2013) and the Serious Accidents Punishment Act (2022), the occupational fatality rate in South Korea's construction industry has remained persistently stagnant, a problem further compounded by the structural vulnerability arising from the rapid increase in elderly and foreign workers. This study aims to identify insufficient implementation capacity among construction site supervisors as a central structural cause of this stagnation, and to derive evidence-based improvement strategies through comparative institutional analysis with advanced economies. Research Design/Methods: As a policy-oriented comparative study grounded in Comparative Institutional Analysis, this research examines the supervisory frameworks of South Korea, the United Kingdom, the United States, Germany, and Singapore across three analytical dimensions: (1) qualification and training systems, (2) legal penalty levels, and (3) the practical exercise of the right to stop work. The core concept of implementation capacity is operationalized through five sub-dimensions: knowledge, technical skills, authority, organizational support, and communication competency. Results: Countries with comparatively lower occupational fatality rates consistently exhibit competency-based qualification systems, effective legal sanctions, and a substantively exercised right to stop work. Under Singapore's bizSAFE and BCSS frameworks, a fatality rate of 0.12‰ per 10,000 workers is observed — approximately one-third of South Korea's rate of 0.39‰. By contrast, South Korea demonstrates clear structural limitations: a mandatory training requirement of only 16 hours per year that is predominantly theoretical, administrative fines capped at KRW 5 million, and a right to stop work that is largely nominal in practice. Conclusions: Five core policies are proposed to address the three identified institutional gaps: (1) introduction of a national qualification certification system for construction supervisors, benchmarked against Singapore's BCSS model; (2) reform of training toward field-based practice, with a minimum of 32 hours, at least 50% hands-on components, and tailored programs for elderly and foreign workers; (3) mandatory exercise of the right to stop work with strengthened legal protection for supervisors, drawing on Singapore's Safety Time-Out (STO) model; (4) modernization of legal penalty levels and institutionalization of adequate construction schedules; and (5) expansion of mutual safety incentive programs between prime contractors and subcontractors. This study seeks to contribute a policy foundation for South Korea's pursuit of OECD average fatality rate levels by 2030.