Working Hours for First Responders - A comparative analysis of the implementation of Directive 2003/88/EC in Sweden and Denmark

Abstract: This essay delves into the implementation of EU Directive 2003/88/EC on working time in Sweden and Denmark, with a specific focus on rest periods for firefighters and ambulance personnel. Analysing both national legislation and collective agreements due to the robust labour market system in both countries, the essay seeks to comprehend Sweden's response to criticism from the European Commission in 2023 and proposes strategies for improvement. Despite similarities, there are some notable distinctions, such as Denmark's Minister of Labour having authority over deviations. The comparative analysis highlights varied collective agreements, where Sweden is more uniform in the design of the agreements, while Denmark is more variable in both design and complexity. Criticisms include inadequate treatment of rest periods and insufficient monitoring of working hours. While recent changes in Swedish agreements address some issues, legislative adjustments are necessary. Proposed theories aim to alleviate employee dissatisfaction, advocating for an equitable distribution of on-call and stand-by shifts. These findings emphasise the persistent challenges in harmonising national regulations with EU directives and prioritising employee well-being through balanced work hours.