The national legal systems reviewed do not adopt a uniform approach to the constitutional recognition of the right to health and safety at work. For example, the Constitutions of Austria and Iceland do not contain any particular regulations referring to such rights, whereas those of Italy and Sweden make specific provision as to health and safety. 125 The constitutional position as to obligations relating to health and safety in Spain arises as a supporting element of social and economic policy, 126 while in Germany it derives from Article 1, 127 Article 2, 128 and Article 20. 129