in the UK and the USA. In the USA, 40% of workers report their job to be very or extremely stressful. In all five reports, the effects of job stress are ranked among the most common work-related health problems.
WORK-RELATED STRESS
The Finnish, German, and Polish analyses note the impact of the significant economic and social changes which took place in the labour markets and society during the 1990s on employees' wellbeing. The possible relationship between unemployment and mental health problems has been a common concern. The German report identifies overemphasis on the outcomes, blurring boundaries between work and the private domain, overload, unpredictability of work requirements, and neglect of safety and health protection at work as the main negative side effects of recent changes in the labour market. The analyses recognise, however, that there were also positive developments during the 1990s, such as decrease in monotony, greater autonomy at work, and increased group work and co-operation. In the case of Poland, the transformation of the socio-economic system has fostered positive values such as pluralism, democracy, and freedom, but it also introduced new problems such as unemployment, growing rates of poverty and crime, and a decreasing sense of security. In the UK and the USA, the labour markets have been more stable with respect to unemployment, although they have been affected by the globalisation process.
COSTS ASSOCIATED WITH MENTAL PROBLEMS
As already mentioned, the costs associated with mental health difficulties are a common concern in all five countries. Governments, employers, employees, insurance companies, and society as a whole bear their share of direct (sick pay, benefits, social security, medical treatments) and indirect costs (loss of productivity and potential output and low morale related to mental health problems). It is easier to quantify costs related to mental health in the USA than in the European economies. In Europe a greater burden is still met by welfare and health services and other government agencies, whereas in the USA employers are directly responsible for employee costs. However, since the methods of evaluation, concepts, and indicators for mental health vary from country to country, it is very difficult to provide any comparable and reliable data concerning either the occurrence of mental health disorders or the costs related to them.
In the member states of the European Union the cost of mental health problems is estimated to be on average 3 to 4 % of GNP. In the USA, the estimates for national spending on depression range from $30 to $44 billion, with approximately 200 million days lost from work each year. A UK governmental agency, the Health and Safety Executive, estimates that mental health problems are the second largest category of occupational ill health after muscular-skeletal disorders, resulting in five to six million working days lost annually. In Finland and in Germany, growing social security costs are of great concern. In both countries early retirement due to mental health difficulties, in particular depression, has been increasing, and mental health difficulties are the most common cause of disability pensions. The Polish situation analysis points out the high costs associated with mental health difficulties but, due to lack of data, it is not able to provide exact figures.
LEGISLATION
It should be emphasised that legislation and the implementation of policies or laws are at the root of national differences in dealing with mental health issues. Generally, the United Kingdom and the United States share
