a common approach with respect to anti-discrimination legislation, whereas Finland and Germany emphasise the importance of a preventative approach. Poland is developing its approach and seems to be following the EU countries. In the UK and the US, the introduction of employment disability anti-discrimination legislation, such as the Americans with Disabilities Act (ADA) of 1990 and the British Disability Discrimination Act (DDA) of 1995, has obliged employers to mainstream people with disabilities into the labour force. Both laws make it unlawful for an employer to discriminate against people with mental health problems and set requirements with respect to employment of people with disabilities.

In Finland, Germany, and Poland, where this strong legal impetus is missing, the approach to mental health issues in the workplace stems more from the perspective of stress prevention and healthy work organisation. Finland does not have over-arching anti-discrimination legislation or a quota-system. In German legislation, people with disabilities are covered by several Acts, including the Severely Disabled Persons Act, which sets a 6% quota for the employment of people with disabilities by public and private companies with minimum workforces of 16 people. German and Finnish legislation puts physically, mentally, and psychologically disabled persons on an equal basis. However, in both countries this leads to unequal treatment, because most of the rehabilitation measures are geared to the needs of people with physical disabilities.

Polish legislation, passed in 1994, specifically addresses mental health concerns. According to the Mental Health Act, mental health is a fundamental human value and the protection of rights of people with mental disorders is an obligation of the State. The Act proclaims, among other things, "...mental health protection shall consist in the promotion of mental health and the prevention of mental disorders." The Polish situation analysis, however, points out that some of the provisions of the Mental Health Act, particularly as it concerns employment and rehabilitation, have not been implemented. This is partly because the socio-economic changes in Poland have affected general employment opportunities and the resources necessary to promote and implement new legislation. In Finland, Germany, and Poland, mental health problems are often seen as disabling only when they are so severe that they prevent a person from obtaining or maintaining employment. In the UK, and in particular in the USA, less severe mental health problems are more likely to be seen as a disability if they interfere with daily living and work. This reflects the emphasis of each country's legislative framework.

ACCESS TO SERVICES

The reports state that access to mental health services is often limited and not comprehensive. There is a lack of parity in resources provided for mental health versus physical health. This is particularly evident in rehabilitation services, which traditionally have been more prevalent for physical disabilities. Several reports also note that often general practitioners, not specialised services, deal with people with mental health problems. For instance, in the UK, 80 % of the people diagnosed with depression are treated entirely within the primary health care services, and it has been estimated that approximately 40 % of all the visits to primary health care are due to the most common mental health difficulties. The countries are also concerned about low detection rates, which indicate that mental health problems are often underreported and underestimated. Stigma associated with mental health issues and use of mental health care services still exists in all five countries. Stigma may prevent the person suffering from a mental health problem from seeking treatment, and ultimately, can lead to unnecessarily severe and costly problems.