The EU legislation on health and safety (EU Directive 89/911) is an example of so called “reflexive law”. It addresses not only the personal responsibility of the employer and the employees, but presupposes (sometimes implicitly) that these key agents reflect on existing workplaces and work processes, and the associated hazards and risks. In this way the EU legislation attributes a central role to the employer and the employees as responsible key agents in a process of self-regulation and self-reflection. In essence that seems to imply a process of cocreation of occupational safety and health. As researchers and consultants we are very committed to supporting such processes of co-creating of occupational safety and health. However, it seems to us that these processes are not yet fully supported by the usual safety models and approaches.