Rather than merely changing the threshold at which RIDDOR reports must be made to the HSE, RoSPA suggests that a greater focus should be on employers’ duties to record and investigate injuries, ill health and near misses internally in order that lessons may be learned and similar occurrences avoided in the future.
The HSE’s consultation on proposals to amend the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) closes on 29 April. The proposals follow a recommendation in Lord Young’s Common Sense, Common Safety report that the trigger for reporting injuries should shift from absences of three consecutive days to absences of seven days, in order to reduce administrative burdens on businesses, particularly smaller firms.
However, RoSPA suggests the burden would increase if reports had to be made less often. Roger Bibbings, RoSPA’s Occupational Safety Adviser, calculated that, based on the RIDDOR over-three-day absence rate for the manufacturing sector in 2008/09, a firm employing 25 people might currently expect to make a RIDDOR notification once every four years. For similar sized businesses in the service sector, it would be once every eight years. At an over-seven-day trigger, he estimates that a small manufacturing firm could expect to make a notification once every 14.6 years and a small service firm once every 30 years.
He said:
“This is such a long interval that corporate memory of the requirement and how to meet it would certainly have evaporated. Inevitably, someone in the company would have to take time out to find out afresh what to do. In all probability, ignorance of the reduced reporting requirement would mean that injury-related absence would go unreported altogether. If adopted, this change will mean that compliance with RIDDOR, which is currently only about 50%, will decline further.”
RoSPA proposes that the duty to notify the HSE should be restricted to fatal and major injuries, cases of work-related ill health on the ‘notifiable’ list and incidents on the list of ‘dangerous occurrences’. To balance this, it suggests that employers should be required to investigate and keep internal records of all injuries requiring A&E attendance or medical intervention, including injury from work-related road crashes. Record-keeping would need to be proportionate and not unduly burdensome but records would need to be made available to enforcing authorities if required.
Roger Bibbings said:
“What is required is a much more radical approach, looking again at objectives to be achieved, focusing particularly on what can be done to encourage better learning by employers, not only from accidents and injuries but from significant ‘near-misses’. While always mindful of the need to avoid unnecessary bureaucracy, RoSPA would suggest that efforts to reduce burdens on business in this area should focus on helping organisations to improve their management of health and safety and thus avoid the heavy costs to which accidents and incidents usually give rise.”
