The consultation on amending the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) in line with the proposals made by Lord Young last year is now live.
 
The principal amendment proposed relates to regulation 3(2), under which duty-holders are currently required to report injuries that lead to a worker being incapacitated for work for three consecutive days. In his review of health and safety published last October, Lord Young of Graffham proposed that this reporting period be extended to seven consecutive days.
 
According to the consultation document, the objective of the change is “to improve the effectiveness of the reporting of workplace accidents by reducing unnecessary burdens on business while maintaining standards of compliance, which should help to contribute towards the overall effectiveness of Great Britain’s health and safety system”. (Northern Ireland has its own reporting system and so would not be affected by any changes.)
 
Currently, the cost to the HSE of dealing with over-three-day reports (O3D) is calculated at £1.3 million a year, while it costs Local Authorities around £267,000 a year. The HSE estimates that extending the reporting period to seven days would result in a reduction of 27,000 in the number of reports submitted each year.
 
This, it says, would translate into a cost saving to business of £220,000 a year in terms of less time spent reporting, and a cost saving to the HSE and Local Authorities of £120,000 in terms of less time spent processing reports. The net benefit to business over ten years would be £1.7m, the HSE concludes.
 
As for how much the change would cost, the Executive estimates that the total quantifiable costs (for example – for updating the legislation and guidance, fulfilling EU requirements to continue to provide data on O3D injuries, and familiarisation costs for business) would be £246,000 in the first year, with annual recurring costs of £6000 thereafter. Of this, £190,000 would be to business and would be incurred in the first year only.
 
In terms of negative impacts, one risk is a reduction in the quality of the dataset; if the requirement to report non-major occurrences is changed from three to seven days the ability to drill down into the data and perform detailed evaluations would be compromised.
 
Also, there will shortly be a legal requirement to provide data on O3D injuries to the EU statistical office Eurostat so if this amendment to RIDDOR is made, another – potentially more expensive – way of generating data for injuries that require between three and six days off work will be necessary.
 
There is also the chance that the change could increase compliance, in that the longer a person is off work after an incident the more likely it is that the incident will be reported. While this, in itself, is positive, increased reporting would also increase costs.
 
Finally, a reduction in the number of non-major reports submitted to the HSE could, it suggests, reduce the ability of inspectors to review cases that were near misses and to target their inspections.
 
Overall, the regulator maintains that there is no evidence to suggest that the proposed amendments and review will have a negative impact on employers, the self-employed and employees.
 
All interested parties are invited to submit their views on the proposed amendments by visiting the ‘current consultations’ area of the HSE website and clicking on CD233 – Proposed amendment to the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR).
 
IOSH members can also submit their comments for inclusion in the Institution's response - click here to find out more.

The consultation is open until 9 May 2011.