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.
I seem to recall the HSE being concerned about RIDDOR under reporting producing figures in the region of 46%. A change to 7 days will surely increase under reporting. Lord Young has no perception that Health and Safety is not about cost – it is about what it can save which I consider is what the HSE should be highlighting more. To say there is a chance because of the change compliance will be increased indicates to me someone is out of touch with reality.
I totally agree to extending the reporting time after 7 consecutive days from 3 days.
If we are to change the time scales of reporting and the EU has again stuck its nose into UK business wouild it not be best to fall in line with there criteria for reporting and not have two sets of reporting criteria or change further down the line. I also agree with weekend and days off not being included in the time scales
Fortunately I’ve never had to resort to RIDDOR in my working life, but the idea of not reporting O3D injuries because of cost leaves a foul taste and devalues it somewhat. I thought the whole point was to report injury & dangerous occurances, surely cost doesn’t come into it. Who decides that because you only need to be off work for 3/4 days its not serious. I know people who would come back to work with one leg, also those who would milk it for all they could – I thought this was safety tool!
Lets face it the Tories just want to go back to the good old days of the slave trade don’t they – just do the job we don’t care about the consequences. WE spoke about the ‘elf n safety excuse last year didn’t we – obviously the government want to abolish it altogether!!!!
On numerous occations when an injury has occured on a thursday people decide to take the friday off (to recouperate) returning to work on the monday with no ill effects at all. In the eyes of the injured party they have taken one or two days off, but according to RIDDOR this is a over 3 day injury.
The improvement to the present system that i would like to see would be to count the 3 days from the injured paries normal working week .
Just another way of saying that they can not police the currant 3 day rule and by extending it they will be able to compleatley ignore it from now on ……..good news for the employers who caint be bothered bad news for the rest of society who study the stats
As with most things Lord Young brought up, there is a good idea somewhere there, BUT
application proposals so far miss the point!
Ensure all is reported under RIDDOR that should be-we all know of the railways not reporting for managements own reasons, we all know of companies not reporting as it makes things “look worse than they are”-apparently!
Use HSE efforts and enforcement there.
If you must make changes, include ONLY working days
I am generally happy with the three day rule. What I feel needs to change is counting weekends and non working days in the calculations. I have a person phone in sick on Thursday with a bad back they say is a result of something that occured at work. He / she comes back in on the following Monday right as reign and it is reportable. Where is the sense in that. I think the law should explude the day of the incident as is and then only count the employees normal working days.
I totally disagree with this change and consider that it is sending the wrong message. Whilst a Health & Safety Professional I am not into dogma and many things are done under the guise of health & safety which should not be however in this case feel that is the wrong way.
From the notes given, cost seems to be the main driver to the proposed changes. The numbers given appear to be small if they are for the whole of the UK.
The prime aim should be to improve H&S standards. There is little reasoning or evidence given to show that the proposed changes would enhance H&S in actual practice.
Great news. And I don’t see how changing it from 3 days to 7 will reduce standards. Surely the culture of organisaitons remains the same regardless of the reporting criteria.
I think it is a good idea to bring RIDDOR in line with the 7 days for Statutory sickness. However clearly with accidents not having to be reported until 7 days absence have passed, the cynic in me can’t help but think that this is going to be used as a statistic for accidents reducing. This wouldn’t be the case as those accidents leading to 3, 4, 5 and 6 days will not be reported but would still have occurred.
Extending to 7 days is an improvement that might cut out some of the stigma for employers that suffer a RIDDOR statistic that doesn’t differentiate between a stubbed toe and a broken neck. That is where RIDDOR needs to be improved.