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Health and safety enforcers and specialists have called for a full review of the RIDDOR Regulations in order to clarify rather than simplify them, accusing the HSE of having no evidence to back up the “deregulatory” proposals in its recently concluded consultation.

The Prospect union, which represents more than 1600 inspectors and specialists in the HSE and Office for Nuclear Regulation, as well as more than 20,000 engineers and managers with statutory responsibility for safety in hazardous workplaces, said the regulator’s plans to simplify the system for reporting injuries, diseases and dangerous occurrences must not be used as a vehicle to cut back on this vital reporting.

The union said it was “alarmed at the signals” sent out by the HSE consultation, which closed yesterday, and which called for an end to employers’ obligations to report occupational-health absences from diseases such as lead poisoning and various disabling lung and skin diseases.

Prospect’s views chime in with those of IOSH, whose head of policy and public affairs confirmed that the Institution is against the changes to RIDDOR “because we believe they would give the dangerous message that [some] failures are unimportant and will not attract enforcement action, no matter how serious”.

As exclusively revealed to SHP in September by a senior specialist occupational-health inspector with the HSE, the regulator’s own staff are unhappy with the proposals, saying they give out the message that “health doesn’t matter”.

Prospect also expressed its concern on proposals in the consultation to remove the duty on employers to report many dangerous occurrences that give strong early warnings of a potential disaster, and to do away with the need to report non-fatal accidents to the public.

Speaking on behalf of the union, health and safety officer Sarah Page said: “We agree with the need to simplify the regulations, but we object to ill-conceived, deregulatory proposals that have no evidence to back them. These proposals would remove reporting requirements for many serious hazardous incidents and jeopardise opportunities for justice expected by the public from its health and safety regulator.

“Worryingly, it would also signal to employers that the occupational health of their workforce is no longer important.”

The union says the HSE consultation uses low reporting levels as a reason to remove the obligation to report on occupational-health incidents at work, except for exposure to biological agents. Said Page: “Since when was it government policy to scrap a law because it is ignored by duty-holders?!” 


Prospect says there needs to be a full review with the “genuine engagement of employers and unions” to explore how the Regulations can be made more effective. It claims employer organisations like the Energy Networks Association don't think the proposed changes will reduce burdens on business and is urging the Government “to listen to those who manage risk before simply repealing legislation for its own sake”.

IOSH, as part of its response to the consultation, suggested a ten-point plan for action on RIDDOR, including improved reporting of occupational diseases, more action to tackle under-reporting, and a government database for sharing anonymised health and safety lessons from a range of incidents.

Added Jones: “IOSH is extremely worried that the changes will mean certain major injuries (including dislocations and temporary blindness) would no longer be reportable. This gives out entirely the wrong message, and is a retrograde step. Such a move could discourage certain duty-holders from reporting, and could lead to more accidents in the future.

“Is that really what the Government wants to do? Our ten-point plan would improve RIDDOR, reducing accidents and boosting productivity, getting Britain back on the road to recovery.”

Prospect’s full response to the RIDDOR consultation is at http://library.prospect.org.uk/id/2012/01650