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October 20, 2014

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Safety and health reporting for duty

Earlier this year I wrote a blog series on strategic OSH – particularly in the supply chain and as part of an organisation’s broader sustainability objectives.

This time I am going to be focusing less on procurement and more on safety and health reporting. I am guessing that as an occupational safety and health professional, you are already feeling much more comfortable with this new direction – at least this terminology is a more familiar part of your day-to-day role.

Reporting trends

The reality is that voluntary sustainability and even mandatory integrated reporting (e.g. South Africa) are proliferating globally. Companies are under increasing pressure, particularly from investors, to be more transparent about the impacts they have and the risks they face. You might be aware that in the UK, non-financial reporting requirements have changed. The Strategic Reporting Regulations 2013 have amended the Companies Act 2006 and require certain companies to report on environmental, employee, community and human rights matters.

How in particular is health and safety relevant here? Well, health and safety related risks might be seen as material to your organisation and sector. Where that is the case, that should of course be included in your non-financial reporting, be it in a standalone sustainability report or in an integrated annual one.

What I want to get onto is how health and safety is actually being incorporated into sustainability reporting frameworks, namely the GRI G4, and reiterate how sustainability encompasses health and safety considerations. I previously spoke about it here.

Again, there is an opportunity for health and safety to take on a more strategic role and for companies to demonstrate how effectively they are mitigating material health and safety risks. The European Agency for Safety and Health at Work determines exactly that: that a CSR [or sustainability] strategy, and particularly a non-financial or integrated report, provides organisations with “an opportunity to raise their commitment to OSH”.[1]

What is the Global Reporting Initiative?

The Global Reporting Initiative (GRI) advocates transparency and provides a framework under which organisations can communicate on their non-financial performance to both internal and external stakeholders. The organisation dates back to 2000 and since then the guidelines have undergone numerous revisions, the most recent of which was launched in May 2013: the GRI G4. Many current GRI reporters are still migrating from the previous framework, the GRI 3.1.

To fill gaps in reporting and push for better quality reporting within sectors, the GRI also introduced sector supplements. These focus more on the key issues for particular sectors, such as noise management for airports or resettlement in the mining sector.

According to a report by KPMG from 2011, some 80% of the global 250 companies were at the very least referencing the GRI framework in their sustainability reports. Why? Because it is considered best practice.

The Capetown International Convention Centre outlines the organisation’s reasons for choosing the GRI on its website. What is worth noting about the GRI is that it outlines a reporting process which ensures that the non-financial information companies report on is meaningful.

What does the GRI G4 framework require?

First and foremost, the focus is on materiality – that is, concentrate reporting efforts on your organisation’s significant environmental, social or economic impacts and those issues that most influence or affect stakeholders. A documented stakeholder engagement therefore forms an indispensable part of this.

There needs to be a disclosure of management approach covering all materials aspects identified.

Organisations can report to either core or comprehensive level. The core level is much easier to achieve as:

  1. There are just 34 mandatory disclosures instead of 58
  2. The reporting organisation only needs to report on one indicator per material aspect identified, as opposed to all the indicators under a material aspect

The mandatory disclosures provide a 360 overview of the reporting organisation and its reporting process. The mandatory disclosures fall under the following categories:

  • Strategy
  • Organizational profile
  • Identified material aspects and boundaries
  • Stakeholder engagement
  • Report profile
  • Governance
  • Ethics and integrity

The material aspects come under three broader headings: economic, environmental, and social. Social is then divided into labour rights and decent work, human rights, society, and product liability.

Needless to say, safety and health reporting comes up under the labour rights and decent work section.

What if health and safety constitutes a material issue?

The answer is simple: then report on it.

The OSH category includes the following indicators:

  • Percentage of total workforce represented in formal joint management-worker health and safety committees that help monitor and advise on occupational health and safety programs
  • Type of injury and rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities by region and by gender
  • Workers with high incidence or risk of diseases related to their occupation
  • Health and safety topics covered in formal agreements with trade unions

Should an impacts assessment and stakeholder engagement identify health and safety issues as material – it’s more than just reporting on indicators, it’s a chance for OSH professionals to showcase their work and assist in branding their organisation as one that takes its health and safety practices seriously.


Larissa Prevett LL.B, LL.M is Jr. Associate at CLT envirolaw



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