Dear All According to the draft Consultation Document on changes to RIDDOR - courtesy of David Young’s report - will cut accident reporting by 30% nationally. The proposal is to redefine ‘over 3 day injuries’ to ‘over 7 day injuries’. The Con Doc is planned to be launched in January 2011 with a 3 month consultation period. [HSE Board paper 2010/623517 - tabled at their meeting of the 15th December 2010. Paper can be found at: www.hse.gov.uk/aboutus/m...s/hseboard/2010index.htm] Apparently ‘This gives a net benefit to business of £1.7 million over 10 years, or £200 thousand pounds in equivalent annualised terms.’ Funny, I thought the annual amount would have been £170,000. However that’s the HSE Economic Unit for you. They went on to state the great saving that by not reporting those injuries currently reported: ‘For each report not submitted there would be therefore a cost saving to business of £7.91.’ On the day of the HSE Board meeting it was reported that Amyas Morse, Head of the National Audit Office did not sign off the House of Commons Members Resource Accounts 2009/10. Source: www.independent.co.uk/ne...ns-accounts-2161191.html This was the first year the NAO oversaw the accounts following the expenses scandals. Mr Morse said there were £13.9 million of payments to MPs which were "either unsupported or where entitlement could not be fully demonstrated". £13.9 million unaccounted cost in one year related to MP’s expenses: proposed £1.9 million saving in 10 years on making 30% of injuries to workers invisible. The requirement for employers to record 3 day injuries in their accident book is recommended to stay. So to simplify reporting requirements, employers will record over 3 day injuries in their accident book but only report such injuries if workers are absent or not undertaking their normal duties for 7 days. Oh yes much simpler than just having one criterion! In the 1980s I spoke to a senior HSE Inspector who argued that employers caught not reporting injuries should face major punishment. His argument was that every injury not reported meant that HSE would base their priorities on ‘misleading’ information. The HSE state they only investigate 0.8% of reported over 3 day injuries. According to the Labour Force Survey for 2008/09 there should have been 256,000 over 3 day reports. In reality there was 104,301: 58% under reporting. Going to 7 day reporting reduces this by another 30%. Does anyone else have any concerns about this proposal? Cheers. Nigel

I feel that RIDDOR must be one of the most misunderstood pieces of legislation that H&S professional have to deal with, if the number of posts and questions on this forum is anything like a reliable indicator. Many years ago I posted in response to somebody that it was a simple matter, only to be shot down in flames by many other posters and I quickly realised that it was far from simple. Current political reality dictates that HSE's time (and EHOs) will be much more scarce than it has been and they will have tough decisions to make on what the Inspectorate should be doing. Some may argue that counting numbers of cut fingers and sprains over a weekend is useful; I cannot. I would much prefer them to be looking at significant injuries, accidents and dangerous stuff and bringing the bad employers (and individuals) to court. RIDDOR is long overdue for change.

For me RIDDOR is a nonsense anyway. The three day rule does not apply to medical issues that I am involved with. If a qualified medical practitioner diagnoses a skin problem as an occupational contact dermatitis then it is reportable, irrespective of whether there has been time off work. However, underreporting of occupational skin diseases is so prevalent that any statistics are something of a sick joke. If you compare our figures with those of other EU countries that have more effective reporting procedures, then you could reach the conclusion that we are doing something different - or that residents in the UK have a unique skin, since our figures are only a fraction of what occurs elsewhere. Several studies have shown this not to be the case. A further complexity arises with the definition of contact dermatitis. When does dry, cracked skin medically become dermatitis? This depends upon the views of the medical practitioner and, to a large extent, the industry that the person works in. A study by the HSE on dermatitis in printers revealed a significant number of workers who did not report a skin problem but, when seen by a dermatologist, were diagnosed with an occupational contact dermatitis. Mechanics may consider their skin to be just workers hands but in a healthcare environment the same condition would definitely be occupational dermatitis. By contrast I often have to deal with diagnoses by GPs of an occupational dermatitis which, on proper investigation, turns out to be a skin problem that is either constitutional or non-occupational. Of course, this might have been reported under RIDDOR (or experience suggests probably not!). So the proposed changes will make little difference as to whether I believe any HSE statistics for my particular area of interest. Chris

I think most folk agree that the Regs need a complete overall - moving from 3 to 7 days is hardly going to resolve the issue of non reporting and therefore using statistics to a positive affect. Most threads on here regarding actions on reported accidents tend to concentrate on HSE investigations when in reality the majority are reviewed and investigated by LA's - I don’t have any comparison figures on this but I would really be interested if any one out there does. The problem I have with the Regs are not with employee accidents that's relatively black and white - it’s the public incidents - the Regs allow judgments to be made via your internal investigations e.g. connected to your working activities or not. The difficulty here is where do you draw the line in this? I have had many a discussion with EHO's on this one and its subjective. The ICC can be of help sometimes but not always as its subjective again Rip them up and start again for me.

We have an issue with the over 3-day reporting category as under the terms and conditions of employment staff can sign themselves off sick for 5 days before there is a need to submit a fit note. This means that if they do this as a result of an incident then it generally falls within the RIDDOR category. There are a large number of incidents where a member will sign themselves off sick and link it to an incident when it more than likely isn't (based on experience of those where we have investigated) If we move to a 7 day category then this means that a person may sign themselves off for 5 days but it would not fall within the RIDDOR requirements.

quote=Billibob]If we move to a 7 day category then this means that a person may sign themselves off for 5 days but it would not fall within the RIDDOR requirements.

There is a danger iin not reporting accidents because the HSE would be blind to the actual number of accidents etc accuring. The whole point of RIDDOR is to enable the enforcing authorities to target thier activities effectivly and to advise employers on strategies to help prevent injuries, ill health and accidental loss (end quotes) If this info is not forthcoming the HSE would be blind and become less effective perhaps that is why the RIDDOR Regs are so disliked who knows. IF the RIDDOR Regs are changed there will still need to be something inplcae to gather this information or HSE would become totally useless and would be abolished eventually.

Under reporting is a fact of life, there is little that can be done about it other than fine anyone who fails to report but that can only happen when it is discovered by the authorities after the fact and with such misunderstanding of the legal requirement it is probable that very few cases would in fact be brought anyway. Chris has pointed out that this is a problem cpmmon throughout Europe. Chris says that the European system is more effective, can he advise us where this is available so we can take a look at the European requirements?

Bob Post#4 Yes I did get confused - too much Christmas Spirit. Dear All Thanks everybody for the responses. The Consultation opens up in January so if anybody has any changes to suggest they can be made then, despite it only covering the amendment from over 3 to over 7 day reporting. I'm with Ron. It seems to me that the whole of RIDDOR should be reviewed, not just one aspect. Cheers. Nigel

Hi all, May seem a daft question, but what are the Health & Safety benefits to the proposed changes?

Thanks BernieV, Glad it's not just me who was struggling to find the H&S benefits. I think most of the recommendations in Lord Young's report are, as he suggests to lesson the burden on businesses, not that I disagree with many of his recommendations at all. However, I didn't see "people" or "improving safety" mentioned much either, although if the recommendations have their intended benefits then perhaps improving the reputation of safety will have a knock on impact by allowing us to being able to concentrate the significant risks, and not waste time with the silly ones. Happy new year to you all too folks! :-)

With LESS than 50% of REPORTABLE accidents being reported under RIDDOR, and almost NONE for the one-man-selfemployed-band, one has to wonder whether LA and HSE employees are fit-for-job ? This state-of-affairs has been going-on for over 10 years with SQUAT being done about it, with NO INTENTION of any problem being fixed, and little interest shown by the orificeorities anyway. The intention to alter RIDDOR is NOT (as in NOT) because of any intention to fix the unfixable problem, but to lower associated costs by having even less reported. The incapacity benefit removed, employment support allowance (the son-of-sick-pay) being rendered a joke by assessment for work examinations that clear terminally ill people as fit for all work, there is not much need for a reporting system that the clowns (employers) regard as a waste of time and money. Things to do 2011: 1. Close HSE down, entirely. Unfit for purpose, a wase of time and space. 2. Make all employers not liable for any/all accidents/injury. 3. Make it illegal for any employees of any employer to institute litigation, of any sort. 4. Replace wages for low paid with food stamps and make them work 100 hours a week 5. Build a load of workhouses 6. Only have one party allowed on an election ballot, the conservative one. All ballots, even union ballots.