The HSE's requirement to keep a record of over three day accidents is trumped by the Social Security requirement to keep a record of 'all' accidents. The guidance even states that an accident book entry will be sufficent record.

We've had a look at the guidance and the amendment to the Regs and would be interested in others interpretation. Our interpretation is slightly different in that yes we record all accidents, but with the new changes in place we will still need to record O3D as a separate category to other non-reportable accidents. The guidance seems to refer to O3D accidents as "non-reportable RIDDOR" (rather than a non-RIDDOR accident) and that HSE can request details etc. upon request. We therefore believe we will need specific data for O3D accidents, like we do currently (the amount of detail / information is greater for RIDDOR accidents than it is for non-RIDDOR). So will have the follow categories (as appose to amalgamating O3D accidents into general accidents): - Non RIDDOR - Non-reportable RIDDOR (O3D) - RIDDOR reportable

RIDDOR only ever required you to record over 3 day injuries. The only change is in the reporting. The requirement to record all accidents in an accident book (or similar) is not a Health and Safety Requirement, it is Social Secuirty one.

The recording of the over 3 day is a requirement of Article 9 of the Framework Directive--irrespective of what occurs in the new Eurostat requirements. This was pointed out by IOSH Article 9 Various obligations on employers 1. The employer shall: (a) be in possession of an assessment of the risks to safety and health at work, including those facing groups of workers exposed to particular risks; (b) decide on the protective measures to be taken and, if necessary, the protective equipment to be used; (c) keep a list of occupational accidents resulting in a worker being unfit for work for more than three working days; (d) draw up, for the responsible authorities and in accordance with national laws and/or practices, reports on occupational accidents suffered by his workers. 2. Member States shall define, in the light of the nature of the activities and size of the undertakings, the obligations to be met by the different categories of undertakings in respect of the drawing-up of the documents provided for in paragraph 1 (a) and (b) and when preparing the documents provided for in paragraph 1 (c) and (d). The IOSH response is at:- http://www.iosh.co.uk/Co...IDDOR%20consultation.pdf

Yes, and this extra complication was my main reason for opposing the changes in my response to IOSH. How most other members who responded didn't agree with me so, to my regret, we are now stuck with the extra category! I have no big issue with moving from 3 to 7 days, just that there should be wider international agreement before doing so, as it's key benchmarking data. But I'm not expecting a rush within the EU to follow UK, based on our likely current national reputation with other member states!