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chris.packham  
#1 Posted : 09 August 2012 09:23:47(UTC)
Rank: Super forum user
chris.packham

I have just been reading the HSE document regarding proposed changes to RIDDOR (http://consultations.hse.gov.uk/gf2.ti/f/16770/442917.1/PDF/-/CD243.pdf) and see that it is proposed to remove the requirement to report any occupational disease, other than those caused by biological agents. Whilst is cannot be denied that current reporting is inadequate, with considerable underreporting, I feel that this change will further reduce the data available on occupational diseases. I fear also that it will send the wrong signal to management, i.e. that if it is not reportable it cannot be something we need to do anything about. What do others feel about this? Chris
jericho  
#2 Posted : 09 August 2012 09:42:58(UTC)
Rank: Forum user
jericho

Good question Chris and I am not sure. It sort of depends. If the point of reporting them in the first place was to find where Occupational Diseases lay in the UK (such as the print industry for skin conditions) then maybe it's done its job. We know where they are now, they can be targeted and there's no real need for more data. However, if that means that new sectors giving rise to OD slip past unnoticed then that's a bad thing. Now, does that mean that sectors with high instances think that because that don't have to report anymore and therefore they don't have to bother about their employees either? I am just fortunate enough not to work for someone like that, but I'd agree that others may well see it that way. As with other changes, some of this similar questions depend on what your view of RIDDOR is. For us, it's simply something we have to do. We don't use the figures in any way, we don't report them internally, or have them as KPIs in fact they could repeal RIDDOR tomorrow and it would make no difference to us. That's not arrogance, it's just that we take care of things in our business without the need to be 'told' to. We care. Sounds corny but it's true. Are there others out there who actively seek to do the minimum in order that they 'comply'? I have to say that in my experience, minimum compliance would be a target for some employers to aspire to!! And by that token, changes in the law don't really affect their thinking that much. Jericho
chris.packham  
#3 Posted : 09 August 2012 09:52:34(UTC)
Rank: Super forum user
chris.packham

Jericho You are lucky to work for an enlightened and caring employer. I encounter many where the approach can best be described as CATNAP (Cheapest available techniques narrowly avoiding prosecution) and who I can see taking the attitude that as HSE has removed the need to report then it isn't serious and they really don't need to do anything about it. The only factor then that will make them take occupational disease seriously is the civil cases of compensation. Chris
chris42  
#4 Posted : 09 August 2012 09:52:52(UTC)
Rank: Super forum user
chris42

Sorry if I have missed something here, but if the employees are having to clean mud / grit off the glasses every few minutes, without them would this mud / grid not be in their eyes instead ?. So aren’t the glasses doing what they are supposed to be doing? Yes I had the same thoughts, I understand the point that the information they get via RIDDOR is incomplete, rather than find a way to make it work they are going stop bothering. As you say I feel this will possibly unintentionally send a message that it is not important for employers to worry about, as it will no longer affect their statistics. I admit I only skim read it the first time, but I seem to recall they are intending to rely on those affected / their families to make a fuss and report it. That will be effective won’t it!
chris42  
#5 Posted : 09 August 2012 09:57:52(UTC)
Rank: Super forum user
chris42

oops I type offline and inadvertently copied and pasted my last post also. Ignore the first part, it should start at "Yes".
Graham Bullough  
#6 Posted : 09 August 2012 11:28:25(UTC)
Rank: Super forum user
Graham Bullough

I agree with earlier comments that drastically reducing the categories of occupational disease which need to be notified to HSE may send a wrong message to some employers. However, massive under-reporting of occupational diseases already exists under the present version of RIDDOR. Part of this stems from the notion that most doctors don't suspect occupational disease in their patients even though about 25% of ALL patient conditions seen by doctors have an occupational cause. This assertion is based on comments made by EMAS doctors and other OH specialists during presentations at IOSH and other OS&H meetings in NW England over recent years. If doctors, especially GPs, are not diagnosing cases of occupational disease as they should be doing, the system is already inadequate. The system further relies on employers being sufficiently diligent to pick out and report notifiable conditions from details on completed 'fit to work' forms (formerly 'sick notes) handed on by employees. Therefore, perhaps a better arrangement would be to revert to the pre-1985 system by which doctors were obliged to notify occupational diseases direct to HSE. During my decade with HSE I jointly investigated with EMAS a fair number of cases which were notified by this route which was based on regulations made under the Factories Act. Moreover, doctors were entitled to a payment of 12.5p per notification. Though this was a trifling sum by the time the notification requirement became obsolete in 1985, it was probably a reasonable amount when the regulations were made. However, whatever system is used would still depend on the capacity for doctors to suspect and diagnose occupational disease. Sadly, the extent of training given to medical students and qualified doctors in the UK about occupational disease and health has reportedly declined over the past decade or more. Unless appropriate changes are already afoot and are being kept very quiet, much greater attention should be given to the need for more training for the benefit of everybody affected or liable to be affected by occupational disease. This includes those running businesses and also taxpayers funding the NHS. For example, an occupational doctor speaking about occupational asthma (OA) to a recent meeting of the inimitable Public Services Section of IOSH Manchester & NW Branch stated that OA was estimated to cost the UK economy over £1 billion/year. Though it's impossible to prevent all cases of OA, early diagnosis and appropriate management would greatly help to reduce the economic burden for the UK as well as the misery experienced by individual sufferers. Therefore, this aspect should be included in approaches to politicians, etc., as to why effective OS&H is vital for the UK.
Mudmuppet  
#7 Posted : 09 August 2012 11:35:49(UTC)
Rank: Forum user
Mudmuppet

I see it as a step back, having worked on the Olympic Park and had the spoils of support from Park health I have been enlightened to challenging our supply chain on this topic and have just made moves on improving employees health in the workplace by challenging their company directors on occupational health. Having had training as a skin monitor I was able to impliment a skin monitoring programme for all supply chain coming onto the project and send some cases to Park Health for referal, I find it is under reported and we need to ensure occupational health moves on to keep our workforce in work and not off ill from our processes. Chris - I like the acronym CATNAP - Brilliant!
chris.packham  
#8 Posted : 09 August 2012 11:42:13(UTC)
Rank: Super forum user
chris.packham

Graham Whilst I entirely agree with your comments, my experience is that with GPs it can work both ways. A considerable amount of my work seems to be in investigating occupational skin problems (rather than preventing them in the first place!), diagnosed as such by the person's own GP. It seems to be that the assumption is often that if you work in that factory up the road, then your skin problem has to be occupational. The investigation often reveals that the true cause is non-occupational. (I even had a case where the anaphylaxis, diagnosed as latex allergy, turned out to be a non-occupational psychosomatic reaction.) Even where there is an occupational element in the cause(s) - and with irritant contact dermatitis it is almost unknown for this to be caused by a single chemical - the 'diagnosis' is often incorrect. Even dermatologists, if not correctly briefed, can do a clinical diagnosis and end up with a result that is clinically correct but occupationally irrelevant. I would not target just the medical profession, however. How many occupational health and safety practitioners have had sufficient training on occupational diseases to be able to play their full role should damage to health in one or more workers occur? Chris
jericho  
#9 Posted : 09 August 2012 11:59:37(UTC)
Rank: Forum user
jericho

To be clear, I am not necessarily for removing the reporting requirement. And I am certainly not blind to the seriousness of occupational disease. But I would ask what, in reality, is the reporting of them doing, in a meaningful way? Those people who will relax their standards because they don't have to report are probably small in number and whilst not to be ignored I doubt ever had really strong OH management schemes in place. Those that do, whilst not having to report, I would think would continue to manage the employees' health. Companies seldom do things really well purely out of compliance pressure. Larger firms are on the radar and can't slide back - there are too many mechanisms to help prevent that; it's out in the open. Chris, I realise your point of view centres largely around skin care, but I am talking in the wider sense of OD here. I like the idea of GPs reporting in the past, but I am also minded that as with 'stress' it would be tempting for the GP to simply label every condition as work related disease. (as CP says) That, I would not want to see. So is the answer to leave it as it is and carry on as we are which we all acknowledge (I think) is not idea, or do we do something different and do it with the purpose of bringing about an improvement? Personally I don't see that leaving RIDDOR as it is, will achieve that. But I am not for taking away without putting something else in its place that is better. So what would we have as an ideal position on OD given a blank sheet. Let's determine that and put it in our evidence submissions. That way we do stand a chance of making the right changes happen. Jericho
chris.packham  
#10 Posted : 09 August 2012 12:30:44(UTC)
Rank: Super forum user
chris.packham

Jericho Had the consultative document indicated that whilst removing the reporting requirement this was because a more effective procedure was being developed/introduced, then I would have been very happy. However, this does not appear to be the case. So the impression that HSE is creating in some minds is that they simply cannot be bothered. This may not be your reaction, but the reality is that this is what a lot of people will think. Bear in mind that many employers are SMEs who are already struggling with health and safety issues (just see what the FSB says on this). I can see the reaction from many of them. "So occupational disease doesn't have to be reported any more so I don't need to worry about it then." Given the way employers' liability is structured in the UK I wonder how we could introduce a more efficient system for reporting of occupational diseases - and I am not concerned here purely with skin. Even in those countries where they have a more effective reporting system than the UK (e.g. Germany, Finland, Sweden, etc.) they will tell you that underreporting (and misdiagnosis) is endemic. Chris
jericho  
#11 Posted : 09 August 2012 12:47:29(UTC)
Rank: Forum user
jericho

Chris, with you completely there. We're not holding opposing views, I was simply saying that we need an argument for either keeping it or binning it plus an alternative if we say there is something better. That alternative needs in my mind to be aimed at bringing about an improvement. What I don't quite see is that employers who only report OD's out of a sense of duty, manage OD well now. I don't see reporting as the lever in making them do it better if that makes sense. I realise that the question in the doc is 'keep or bin', but I am in the position to be able to influence certain decision makers and having something to take to them as an alternative has been successful in the past. Jericho
Ron Hunter  
#12 Posted : 09 August 2012 13:07:15(UTC)
Rank: Super forum user
Ron Hunter

The previous RIDDOR revision to take away >3 day reporting effectively told Eurostat and WHO that the UK wasn't interested in contributing to Industrial Injury statistics in any meaningful way. You may recall from the last consultation exercise that the HSE proposed to compile and provide "synthetic estimates" to Eurostat for >3 day figures. In my book, "synthetic estimate" equates to guessing (but there may be Statisticians out there who can keep me right here). The requirement on European Member States to provide >3 day stats is a Legal one. I wonder if there are similar legal requirements to provide stats for occupational diseases?
Ron Hunter  
#13 Posted : 09 August 2012 13:29:49(UTC)
Rank: Super forum user
Ron Hunter

An update: I just had a check through the relevant EU Regs [(REGULATION (EC) No 1338/2008 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 December 2008 on Community statistics on public health and health and safety at work] and specifically the reference at page 1, paragraph 3 of that document, which makes reference to a European schedule of occupational diseases - which is in turn detailed in the referenced COMMISSION RECOMMENDATION of 19 September 2003. (see http://eur-lex.europa.eu...003:238:0028:0034:EN:PDF). The list of occupational diseases there is much as we would expect it to be, certainly not limited to biological agent issues. Notable perhaps that Reg 1338/2008 above also seeks to gather seperate information about pandemics and transmissable diseases (in a public health context). Now I freely concede that I may be out-of-date with some of my references here (navigation of EU Regs and http://eur-lex.europa.eu/ isn't my strong point) but I can't help but wonder whether; (a) the HSE have problems in interpreting EU Regulation, or (b) they choose, or are being directed to, simply ignore the requirment placed on UK by these Regulations. Once again, with all things emanating from the LY Report, it is difficult to distill the overtly political and possible anti-European tone from some of these proposals. I do feel for the HSE, who are essentially bound to do as they are told.
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