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bxuxa  
#1 Posted : 09 July 2025 13:02:59(UTC)
Rank: Forum user
bxuxa

Hi all,

I’d appreciate your views on whether the following incident may fall under RIDDOR.

An operative was returning to the depot after clearing materials from site. During a stop at a lay-by on a public road, he exited the vehicle and, while stepping onto a kerb, their foot slipped along the side of it. At the time, he believed they may have twisted their ankle but felt no immediate pain and continued the journey back to the depot, where they were still able to drive.

Later that day, the operative reported increased pain and difficulty walking. Next week, he attended a local hospital and was diagnosed with an ankle fracture beneath the heel. A plaster cast was applied, and he is advised to keep the foot elevated and return to hospital within 4–8 weeks for follow-up.

Allegedly, he was wearing safety footwear at the time of the incident.

The incident occurred during a "comfort break", not while conducting any manual handling or job-specific task.

Would you consider this reportable under RIDDOR, considering the injury type and the circumstances in which it occurred? and why?

Thank you

HSSnail  
#2 Posted : 09 July 2025 13:25:13(UTC)
Rank: Super forum user
HSSnail

Dont we all love RIDDOR?

For me key to this can be found in section 2 of the Regs - interpritation, specifically

(2) In these Regulations, any reference to a work-related accident or dangerous occurrence includes an accident or dangerous occurrence attributable to—

(a)the manner of conducting an undertaking;

(b)the plant or substances used for the purposes of an undertaking; or

(c)the condition of the premises used for the purposes of an undertaking or any part of them.

while it appears the injury was due to the slippy curb i do not belive this satisfies section c - its a public area not part of the premises, likewise i dont think a or b are satisfied, so for me this is not a work-related accident so the injury is not reportable.

Had this been a road works situation where the driver was for example delivering something to the layby, or had it happend in the company carpark which they were responsible for mainatining then i might consider it part of the works premises- but that would need a site inspection.

thanks 2 users thanked HSSnail for this useful post.
Holliday42333 on 09/07/2025(UTC), bxuxa on 09/07/2025(UTC)
Holliday42333  
#3 Posted : 09 July 2025 14:16:35(UTC)
Rank: Super forum user
Holliday42333

Nobody loves RIDDOR HSSnail ;)

I agree; not reportable.

At work but not 'work-related' so far as RIDDOR is concerned

thanks 1 user thanked Holliday42333 for this useful post.
bxuxa on 09/07/2025(UTC)
peter gotch  
#4 Posted : 09 July 2025 15:57:13(UTC)
Rank: Super forum user
peter gotch

Hi bxuxa

I don't think it's reportable but for different reasons to those cited by the Snail.

The Royal We don't love RIDDOR in its current form, but then We were not in love with the previous iteration of RIDDOR, We disliked NADOR intensely and We were not particularly enamoured by Sections 80-82 of the Factories Act 1961 and the parallel legislation that applied to some sectors other than factories (and so called 'notional factories').

First you have to consider whether this person was "at work" a term defined in Section 52 of HSWA and I think the answer to that is YES as any worker should be entitled to a "comfort break" - during the course of his employment (LOTS of case law on interpreting those wordsand the Interpretation Act 1978 tells you to interpret his and including her)

Next you have to consider whether this was a "work-related accident" and I am not going to make judgement on that, but would note that I would treat the HSE guidance with a huge pinch of salt. So may be,  may be not.

What I am certainly NOT going to say is the parameter is whether the kerb was part of "premises" as that is a defined term in Section 53 of HSWA which says:

" premises " includes any place and, in particular, includes—

(a) any vehicle, vessel, aircraft or hovercraft,

(b) any installation on land (including the foreshore and other land intermittently covered by water), any offshore installation, and any other installation (whether floating, or resting on the seabed or the subsoil thereof, or resting on other land covered with water or the subsoil thereof), and

(c) any tent or movable structure ;

The important bit are the words "any place" but the rest serves to remind us that "premises" doesn't need any physical structures (even though arguably the kerb is part of a structure).

However, the reason why this is not reportable in my opinion is mostly for exactly the same reason why the vast majority of work=related transportation accidents are not reportable even if they meet the seveity threshold for e.g. an "over 7 day injury" accident. 

You have to go towards the end of RIDDOR to find key exceptions to its scope including Regulation 14(3):

(3) Where the injury or death of a person arises out of or in connection with the movement of a vehicle on a road, the requirements of regulations 4, 5, 6 and 12(1)(b) do not apply, UNLESS that person—

(a) was injured or killed by an accident involving a train;

(b) was injured or killed by exposure to a substance being conveyed by the vehicle;

(c) was engaged in work connected with the loading or unloading of any article or substance onto or off the vehicle at the time of the accident, or was injured or killed by the activities of another person who was so engaged; or

(d) was engaged in, or was injured or killed by the activities of another person who was at the time of the accident engaged in, work on or alongside a road.

If the driver had been unloading then we could have a debate about whether the incident met the requirement for the incident to be "work-related". But if they were just stopping for a "comfort break" then it seems to me that the incident is outside the scope of RIDDOR.

Edited by user 09 July 2025 15:58:12(UTC)  | Reason: Typo

thanks 1 user thanked peter gotch for this useful post.
bxuxa on 09/07/2025(UTC)
bxuxa  
#5 Posted : 09 July 2025 20:26:00(UTC)
Rank: Forum user
bxuxa

Thank you, everyone, for these fantastic comments! It's genuinely an expert space.

While I acknowledge Peter's valid point that Section 53 of HSWA broadly defines 'premises' to include 'any place', which indeed extends beyond an employer's direct control to encompass where work activities might impact safety, the critical element for RIDDOR in this scenario is whether the accident was 'work-related' in the specific sense of the reporting regulations. Our lack of control over the public kerb, and the fact it's not our 'workplace' in the operational sense, means we cannot be held responsible for its condition, in line with what HSSnail mentioned. This leads us to the specific exemptions within RIDDOR itself.

This distinction becomes apparent when considering Regulation 14(3) of RIDDOR, which provides a specific exemption for road traffic accidents. The driver was simply on a public road for a 'comfort break,' which falls squarely outside the exceptions for reporting such incidents.

Reflecting on what constitutes a work-related accident is to be at work, as per RIDDOR interpretation and Section 52 of the HSWA. A comfort break is not being at employment in my view, especially when outside a space that we control.

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