RIDDOR consultation.
The consultation document states - " Businesses would see a significant reduction in the number of reports they need to make; it would also improve the accuracy of national statistics."

If businesses want to reduce the number of RIDDOR reports that they make then they should manage Health and Safety to a sufficient degree to prevent accidents.

RIDDOR would if we had effective enforcement, be another tool that would help to reduce "accidents". That would improve the accuracy of national statistics.

I repeat my suggestion that every accident reportable under RIDDOR (3 days) should by law be investigated, with a copy of the report going to the HSE. The investigation should be carried out by a registered Health and Safety consultant at the businesses cost (to a fixed scale of charges set by the HSE?).

The consultation makes much comment about the burden on business. Reporting is not and never will be the same burden that accidents and the injuries and ill-health that they cause are on business or the VICTIMS of those accidents.

The potential that a properly enforced 3 day RIDDOR reporting system would have on the burden that is placed on the VICTIMS of accidents is wonderful to think of, and what about the burden of accidents on the NHS and the other emergency services and on the un-employment and other benefits that result from accidents.

Please think long and hard before we are pushed further backwards in the effort to adequately manage Health and Safety, and at least do the sums that include all of the burdens to include the burden that accidents place on the victims and the taxpayer.

I think I understand where you are coming from Robin, but I think the point you're missing is that there are many RIDDOR LTAs that are not reported for one reason or another. When "bonus" schemes, for management and staff, are based on not having a "reportable" there will be pressure on the injured party, colleagues and management to avoid making the report.

The change from 3 day to 7 day reporting is, I believe, an attempt to get some joined up thinking within health provision and the reporting criteria.

I would hazard a guess that the three day RIDDOR criteria came about because in the good old days, if you were off for more than 3 days a Dr's sick note was needed. Presumably the hope was that the Dr would somehow prompt a report to HSE if industrial injury was the cause of the sickness. Nowadays, I guess the powers that be think that the visit to the GP after 7 days will prompt the report - some hope!

I guess that the non working days are counted to account for someone twisting their ankle or such like on Wednesday, having Thursday and Friday of 'sick', playing Rugby on Saturday and going sick again on Monday due to Wednesdays injury or am I being cynical!

Seriously though, any serious effects of a 'minor inlury' should account for the whole period of the injury and not just the bottom line cost of the absence from work.

In my particular area of health and safety (occupational contact dermatitis) the three day rule does not apply. What is relevant here is a diagnosis of occupational contact dermatitis by a registered medical practitioner. So whether three or seven days is irrelevant. However, from personal experience I can confidently state that an extremely large number of occupational skin diseases go unreported. If you need further proof of this just look at the results of the study done for the HSE on printers in the East Midlands.

If we compare UK statistics on occupational skin disease with those from other countries with more effective reporting systems (e.g. Germany, Denmark) the discrepancy between statistics from these countries and those of the UK mean either that we have a fantastic system of prevention in place throughout the UK, or that British workers have a unique skin that is almost indestructible, or that we simply have no real idea of the true picture. My bet is with the latter!

Will the proposed changes in RIDDOR deal with this? I don't think so.

Chris

Where I work we investigate every incident including near misses regardless of whether accidents are reportable under RIDDOR with a view to preventing recurrences. And this really is what a good pro-active health and safety management system should be all about.

Personally I have no issues with reporting over 3 or 10 days. 10 days will mean our stats on tender documents look better and there would be less time spent reporting things through on line - not that we have tons to report anyway!

HSE and Local Authority vary greatly across the country as to whether they will come in and investigate a reportable incident or not, depending on their priority areas at the time in many instances, and whether their input is always helpful is also questionable.

It's a sort of non-issue really. There aren't enough inspectors to investigate all reportable incidents and the politicians win by "cutting red tape for business" ....

There are 2 points that I am going to respond to. Please note that these comments are not directed against any individual, but are my opinions.

1. External accident investigation - This is justified on the grounds that an accident is proof that there has been a failure of Health and Safety management.
Independent investigation removes any pressure that may be brought to bear by employers for the investigation to perhaps "not emphasise" some issues or to apply careful use of information. There appear to be examples of this happening within business and government.
A failure of a system of management that has been developed by an internal Health and Safety adviser, are we ever critical of the perfect systems that we develop?
Most Health and Safety professionals that I talk to wish for more time to carry out their duties, an independent investigator would relieve a lot of the strain that an investigation would cause to an in-house professional.
Ideally the HSE would investigate these incidents, but they do not have the resource, so why shouldn't business pay for its' mistakes and for the benefit of an independent consultation.
They used to say if you can't do the time don't do the crime (failure to adequately manage Health and Safety is a criminal offence).

2. The issue of using a registered consultant.
The intention of the register is to provide a source of Health and Safety consultants who have proved that they meet a minimum level of competence.
The register has been coming for a long time, we have known what the requirements for registering were likely to be, in the case of Health and safety - CMIOSH or the equivalent. I have heard excuses such as - I am too busy, I don't think it will help my business, the cost, etc. Excuses that I think could be construed as signs of a shortfall in competence, especially as time and other resources are key components of the definition of competence.
Medical staff, Architects, Legal practitioners, etc have to meet minimum professional competence standards and to be entered onto the appropriate register. Why would anybody treat Health and Safety professionals with professional respect if there is not a robust system of setting and registering their professional competence?

Sorry Robin, the intention of the register is NOT "to provide a source of Health and Safety consultants who have proved that they meet a minimum level of competence" as you erroneously suggest.

Being endorsed on the new register does nothing of the sort - it conveys a message to the effect that the registrant has reached a standard. One must ask "What standard?

Competence is not tested or measured. It would appear that anyone who has the magic letters after his /her name can now be a "consultant" simply by paying £30.00 and ticking a few online boxes. A monumental leap forward for H&S ?


Jon

Just a reminder the topic is about the RIDDOR Consultation and not the Consultants Register which exists as a separate topic.

Carry on.

Some interesting and passionate responses to the RIDDOR topic.....my business is well managed from a safety point of view, my RIDDOR's reduced by 14% year on year but is this luck or management?

The main issue with the current RIDDOR system is that a member of staff can self certify sickness for 5 days, so the reported minor back strain opens up an opportunity for a week off before a doctor needs to confirm the severity of the injury.

All of my last years RIDDOR's were over 3 day reports, more than half of these were staff self certifying following a minor incident, as a safety manager what control do I have when it comes to the management of the individual?

We investigate every incident to find route cause and prevent re-occurrence.

Yes we have a proactive HR dept who manage absence.

The RIDDOR means work for me, the HSE, the local authority and does not fit with the current health system sign off fit note process.

I say time for a change!