Is anyone else out there considering the Consultation Document on Proposed Amendment to the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) looking beyond the question set and exploring the greater content of HSE CD233? http://www.hse.gov.uk/consult/condocs/cd233.htm As I read this document, there appears to be some sort of fundamental flaw in the argument with respect to continued “Eurostat” reporting requirements. CD233 references and acknowledges (at page 11 of the pdf) the Eurostat Framework Regulation (1338/2008) (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) http://epp.eurostat.ec.e...2008%20OJL354%20p.70.pdf Annex IV of that document states, inter alia: “Domain: Accidents at work (a) Aims The aim of this domain is the provision of statistics on accidents at work. (b) Scope An accident at work is defined as ‘a discrete occurrence in the course of work which leads to physical or mental harm’. The data shall be collected, for the entire workforce, for fatal accidents at work and accidents at work resulting in MORE THAN 3 DAYS of absence from work, using administrative sources complemented with relevant additional sources whenever necessary and feasible for specific groups of workers or specific national situations.” The cost/benefit analysis associated with this proposal would therefore appear to be fundamentally flawed. Page 14 of the CD233 pdf discusses “main costs” attributable to HSE in “continuing to provide Eurostat with data in the format required (£27 thousand in the first year, with annual recurring costs of £7 thousand), and from adapting past data to enable comparison”. The required Eurostat format is >3 day injuries. How do the HSE propose to provide data they no longer have? I do not profess to be an expert in European Directives or the binding nature of EC Regulations such as 1338/2008. Nevertheless, it is surely inadvisable for the UK to fail to contribute meaningful and comparable data to such a worthy enterprise, one which ultimately informs the World Health Organisation. There is of course an obvious existing discrepancy between the Eurostat and RIDDOR definition of “over 3 day” accident. Eurostat looks to be specifically interested only in absence from work, and the Lord Young Report appears to work to that same principle, whereas the RIDDOR 1995 L73 Guidance extends this to include “the injured person being…….unable to do the full range of their normal duties for more than three days”. Over-and-above all of this, I have to ask why the HSE are consulting on this relatively minor issue, when it is widely acknowledged that the same process is to be applied for the wider-ranging proposal in the Lord Young Report: “I therefore recommend that the HSE re-examine the operation of RIDDOR to determine whether this is the best approach to providing an accurate national picture of workplace accidents.” To expend effort tinkering around the edges of an issue acknowledged as requiring a root-and branch review would seem to me to be just plain incompetent – far from “common sense”.

Unfortunately Young didn't just recommend that HSE reexamine RIDDOR but also in Annex M recommended a consultation document. Would make it very difficult for UK not to fall foul of the EU.

If you read Article 4 of the same European Regulations, regarding the SOURCES of the data, it states that:- "Member States shall compile data concerning public health and health and safety at work from sources which shall, depending on the domains and subjects and on the characteristics of the national systems, consist of either household or similar surveys or survey modules, or national administrative or reporting sources" Therefore, in principle, the HSE may be able to justify using the Labour Force Survey to compile the over 3 day data, especially when it is well known that the RIDDOR data has significant under-reporting.

Some very good points. Have you copied them to Murray Clark, who is compiling the IOSH response to this consultation? I think it would help her to receive them, and all other points members think are worth making, direct rather than assuming they will be transferred somehow from this chain.

I think you might want to re-check the ConDoc, they've already identified this in paragraph 25 and 39. Kind regards

Sorry, should read "somewhat subjective question set". And let's remember folks, there;s worse still to come.........