Employers should be compelled to establish better internal reporting and investigation processes for workplace accidents, according to the Royal Society for the Prevention of Accidents (RoSPA).
In its response to a consultation on the future of RIDDOR, RoSPA has urged a more radical approach to how accidents in Britain's workplaces are recorded.
The HSE's consultation on proposals to amend the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) closes at the end of this week (29 April). Lord Young's Common Sense, Common Safety report recommended that the trigger for reporting injuries should shift from absences of three consecutive days to absences of seven days, to reduce the administration burden, particularly for smaller businesses.
However, rather than merely changing the threshold at which RIDDOR reports must be made to HSE, RoSPA suggests that a greater focus should be on employers' duties to record and investigate injuries, ill health and near misses internally so that lessons may be learned and similar occurrences avoided in the future.
Roger Bibbings (pictured), RoSPA's occupational safety adviser, calculated that, based on the RIDDOR over-three-day absence rate for the manufacturing sector in 2008/09, a firm employing 25 people might currently expect to make a RIDDOR notification once every four years. For similar size businesses in the service sector, it would be once every eight years.
At an over-seven-day trigger, he estimates that a small manufacturing firm could expect to make a notification once every 14.6 years and a small service firm once every 30 years.
He said: "This is such a long interval that corporate memory of the requirement and how to meet it would certainly have evaporated. Inevitably, someone in the company would have to take time out to find out afresh what to do. In all probability, ignorance of the reduced reporting requirement would mean that injury-related absence would go unreported altogether. If adopted, this change will mean that compliance with RIDDOR, which is currently only about 50%, will decline further."
RoSPA wants the duty to notify HSE to be restricted to fatal and major injuries, cases of work-related ill health on the 'notifiable' list and incidents on the list of dangerous occurrences. To balance this, employers should be required to investigate and keep internal records of all injuries requiring A&E attendance or medical intervention, including injury from work-related road crashes. Record-keeping would need to be proportionate and not unduly burdensome, but records would need to be made available to enforcing authorities if required.