Prepared by the Health and Safety Laboratory for the Health and Safety Executive 2013
Health and Safety Executive
Research to explore the effect of post ‘Common Sense, Common Safety’ amendment to RIDDOR Regulation 3(2) on Health and Safety Standards in Great Britain
RR984Research Report
Dr Chrysanthi Lekka, Sarah Binch, Jo Bowen and Dr Nadine Mellor Health and Safety LaboratoryHarpur HillBuxtonDerbyshire SK17 9JN
This report examines employers’ perceptions of the change in RIDDOR reporting requirements, and explores its perceived influence on employers’ behaviours and the management of health and safety. Forty telephone interviews were conducted with employers across the manufacturing, construction, public services and retail sectors. Perceived benefits associated with the changes to the reporting requirements included focusing reporting on more serious injuries, better management of work-related sickness absence, and allowing employers more time to conduct incident investigations and submit the RIDDOR report. Some concerns were expressed that employers may either forget to report or view the submission of the RIDDOR report as less of a priority as a result of the extended reporting period. Issues associated with the increased reporting threshold included employers failing to act on over-three-day incidents; however, these concerns were not widely shared among the sample.
The changes in the RIDDOR reporting requirements were not perceived as having a prominent influence in the management of health and safety. A number of internal (eg duty of care, organisation-specific trends in incidents and near misses) and external (eg customer pressures, costs associated with potential claims) drivers, other than RIDDOR, were identified as important for the management of health and safety.
This report and the work it describes were funded by the Health and Safety Executive (HSE). Its contents, including any opinions and/or conclusions expressed, are those of the authors alone and do not necessarily reflect HSE policy.
Research to explore the effect of post ‘Common Sense, Common Safety’ amendment to RIDDOR Regulation 3(2) on Health and Safety Standards in Great Britain
HSE Books
Health and Safety Executive
© Crown copyright 2013
First published 2013
You may reuse this information (not including logos) free of charge in any format or medium, under the terms of the Open Government Licence. To view the licence visit www.nationalarchives.gov.uk/doc/open-government-licence/, write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email [email protected].
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Acknowledgements
The authors would like to thank all the participants for their time and views on the issues raised in this report. Thanks also go to HSE colleagues for their help during the recruitment phase.
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KEY MESSAGES
The majority of participants (32/40) were aware of the increased reporting threshold to
over-seven days, however, fewer than half of them (16/40) were aware of the extended
reporting period.
A number of perceived benefits were associated with the increased reporting threshold
including focusing reporting on more serious injuries (i.e. often perceived to be injuries
leading to hospitalisation, and or incapacitation), better management of work-related
sickness absence and reducing uncertainty regarding the length of absence and nature of
work-related injury among others.
A number of internal (e.g. duty of care, organisation-specific trends in incidents and near
misses) and external (customer pressures, costs associated with potential claims, and sector-
specific influences, such as compliance with specific legislation) drivers were identified as
important for the management of health and safety. As such, the changes in the RIDDOR
reporting requirements, and RIDDOR more broadly, were not perceived to be a significant
driver in the management of health and safety.
Concerns expressed regarding the increased reporting threshold included employers failing
to act on over-three-day incidents potentially leading to complacency and a drop in health
and safety standards; however, these concerns were not widely shared among the sample.
Perceived benefits associated with the extended reporting period included amongst others,
allowing more time for employers to conduct incident investigations and submitting the
RIDDOR report.
Some concerns were expressed that employers may forget to report and/or submitting the
RIDDOR report may become less of a priority as a result of the extended reporting period.
Participants that had not submitted a RIDDOR report within the last two years were more
likely to hold neutral views regarding any perceived benefits (or lack thereof) of the changes
to the reporting requirements, whilst some found it difficult to comment on the changes.
Approximately half of the participants (18/40) stated that the changes to the reporting
requirements would not influence their levels of reporting to the HSE, whilst just under half
of the participants (15/40) suggested that the changes would facilitate reporting.
Although the majority of participants stated that they would still record over-three-day
injuries (39/40), very few appeared to be aware that keeping an internal record of over-
three-day injuries was a legal requirement. Only three participants explicitly mentioned that
they would continue to record over-three-day incidents because it is a legal requirement
whilst one participant mentioned that the organisation would not record O3D incidents
because it was not a legal requirement.
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EXECUTIVE SUMMARY
BACKGROUND
The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR)
require employers and others with health and safety responsibilities to report certain types of
injury, some occupational diseases and dangerous occurrences that arise out of or in connection
with work. As of 6th of April 2012, the requirement to report incidents resulting in
incapacitation for over-three-days was changed to over-seven-days. However, under EU law,
employers and others with responsibilities under RIDDOR must still keep a record of all over-
three-day (O3D) injuries – if the employer keeps an accident book, then this record will be
enough. This means that employers are legally required to report injuries where employees are
absent from work or are unable to carry out the full range of their normal duties for more than
seven consecutive days (not counting the day of the accident, but including weekends and rest
days). Employers are also given a longer period to report increasing from ten to fifteen days
from the time of the accident. The increase in the reporting threshold from over-three to over-
seven days helps align injury reporting more closely with the fit note, which employees must
obtain from their doctor if they are absent from work due to ill health or injury for more than
seven days. It is anticipated that the change to RIDDOR will reduce administrative costs for
businesses as well as help employers to better manage sickness absence.
The Health and Safety Executive (HSE) commissioned the Health and Safety Laboratory (HSL)
to examine employers’ views and perceptions of the change in RIDDOR reporting
requirements, and explore its perceived influence on employers’ behaviours and the
management of health and safety. Potential differences in terms of perceptions, reactions and
influence on health and safety management between employers who have made a RIDDOR
report to the HSE and those who have not were also explored.
METHODOLOGY
Forty telephone interviews were conducted with employers across the top four sectors in terms
of the number of RIDDOR reports made: manufacturing, construction, public services and
retail. Of the forty interviews, twenty were conducted with employers that have submitted a
RIDDOR report to HSE within the last two years (i.e. RIDDOR reporters), and twenty with
employers that have not submitted a RIDDOR report within the same time period (i.e. non-
reporters). The same sectors were matched to enable comparisons between the RIDDOR
reporter and non-reporter groups. Approximately five interviews with employers from each of
the four sectors were conducted for each group. As much as possible, a spread of small,
medium-sized and large organisations was included in the sample.
A systematic analytical approach was adopted for identifying recurrent themes and patterns
across the data. The aim of the analysis was to explore the range of views regarding employers’
perceptions and reactions to the changes in the RIDDOR reporting requirements and their
perceived influence on health and safety management, as well as to highlight any themes that
were prevalent (i.e. most and/or least widely shared) across the sample.
FINDINGS
Awareness/knowledge of change in RIDDOR reporting requirements
The majority of participants were aware of the increased reporting threshold of over-seven-day
(O7D) injuries (32/40), but fewer than half of them were aware that the period for reporting the
O7D injury had been extended to fifteen days (16/40). Overall, RIDDOR reporters in this
v
sample were more likely to be aware of the changes (both of the requirement to report O7D
injuries and the extended reporting period) compared to non-reporters.
Reactions to the O7D injury reporting requirement and extended reporting period
The overwhelming majority of participants perceived the increase in the reporting threshold
from over-three to over-seven days as beneficial. Perceived benefits included:
A shift in focus towards reporting more serious injuries,
Reduction of instances where absence from work may be deliberately extended,
Reduced uncertainty regarding the length of work-related sickness absence and nature
of work-related injury,
Reduced administrative burden resulting from fewer reports submitted,
Improved organisational reputation due to a decrease in the number of RIDDOR reports
made (i.e. as O3D injuries no longer need to be reported to the HSE).
A minority of participants expressed concerns over:
The increase in the reporting threshold which could result in a drop in health and safety
standards as employers may fail to take action on injuries that are not reportable and
reduce investments in health and safety due to improved accident statistics (i.e. there
was an expectation that the change would result in fewer RIDDOR reports submitted,
which indeed some participants had already observed).
Potential confusion among employers regarding reporting requirements (i.e. the
requirement to keep a record of O3D injuries, but only report O7D injuries to HSE),
Possible under-reporting due to fears of Fee for Intervention (FFI) visits by HSE, and
Pressure exerted from employers to ensure that employees return to work within a
week.
However, these latter concerns represented marginal views and were not widely shared among
the sample.
A small number of participants, particularly non-reporters, felt that they could not comment on
the change either because they have never had a reportable incident or because their operations
were ‘low risk’ and as a result they experienced very few reportable incidents.
Further, the majority of participants felt that the extended reporting period would allow
employers more time to conduct incident investigations and ascertain more accurately the
circumstances of the incident (for instance, by obtaining the injured worker’s version of events).
However, some concerns were expressed that employers may forget to report or may view the
submission of the RIDDOR report as less of a priority because of competing demands on their
time. Equally, however, some RIDDOR reporters and non-reporters felt that there was no
benefit to the extended reporting period.
Perceived influence of RIDDOR changes on ‘reporting behaviours’ to the HSE
Approximately half of the participants in this sample (18/40) felt that the changes to the
reporting requirements would not influence the levels of reporting to HSE, whilst just under half
of the respondents (16/40) suggested that the changes would facilitate reporting. Commonly
cited reasons among participants who felt that the changes would facilitate reporting to the HSE
included i) having more time to conduct internal investigations and collect the required
information (particularly medical information that may not be readily available in a shorter time
frame), ii) having more time to prepare and submit the RIDDOR report, and iii) reporting would
focus on more serious incidents so that fewer number of RIDDOR reports would need to be
submitted to the HSE.
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Perceived influence of RIDDOR changes on the management of health and safety
The RIDDOR reporting requirements did not appear to have a prominent influence on the
management of health and safety, although it was acknowledged that RIDDOR helps promote a
greater awareness among employers of the importance of health and safety. A number of key
drivers for the management of health and safety were identified and included: i) an
acknowledgment that employers have a duty of care towards employees and that accidents are
costly for businesses, ii) customer expectations/pressures that high health and safety standards
are maintained, iii) guarding against potential claims arising from work-related injuries, and iv)
sector-specific drivers, such as compliance with legislation. Some concerns, albeit marginal (i.e.
not widely shared) were expressed that improved RIDDOR statistics might encourage
organisations to invest fewer resources in health and safety. On the other hand, few participants
noted that the changes could potentially help improve the management of health and safety by
enabling employers to focus more on risks that result in serious injury and conduct more
thorough incident investigations.
Consistent with the above, the change in the reporting requirements did not appear to have an
influence on the internal recording of health and safety incidents. Although specific changes had
been implemented to accommodate the new reporting requirements (e.g. changes in health and
safety policy and reporting systems to capture both O3D and O7D injuries), the overwhelming
majority of participants commented that all incidents and/or injuries (including O3D injuries)
were recorded. However, the vast majority of respondents did not appear to be aware that
keeping an internal record of O3D injuries is a legal requirement. Responding to potential
claims, as well as preventing incidents from recurring, were some of the factors that influenced
the recording of incidents.
Finally, the severity or potential severity of the incident (or near miss), as well as the extent to
which it could affect other workers, rather than whether the incident was reportable or not, were
identified as criteria used for determining whether an investigation was required. As such, the
change in the reporting requirements did not appear to have an influence on employers’
approach to incident investigations.
Research caveats
The study explored employers’ views and reactions to the changes in the RIDDOR reporting
requirements and their potential influence on the management of health and safety. However,
this study is not an impact evaluation, as this would have required a quantitative approach with
assessments carried out before and after the RIDDOR changes were introduced. Whilst the
findings provide an important insight into employers’ views, the findings cannot be generalised
to the wider population of GB businesses in the sectors studied due to the nature of the sample
and method of investigation chosen.
Conclusion
The findings from this study suggest that, for the majority of participants, there were several
benefits associated with the changes to the reporting requirements, including focusing reporting
on more serious incidents, better management of work-related absence and allowing employers
more time to conduct incident investigations. These benefits notwithstanding, some concerns
were expressed that employers may forget to report and/or view reporting as less of a priority as
a result of the extended reporting period. The findings also suggest that the majority of
participants in this sample did not appear to be aware that keeping a record of O3D injuries is a
legal requirement. Finally, the changes to the RIDDOR reporting requirements and RIDDOR
more broadly, are not perceived as having a prominent influence on the management of health
vii
and safety. This is because drivers, other than RIDDOR were identified as important for the
management of health and safety, including customer pressures to maintain health and safety
standards, and costs associated with work-related injury claims.
CONTENTS PAGE
1. INTRODUCTION .................................................................... 1
1.1 Background 1 1.2 Research aims and objectives 2
2. METHODOLOGY ................................................................... 3
2.1 Research design 3 2.2 Sample 3 2.3 Procedure 4 2.4 Analysis 4
3. FINDINGS .............................................................................. 6
3.1 Awareness of changes in reporting requirements 6 3.2 Reactions to changes in reporting requirements 6 3.3 Perceived Influence of changes on reporting behaviour 14
3.4 Perceived influence of changes on H&S management 16 3.5 Differences in employers’ reactions and behaviours 19
3.6 Research caveats 19 3.7 Conclusion 20
4. REFERENCES ..................................................................... 21
5. APPENDICES ...................................................................... 22
5.1 APPENDIX A: Recruitment of sample 22
5.2 APPENDIX B: Research tools 22
1
1. INTRODUCTION
1.1 BACKGROUND
Employers have a legal duty to keep a record of deaths, major injuries1, over-seven day injuries,
dangerous occurrences2 as well as cases of occupational disease
3 under the Reporting of Injuries,
Diseases and Dangerous Occurrences Regulations (RIDDOR) 1995. The death/injury must
result from an accident that arose out of or was connected with the work activity.
The seven-day reporting requirement came into effect on the 6th of April 2012 following a
recommendation made by Lord Young in his 2010 review of the health and safety system in the
UK, “Common Sense, Common Safety”4. Lord Young recommended that RIDDOR Regulation
3(2) is amended to increase the over three day (O3D) time period after which an injury must be
reported to over seven days (O7D). In practice, the change means that organisations (or the self-
employed) have the responsibility to report a RIDDOR using the Health and Safety Executive’s
(HSE’s) online system for any employee who is absent from work or is unable to do the full
range of their normal duties for more than seven consecutive days (not counting the day of the
accident, but including weekends and rest days). Employers are also given a longer period to
report, increasing from ten to fifteen days from the time of the accident.
The change from O3D to O7D reporting takes forward the first recommendation made by Lord
Young. It is anticipated that the increase in the reporting threshold from over three to over
seven days will reduce administrative burdens for businesses and enable employers to better
manage sickness absence. Under EU law, however, employers and others with responsibilities
under RIDDOR must still keep a record of all O3D injuries (for instance, in an accident book),
even though they are no longer required to report these to the HSE. Deaths and major injuries
still need to be reported to the HSE without delay. The HSE commissioned the Health and Safety Laboratory (HSL) to examine employers’
perceptions of the change from O3D to O7D RIDDOR reporting and explore the perceived
influence of this change on employers’ reporting behaviours and health and safety management.
Such research would also provide a useful comparison for the findings of any subsequent
research carried out to explore employers’ perceptions following any future changes to
RIDDOR. Further, it is anticipated that the act of RIDDOR reporting may play a role in
workplace health and safety management5 on the basis that reporting could trigger organisations
to investigate incidents themselves. As such, exploring any potential differences in perceptions
and/or behaviours between employers who have previously submitted a RIDDOR report to HSE
with those who have not is also important to address.
1 Major injuries can refer to ‘loss of sight’, ‘dislocation of shoulder, hip, knee or spine’. [See
http://www.hse.gov.uk/riddor/what-must-i-report.htm] 2 These can be certain listed near-miss events such as: ‘collapse, overturning or failure of load-bearing parts of lifts
and lifting equipment’. [See http://www.hse.gov.uk/riddor/what-must-i-report.htm] 3 Example occupational diseases include ‘cramp of the hand or forearm due to repetitive movements’, ‘hand-arm
vibration syndrome’. [See http://www.legislation.gov.uk/uksi/1995/3163/schedule/3/made] 4 Source: Common Sense, Common Safety; page 16; http://www.number10.gov.uk/wp-
content/uploads/402906_CommonSense_acc.pdf 5 Health and safety management is often reflected in a company’s health and safety practices; these can either be
very formal (i.e. established health and safety management systems) or more informal (e.g. presence of components
of a system, such as a health and safety policy or risk assessments for certain work tasks). The former tends to be
characteristic of large organisations and the latter of small companies.
2
1.2 RESEARCH AIMS AND OBJECTIVES
The overall aim of the research is to explore employers’ perceptions of the new RIDDOR
reporting requirements and their perceived influence on the management of health and safety.
The specific objectives of the research are to:
Explore employers’ perceptions (e.g. awareness, knowledge, reactions) of the changes
in RIDDOR reporting requirements,
Identify whether the changes have facilitated or hindered the reporting of RIDDORs
both to HSE and internally (e.g. accident investigations, recording in accident books),
Examine how the changes have influenced employers’ behaviours in relation to their
health and safety management, and
Explore potential differences in perceptions and behaviours (e.g. reporting, health and
safety management) between employers who have submitted RIDDOR reports to HSE
and those who have not.
3
2. METHODOLOGY
2.1 RESEARCH DESIGN
A qualitative approach was used to address the study’s aims and objectives. The goal of
qualitative research is to capture participants’ views, experiences and understandings of a
particular phenomenon (Denzin and Lincoln, 1994). Qualitative semi-structured interviews were
suited for this research to gain an in-depth understanding of employers’ perceptions regarding
the change in RIDDOR reporting requirements and the extent to which it has had an influence
on the management of health and safety.
2.2 SAMPLE
A purposive sampling approach (Ritchie and Lewis, 2003) was used for the recruitment of
participants. This approach focuses on particular characteristics of a population that are of
interest and can best address the research questions. Consistent with this approach, two groups
of employers were included in the study. The first group included employers who had submitted
a RIDDOR report to HSE within the last two years (referred to as ‘RIDDOR reporters’
hereafter), and the second group included employers that had not submitted a RIDDOR report to
HSE within the same time period (referred to as ‘non-reporters’ hereafter). In agreement with
HSE, the sample was drawn from the top three sectors in terms of the number of RIDDOR
reports made. These included service industries, manufacturing and construction. Given the
breadth and diversity of the service industries sector, a further decision was made to break down
the sector into public sector (e.g. hospitals) and retail (e.g. supermarkets), which would provide
a more valuable approach to exploring any issues pertaining to the two sectors. In order to allow
for a meaningful comparison, the same sectors were matched in the RIDDOR reporter and non-
reporter samples.
Forty interviews, twenty with RIDDOR reporters and non-reporters respectively were deemed
sufficient to draw meaningful comparisons between the two groups. For each sample, it was
agreed that five interviews would be conducted within each sector representing a spread of
small and medium-sized companies (SMEs), as well as larger organisations.
For the recruitment of the RIDDOR reporter sample, HSE’s RIDDOR team selected a sample of
contacts from the RIDDOR database whereas a UK Public Database was used for the
recruitment of the non-reporters’ sample (see Appendix A for further information on sample
recruitment). Table 1 summarises the sample characteristics, including information on the sector
and organisational size of the employers that took part in the study.
A number of challenges were experienced during the recruitment process and as a result it was
not possible to achieve the desired spread of SMEs and large organisations for each group.
Specifically, for the non-reporters’ sample it was not possible to recruit large organisations (i.e.
with more than 250 employees) across any of the four sectors because all of the organisations
contacted had submitted RIDDOR reports to HSE within the last two years. For similar reasons,
it was also not possible to recruit medium-sized organisations in the public sector. As a result,
the non-reporters sample primarily consisted of SMEs (i.e. organisations with up to 250
employees).
For the RIDDOR reporter sample, it proved very difficult to contact the individuals responsible
for health and safety within large organisations in the construction sector (for example, they
often seemed to be out on site) and therefore it was not possible to include this group of
employers in the sample. Further, it was not possible to include small organisations (i.e. 10-49
employees) in the retail sector, as there were an insufficient number of contacts for this group of
4
employers in the RIDDOR database. This was also the case for medium-sized organisations (i.e.
50-249 employees) in the public sector where additionally existing public sector contacts in the
RIDDOR database did not fall in the medium-sized range.
Table 1. Sample information on sector and organisational size
Sector Number of
employees
RIDDOR
reporters
Non-reporters Total
Manufacturing 10-49 2 2 4
50-249 2 3 5
250+ 2 0 2
Construction 10-49 1 3 4
50-249 4 2 6
250+ 0 0 0
Retail 10-49 0 3 3
50-249 1 2 3
250+ 4 0 4
Public Sector 10-49 1 5 6
50-249 0 0 0
250+ 3 0 3
Total number of
interviews
20 20 40
2.3 PROCEDURE
Semi-structured interviews were conducted over the telephone between November 2012 and
January 2013. All the interviews were conducted with individuals responsible for health and
safety in their respective organisations.
At the start of each interview, participants were briefed about the purpose of the research and
they were assured of confidentiality and anonymity. All interviews, bar one where only notes
were taken at the request of the interviewee, were recorded and transcribed for the purpose of
data analysis. Verbal consent was obtained from participants before recording equipment was
used (information on the research tools and the topics explored during the interviews can be
found in Appendix B).
2.4 ANALYSIS
The data from the interviews were analysed using the Framework analysis, which is a
systematic approach to data management and analysis developed by the National Centre for
Social Research (Richard and Lewis, 2003). The analysis involved the following stages:
Familiarisation with the interview transcripts in order to obtain an initial understanding of
the emerging themes.
Development of an analytical framework and a series of thematic matrices, which were
used to summarise the key issues from each interview consistent with the study’s research
objectives.
Working through the data identifying the range of views and experiences and any emergent
patterns including any differences between the two groups (RIDDOR reporters and non-
reporters).
5
Additional analysis was carried out in order to determine the relative prevalence of the themes
identified across the sample (i.e. the degree to which a theme was shared). This involved
counting the number of times that a particular theme was discussed across the sample (Braun
and Clarke, 2006). This approach helped highlight the extent to which themes appeared to be
most or least shared across the participants.
6
3. FINDINGS
3.1 AWARENESS OF CHANGES IN REPORTING REQUIREMENTS
The first objective of the study examined the extent to which employers were aware of the
changes to RIDDOR reporting requirements and were knowledgeable of what the changes
entailed. Table 2 provides a summary of RIDDOR reporters and non-reporters’ awareness/
knowledge of the changes to RIDDOR.
Table 2. Overview of participants’ awareness/knowledge of changes in RIDDOR reporting
requirements (based on 40 interviews)
Awareness/knowledge of O7D
reporting requirement
Awareness/knowledge of deadline
extension to 15 days
Sample Yes No Yes No
RIDDOR reporters (20) 20 0 10 10
Non-reporters (20) 12 8 6 14
Total (40) 32 8 16 24
It can be seen that the majority of participants were aware that they were required to report the
O7D injuries (32/40), whilst fewer than half of the participants were aware that the period for
reporting the O7D injury had been extended to fifteen days (16/40).
In both cases, RIDDOR reporters were more likely to be aware of the changes in the RIDDOR
reporting requirements compared to non-reporters. Specifically, all twenty RIDDOR reporters
were aware of the O7D reporting change compared to twelve non-reporters. Similarly, ten
RIDDOR reporters were aware of the extended reporting period compared to six non-reporters.
In summary, the findings suggest that the majority of employers in this sample were aware of
the O7D change, whilst fewer than half of participants were aware of the extended reporting
period. Further, RIDDOR reporters in this sample were more likely to be aware of the changes
compared to non-reporters.
3.2 REACTIONS TO CHANGES IN REPORTING REQUIREMENTS
This section presents the findings regarding employers’ views and reactions to the changes in
RIDDOR reporting requirements. The analysis identified a range of reactions regarding the
changes. Given the plethora of views expressed, additional analysis was conducted in order to
determine the prevalence of key themes, that is, the degree to which each theme was widely
shared across the sample. High prevalence indicates a higher level of agreement (i.e. whereby a
theme is more frequently mentioned across the sample), whereas lower prevalence indicates
themes that were less widely shared across the sample (Braun and Clarke, 2006).
3.2.1 Issues associated with the O7D reporting change
Figure 1 provides a summary of the key themes that emerged and an indication of their
prevalence across the sample. The themes that were most prevalent appear first followed by
7
those that had a lower level of prevalence (i.e. were not widely shared across the sample). It can
be seen that the majority of participants held positive views toward the O7D reporting change as
indicated by their higher levels of prevalence (HP denotes high prevalence in the figure below,
LP stands for low prevalence). Each theme is discussed below.
HP
LP
Figure 1. Summary of key themes associated with the O7D change and their prevalence across
the sample (based on 40 interviews)
Shift focus on more serious injuries
Reduction of instances where absence from work may be deliberately
extended
Reduced uncertainty regarding the length of sickness absence
and nature of work-related injury
Reduced administrative burden
Over time organisations could become
complacent resulting in a drop in health and
safety standards
Improved organisational reputation due
to a decrease in the number of RIDDOR
reports submitted
Potential confusion
over reporting
requirements
Potential under-reporting due
to fear of FFI
Pressure on
employees to
return to work
8
3.2.1.1 Perceived benefits of the O7D reporting change
The vast majority of participants perceived the increase in the reporting threshold from over-
three to over-seven days as a beneficial change. Unless otherwise stated in the text, the key
themes discussed below were common to both groups (i.e. RIDDOR reporters and non-
reporters). Perceived benefits of the increased reporting threshold that were discussed by
participants were as follows:
Shift focus on reporting more serious injuries6: The change towards reporting O7D
injuries was often described as ‘common sense’ and ‘sensible’. Several participants felt that
O3D injuries were very often minor and hence not worth reporting. Consistent with this, the
change was very often perceived as a positive shift towards reporting more serious injuries
to the HSE.
Reduction of instances where absence from work may be deliberately extended: Several participants felt that workers may sometimes either ‘feign’ injury or deliberately
extend work-related absence for injuries that were minor. There was a belief that the change
would mean that workers would be more likely to be off work for seven days for injuries
that were ‘genuine’. Consistent with this, the change to reporting O7D injuries was
perceived as a positive one because it aligned with the fit note system, which helped validate
the genuineness of an employee’s sickness absence. Thus, the need to obtain a fit note
would help eliminate such cases, as employees would normally be back at work within
seven days.
Reduced uncertainty regarding the length of sickness absence and nature of work-
related injury: There was a perception that the increased reporting threshold would help
remove any uncertainties regarding the length of absence due to a work-related injury. This
was particularly the case for organisations that operate shift patterns (e.g. 4 days on/ 4 days
off shifts). Examples were provided where workers might sustain a work-related injury on
their last day of shift, which often made it difficult for employers to ascertain the length of
absence or whether the injury qualified as a RIDDOR under the previous O3D requirement.
The change meant that workers were either likely to be back at work within seven days or
inform their supervisor/line manager of their absence making it easier to manage sickness
absence. It was also suggested that within seven days, employers were more likely to have
an accurate picture of the nature and the extent of the injury, which was not possible under
the previous reporting requirement.
Reduced administrative burden: Several participants felt that the previous requirement
created unnecessary administrative workload for businesses, as many O3D injuries were
perceived to be minor. It was believed that the O7D change would result in a reduction of
administrative workload for employers because reporting would focus on a smaller number
of more serious injuries. Organisations that submit a large number of RIDDOR reports were
perceived as particularly benefiting from this change. Indeed, few RIDDOR reporters
mentioned that they had observed a reduction in the number of RIDDOR reports submitted
to HSE with one participant citing that the number of reports submitted had reduced by half
to those reported under the previous requirement. However, a small number of RIDDOR
6 There was variation in participants’ understandings of what constituted a ‘serious’ injury. For instance, some
perceived serious injuries as those requiring hospitalisation and/or injuries that resulted in workers’ being unable to
carry out their normal work activities. Others defined an injury as serious depending on the resulting number of days
that a worker had to be absent from work (e.g. in some cases being absent from work for more than three and/or
seven days was classified as a serious injury).
9
reporters noted that, contrary to expectations, there had not been a significant decrease in the
number of RIDDOR reports. This was often attributed to the fact that the majority of
injuries reported under the previous requirement in fact extended to seven days (thus the
number of RIDDOR reports were the same under both the previous and new requirements).
Improved organisational reputation due to a decrease in the number of RIDDOR
reports submitted: It was described that the number of RIDDOR reports submitted often
influences customers’ decisions to work with an organisation. For instance, it was described
that customers often request information regarding the number of RIDDOR reports
submitted by an organisation. A perceived benefit of the O7D change, discussed by a small
number of RIDDOR reporters, was that the number of RIDDOR reports would decrease (i.e.
as O3D injuries no longer need to be reported to the HSE), which would help improve
organisations’ accident statistics and, in turn, their image and reputation externally (i.e. to
customers).
Box 1. Example interview extracts illustrating positive views towards the O7D change
“It’s definitely a more commonsense approach to be seven days rather than three which is, you
know, three days is nothing. People have three days off for a cold these days.”
(Interview 5, non-reporter, retail)
“They used to sort of feign an injury and because the weekend was included… because
Saturday and Sunday was included you were having to report accidents...” (Interview 14, non-
reporter, construction)
“If it [the injury] happens towards the end of that shift it’s sometimes difficult to find out
whether the absence or incapacity to work qualifies for a RIDDOR report because they’re not
on site and they’re resting anyway […] It does strengthen if you like the sort of validation of
the absence connected to an incident at work, because people are not likely to take seven days
off and therefore have to get a sick note unless it’s genuine as it were.” (Interview 27,
RIDDOR reporter, public sector)
“It takes away some of the bureaucratic red tape in terms of informing the controlling body of
every single thing that happens over a three day injury although it could be serious it’s not
always serious. But when you’re looking at over seven day injury you’re obviously looking at
something that is quite serious that should be addressed and the authorities should be aware
of. So from that sense yes, it’s actually very positive.” (Interview 34, RIDDOR reporter, retail)
3.2.1.2 Perceived concerns associated with the O7D reporting change
A minority of participants disagreed with the change towards reporting O7D injuries. The key
issues identified were as follows:
Concern that, over time, organisations could become complacent resulting in a drop in
health and safety standards: Few participants expressed a concern that the change towards
reporting O7D injuries could encourage employers to turn a blind eye to and/or fail to take
action on O3D injuries. Specifically, it was suggested that five or six-day work-related
injuries could be serious. However, as they do not need to be reported to HSE, employers
may ‘push these injuries under the carpet’. Consistent with this, it was suggested that
management places a strong emphasis on RIDDOR as an indicator of safety performance
such that a high number of RIDDOR reports typically trigger ‘alarm bells’. There was a
concern that improved accident statistics (as a result of fewer RIDDOR reports submitted)
10
could in turn encourage management to reduce the amount of resources invested in health
and safety (through beliefs that health and safety performance has improved) thus fostering
complacency in the long-term.
Potential confusion over reporting requirements: A marginal (i.e. not widely shared)
view expressed was that the O7D change could potentially create confusion among
employers making it harder to comply with the reporting requirements. The source of
confusion could arise from the fact that employers are still legally required to keep an
internal record of any O3D injuries, even though only the O7D injuries need to be reported
to the HSE.
Potential under-reporting due to fear of Fee for Intervention (FFI) by HSE: A
marginal view expressed was that the change to reporting O7D injuries would enable HSE
to identify incidents where enforcement action would be appropriate. There was a concern
that this could potentially discourage employers from reporting injuries that are perceived as
‘borderline’ (e.g. where there are unclear guidelines as to whether they are reportable under
RIDDOR) in order to avoid a potential FFI visit by the HSE.
Pressure on employees to return to work as a means of avoiding having to submit a
RIDDOR report: Another marginal view expressed was that the change could result in
employers exerting pressure on employees to come back to work within a week in order to
avoid having to submit a RIDDOR report.
It should be acknowledged, however, that these two latter points (e.g. potential under-reporting
and pressure on employees to return to work) would be equally applicable to incidents reported
under the previous O3D requirement, and thus do not exclusively pertain to the change towards
reporting O7D injuries.
Box 2. Example interview extracts illustrating concerns toward the O7D change
“My view was that I thought it [the O7D change] was slightly negative. Because, I mean not
that I think companies try and get out of reporting minor injuries anyway so I think this will
just give them another way of avoiding it because they’ll try and get people back to work
within a week.” (Interview 39, RIDDOR reporter, construction)
“I would be concerned that some of the less serious things might be then just pushed under the
carpet to be honest […] if something puts you off work for five, six days it’s fairly serious, if
you haven’t got to report it because they haven’t been off for seven days then you’ve got away
with it; in reality that’s the way I would see it.” (Interview 18, non-reporter, public sector)
“They’ve made it more complicated for an employer to comply by saying that HSE only want
to know about seven days but by the way you’ve got to keep a library of three day incapacity
incidents just in case HSE turn up.” (Interview 25, RIDDOR reporter, public sector)
3.2.1.3 Ambivalent/Neutral reactions to the O7D reporting change
A small number of participants, particularly non-reporters, felt that they could not comment on
the change and/or the change would not have an impact on the organisation, either because they
have never had a reportable incident or because their operations are ‘low risk’ and thus they
experience very few reportable incidents. In a small number of cases, any RIDDOR reports
made were due to occupational diseases (e.g. hand/arm vibration syndrome) rather than over
11
three day or seven day absences; thus the change was not perceived as affecting the
organisation.
3.2.2 Issues associated with the extended reporting period
This section discusses the key themes that were identified regarding employers’ reactions to the
extended reporting period. Figure 2 summarises the themes that emerged according to their
prevalence. It can be seen that there were mixed views regarding the potential benefits of the
extended reporting period. Although the majority of participants felt that the change would
allow employers more time to conduct incident investigations, there was also a concern that the
reporting of O7D injuries could become less of a priority among employers. These issues are
discussed in more detail below.
HP
LP
Figure 2. Summary of key themes associated with the extended reporting period and their
prevalence across the sample (based on 40 interviews)
Box 3. Example interview extracts illustrating ambivalent/neutral views towards the O7D
change
“The bulk of our RIDDOR reports have not been because of over three day injuries or over
seven day injuries latterly. It’s been because of industrial injuries or diseases shall we say
that fall under RIDDOR reporting […] it [the O7D change] might take the odd injury out of
needing to be reported under RIDDOR but no, I don’t think that that particular change has
really had any effect on us.” (Interview 21, RIDDOR reporter, manufacturing)
“I don’t have an opinion of this change. I’ll tell you why, because our company is quite small
and we’re office-based and we’ve never had a work-related injury of a nature that would
require reporting.” (Interview 8, non-reporter, manufacturing)
“I think we’ve had one reportable accident in the past ten years so it’s not something that’s
got a major impact on us.” (Interview 1, non-reporter, construction)
More time to conduct internal incident investigations
Reporting of O7D injuries could become less of a priority for
employers
No perceived benefits/ extended reporting period
unnecessary
Allowing more time to submit
RIDDOR report potentially
improving compliance
Improved
quality of
information in
RIDDOR
reports
12
3.2.2.1 Perceived benefits associated with the extended reporting period
Key themes that emerged among both RIDDOR reporters and non-reporters that favoured the
extended reporting period of fifteen days were as follows:
Allowing more time to conduct internal incident investigations: The extended reporting
period was perceived favourably among several RIDDOR reporters and non-reporters
because it would allow employers more time to conduct incident investigations and
ascertain more accurately the circumstances of the incident (for instance, by obtaining the
injured worker’s version of events). Specifically, it was described that the extended
reporting period would enable employers to ascertain whether an injury was work-related
and gather the necessary information regarding the extent and nature of the injury (e.g. by
obtaining GP/hospital assessments). Further, the extended reporting period would provide
employers with sufficient time to collect and collate the required information from different
individuals (e.g. injured worker, supervisor), especially where they are geographically
dispersed (e.g. working across different sites). It was also noted, however, that it was
important for employers to initiate incident investigations promptly in order to benefit from
the extended reporting period.
Allowing more time to submit RIDDOR report potentially improving compliance: Another perceived benefit reported was that the extended reporting period would provide
more time for employers to collate all the required paperwork and submit the RIDDOR
report, thus facilitating compliance with the reporting requirements. Further, for
organisations where one person held responsibility for submitting the RIDDOR report, the
extended reporting period would accommodate instances where the individual responsible
was either on holidays or off work due to sickness absence at the time when the reportable
injury took place.
Improving the quality of information in RIDDOR reports: It was suggested that often
RIDDOR reports were based on assumptions regarding the causes and circumstances of the
incident, as it was not possible to collect all relevant information under the previous
reporting period of ten days. Further, there was a perception that the completion of the
online RIDDOR form sometimes required ‘guesswork’ as it was not possible to leave blank
fields on the form for information that was not yet known and return to it at a later stage.
The extended reporting period was perceived as enabling employers to obtain a more
comprehensive picture of the incident (for instance, by collecting information from different
sources such as the worker, GP/hospital), thus eliminating the need to make assumptions
regarding the incident and improving the accuracy of information submitted to the HSE.
Box 4. Example interview extracts illustrating positive views towards the extended
reporting period
“You’ve got more time to get your facts together and you know make sure that you’ve got all
your paperwork in order and that you can do it without being under pressure of running out
of time.” (Interview 13, non-reporter, retail)
“It’s a bigger window isn’t it in which to do it so you can remain compliant in that sense […]
By extending it to fifteen days it allows you that little bit of leeway, you can’t not be
compliant really within fifteen days can you?” (Interview 16, non-reporter, public sector)
13
“[…] If that person is off ill due to that incident I can’t report it because I haven’t got a clear
picture because they’re off sick so I can’t do an investigation with that person. So those extra
days are good in my opinion.” (Interview 23, RIDDOR reporter, retail)
“[…] Ten days I sometimes found short in terms of... If there’s only one person in the
company like I am then it becomes a problem sometimes if they’re absent or they’re on
holiday or something like that. And fifteen days is now better in that way that we’ve got that
extra week to do it.” (Interview 26, RIDDOR reporter, construction)
3.2.2.2 Perceived concerns associated with the extended reporting period
A concern voiced by both RIDDOR reporters and non-reporters was that the extended reporting
period would send a signal to employers that the reporting of the O7D injury is less of a priority.
Some participants felt that O7D injuries are serious incidents that should be reported as soon as
possible. In light of this, there was a concern that the increased reporting period would
encourage employers to view the submission of the RIDDOR report as less of a priority and as a
consequence it would ‘go further down the pile’. It was also suggested that employers might
forget to report the O7D injury because of competing demands on their time, particularly
because customer requirements would be prioritised. In a minority of cases, extending the
reporting period was described as ‘relaxing the rules’ and ‘dropping the standards’. Some of
the participants that opposed this change reported that they would not take advantage of the
extended reporting period and would submit the RIDDOR report within ten days (consistent
with the previous requirement).
Box 5. Example interview extracts illustrating concerns towards the extended reporting
period
“I think you’re better reporting things quickly […] if you say I’m going to leave it for fifteen
days by the time the fifteenth day comes, you know, some other priority may have taken over
and it could be easy to forget it.” (Interview 14, non-reporter, construction)
“If it’s serious enough that it needs reporting then really it’s serious enough that you need to
do your report straight away [...] it [the extended reporting period] gives me the opportunity to
allow it not to be at the top of the pile and really it should be at the top of the pile.” (Interview
4, non-reporter, public sector)
“I mean it should be a priority in my opinion so we would certainly do it [report the O7D
injury] well within the ten days.” (Interview 22, RIDDOR reporter, manufacturing)
“For me, if it [the reporting period] was shorter it’d make me more focussed to ensure that
these people were back […] when it was shorter it was on my radar a lot longer or more than
it is now.” (Interview 33, RIDDOR reporter, retail)
3.2.2.3 Ambivalent/Neutral reactions to the extended reporting period
Several RIDDOR reporters and non-reporters felt that there was no benefit to the extended
reporting period. Specifically, the previous requirement according to which an injury had to be
reported within ten days was perceived as sufficient in enabling employers to ascertain the
circumstances of the incident and complete the RIDDOR report. For some, there was an
14
expectation that employers should be able to submit a RIDDOR report within ten days so that
extending the reporting period was perceived as unnecessary. Consequently, the extended
reporting period was not perceived as offering employers any additional benefits. Others felt
that the change would not affect their organisation either because they have never had a
reportable incident (in the case of non-reporters) or because they experience very few reportable
incidents (in the case of RIDDOR reporters).
3.3 PERCEIVED INFLUENCE OF CHANGES ON REPORTING BEHAVIOUR
The second objective of the study explored the extent to which the changes in the RIDDOR
reporting requirements would have an influence on employers’ reporting behaviours to the HSE.
The findings showed that there were mixed views regarding the extent to which the changes to
the RIDDOR reporting requirements would influence (i.e. either hinder or facilitate) reporting
behaviours (see Table 3).
Table 3. Summary of participants’ responses regarding the influence of the RIDDOR changes
on reporting behaviours
Perceived influence of RIDDOR changes on reporting behaviours
Group Negative No influence Positive Unsure
RIDDOR reporters 1 10 7 2
Non-reporters 2 8 8 2
Total 3 18 15 4
Specifically, approximately half of the participants (18/40) in this sample felt that the changes to
the reporting requirements would not influence their levels of reporting to HSE, whilst just
under half (15/40) suggested that the changes would facilitate reporting.
Looking first at those participants that felt that the changes would not influence reporting
behaviours, different issues were raised among RIDDOR reporters and non-reporters. On one
hand, RIDDOR reporters felt that the changes would not have an influence on RIDDOR
reporting because the process had remained the same and only the reporting thresholds had
changed. On the other hand, non-reporters felt that the change in RIDDOR reporting
Box 6. Example interview extracts illustrating ambivalent/neutral reactions to the
extended reporting period
“I thought ten days was long enough, I don’t see any good reason to extend that and I don’t
know what the reasons are behind it to be honest with you.” (Interview 2, non-reporter,
construction)
“Why you would need three weeks to report a RIDDOR accident? Because by then you know
what’s gone on in terms of the individual as to whether they need to have it reported. I can’t
imagine any instance where you wouldn’t know.” (Interview 3, non-reporter, manufacturing)
“I don’t think fifteen days are necessary, I think if a business can’t get its act in gear in ten
days then there’s a problem. […] I thought that ten days was ample.” (Interview 35,
RIDDOR reporter, manufacturing)
“It’s not a significant advantage. We were compliant with the ten days.” (Interview 25,
RIDDOR reporter, public sector)
15
requirements would not influence their reporting behaviours, either because they have never had
a reportable incident or because their organisation experienced reportable incidents infrequently.
Commonly cited reasons among participants who believed that the changes would facilitate
reporting to the HSE included i) having more time to conduct internal investigations and collect
the required information (particularly medical information that may not be readily available in a
shorter time frame), ii) having more time to prepare and submit the RIDDOR report, and iii)
reporting would focus on more serious incidents so that fewer number of RIDDOR reports
would need to be submitted to the HSE.
Three participants noted that the changes would have a negative influence on employers’
reporting behaviours. Specifically, two non-reporters felt that the extended reporting period
would make it harder to prioritise the submission of the RIDDOR report, whilst one RIDDOR
reporter noted that the dual reporting threshold (i.e. internal recording of O3D injuries and the
reporting of O7D injuries to HSE) could potentially create confusion among employers making
it harder to comply with the requirements.
Finally, four participants could not comment on the potential influence of the changes on their
reporting behaviours. This was either because they have not had a reportable incident since the
changes came into effect and therefore they did not have a frame of comparison (in the case of
RIDDOR reporters) or because they have never had a reportable incident (in the case of non-
reporters).
3.3.1 Employers’ views regarding the time it takes to submit a RIDDOR report
RIDDOR reporters were also asked to indicate the extent to which they agreed or disagreed with
a number of assumptions regarding the time it takes to complete the following activities: i)
complete the accident book, ii) gather additional information and prepare to submit the online
RIDDOR form, iii) complete the online RIDDOR form, and iv) print and file the paperwork. All
RIDDOR reporters in the sample had health and safety responsibilities as part of their role and
the majority of them were responsible for submitting the RIDDOR reports. They typically
occupied managerial positions in their respective organisations (e.g. Health and Safety manager,
HR manager, Planning manager). In a minority of cases, RIDDOR reports were submitted by
administrative staff, but in these cases, the information would be collected and/or checked by a
manager. Table 4 presents a summary of participants’ responses.
Table 4. Summary of participants’ views on the time it takes to submit a RIDDOR report (based
on twenty interviews with RIDDOR reporters)
To what extent do you agree that it takes approximately:
10 minutes to complete
the accident book
10 minutes to gather
additional information
and prepare to submit the
RIDDOR form
15 minutes to complete
the online RIDDOR
form
2.5 minutes to print and
file the paperwork
Agree Disagree Not
sure
Agree Disagree Not
sure
Agree Disagree Not
sure
Agree Disagree Not
sure
13 4 3 6 11 3 13 3 4 13 4 3
It can be seen that the majority of RIDDOR reporters agreed with the estimations regarding the
time it takes to complete the accident book and the online RIDDOR form, as well as printing
and filing the paperwork (13/20 participants in all cases). However, just over half of the
RIDDOR reporters disagreed with the assumption that it takes ten minutes to gather additional
information and prepare to submit the RIDDOR form (11/20). It was suggested that this activity
16
could take considerably longer depending on the severity of the incident. Some participants
stated that gathering additional information could take between forty-five minutes up to one
hour, whilst others found it difficult to comment as the time required varied considerably
depending on the nature of the incident.
Finally, RIDDOR reporters were asked to indicate the extent to which they agreed or disagreed
as to whether the time required to prepare and submit the RIDDOR report amounted to thirty-
seven and a half minutes (i.e. total derived by adding the amount of time required to complete
each of the individual activities shown in Table 4). Seven RIDDOR reporters agreed with the
estimated time of thirty-seven and a half minutes, whilst eight participants disagreed. Of those
who disagreed, two stated that preparing and submitting the report would take less than the
estimated time (about half an hour) and six participants stated that it took considerably longer
(estimations ranged from forty minutes to half a day). The remaining five participants could not
provide an estimate for the time required to prepare and submit a RIDDOR report as this varied
depending on the type of incident.
3.4 PERCEIVED INFLUENCE OF CHANGES ON H&S MANAGEMENT
A recurrent theme that emerged was that the changes in the RIDDOR reporting requirements,
and RIDDOR more broadly, were not perceived to be a significant driver in the management of
health and safety. Although some participants noted that RIDDOR has a positive influence in so
far as it promotes a greater awareness among employers of the importance of health and safety,
for the overwhelming majority of participants RIDDOR was perceived as having a limited
influence on the management of health and safety. For instance, it was mentioned that
reportable incidents constitute only a small proportion of the incidents that organisations
experience, thus focusing solely on reportable incidents would limit an organisation’s ability to
learn and improve its management of health and safety. Related to this, it was also suggested
that focusing on reportable incidents alone does not provide an accurate reflection of an
organisation’s safety performance. Although participants mentioned specific changes that they
had implemented to accommodate the new reporting requirements (e.g. changes in the health
and safety policy and reporting systems), a number of factors were identified that had a more
prominent influence on the management of health and safety. These factors are depicted in
Figure 3 and are discussed below.
Internal factors External factors
Figure 3. Factors influencing health and safety management
Health and
safety
management
Commitment to duty
of care
Work-related injury
claims
Customer expectations
regarding health and
safety standards
Organisational
trends in
accidents and
near misses
Sector-specific drivers:
Legislation
Regulators
Industry-specific H&S indicators
17
Both internal (i.e. organisation-specific) and external drivers of health and safety were
identified. Internal drivers included:
Commitment to duty of care: Several participants mentioned that their duty of care
towards employees and their commitment to maintaining a safe working environment
influenced their approach to the management of health and safety. Consistent with this,
RIDDOR reporters and non-reporters often advocated a proactive approach to health and
safety (e.g. through site inspections and employee briefings on health and safety). In some
cases, health and safety guidelines were imposed by parent companies (such as, frequency
of inspections and health and safety audits). Some participants acknowledged that
accidents were costly for their organisation, whilst maintaining high standards of health
and safety ensured that work was carried out more efficiently.
Organisational trends in incidents and near misses: Few RIDDOR reporters mentioned
that previous incidents (irrespective of whether they were reportable or not) and near miss
patterns influence the management of health and safety by ensuring that appropriate
actions are taken to prevent similar incidents from recurring (e.g. through provision of
training for staff and risk assessment revisions).
External drivers of health and safety included:
Customer expectations/pressures: Customer expectations regarding maintaining high
standards of health and safety were identified as an important driver of health and safety
management, particularly among non-reporters in the manufacturing, construction and
retail sectors. For instance, employers in the construction sector identified Local
Authorities’ expectations of health and safety standards as a key influence in the
management of health and safety. Further, the effective management of health and safety
was seen as crucial for winning future contracts.
Claims culture: Keeping costs down due to claims arising from work-related injuries was
another driver of health and safety that was discussed by both RIDDOR reporters and non-
reporters. Investing in health and safety (both in terms of accident prevention and
investigation) was seen as crucial in reducing claim-related costs, as well as enabling
organisations to invest more resources in areas such as training and equipment.
Sector-specific drivers: A number of sector-specific drivers of health and safety were also
identified. Specific health and safety guidelines that need to be adhered to were identified
as a driver of health and safety among some non-reporters in the public sector (e.g. care
homes). Employers in this sector emphasised that maintaining high standards of health and
safety are crucial as they are not only accountable to the HSE, but also to other regulators
(such as the Care Quality Commission) as well as Local Health Authorities. Further,
specific changes to legislation (such as, work at height, use of PPE) were identified as a
key influence in health and safety management among RIDDOR reporters, particularly in
the manufacturing, construction and retail sectors. Finally, for RIDDOR reporters in the
manufacturing sector, lost-time injuries (LTIs) were one of the key drivers of health and
safety management, which were described as ‘stricter measures’ of health and safety
compared to RIDDOR.
Even though the aforementioned factors played a more prominent role in the management of
health and safety, some concerns, albeit marginal (i.e. not widely shared) were expressed that
improved RIDDOR statistics might encourage organisations to invest fewer resources in health
and safety. On the other hand, few RIDDOR reporters and non-reporters felt that the changes
18
could potentially help improve the management of health and safety by enabling employers to
focus more on risks that result in serious injury and conduct more thorough incident
investigations.
3.4.1 Recording of health and safety incidents
For the majority of participants the changes in RIDDOR reporting requirements had not and/or
would not influence the recording of health and safety incidents. With the exception of one
RIDDOR reporter, all participants mentioned that they recorded all incidents and/or injuries
(including O3D injuries) irrespective of whether the incident or injury had to be reported to
HSE (although there was variation across participants in terms of the extent to which minor
incidents, such as cuts, would always be recorded). The systematic recording of health and
safety incidents was perceived as crucial for the following reasons:
Incidents and injuries (including O3D injuries) contribute to an organisation’s accident
statistics and/or key performance indicators and therefore it is important that they are
accurately recorded;
Incidents and injuries are viewed as opportunities to learn and identify areas that require
action (such as improving working practices) to prevent the incident or injury from
recurring;
Keeping a record of all injuries was perceived as important in the event where a minor
injury might develop into a more serious condition that would require the employee to take
time off work in the future;
The systematic recording of incidents and injuries was necessary for insurance purposes
and ensuring that the organisation is ‘covered’ against, and can respond to, potential claims
as a result of a work-related injury.
It is important to note, however, that the vast majority of participants in this sample did not
appear to be aware that they are still legally required to keep a record of O3D injuries.
Specifically, although thirty-nine of the forty participants stated that they would continue to
record O3D incidents, only three (all RIDDOR reporters) explicitly mentioned that they would
do so because it is a legal requirement. On the other hand, one participant (RIDDOR reporter)
mentioned that the organisation would not record O3D incidents because it was not a legal
requirement.
3.4.2 Approach to incident investigations
As was the case with health and safety incident recording, the changes to RIDDOR did not
appear to be a key driver in participating organisations’ approach to incident investigation.
Participants reiterated the need to instigate the investigation as soon as possible in order to
establish the circumstances of the incident and identify the required actions that need to be taken
to ensure that the incident does not recur. The severity or potential severity of the incident (or
near miss), as well as the extent to which it could affect other workers, rather than whether the
incident was reportable or not, were identified as criteria for determining whether an
investigation was required. For instance, one participant provided an example of a near miss
where a forklift truck almost hit a pedestrian. The near miss was investigated immediately
because the organisation recognised that it could have resulted in a serious injury.
Additionally, for RIDDOR reporters in particular, incident investigations were used to gather
the required information so that the organisation was adequately ‘prepared’ in the event of a
19
claim. Thus, for the majority of participants the aforementioned issues shaped their approach to
incident investigations rather than the degree to which an incident was reportable or the actual
length of work-related absence (i.e. three and/or seven days). It is important to highlight,
however, that one RIDDOR reporter commented that the organisation would no longer
investigate and/or examine as thoroughly O3D incidents and would predominantly focus on
investigating O7D incidents.
3.5 DIFFERENCES IN EMPLOYERS’ REACTIONS AND BEHAVIOURS
The findings suggest that there were differences in the levels of awareness regarding the change
in the reporting requirements between the two groups. Specifically, RIDDOR reporters were
more likely to be aware/knowledgeable of both the increase in the reporting threshold and the
extended reporting period compared to non-reporters.
With regards to potential differences in participants’ reactions toward the changes, non-reporters
were more likely to hold neutral views regarding any perceived benefits (or lack thereof) of the
changes to the reporting requirements. This is not surprising as non-reporters were more likely
to state that the changes to the RIDDOR reporting requirements would not affect them, either
because they never had a reportable incident or because they experienced reportable incidents
very infrequently. In some cases, non-reporters found it difficult to comment on the changes. On
the other hand, RIDDOR reporters appeared to hold stronger views (either positive or negative)
regarding the changes, possibly because the changes are more likely to affect them as they make
a higher number of RIDDOR reports.
A commonality among both RIDDOR reporters and non-reporters was that the changes in the
reporting requirements, and RIDDOR more broadly, were not perceived as a key driver for the
management of health and safety. A number of other internal and external drivers were
identified, including pressures from customers, employers’ duty of care and commitment to
providing a safe working environment, as well as guarding against potential claims as a result of
work-related injuries. Additionally, the majority of both RIDDOR reporters and non-reporters
suggested that the changes would neither influence how they recorded health and safety
incidents nor alter their approach to incident investigation. For instance, recording and
investigating incidents (including O3D injuries) was perceived as necessary for both defending
potential claims and ensuring that similar incidents do not recur. Further, for RIDDOR
reporters, recording O3D incidents enabled them to benchmark their organisation by comparing
their performance with the data from the previous year. However, with the exception of three
RIDDOR reporters, none of the participants appeared to be aware that they are legally required
to keep an internal record of O3D injuries.
3.6 RESEARCH CAVEATS
The present study has a number of caveats that should be considered when interpreting the
findings:
The study explored employers’ views regarding the changes in RIDDOR reporting
requirements and their potential perceived influence on the management of health and
safety. Strictly speaking, it cannot be considered as an impact evaluation of the changes
in RIDDOR reporting requirements. An impact evaluation would have required a
quantitative approach with assessments carried out before (i.e. before April 6th 2012)
and after the RIDDOR changes were introduced.
The qualitative findings provide an insight into a range of employers’ views towards the
changes in RIDDOR reporting and their perceptions of their potential influence on
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health and safety management. Whilst the findings provide sufficient and balanced
information to explain how the changes are perceived, the findings cannot be
generalised to the wider population of UK businesses in the sectors studied due to the
nature of the sample and chosen method of investigation.
Non-reporters in this study were defined as employers that have not submitted a
RIDDOR report to HSE within the last two years. However, it was not possible to
identify organisations that did not submit a RIDDOR report to HSE, but should have
legally done so.
3.7 CONCLUSION
The findings from this study suggest that for the majority of participants in this sample, there
were several benefits associated with the changes to the reporting requirements, including
focusing reporting on more serious incidents, better management of work-related absence and
allowing employers more time to conduct incident investigations. These benefits
notwithstanding, some concerns were expressed that employers may forget to report and/or
view reporting as less of a priority as a result of the extended reporting period. The findings also
suggest that the vast majority of participants did not appear to be aware that keeping an internal
record of O3D injuries is a legal requirement. Finally, the changes to the RIDDOR reporting
requirements and RIDDOR more broadly, are not perceived as having a prominent influence on
the management of health and safety. This is because drivers other than RIDDOR were
identified as important for the management of health and safety, which included customer
pressures to maintain health and safety standards, and costs associated with work-related injury
claims.
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4. REFERENCES
Braun, V. and Clarke, V. (2006). Using thematic analysis. Qualitative Research in Psychology,
3, 77-101.
Denzin, N. K. and Lincoln, Y. S. (1994). Introduction: Entering the field of qualitative research.
In N. K. Denzin and Y. S. Lincoln (Eds.), Handbook of Qualitative Research, (2nd
ed., pp. 1-17)
Thousand Oaks, CA: Sage.
Löfstedt, R. E (2011). Reclaiming health and safety for all: An independent review of health
and safety legislation. Accessed from http://www.dwp.gov.uk/docs/lofstedt-report.pdf on
18/02/2013.
Ritchie, J. and Lewis, J. (2003). Qualitative research practice: A guide for social science
students and researchers. London: Sage.
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5. APPENDICES
5.1 APPENDIX A: RECRUITMENT OF SAMPLE
The recruitment of both groups of participants (RIDDOR reporters and non-reporters) was
outsourced to an external recruitment company. The recruitment company was provided with:
A list of 300 companies (including submitter’s name and telephone number) from the
RIDDOR database to recruit a sample of 20 participants to be interviewed for Group 1
(RIDDOR reporters). This allowed for a 1 in 15 hit rate, with the typical hit rate being
1 in 10, in order to account for any potential difficulties in recruitment.
The sample breakdown for each group specifying the number of interviews required for
each selected sector. A public database of UK businesses was used to recruit 20
companies for Group 2 (non-reporters).
A recruitment brief, which was used to inform potential participants on the purpose of
the research and what taking part would involve. Screening questions were included to
ensure that a representation of small and medium-sized organizations were included,
and in the recruitment of companies belonging to Group 2 (non-reporters) to ensure that
they had not submitted a RIDDOR report in the last 2 years.
5.2 APPENDIX B: RESEARCH TOOLS
A number of questions were developed in order to address the research objectives. The broad
topics covered during the interviews included:
Awareness of changes in RIDDOR reporting requirements and understanding of what the
changes entailed,
Perceived benefits (or lack thereof) associated with the increased reporting threshold and
the extended reporting period,
Perceived influence of the changes on the management of health and safety,
Systems in place for recording health and safety incidents, and
Investigation of health and safety incidents.
In addition, participants who had submitted a RIDDOR report within the last two years were
asked a number of questions on the following:
Time taken to submit a RIDDOR report,
Who RIDDOR reports are submitted by, and
Time taken to complete an accident book if any injury occurs but no RIDDOR report is
required.
Published by the Health and Safety Executive 11/13
Research to explore the effect of post ‘Common Sense, Common Safety’ amendment to RIDDOR Regulation 3(2) on Health and Safety Standards in Great Britain
Health and Safety Executive
RR984
www.hse.gov.uk
This report examines employers’ perceptions of the change in RIDDOR reporting requirements, and explores its perceived influence on employers’ behaviours and the management of health and safety. Forty telephone interviews were conducted with employers across the manufacturing, construction, public services and retail sectors. Perceived benefits associated with the changes to the reporting requirements included focusing reporting on more serious injuries, better management of work-related sickness absence, and allowing employers more time to conduct incident investigations and submit the RIDDOR report. Some concerns were expressed that employers may either forget to report or view the submission of the RIDDOR report as less of a priority as a result of the extended reporting period. Issues associated with the increased reporting threshold included employers failing to act on over-three-day incidents; however, these concerns were not widely shared among the sample.
The changes in the RIDDOR reporting requirements were not perceived as having a prominent influence in the management of health and safety. A number of internal (eg duty of care, organisation-specific trends in incidents and near misses) and external (eg customer pressures, costs associated with potential claims) drivers, other than RIDDOR, were identified as important for the management of health and safety.
This report and the work it describes were funded by the Health and Safety Executive (HSE). Its contents, including any opinions and/or conclusions expressed, are those of the authors alone and do not necessarily reflect HSE policy.
