A 12-week consultation has begun on changes to the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR). If these proposals go through, they could increase the burden on companies, so the focus should be on improving internal health and safety management.

The consultation on wider amendments to RIDDOR, which kicked off on 2nd August, follows injury reporting changes which took effect in April. The proposed changes will remove the duty to report in cases where the information is of little use or better collected through other means.

The idea behind the changes in April, to increase the RIDDOR trigger for reporting injuries from absences of three consecutive days to absences of seven days, was to reduce administrative burdens on businesses, particularly smaller firms.

However, it has been suggested that if reports have to be made less often, this would actually have the opposite effect of increasing the burden on companies and their health and safety management systems.

The Royal Society for the Prevention of Accidents (RoSPA) calculated that, based on the RIDDOR over-three-day absence rate for the manufacturing sector in 2008/09, a firm employing 25 people might 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, RoSPA 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.

Roger Bibbings, RoSPA’s occupational safety adviser, notes: “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 per cent, will decline further.”

Even with an over-three-day reporting period, the infrequency of the reports means that health and safety management teams will find it hard to build a reliable picture for their businesses and organisations using this data alone.

As there is already massive underreporting of incidents, this is hardly likely to encourage better reporting practices, which will dilute statistics and make them much less valuable. There is evidence, therefore, to show that the changes already made to RIDDOR decreased the significance of information and increased workloads.

The government’s proposals to change this piece of legislation again will only compound this issue. It will also make it more difficult for UK companies to keep up to date.

Instead, as RoSPA suggests, the focus should be on helping organisations to improve health and safety management and therefore avoid the heavy costs relating to accidents and incidents. There should be a greater focus on internal procedures for employers to record and investigate injuries, ill health and near misses so that lessons may be learned and similar occurrences avoided in the future.

Your organisation should be encouraging top managers to actively engage in risk reduction and encouraging employees to work with health and safety management teams to reduce risks. An effective health and safety management system along with compliance software can make this process simple.

This is far more effective than further reforms to a law requiring you to report an incident that may only kick in once every 30 years.