RIDDOR Consultation
This is a friendly reminder that there are only 25 days left to participate in the HSE's Consultation on revising RIDDOR. Your input is valuable, and you can share your thoughts here:
Consultation on proposals for The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013
A few of my responses:
Do you think the period of around 10 minutes to gather the relevant material to complete a RIDDOR form is about right?
Much too low. The requirement for the victims home address and telephone number (which I support; it is right that enforcement officers can interview away from the workplace if necessary) means that there is usually more than one person responsible for completing a RIDDOR in medium to large sized organisation.
I am concerned that this might reduce the incentive for the HSE and other enforcement agencies to follow up with the victim. If this declines then public trust declines too. Victims want to know their accident is being investigated.
Also making the admin process seem quick/convenient in order not to appear onerous and discourage reporting runs counter to the real need we have to investigate to root cause level. The latter is a more important priority for overall safety improvement than the need for the HSE to have some stats.
HSE does not propose including work-related stress and suicide, for the reasons given in the HSE proposal section. Aside from those, are there any other occupational diseases which should be included in RIDDOR?
I would suggest that the RIDDOR Occupational Disease list should tally with the ILO list set back in 2010. Asbestosis and Silicosis must and should be added. I would add
Noise induced hearing loss
Illness following radiation exposure
Lower body and low back musculoskeletal disorders (MSDs)
Carpal Tunnel Syndrome from ANY cause.
Dangerous occurrences are certain incidents with a high potential to cause death or serious injury. Are there any other dangerous occurrences which are not included, or not already proposed, that should be?
Yes.
Near misses for accidental releases in the chemical industry (these are reportable in US Environmental Protection Agency Risk Management Plan and
OSHA’s Process Safety Management process)
Passenger lift structural failures or free-falls (as per reporting in Canada).
Hydraulic lift pressure failures that lead to uncontrolled descent
Unoplanned evacuation of a premises
Interruption of a main ventilation system in any underground excavation or civil engineering tunnel project as the do in Australia
Structural failure or collapse of any wall, floor, or moving structural element not just a whole building or a scaffolding
Mechanical failure of grinding discs ( abrasive wheels used to be reportable I think; have they stopped occurring?)
Deformations or thinning in boiler walls (Japan also requires reporting irregularities in pressure gauges
Are you aware of any impact on the environment these proposals may have?
Yes. There are environmental consequences of dangerous occurrences that are currently not reported under RIDDOR. There is a general decline in accountability for environmental harm in the UK; the EA has been undermined, defanged, reduced and discredited. The environmental condition of water and land has declined (air has improved somewhat). Reforming RIDDOR whilst not addressing these wider environmental impacts (which also impact human and public health) seems to me like this government is deckchair shifting.
Do you have any further comments you would like to make about the regulation of RIDDOR?
Yes. I would make a plea for all accidents entailing physical injury to a person to be investigated by the employer by law. Many people who learn about H&S are astonished that investigation isn't a legal requirement. There should be a legal obligation for all employers to investigate every accident at work in which harm to any individual arises. there should be mandatory training for at least one person in investigation for all organisations employing 20 or more workers.