CWU Respond To HSE Consultation On Proposed Amendment To RIDDOR
As originally reported in December by Unionsafety, the publication of consultation documents on proposed changes to the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) was agreed by the HSE at its board meeting December 15th 2010.
The CWU Health, Safety and Environment Department has submitted a detailed response on behalf of the Union to the Coalition Government's prompted, HSE consultation on proposed amendments to the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR).
Letter to branches, LTB432/11 contains the full detail of the Union's response:
"The CWU Health, Safety and Environment Department are extremely concerned that the Young report recommends a weakening of the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR). Research shows that only 32% of the reportable injuries suffered by workers and 12% by the self-employed are not properly recorded with the HSE under RIDDOR and the legislation isn't effectively enforced which is why so many employers ignore it. When injuries are not properly recorded it makes it difficult to accurately assess the risks workers face and difficult for enforcers to protect
them.
Changing the accident reporting criteria from 3 days to 7 days will only serve to take a huge number of injuries out of the official statistics and erode standards further. Rather than recommending weakening the regulations, Lord Young should have examined how the existing rules can be strengthened and adequately enforced. RIDDOR is one of the most important sources of information for the enforcing authorities."
The CWU is strongly opposed to the change proposed by Lord Young in his report "Common Sense, Common Safety" which is reflected in the consultation proposals (CD233). The Union sees no justifiable good reason to change the period of incapacitation after which an injury to a person at work must be reported to the enforcing authority from over three to over seven days.
Further, the Unions has told the HSE that there is an urgent need for the HSE to address the issues as identified by the HSE in the earlier 2005 RIDDOR Consultation in respect of the enforcement of the Regulations."
The letter to branches then gives details of the CWU response:
In our response we have set out to the HSE, DWP and Government that the CWU supports the view that the main objectives of RIDDOR should be:
- To ensure that there is sufficient knowledge of the scale of injuries, diseases and dangerous occurrences to allow informed decisions to be made on priorities for prevention by the Government, employers and regulators,
- To identify new and emerging hazards,
- To ensure that enforcing agencies have information on which to determine their interventions, by both individual employer and sector,
- To ensure that employers keep information necessary to investigate and prevent injuries, and identify and prevent possible industrial diseases,
- To allow Safety Representatives access to meaningful data on injuries, diseases and dangerous occurrences in the workplace,
- To ensure that Safety Representatives are notified of accidents immediately so that they can carry out a meaningful accident investigation as provided for under the SRSC Regulations 1977,
- To revise the RIDDOR form so that it asks employers to identify the Safety Representative and indicate that the Representative has been informed,
- To harmonise with both European and ILO reporting systems, implementing the terms of ILO Convention 155, and the protocol of 2002 on accident reporting and notification,
- Develop a system for sharing information and safety lessons from a range of accidents and incidents,
- Make work-related road traffic incidents reportable under RIDDOR. (Employers are already required to report RTAs under road traffic legislation for Insurance purposes so why not to HSE under RIDDOR).
Dave Joyce, the Unions National Health, Safety & Environment Officer appeals to Safety Reps and Branches to be involved in the consultation exercvise and asks CWU Safety Reps, Branches and Safety Forums to please ensure that replies are made and sent in response to the Consultation Document to the Health and Safety Executive before 9 May 2011
Download the full CWU response form th E-Library Database here using the search word 'RIDDOR'.
Responses can be sent via e-mail: riddor2011@hse.gsi.gov.uk
By post to Ron Griffiths, HM Inspector of Health and Safety, Operational Strategy Enforcement and Accountability Unit, 1.3.58 Redgrave Court, Merton Road, BOOTLE, Merseyside, L20 7HS.
Your response does not have to be as detailed as the National Union response but needs to express the fact that to reject the proposed change from over 3 day reporting to over 7 day reporting and emphasise some
of the bullet points above.
See also: Consultation Opens On RIDDOR Changes
Source: CWU
