Calling All Union Safety Reps And Trade Unions To Respond To HSE Consultation On RIDDOR
RIDDOR (The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013) has long been in need of changes, especially when you consider that the HSE bases all of its claims that the UK is one of the safest places to work!
The reality is that their stats used to make this claim is based solely on Employers' reporting of incidents using RIDDOR.
If an accident, injry, or even death is not reported by the employer, it may well not be recorded in the statistics. Further, RIDDOR is only compulsory when work absences occur as a result of an accident, injury, or work-related illness.
Anouncing this consultation on 1st April, the HSE website says:
" The Health and Safety Executive (HSE) undertakes a wide range of regulatory functions fundamental to enabling a safe and healthy workplace. We are dedicated to protecting people and places and helping everyone lead safer and healthier lives. Our role goes beyond worker protection to include public assurance. We work to ensure people feel safe where they live, where they work and, in their environment."
The statement goes on to claim:
Great Britain (GB) has one of the best workplace health and safety performances in the world and achieves some of the lowest rates of occupational injury and fatality in Europe.
The reality of course is that the current use of RIDDOR to back up that claim, is dependent on the fact that it one: relies purely on the employer to report incidents, and two: there is no legal action against employers not reporting incidents and, third: the criteria for reporting is limited to 'at place of work' and ensures most deaths, injuries, and illnesses because of work; is not reported.
It is the view of Trade Unions and USRs, that Changes to this to show the true picture, will be vigorouasly denied to be put in place.
Interestingly, there is no mention of Trade Unions or Safety Reps in the paragraph listing those who it is relevent to respond to the consultation, although it may be seen as inferred:
"This consultation is relevant to all sectors and industries – in particular duty holders, self-employed people and those in control of work premises. It is also relevant to associated professions, including health care practitioners. Certain proposals, however, may apply more specifically to particular roles than to others."
The HSE concultation page, provides for a detailed description of the regulations, and the consultation document which can be downloaded as a Word docuemnt, filled in and posted back to them; as well as being filled in on-line:
It is imperative that those responding to the consultation, read carefully the definitions, which in themselves determine the effeciveness of RIDDOR, because it does not include accidents/injuries/death whilst travelling as part of work, in any of its forms, which has often been highlghted by Hazards,
While the TUC's formal 2026 response is expected during the consultation window (1st April to 30th June), they have historically criticised such consultations for focusing too heavily on the views of employers over the workers who are at risk:
Summary of TUC Recommended Reforms
| Recommendation | Reason |
|---|---|
| Include work-related suicides | To force investigations into workplace stress and mental health. |
| Enable Union reporting | To counter employer bias and the "widespread under-reporting" of incidents. |
| Add ethnicity data | To help identify and tackle racial health inequalities in the workplace. |
| Increase inspections | To ensure RIDDOR reports actually trigger enforcement action. |
To take part in the consultation via the HSE website, and on-line: click here
To download a Word version of the consultation document, for printing and posting or sendng via email; click on the document image top right.
Source: HSE / Hazards / TUC

