The HSE just released a consultation document on proposed amendments to RIDDOR 2013, and there are some technical changes that we, as practitioners, really need to dig into.
Key Highlights:
- Cutting down on perceived ambiguity: Legislative and guidance-based updates to define ambiguous terms. For example, aligning the definition of an “enclosed space” with the Confined Spaces Regulations 1997 to stop people reporting accidents in “small offices” as “enclosed space” incidents
- Adding new (or replacing previously removed) occupational diseases and dangerous occurrences: Reintroducing 9 diseases (like asbestosis and silicosis) and adding 4 new ones (like noise-induced hearing loss and “popcorn lung”) to the reportable list. Updating Schedule 2 to include modern risks such as: tunnelling activities; dropped objects (even if they didn’t hit anyone); Net Zero technologies (geothermal wells, wind farms)
- Proposal 3 (Diagnosis): This is a big one. They want to broaden “diagnosis” (Regulation 2) beyond GMC-registered doctors to include registered nurses and physiotherapists. They’re using the 2022 “Fit Note” changes as a proxy for how this might work. Does your organisation already accept internal OH nurse diagnoses for record-keeping
- Proposal 4 (Dangerous Occurrences): New categories in Schedule 2 include dropped objects (unintentional falls from construction/demolition structures) and uncoiling/projection of material (like concrete pump hose whips). They are also expanding “wells” to include geothermal.
- The “Over-Reporting” Problem: HSE data shows ~7,700 reports a year (8.2%) aren’t actually reportable. They’re proposing a re-order of the online form to move “injury severity” questions to the start to triage users out earlier.
- Automation: They are exploring re-enabling automated reporting from internal H&S software, which was decommissioned in 2022.
- The CBA Catch: The Cost-Benefit Analysis assumes businesses will spend about 1 hour on familiarization, costing roughly £31 per business. For those of us in larger or high-risk firms, does that seem realistic? The HSE admits they need to prevent between 250 and 2,000 “Over 7-Day” ill-health cases over 10 years just to break even on the societal costs of these changes.
What are your thoughts on the consultation? Will allowing non-doctors to diagnose lead to a spike in reports, or just more accurate ones?