For many organisations, Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) compliance is viewed as an administrative requirement. An incident occurs, a decision is made on whether it is reportable, and, where necessary, a report is submitted to the Health and Safety Executive (HSE).
However, the recent HSE consultation on proposed changes to RIDDOR suggests a broader shift in thinking. Rather than simply refining the reporting process, the proposals indicate a desire to improve the quality of information available about workplace injuries, dangerous occurrences and, importantly, occupational ill health.
Although the consultation has now closed and no legislative changes have yet been confirmed, the proposals provide a useful indication of the direction in which workplace reporting may be heading. For EHS managers, that makes this an ideal time to review existing arrangements rather than waiting for new regulations to be introduced.
Why Review RIDDOR?
The current version of RIDDOR has been in force since 2013. During that time, the nature of work has changed considerably. New technologies, changing industries, greater awareness of occupational health and evolving patterns of work have highlighted areas where the current reporting framework may no longer provide the most useful information.
HSE has recognised that effective regulation relies on accurate intelligence. Reliable reporting enables emerging trends to be identified, enforcement priorities to be targeted and future guidance to be based on evidence.
The consultation therefore focused not only on simplifying reporting but also on improving the relevance and quality of the data collected.
What Has Been Proposed?
The consultation sought views on several significant changes.
These included expanding the list of reportable occupational diseases to include conditions such as silicosis, asbestosis, occupational asthma, noise-induced hearing loss and other illnesses associated with exposure to hazardous substances, dusts and repetitive work.
Another proposal would allow diagnoses made by appropriately registered healthcare professionals—not solely doctors—to trigger reporting requirements where appropriate.
HSE also consulted on revising the list of dangerous occurrences to better reflect modern workplace risks, alongside simplifying and streamlining the online reporting process.
Although these remain proposals at this stage, they illustrate an increasing focus on occupational health rather than simply workplace accidents.
A Shift Towards Occupational Ill Health
One of the most notable aspects of the consultation is its emphasis on occupational disease.
Historically, workplace accidents have often received greater attention because they are immediate, visible and frequently require urgent investigation.
Occupational ill health is different.
Many conditions develop gradually over months or years. Noise-induced hearing loss, occupational asthma and diseases resulting from exposure to hazardous substances may not become apparent until long after the original exposure occurred.
These illnesses can have profound consequences for individuals and organisations alike, yet they are often more difficult to identify and investigate.
The consultation reflects an acknowledgement that improving occupational health reporting could provide a more complete picture of work-related harm across the UK.
What Should Employers Be Doing Now?
Although there is currently no change to employers’ legal duties under RIDDOR, organisations should not regard this as a reason to delay reviewing their own arrangements.
Well-managed organisations routinely assess whether their reporting systems remain effective, regardless of legislative change.
This includes considering whether managers understand reporting requirements, whether occupational health information is communicated effectively and whether incident investigations capture the information needed to identify underlying trends.
Accurate reporting should support learning and continual improvement, rather than simply satisfying a legal requirement.
Five Questions Every EHS Manager Should Ask
As organisations await HSE’s response to the consultation, there are several practical questions worth considering.
1. Are we identifying work-related ill health as effectively as workplace injuries?
Many organisations have mature accident reporting systems but less developed processes for recognising occupational disease.
2. Would we recognise a reportable occupational disease if it occurred?
Early recognition often depends upon effective health surveillance, occupational health support and competent management.
3. Do managers understand when a RIDDOR report may be required?
Consistency in decision-making is essential, particularly where occupational illness develops gradually.
4. Is our incident data helping us identify trends?
Reporting should generate meaningful management information rather than simply fulfil a legal obligation.
5. Are our reporting arrangements ready for future change?
Even if the final regulations differ from the consultation proposals, organisations with robust reporting systems are likely to be well placed to adapt.
Looking Ahead
The consultation has now closed, and HSE will consider the responses before deciding whether to amend the Regulations.
Whatever the final outcome, the proposals demonstrate a growing recognition that occupational health deserves the same level of attention as workplace safety.
For EHS professionals, the message is clear. RIDDOR should not be viewed solely as a compliance exercise. High-quality reporting provides valuable intelligence that supports risk management, helps identify emerging issues and contributes to preventing future harm.
By reviewing reporting arrangements now, organisations will not only be better prepared for any future regulatory changes but will also strengthen their ability to protect the health, safety and wellbeing of their workforce.
If you would like help determining your health, safety or environmental compliance status, call us on 07764302858 or email Jamie@ehsmanagement.co.uk.
