The Health and Safety Executive (HSE) are running a consultation on proposed reforms to the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) 2013, and the Civil Engineering Contractors Association (CECA) have shared their thoughts
Responding to the consultation on updated RIDDOR regulations, the CECA have said that the regulations need to be clear, proportionate, and practical for civil engineering contractors.
This would include sector-specific guidance and understanding of the operational realities of complex infrastructure delivery.
The CECA are supporting reforms
The response supports the proposals in terms of clarifying definitions, improving occupational health reporting, broadening who can diagnose occupational diseases, and reviewing dangerous occurrences.
Where the reforms need to support civil engineers is in maintaining proportionate thresholds and accommodating the cost and complexity associated with reportable incidents in the sector.
Ensuring that rules are clear will reduce instances of under-reporting and over-reporting, improving national data quality and allowing for more targeted prevention activity.
Therefore, the CECA is calling for an updated RIDDOR to be published in plain English, including practical construction-based examples with scenarios related to highways, utilities, railway, and other infrastructure settings.
Some parts should be reconsidered or clarified
The CECA has asked the HSE to clarify how reporting duties for occupational disease will apply when a current employer identifies a disease, but the relevant exposure may have occurred with a previous employer.
Furthermore, clarity must be brought to the competence requirements for healthcare professionals registered with the General Medical Council in diagnosing reportable occupational diseases, and that the proposed wording for the expansion of reporting dangerous occurrences must be made much clearer. For example, the phrase “could cause the death of a person” is quite subjective, and clarity should be brought on how effective direct controls should be in influencing whether an incident is reportable.
CECA director of policy & public affairs, Ben Goodwin, said: “CECA strongly supports efforts to improve the clarity and effectiveness of RIDDOR. Clearer reporting rules have the potential to improve data quality, support prevention, and help duty holders understand when a report is required.
“However, any changes must be applicable to real-world infrastructure delivery. Civil engineering projects are often complex environments involving multiple duty holders, supply chain partners and changing site conditions. We are particularly keen to see clear, plain English guidance, with practical examples that reflect on the ground scenarios.
“HSE must also recognise that the cost of a RIDDOR-triggering event is not simply the time taken to complete a form. For contractors, reportable incidents can involve investigation, legal, insurance, commercial and client-related consequences. With the right guidance, proportionate thresholds and sufficient transition time, these reforms can support better reporting and stronger prevention. CECA is committed to ensuring the final approach is effective, workable and aligned with the realities in which our members work.”
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