Select Committee on Work and Pensions Written Evidence


Additional memorandum submitted by DWP

What is HSE's estimate of the level of under-reporting of accidents under RIDDOR and what is the confidence level of this estimate? Is the degree of under-reporting similar across all categories of RIDDOR cases?

  1.  HSE estimates the reporting level for injuries by comparing injury rates calculated from injuries reported under the Reporting of Injuries, Diseases & Dangerous Occurrences Regulations 1995 (RIDDOR) with rates based on self-reported injuries from the Labour Force Survey (LFS). Successive three-year periods are averaged to reduce the statistical uncertainties in the LFS injury measure

  2.  Table 1 summarises reporting levels for RIDDOR reportable injuries to employees in the last decade.

Table 1

OVERALL RIDDOR REPORTING LEVELS FOR REPORTABLE INJURIES TO EMPLOYEES 1998-99 TO 2006-07 BASED ON 3-YEAR AVERAGED LFS RATES OF REPORTABLE NON-FATAL INJURY, SHOWING CENTRAL ESTIMATE AND UPPER AND LOWER 95% CONFIDENCE LIMITS

1998-99 to 2000-01 2001-02 to 2003-042004-05 to 2006-07 (p)
Central45% 43%52%
Lower43%41% 49%
Upper47%45% 54%




  The rates of reportable injury, calculated from both the LFS and from RIDDOR reports, have fallen but in the last few years, the LFS rate has fallen more steeply than the RIDDOR rate, implying that the proportion of (reportable) injuries reported has improved.

  3.  Reporting levels for the self employed are consistently very low, running at about a tenth of the levels for employees.

  4.  Reporting levels vary considerably between sectors, and the pattern for the most recent three year period is shown in Table 2. The lowest reporting level is recorded in the consumer and personal services sector, and the highest in transport and communication where the RIDDOR-based rate is actually higher than that from the LFS (probably influenced by assiduous reporting by the Royal Mail).

Table 2

RIDDOR REPORTING LEVELS FOR REPORTABLE INJURIES TO EMPLOYEES 2004-05 to 2006-07 BY SECTOR BASED ON 3-YEAR AVERAGED LFS RATES OF REPORTABLE NON-FATAL INJURY, SHOWING CENTRAL ESTIMATE AND UPPER AND LOWER 95% CONFIDENCE LIMITS
Agriculture, hunting, forestry & fishing Central31%
Lower24%
Upper46%
Extractive & utility supplyCentral *
Lower*
Upper*
ManufacturingCentral 76%
Lower68%
Upper87%
ConstructionCentral 59%
Lower52%
Upper70%
Distribution & RepairCentral 42%
Lower37%
Upper49%
Hotel & CateringCentral 29%
Lower23%
Upper39%
Transport & CommunicationCentral 108%
Lower93%
Upper129%
Finance & businessCentral 60%
Lower49%
Upper78%
Public sector servicesCentral 67%
Lower60%
Upper74%
Consumer/PersonalCentral 24%
Lower20%
Upper30%
All sectorsCentral 52%
Lower49%
Upper54%

* numbers too low for reliable LFS estimate


  5.  Calculating reporting levels for different categories of accident, eg by type of injury such as slips and trips, falls from a height etc, is more challenging. We are able to compare the incidence profiles (ie the breakdown of all injuries by percentage of each type) produced by analysis of RIDDOR reports and LFS self-reports—see Table 3. These profiles vary, for example slips and trips form a higher proportion (25%) of RIDDOR injuries than of LFS injuries (20%), implying that they are relatively better reported, while the opposite is true for falls from a height (5% and 8% respectively). These differences will not be independent from the differences between sectors, ie the different accident and injury profiles. The apparent variation in reporting levels will be at least partly attributable to this.

Table 3

ESTIMATED LFS INCIDENCE AND RATES OF REPORTABLE NON-FATAL INJURIES TO WORKERS AND RIDDOR REPORTED INJURIES AND RATE TO EMPLOYEES, BY ACCIDENT KIND, 2004-05

LABOUR FORCE SURVEY (LFS) RIDDOR 2 INCIDENCE PROFILES
Accident kindSample cases1 Estimated incidence (thousands) Rate per 100,000 workers Reported injuries
95% C.I. 95% C.I. 95% C.I.

Injuries

central lowerupper centrallower upperThousands Rate per 100,000  employees LFS Central estimate) RIDDOR (Reported injuries)
Hit by moving, flying or falling object 482619 349768 1251870 8%12%
Injured handling, lifting or carrying177 9682111 351298403 5521429% 36%
Slipped, tripped or fell on same level 1306755 79244201 28738149 20%25%
Fell from a height49 271934 9870125 8328% 5%
Physically assaulted by a person26 14819 503170 6244% 4%
Other kinds of accident175 9681110 349296401 259829% 17%
Missing3.. ...... ........ ....
Total608328 3013541,195 1,0991,291151 587100%100%

Source: LFS, RIDDOR

Notes:

1.  For people with a RIDDOR reportable non-fatal injury.

2.  RIDDOR figures are currently provisional; the final figures may vary between 1-3% of this figure.

..  Not applicable

How many inspectors does the HSE have in each of its operational directorates? How have these numbers changed over the past six years?

  6.  The table below shows the total number of inspectors, including managers, in HSE's operational directorates. Inspectors in some directorates carry out work with stakeholders that does not include site inspection, investigation and enforcement or the assessment of safety cases, eg those in the Local Authority Unit, Sector teams (now part of Policy Group) and Operational Policy & Support Division. They have traditionally been categorised as "operational" because they face directly to employers, employees and their representatives rather than to Ministers or internally. Directorates which do carry out inspection, investigation etc are the Field Operations Directorate, Hazardous Installations Directorate and Nuclear Directorate. Some inspectors in the Science and Technology Group also carry out these functions.

  7.  As can be seen, the numbers fluctuate somewhat over the years in question and the trend is downwards. It should be noted that 99 inspectors moved from HSE to ORR on 1 April 2006.

Table 4

TOTAL INSPECTORS IN OPERATIONAL DIRECTORATES—APRIL 2002 to DECEMBER 20071

DIRECTORATE/DIVISIONApr 20022 Apr 2003Apr 2004 Apr 2005Apr 20063/4 Apr 2007Dec 2007
Field Operations Directorate 916844818 752747680
Hazardous Installations Directorate 374388363 366369363
Local Authority Unit 41
Nuclear Directorate185 181173167 178169
Operational Policy & Support Div 151215 1176
Policy Group 3837115 10587
Rail Directorate107 1201032
Science & Technology Group5 51
Grand Total61,597 1,5831,509 1,4131,4101,357

Notes:

1.  Total inspector numbers include Operational Inspectors.

2.  Breakdown not available, total inspectors in HSE at 1 April 2002 1,625.

3.  Figures as at 1 April 2006 exclude inspectors who transferred to the Office of Rail Regulation (ORR) on that date—when responsibility for rail regulation health & safety matters transferred from HSE to ORR.

4.  Figures at 1 April 2006 show Sectors staff transferred from Ops Group to Policy Group.

5.  Science and Technology Group formed on 1 October 2007 from staff transferred from FOD, HID, ND and Policy Group.

6.  The figures in this table differ from those provided recently in answer to the Chair's request for figures of the number of inspectors in HSE over the last 10 years. The previous response confirmed the annual totals for inspectors HSE-wide, whereas these figures show, as requested, only inspectors in operational directorates.


How is the HSE's risk-based system, as it applies to FOD, structured? In particular, what are the criteria which are used within this system?

  8.  FOD has three broad priority areas of work. Reactive investigation work that flows from applying the incident selection criteria within HSC's Enforcement Policy Statement, as well as complaints made about working conditions. FOD's proactive work makes best use of the remaining resource available to help deliver HSE's targets, and deal with poor performers. In recent years such proactive work has amounted to around 50% of FOD's resource.

Planning framework

  9.  FOD plan their proactive risk-based work within the following framework:

    —  contributing to HSE's PSA targets;

    —  working within the HSC strategy, eg with local authorities;

    —  aiming to deliver business imperatives, eg dealing with vulnerable workers or identifying poor performers;

    —  using all available evidence (eg statistics), to facilitate the selection of broad areas for action—eg the types of harm, sectoral variation etc;

    —  ensuring that FOD remains able to respond to quickly emerging issues;

    —  ensuring that the planned work is challenging but achievable and makes best use of the abilities of all staff; and

    —  the need to deal with key health and safety issues that are encountered, such as legionella, "matters of evident concern" (issues that may result in death or serious ill health).

Selection of work

  10.  FOD selects where best to intervene, using a range of techniques, and drawing on the following types of information:

    —  industry type, eg construction;

    —  activity or process, eg work at heights;

    —  number of employees;

    —  the risk to the public;

    —  the presence of vulnerable workers;

    —  injury or ill health records;

    —  complaints received;

    —  previous advice and enforcement action;

    —  whether the business is new; and

    —  notifications received by HSE, eg relating to construction projects or asbestos.

  11.  Sourcing data to ensure that appropriate targets are chosen is key, but difficult not least because of the rapid continuing turnover amongst small businesses, in particular. Sources used by FOD include Office of National Statistics, HSE's own operational intelligence system ("COIN"), trade and industry associations, trades unions and local knowledge built up within FOD divisions. An important source of information is obtained through liasing with other regulators, such as local authorities or the environment agencies. This liaison can tell us whether the business or its principals might be classed as "rogues" or have been the subject of enforcement action on other issues and thus less likely to be managing health and safety adequately.

  12.  Following HSE's "Fine tuning" review in 2006-07, HSE is implementing recommendations on better targeting of business and intelligence. One such is a current pilot of `intelligence officers', working within FOD divisions, to provide more detailed targeting information in a more effective and efficient way, allowing inspectors to expand their direct interventions with dutyholders and targeting poor performers.

Can budgetary breakdowns be provided which show how the HSE's budget is allocated among its different directorates and the proportion of monies spent by HSE on advice, inspection and enforcement respectively?

  13.  Table 5 below shows the outturn of HSE's expenditure by its different directorates for the last full year 2006-07 available. Both Resouces and Planning Directorate (RPD) and Corporate Science and Analytical Services Directorate (CoSAS) hold significant cross-cutting budgets used across the whole of HSE.

  14.  Table 6 below shows the proportion of monies spent by HSE for the same year (2006-07) on:

    —  inspection and assessment of safety cases and safety reports—the process undertaken in the major hazards regimes for ensuring duty holders planned methods of operation are robust if properly carried out;

    —  investigation and enforcement—HSE measures the cost of enforcement from the point at which it decides to proceed with legal sanctions and the cost depends on a range of factors many of which are not in HSE's control, eg whether a prosecution is defended. HSE investigates those incidents that fall within the Commission's incident selection criteria and this is one of the main activities from which enforcement is initiated, proactive inspection being the other;

    —  "advice" includes that given by inspectors in Field Operations Directorate etc. Table 6 also shows the resources HSE spends on providing information (eg through Infoline and campaigns), and guidance eg through publications and staff in other directorates.

Table 5

HSE 2006-07 OUTTURN (BY DIRECTORATE)

OPSDLAU HIDFOD NDOPS Group Total
£k£k £k£k £k£k
Admin2,063842 32,24166,60816,794 118,548
Programme0262 13972,848 3,508
Total Expenditure2,063 1,10432,242 67,00519,642 122,056
Income(105)(1) (15,912)(8,085)(25,077) (49,180)
Net Resources1,958 1,10316,330 58,920(5,435) 72,876
HSCLAO COMMSPOLICY POLICY
Group Total
£k£k £k£k £k
Admin8561,987 1,40519,66123,909
Programme00 07,6207,620
Total Expenditure856 1,9871,405 27,28131,529
Income00 0(271)(271)
Net Resources856 1,9871,405 27,01031,258
RPDCOSAS HSLHSC/E (excl
HSL) Total
£k£k £k£k
Admin78,6253,601 30,769224,683
Programme13,07039,952 4,76764,150
Total Expenditure91,695 43,55335,536 288,833
Income(5,646)0 (35,536)(55,097)
Net Resources86,049 43,5530 233,736

Notes:

1.  The above figures are based on 2006-07 final outturn figures;

2.  RPD's admin expenditure includes corporate costs for all of HSE (eg for estates, training & Conferences, IS/IT, depreciation etc);

3.  RPD programme expenditure contains the costs of information, publicity, publications and printing which pays for these activities in intervention programmes across a wide range of industries and hazards; and

4.  CoSAS programme expenditure pays for the costs of forensic incident investigation and analysis by the Health and Safety Laboratory and planned scientific support and research including surveys, across a wide range of sectors and hazards.

Abbreviations:

OPSD: Operational Policy & Support Division, LAU: Local Authorities Unit, HID: Hazardous Installations Directorate, FOD: Field Operations Directorate, ND: Nuclear Directorate, HSC: Health & Safety Commission, LAO: Legal Adviser's Office, COMMS: Communications Directorate, RPD: Resource and Planning Directorate, CoSAS: Corporate Science and Analytical Services Directorate, HSL: Health & Safety Laboratory.


Table 6
% of HSE Expenditure
Inspection and Assessment21.0
Other proactive work (Fit3)4.3
Proactive science support2.3
Total Proactive work127.6
Enforcement and Investigation13.0
Reactive science support4.7
Total Reactive work217.7
Advice6.2
Information & Publicity5.1
Info Line0.3
Total Advice311.6

Notes:

1.  HSE categorises assessment and inspections as elements of proactive work. Figures cover FOD, HID, and ND, and include Policy Group and CoSAS budget spent supporting inspections.

2.  HSE categorises investigations and enforcement as reactive work. Figures cover FOD, HID, and ND, and include Policy Group and COSAS budget spent supporting reactive work.

3.  Advice covers advice by FOD inspectors at site visits and includes provision of information through Info-line, publications, other HSE staff etc.


Could HSE tell the Committee how much profit it makes from its subscription service "HSE Direct" and also from any guidance publications that it charges for?

  15.  HSE does not have a trading fund for its publications. Therefore, we are not able to make a profit from the publications we charge for and the HSE Direct subscription service. We are only permitted to recover our costs, in any given year, from income derived from the full range of our priced products.





 
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