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
2. Table 1 summarises reporting levels for
RIDDOR reportable injuries to employees in the last decade.
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 2003-04||2004-05 to 2006-07 (p)
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).
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
|Extractive & utility supply||Central
|Distribution & Repair||Central
|Hotel & Catering||Central
|Transport & Communication||Central
|Finance & business||Central
|Public sector services||Central
* 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-reportssee
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.
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)
|Accident kind||Sample cases1
||Estimated incidence (thousands)
||Rate per 100,000 workers
||95% C.I. ||
||Rate per 100,000 employees
||LFS Central estimate)
||RIDDOR (Reported injuries)
|Hit by moving, flying or falling object
|Injured handling, lifting or carrying||177
|Slipped, tripped or fell on same level
|Fell from a height||49
|Physically assaulted by a person||26
|Other kinds of accident||175
Source: LFS, RIDDOR
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
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.
TOTAL INSPECTORS IN OPERATIONAL DIRECTORATESAPRIL
2002 to DECEMBER 20071
||Apr 2003||Apr 2004
||Apr 2005||Apr 20063/4
||Apr 2007||Dec 2007
|Field Operations Directorate||
|Hazardous Installations Directorate||
|Local Authority Unit||
|Operational Policy & Support Div||
|Science & Technology Group5||
1. Total inspector numbers include Operational Inspectors.
2. Breakdown not available, total inspectors in HSE at 1 April
3. Figures as at 1 April 2006 exclude inspectors who transferred
to the Office of Rail Regulation (ORR) on that datewhen
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
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.
9. FOD plan their proactive risk-based work within the
contributing to HSE's PSA targets;
working within the HSC strategy, eg with local
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 actioneg
the types of harm, sectoral variation etc;
ensuring that FOD remains able to respond to quickly
ensuring that the planned work is challenging
but achievable and makes best use of the abilities of all staff;
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
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;
the risk to the public;
the presence of vulnerable workers;
injury or ill health records;
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 reportsthe process undertaken in the major hazards
regimes for ensuring duty holders planned methods of operation
are robust if properly carried out;
investigation and enforcementHSE 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.
HSE 2006-07 OUTTURN (BY DIRECTORATE)
||ND||OPS Group Total
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
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
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.
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 &
|% of HSE Expenditure
| Inspection and Assessment||21.0
|Other proactive work (Fit3)||4.3
|Proactive science support||2.3
|Total Proactive work1||27.6
|Enforcement and Investigation||13.0
|Reactive science support||4.7
|Total Reactive work2||17.7
|Information & Publicity||5.1
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.