HSE had initially proposed to remove the requirement for reporting of occupational cancers, diseases attributable to biological agents and six short-latency diseases. It changed its decision after a public consultation exercise
BOHS chief executive Steve Perkins said: “BOHS welcomes HSE’s decision to retain the requirement to report occupational cancers, diseases attributable to biological agents and six short-latency diseases (hand-arm vibration syndrome, dermatitis, carpal tunnel syndrome, severe cramp of the arm, tendonitis and occupational asthma). These account for 90% of all ill-health RIDDOR reports to the HSE. It is therefore important these are retained under RIDDOR reporting requirements.”
Reform of the Reporting of Injuries, Diseases & Dangerous Occurrence Regulations 1995 (RIDDOR) initially arose from the HSE’s review of the regulations, which was recommended by the Young Review in 2010 and endorsed by the Löfstedt Review in 2011.
A formal public consultation took place between August and November 2012.
In response to the public consultation, BOHS set out three main areas why reporting occupational diseases such as occupational cancer should remain a key part of RIDDOR.
One of its concerns was that there would otherwise be a lack of surveillance data for epidemiological purposes. Existing data reveals that 500,000 ‘new’ work-related illnesses occur each year which ultimately costs the economy £8.2bn annually, said BOHS. Even with its limitations, without RIDDOR disease data, fighting for healthier working environments, which all workers deserve, is harder, it added.
Changing the rules would have left the HSE without valuable information for HSE inspections, said BOHS. “As industry changes, so does the incidence of disease and HSE would have had no data to see this happening. Most disease has a long latency which slows down the intervention and control process,” it said. “Removing the requirement to report disease would have slowed the process even more.” Not all occupational disease has a long latency – for instance dermatitis - and even when it does have a long latency, the reporting of a single case in a workplace indicates that other workers are probably being exposed, said BOHS. “Interventions at this stage can still prevent future cases.”
BOHS was also concerned about messages sent to industry about priorities. “The removal of the requirement to report diseases would have sent an incorrect message to industry about how HSE perceives its importance,” said BOHS. “There could have been a perception in some industries that if they were not required to report then the risks do not require controlling. If occupational diseases were no longer required to be reported then industry would have been even less inclined to undertake health surveillance.”
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