CECA has urged the Health and Safety Executive to ensure that proposed changes to the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 are clear, proportionate and practical for civil engineering contractors.
Responding to HSE’s consultation on proposed reforms to RIDDOR, CECA said it supports the overall aim of improving the clarity and effectiveness of the reporting framework, but warned that changes must reflect the operational realities of complex infrastructure delivery. You can read CECA’s full response to the consultation here.
CECA’s response, developed following consultation with members, supports proposals to clarify definitions, improve occupational health reporting, broaden who can diagnose occupational diseases, and review dangerous occurrences. However, CECA said successful implementation will depend on clear definitions, practical sector-specific guidance, proportionate thresholds, and a fuller understanding of the cost and complexity associated with reportable incidents.
CECA argues that clearer rules could help reduce both under-reporting and unnecessary over-reporting, improving national data quality and supporting more targeted prevention activity. However, the Association warned that uncertainty around reportability can create inconsistency, particularly on major construction projects involving multiple duty holders, subcontractors and evolving site circumstances.
CECA has called for HSE to publish plain-English guidance with practical construction-based examples, including scenarios relevant to highways, utilities, rail and other infrastructure settings. It also said guidance should reflect the realities of work under the Construction (Design and Management) Regulations, where responsibility for incident management and reporting may involve a number of parties.
On occupational disease reporting, CECA supports the objective of improving occupational health intelligence but has asked HSE to clarify how reporting duties should apply where a current employer identifies a reportable disease but the relevant exposure may have occurred with a previous employer or across several employers. CECA said this is particularly important in relation to long-term occupational health risks, where attribution can be difficult.
CECA also supports in principle the proposal to allow suitably qualified healthcare professionals other than doctors registered with the General Medical Council to diagnose reportable occupational diseases. However, the Association has called for clear competence requirements to ensure consistency and avoid uncertainty for employers.
On dangerous occurrences, CECA supports expanding reporting where events have the potential to cause serious injury or fatality, but warned that the proposed wording must be much clearer before any changes are introduced. In particular, CECA raised concerns about the subjectivity of phrases such as “could cause the death of a person” and has asked HSE to clarify how effective direct controls should influence whether an incident is reportable.
CECA has also urged HSE to revisit its assessment of the cost impact of the proposals. The Association said that the cost of RIDDOR reporting in the infrastructure sector is rarely limited to the administrative time needed to complete an online form. Depending on the circumstances, a reportable incident may trigger site investigation, subcontractor coordination, client reporting, preservation of evidence, legal review, insurer notification, management time, programme disruption, commercial scrutiny and potential regulatory follow-up.
Commenting, 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.”