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					Comments on the review of Reporting of Injuries, Diseases and Dangerous Occurrences
Regulations 1995 (RIDDOR) put forward by the Health and Safety Commission (HSC).

   PROPOSAL 4 - CONSIDER WHETHER TO MAKE
    ‘AT WORK’ WORK-RELATED ROAD TRAFFIC
     INCIDENTS REPORTABLE UNDER RIDDOR

Contents

1 Introduction ....................................................................................................................... 2
2 Our credentials to comment on and support this question ................................................ 2
3 Why RIDDOR data is important for work-related road safety............................................ 3
   3.1 National level .............................................................................................................. 3
   3.2 Organisational/fleet level ............................................................................................ 4
4 Lessons from other countries ............................................................................................ 7
   4.1 Finnish data ................................................................................................................ 7
   4.2 US data ...................................................................................................................... 7
   4.3 Australian data ........................................................................................................... 7
5 The practicalities of, and barriers to, implementation ........................................................ 9
   5.1 HSC/E’s existing policy .............................................................................................. 9
   5.2 Unnecessary burden on industry ................................................................................ 9
   5.3 Extra work for enforcing authorities .......................................................................... 10
   5.4 Diversion from HSC strategy priorities ..................................................................... 11
   5.5 Likely impact and costs to our business or organisation .......................................... 11
6 Summary and recommendations .................................................................................... 11
7 References ..................................................................................................................... 12

From:

Dr Will Murray
Research Director
Interactive Driving Systems
UK-AUSTRALIA-EU-USA
Visiting Research Fellow
Centre for Accident Research and Road Safety - Queensland
Telephone: ++ 44 (0) 1484-400399
Mobile: ++ 44 (0) 7713-415454
Email: willmurray@roadrisk.net
Web: www.VFRM.net, www.highwaycode.net, www.vfsm.net and www.drwillmurray.com

Ref: idsriddorresponse, July 1, 2005, 4081 words




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1 Introduction
Many thanks for the opportunity to contribute to your consultation on Question 11 (para 66)
of your RIDDOR review: What are your views on making ‘at work’ work-related road traffic
incidents reportable under RIDDOR?

We believe that it is an excellent idea and that you should work to make it happen as soon
as is practically possible, for the wide range of reasons set out below. The following
document focuses on:

      Our credentials to comment on, and help you with this issue.
      Why it’s important.
      Lessons we can learn from other countries.
      The practicalities and likely barriers.
      Overall recommendations.



2 Our credentials to comment on and support this question
We have strong credentials to comment on making ‘at work’ work-related road traffic
incidents reportable under RIDDOR and to give you a great deal of support, because we
have been involved in many work-related road safety data project with Government and
industry all around the world, including the following examples:

      Analysis of fleet insurance claims data for large and small organisations in the UK,
       Europe, Middle East, Australia and USA

      Development and implementation of the online CrashCOUNT tool, to allow
       organisations visibility to their work-related road safety incident data.

      Published academic and industry papers and reports on work-related road safety
       data issues, funded by the UK Government, the US Government, the European
       Union, the Australian Government and organisations in all those regions (see
       references for examples).

      We, or our customers, have won awards in the UK and Australia for the
       development of Crash Analysis Procedures. For examples see ‘awards’ at
       www.vfrm.net

All of these projects have developed because work-related road safety incident data is a
very important issue for a range of Government and business level reasons.




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3 Why RIDDOR data is important for work-related road safety
In terms of data, making ‘at work’ work-related road traffic incidents reportable under
RIDDOR is important at the macro, national or government level and at the micro,
organisational or business level.



3.1 National level

The unavailability of purpose of journey data in the Police Stats19 system and the lack of
RIDDOR data on ‘at work’ work-related road traffic incidents have been a recurring theme
for academics and industry for many years. This lack of data means that there has been
no clear picture of the real extent of the work-related road safety problem. From January
2005 this problem has been addressed in the Police Stats19 system, where purpose of
journey data is now available, which over time should give much needed visibility in that
data. However, without RIDDOR data there will still be many gaps and a great deal of
under reporting in the data collected. Stats19 data is typically good on fatalities, not too
bad (about 30-40% underreporting) on injuries and almost non-existent on damage only.
RIDDOR data is clearly needed to help close this gap.

Another problem at the national level is that many corporate crashes appear to get 'lost'
somewhere between the police, insurers, vehicle operators themselves, the hospitals, the
Department for Transport (DfT), Health and Safety Executive (HSE) and local authorities.
At present it appears that the vast majority of work related crashes, including many serious
injuries, fall outside of national statistics. The current data also leads to a major
misunderstanding of some of the key risks. Reversing safety is a classic case, with the
department for Transport suggesting it is not a priority issue – with only 2% of its Stats19-
based road fatalities involving vehicles travelling backwards. In HSE data, it is suggested
that reversing was a factor in 25% or more of the fatalities involving vehicles. This HSE
data is backed up by research from the University of Huddersfield which suggested that for
work-related vehicles (particularly trucks and vans operating in urban areas) reversing is a
major road safety risk. This is further supported by data analysis we have undertaken with
many individual fleets – which we are happy to share with HSE if required. A problem is
that the current RIDDOR cut off point of the ‘work site’ is an artificial one, because
reversing, and many other slow speed collection and delivery-based incident types, are not
restricted just to work sites. Figure 1, from a typical UK retailer, indicates that clearly.

Including ‘at work’ work-related road traffic incidents as reportable under RIDDOR would
help to close that gap, and be a big step towards integrating all of the separate data sets to
give much better data visibility. Although it is probably a long term vision rather than a
short term goal at present, as a nation concerned about Road Safety and Worker Health
and Safety we should be looking to integrate and learn from all the available police,
insurer, vehicle operator, hospital, DfT, HSE and local authority data. Including ‘at work’
work-related road traffic incidents as reportable under RIDDOR would help the HSE to be
an innovative leader in this process.

If work-related road safety is as big a problem as it is estimated to be, a factor in 800-1000
road fatalities each year, it is potentially one of UK’s the biggest workplace risks, which
suggests that the HSE has a duty of care to at least be able to monitor and understand the
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true extent of the problem – even if it then decides that it is not the best agency to lead the
improvement of it. RIDDOR data is necessary to really understand the extent of the
problem, and its importance in relation to other workplace risks.

Including ‘at work’ work-related road traffic incidents as reportable under RIDDOR is also
important at the national level for the following reasons.

      To create a detailed picture of the scale of injuries from at-work road crashes.
      To encourage organisations to sharpen up their health and safety policies and data
       management, by sending an important signal to all occupational health and safety
       officers/managers that road injuries are within their remit and therefore should be
       managed like other Occupational Safety and Health risks.
      To target investigations by the enforcing authorities.
      Information to form the basis for prosecutions in cases of negligence, or to defend
       bogus claims.
      Enforcing authorities can build up a statistical database on the extent of incidents
       where there had been a safety management failure, and can monitor/act on any
       persistent offenders. This has already been shown to be of value in the Australian,
       American and Finish research described below.
      To encourage senior management duty holders to manage work-related road safety
       as part of their overall health and safety system.
      The Work-Related Road Safety Task Group/Dykes Report, Work and Pensions
       Select Committee, Motorists Forum, Occupational Road Safety Alliance,
       Parliamentary Advisory Council for Transport Safety (PACTS), Department for
       Transport Research Reports 31 and 51, Brake, the Royal Society for the Prevention
       of Accidents (RoSPA), and Roadsafe all recommend at-work road crashes should
       be included in the regulations. All of these groups cannot all be wrong.
      RIDDOR is one of the most important sources of information for the enforcing
       authorities and guides some, but not all, regulatory activity – work-related driving is
       work activity!
      Even if the HSE only made limited use of the information to target enforcement
       action, it would allow the police to take a better lead in the investigation of road
       traffic incidents on the public highway.




3.2 Organisational/fleet level

At the individual organisational level there are many benefits that could be gained from
having better data visibility and disciplines through the inclusion of ‘at work’ work-related
road traffic incidents as reportable under RIDDOR, including the following:

      Easier to measure and benchmark process and outcomes. At present there is no
       industry standard, like RIDDOR, for every organisation to work to – making
       benchmarking projects fraught with data difficulties.
      RIDDOR reporting would encourage/force/give people a reason to improve their
       crash reporting, recording and data disciplines, which is important because what

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       gets measured gets bettered – but sometimes people/organisations need support or
       a reason to do it. RIDDOR could provide that reason as well as a tried, tested,
       standardised, pre-existing format for achieving it.
      RIDDOR reporting would help to make countermeasures more needs-based and
       effective. At present industry, and therefore ‘UK Plc’, wastes a great deal of time,
       money and energy on countermeasures, particularly driver training, which are in no
       way geared towards the actual risks the organisations face. The data visibility
       provided by RIDDOR could be effectively used to target resources at the actual
       risks.
      RIDDOR reporting would allow better program evaluation, giving people a useful
       source of data to assess the effectiveness of the countermeasures they have
       implemented. This is a particularly important and useful benefit from RIDDOR
       reporting, because our research and experience over many year shows that time
       and time again evaluation, and the data required to undertake it, is at best an
       afterthought – and at worst just not undertaken due to lack of data.
      RIDDOR reporting would allow organisations to develop a continuous improvement
       process, which current data disciplines often do not allow, and would also help to
       prevent future incidents through the provision of better data for investigation.
      Finally at the organisational level, RIDDOR reporting could allow managers and
       organisations to protect themselves internally against accountants wishing to cut
       their safety budget; and externally, against personal injury (PI) claims and
       ambulance chasers, as well as against Health and Safety regulations, Corporate
       Manslaughter and Operator Licensing offences.


Overall, there appear to be many compelling national and organisational level reasons to
make ‘at work’ work-related road traffic incidents reportable under RIDDOR, as is the case
in several other countries including Finland, the USA and Australia.




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Figure 1 - Incidents involving delivery vehicles from a typical retail regional distribution centre (RDC)

RSU = recycling unit; Store = retail outlet; Supplier site = factory/other supplier; On route = road traffic collision; On site = at RDC
  OTHER STORES

           ST O R E 27

           ST O R E 26

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           ST O R E 24

           ST O R E 23

           ST O R E 22

           ST O R E 21

           ST O R E 20

           ST O R E 19

   S U P P L IE R S IT E

           ST O R E 18

           ST O R E 17

           ST O R E 16

           ST O R E 15

           ST O R E 14

           ST O R E 13

           ST O R E 12

           ST O R E 11

           ST O R E 10

            STOR E9

            STOR E8

            STOR E7

            STOR E6

            STOR E5

            STOR E4

            STOR E3

            STOR E2

            STOR E1

                  R SU

         ON ROUTE

            O N S IT E


                           0      20               40               60               80              100              120              140




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4 Lessons from other countries
In Finland, the USA and Australia similar data to RIDDOR is already available, and being
used to improve workplace health and safety through work-related road safety.


4.1 Finnish data

Salminen (2000, 2004) showed that in Finland road traffic is the most important cause of
accidental at-work deaths. For example, from 1975 to 1994, 50% of all the accidental
workplace deaths in Finland were related to traffic collisions. The data was taken from the
Federation of Accident Insurance Institutions, which keeps the official statistics on
occupational accidents, the Traffic Insurance Centre which contained all the traffic
collisions and Statistics Finland, which covered a representative sample of the Finnish
population who had been interviewed on their traffic collision history.



4.2 US data


The National Institute for Occupational Safety and Health (NIOSH 2004) in the US has
produced some excellent research and guidance on work-related road safety. This has
identified that motor vehicle-related incidents are consistently the leading cause of work-
related fatalities in the United States. Of approximately 6,000 worker fatalities annually
reported into Bureau of Labor Statistics, over 35% are associated with motor vehicles.

Between 1997 and 2001, on average:

      1,421 workers died each year from crashes on public highways.
      368 workers died each year in crashes that occurred off the highway or on industrial
       premises.
      382 pedestrian workers died each year as a result of being struck by a motor
       vehicle.



4.3 Australian data

In a study funded by the Australian Transport Safety Bureau (ATSB), Murray (et al 2002)
identified that work-related crashes are a significant element of the Australian road toll and
a high proportion of all work-related deaths and injuries. This means that there are strong
grounds to believe that fleet safety programs will have a positive impact on the road toll
and bring significant Occupational Safety and Health (OHS) gains.

The ATSB research drew heavily on two studies of work-related fatalities conducted by
Australia’s National Occupational Health and Safety Comission (NOHSC). The first of
these studies covered 1982-1984. During this period 39% of work-related fatalities
involved driving or commuting for work – which was seen by some commentators as

                                                                                            7
under-estimation. These drivers tended to be older (30-50) than the average crash victim,
typically male and most frequently in urban areas, often between 2am and 4am. Excluding
commuting, heavy trucks accounted for about 60% of the work-related driving fatalities.

By the time of the second and most recent study, covering the period 1989-1992, the 39%
figure had increased to 49%, which was 13% of the 9,219 road fatalities during the same
period. The data is quite old because detailed information has to be extracted from
coronial files.

Figure 2 shows that NOHSC’s second investigation into work-related fatalities during 1989
to 1992 found that 541 people were killed in on-road work-related incidents. Another 628
were fatally injured travelling to or from work. Further correspondence with NOHSC found
that 225 of the total on-site workplace fatalities involved vehicles, including tractors, heavy
and light vehicles.

Figure 2 - ‘At work’ fatalities in Australia 1989-1992

                           Total deaths   % of total deaths 1989-1992   % of total deaths 1982-84
At workplace-non-vehicle       995                    42%                            ?
At workplace – vehicle         225                     9%                            ?
Work-related on-road           541                    23%                          24%
Commuting on-road              628                    26%                          14%
Total                         2,389

Overall then, 58% of at work fatalities in Australia were driving/vehicle related.

More recently this data has been written up in more detail by the original authors of the
NOHSC research (see Mitchell et al 2004). Further research has also been undertaken on
the use of RIDDOR type OSH data for road safety improvements (see Smith et al 2004).

At the state level in Australia, data from the Queensland Workers compensation agency
for the period 1998-2001 is also interesting (Figure 3).

Figure 3 – Queensland workers compensation data

Transport % of fatalities            43%
Transport % of costs                 10%
Transport % of total lost time        9%
Transport % of total claims           5%

Transport related incidents make up almost half (43%) of the fatal workers compensation
claims in Queensland, even though they only make up 5% of total claims.

At present, because ‘at work’ work-related road traffic incidents are not reportable under
RIDDOR, the HSE could easily be seen to be neglecting its duty of care to the country - by
failing to monitor one of the key risks faced by many workers in the UK. Not knowing, or
ignorance of the risks because the data is not collected, would not be a reasonable
defence. The Finish, US and Australian data makes a clear case for the inclusion of ‘at
work’ work-related road traffic incidents as reportable under RIDDOR.




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5 The practicalities of, and barriers to, implementation
These relate to the HSC/E’s existing policy on work-related road safety, adding
unnecessary burden on industry, extra work for enforcing agencies, diversion of HSE from
strategic goals and the likely impact on our own operations.


5.1 HSC/E’s existing policy

In paragraph 66 of the consultation, HSC/E expressed concern that the ‘existing policy on
‘at work’ road traffic incidents is based on the premise that we do not generally seek to
apply HSW legislation where there is more specific and detailed law (in this case the Road
Traffic Acts and related regulations administered by other enforcing agencies) that
adequately protects public and worker safety. Road traffic law is enforced by the police
and others, e.g. the highways authorities and traffic commissioners. The police will, in
most cases, take the lead in the investigation of road traffic incidents on the public
highway. HSE would only make limited use of this information to target enforcement
action’.

RIDDOR reporting need not change the HSC/E’s stance on this issue. Improving the
availability of data is not just about law and enforcement of minimum legal standards. It is
also about best practice, education and information in the form of data provision. There is
lots of existing HSE best practice that can be applied to on-road incidents. RIDDOR
reporting is important as a starting point to identify problem areas that can be focused on,
by industry, the police and other enforcing bodies. Now that purpose of journey data is in
place in the Police/DfT Stats19 data system, RIDDOR reporting is the next logical step in
closing the work-related road safety data availability gap.



5.2 Unnecessary burden on industry

HSC/E is concerned that ‘notification and reporting of all work-related road safety incidents
would add an unnecessary burden on business’.

For most organizations this is simply not true. RIDDOR reportable accidents, dangerous
occurrences and diseases are comparatively rare events. Most work-related road safety
incidents involve asset damage or very minor injury only – although they have the potential
to be serious or fatal. Depending on the work undertaken, and how well risk-managed the
fleet is, a typical group of 100 work-related drivers may have 50 reportable minor asset
damage incidents in a year. Of these, 1 or 2 at most are likely to be RIDDOR reportable.
Figure 4 shows data from a large vehicle fleet, driven by over 100,000 people who were
involved in 60,000 incidents over two years. During the same time period there were less
than 1,100 injuries to the organization’s own people or third parties. In other words, less
than 2% would have even been considered as RIDDOR reportable. Many of these were
probably below the RIDDOR threshold of ‘3 days lost time’ anyhow.




                                                                                           9
Figure 4 – Sample work-related road safety data


               TP - Minor
             TP - Serious
              TP - Fatality
    Insured Pass - Minor
  Insured Pass - Serious
   Insured Pass - Fatality
    Insured Driver - Minor
  Insured Driver - Serious
  Insured Driver - Fatality

                              0   100   200   300    400     500     600     700



RIDDOR is the best means of gathering information because all companies, institutions
and organisations already have to comply, so no ‘new’ mechanisms would need to be
developed to collect the information, which means that no extra administrative burden
would be necessary.



5.3 Extra work for enforcing authorities

HSC/E fears that ‘enforcing authorities would have to handle a potentially very sizable
increase in the number of reports and potentially serious resource implications as a result’.

There would be some extra recording of incidents, but the resources implications of this
would not be great in relation to the likely benefits and data visibility described above. As
well as the information on the existing form F2508, this review of RIDDOR is also an
opportunity to consider several other data fields which would be important in relation to
monitoring vehicle incidents. These should include the following, which would potentially
bring many benefits, in terms of data collection coding, analysis, strategy development and
inter-agency integration.

       Insurance claim/reference number.
       Hospital incident number.
       Police Stats 19 incident number.
       Vehicle type (eg van, car, bus, truck, bike, motorbike).
       Vehicle Movement (eg forward, reversing, stationery, parked).
       Location type (eg on the road, collection/delivery point, own site, other).

We can advise on these codes in more detail if required.




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5.4 Diversion from HSC strategy priorities

HSC/E fears that it ‘might find itself being diverted from its current HSC Strategy priorities
to the detriment of its strategic programs’.

This could be true, but is unlikely. Even just by collecting and allowing data visibility HSC/E
would be performing a very important role. If the data, or at a future time a change of
priorities for the Minister or the HSC, led to work-related road safety becoming a core
strategic program, then the data would be available to justify it. If the extent of the problem
is not as great as has been predicted, or as it is in the US, Finland and Australia, then the
data would allow great scope and backing for the current strategy priorities.



5.5 Likely impact and costs to our business or organisation

The likely impact on our business will be substantial and positive. It will make it much
easier to target our own and customer efforts to improve road safety, reduce human harm
and minimise asset damage. As well as improved data to target risks with relevant
countermeasures, it will also mean everyone is working towards the same high level
incident definition of ‘3 days lost time’ – which will allow more effective benchmarking and
collaboration on safety within and between organisations – at the organisational as well as
national level.



6 Summary and recommendations
Our submission to your consultation on RIDDOR has focused on four main areas:

   1.   Our credibility to support you with this issue.
   2.   Why it is important to Government and industry.
   3.   Lessons from other countries.
   4.   The practicalities and barriers.

Including ‘at work’ work-related road traffic incidents as reportable under RIDDOR will help
overcome the current lack of information available to the HSE, other agencies and industry
to facilitate the following urgently required tasks:

1. Investigate national and local work-related road safety collision trends.
2. Carry out work related road safety collision investigations and preventative actions.
3. Assess the effectiveness of work-related road safety activities, national performance,
   particular industries and the success of remedial measures.
4. Provide a common framework to compare work-related road safety performance.

Over time, RIDDOR reporting of work-related road traffic incidents will also facilitate and
allow closer working, and data integration, between all the key work-related road safety
stakeholders - including the police, insurers, vehicle operators, hospitals, the DfT, HSE
and local authorities.


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The HSE, in the form of RIDDOR, is in the best position to lead this process. The RIDDOR
system is already a tried and tested one – which all organisations already need to comply
with.

We are in no doubt that ‘at work’ work-related road traffic incidents should be made
reportable under RIDDOR at the earliest possible time.

We would be very happy to use our experience from around the world to assist you with
this process.



7 References

   1. McCorry, B and Murray, W. (1993) Reducing commercial vehicle road accidents.
      International Journal of Physical Distribution and Logistics Management, , Vol 23
      (4), p35-41
   2. Mitchell R, Driscoll T, and Healey S. (2004) Work-related road fatalities in Australia.
      Accident Analysis and Prevention, 36 (5), 851-60
   3. Murray W & Dubens E. (2000) Creating a crash-free culture, 4Di, Brighouse, UK
   4. Murray W & Hansen R. (Eds.) Work-Related Road Trauma and Fleet Risk
      Management in Australia. Australian Transport Safety Bureau: Canberra, 2002,
      www.carrsq.qut.edu.au/staff/murray.jsp
   5. Murray W & Whiteing T. (1995) Reducing commercial vehicle accidents through
      accident databases, Logistics Information Management, 18 (3), p22-29.
   6. Murray W, Newnam S, Watson B, Davey J and Schonfeld C. Evaluating and
      improving fleet safety in Australia. Australian Transport Safety Bureau Report,
      November 2002 (www.drwillmurray.com/ozreport.html)
   7. Murray W, Whiteing T & Bamford C. Managing occupational road risk in SME
      organisations. Paper published in the proceedings of the RoSPA Safer driving - the
      road to success 67th Road Safety Congress, Stratford upon Avon, 4-6 March 2002.
   8. Murray W. Company Vehicle Incident Reporting and Recording (CoVIR).
      Department     for    Transport   Road Safety  Report   31,   2003,
      (www.drwillmurray.com/covir.html)
   9. NIOSH. Motor Vehicle-Related Incidents: The Leading Cause Of Occupational
      Fatalities In The United States, 2004 (www.vfrm.com/news.php)
   10. Salminen S. (2000) Traffic Accidents During Work and Work Commuting.
       International Journal of Industrial Ergonomics, P 75-85
   11. Salminen S. Work-related traffic accidents and how to prevent them. Paper
       presented at the 3rd International Conference on Traffic & Transport Psychology
       (ICTTP), Nottingham, UK, 5-9 September 2004
   12. Smith N, Wishart D, Manderson J and Murray W (2004) Truck Crashes by Industry
       Sector, 2004, Austroads Project No. RS.SS.N.542, Austroads Publication No. AP–
       R251/04, ISBN 0 85588 700 1




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Maureen Disson
Health and Safety Executive
Policy Group - Cross Cutting Interventions Division
9 th Floor South Wing
Rose Court
2 Southwark Bridge
London SE1 9HS

Tel: 020 7717 6399
Fax: 020 7717 6891
email: riddor.dd@hse.gsi.gov.uk




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