Management Information: Coronavirus (COVID-19) disease reports made by employers to HSE and Local Authorities

Technical summary of data

Overview

Under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR), certain cases of COVID-19 in workers where there is reasonable evidence to suggest that it was caused by occupational exposure are reportable to the relevant enforcing authority.

In order to contribute to evidence around cases of coronavirus (COVID-19) in workers, the Health and Safety Executive (HSE) are publishing counts of notifications made by employers to the enforcing authority (either HSE or Local Authority) of suspected cases of occupational COVID-19 in workers in Great Britain, based on these statutory reports.

The figures include:

• total count of notifications where a worker is reported as having died as a result of COVID-19 following suspected occupational exposure
• total count of notifications where a worker has been diagnosed as having COVID-19 following suspected occupational exposure

Description of the data source

HSE collects data on cases of disease in workers resulting from exposure to biological agents under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (2013) - RIDDOR. (Specifically, regulation 6(2) and 9(b)). The intention of these regulations is to ensure that the enforcing authority (either HSE or Local Authority) is notified of cases of certain occupational disease so that where appropriate, they can take follow-up action. 

SARS-CoV-2 (coronavirus) is classified as a hazard group 3 pathogen, so therefore is a biological agent as defined under the Control of Substances Hazardous to Health (COSHH). Consequently, RIDDOR regulation 6(2) and 9(b) applies to cases of COVID-19 due to occupational exposure.

Up until 31 March 2022, RIDDOR reporting guidance required all confirmed cases of COVID-19 where there was reasonable evidence to suggest that it was caused by occupational exposure to be reported. On 1 April 2022, revised guidance on RIDDOR reporting requirements for COVID-19 was issued. Only cases of COVID-19 due to either deliberately working with the virus (such as in a laboratory) or being incidentally exposed to the virus from working in environments where people are known to have COVID-19 (for example in health and social care) are reportable. Cases due to general transmission (either worker-to-worker, or from contact with members of the public) are no longer reportable. Full details on reporting requirements post April 2022 can be found on our guide RIDDOR reporting of COVID-19.

Notifications must be sent to HSE without delay. Reports are made via the online reporting tool provided on HSE's website. For deaths, employers can also report by telephone to HSE's Incident Contact Centre.

On receipt of the notification in the database, the report is automatically allocated to the appropriate enforcing authority where further checks on the data provided are made and where appropriate investigations initiated. During these checks, some reports may be identified as non-reportable under RIDDOR requirements (for example they may be reports of general workplace COVID-19 concerns) while for others, the enforcing authority may conclude that there is insufficient evidence to confirm work as the source of exposure. Reviewing individual case reports can take some time. This further information is not retrospectively recorded against the original report.

Previously published data

HSE does not routinely publish statistics based on RIDDOR disease notifications. This is because the disease notification system suffers wide-spread under-reporting and has the potential to give a distorted view of both the scale and spread of cases by important risk factors (such as industry sector). While HSE routinely publish statistics based on RIDDOR injury notifications, there are a number of important differences:

• the level of under-reporting of non-fatal injuries can be quantified (we only publish statistics of non-fatal injuries to employees and not self-employed due to the substantial under-reporting for these workers)
• RIDDOR non-fatal injuries to employees is used as a secondary source of data to support and complement statistics on workplace non-fatal injuries from the Labour Force Survey

Disease reporting also has the additional difficulty of reliably attributing a case of disease to an occupational exposure. This is particularly difficult in the case of COVID-19 where the infection is prevalent in the general community.

However, given the current priority of COVID-19, HSE is publishing, as management information, details of work-related COVID-19 reports made to the enforcing authorities under RIDDOR. This data, while not providing an accurate count of the absolute number of occupational COVID-19 cases in Great Britain, will provide an indicator of the numbers being reported to the enforcing authority and show how this changes over time.

The following limitations should be borne in mind when considering the data:

• the count comprises cases of COVID-19 in workers that are reported by employers to the enforcing authority - data is 'as-reported' by employers. (Reports made in error relating to non-workers, particularly to residents in care and residential homes, users of social day care services and students/pupils, have as far as possible been excluded as they are outside the scope of RIDDOR reporting requirements).
• changes in reporting requirements from April 2022 means the number of reports made from April 2022 onwards is not directly comparable with earlier time periods.
• the data does not give an accurate measure of the absolute scale of occupational COVID-19 cases due to a number of factors including:
  • widespread under-reporting of cases in RIDDOR
  • while reports by employers should only be made where there is reasonable evidence that the worker was exposed because of their work, the strength of evidence in reports appears variable, some reports just noting the potential for work-related exposure to have occurred
  • individual case reviews by the relevant enforcing authority may conclude that there is insufficient evidence to confirm work as the source of exposure. Further, some reports may be found to be general workplace concerns and so not-reportable under RIDDOR.
• because the data is 'as reported' by employers, there is potential for some error in some of the reported data items. In particular, there is potential for some non-fatal COVID-19 cases to have been reported as fatal and vice versa. Further, a review of a sample of reports shows some mis-allocation in the coding of the industry in which the worker is employed. In particular, workers in residential and social care, often get incorrectly recorded as working in the accommodation sector or in personal services
• data on cases of COVID-19 is only available from 10 April 2020. This was the date at which HSE modified the disease report form to enable cases of COVID-19 to be readily identified. (Also, the date at which HSE issued guidance around the reporting of cases of COVID-19 deaths).

Full details on reporting requirements post April 2022 can be found on our guide RIDDOR reporting of COVID-19.