RIDDOR for Vet Practices: What to Report

The reporting decision nobody wants to make at 6pm

A nurse is bitten. It is deep, it bleeds, she goes to A&E, and she is back on Thursday. Somewhere between the incident and the end of the week, someone has to decide whether that was a RIDDOR report or an accident book entry.

Most practices get this wrong in the same direction — they under-report, not out of evasion but because the test they are applying is severity, and the test the law applies is different.

The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 apply across Great Britain. Northern Ireland has its own RIDDOR, with a lower reporting trigger and a shorter deadline — a section below sets out the differences, and a practice there should read that section before applying anything else on this page.

The Act they are made under is what settles the Northern Ireland position, and it is quoted below. Separately, regulation 19 extends the Regulations beyond the mainland: "These Regulations apply to premises and activities outside Great Britain to which sections 1 to 59 and 80 to 82 of the 1974 Act apply by virtue of the 2013 Order as they apply within Great Britain."

Two provisions do most of the work in a veterinary setting.

Trigger one: seven days off routine work

Regulation 4(2) is the one that catches practices out, because it has nothing to do with how bad the injury looked.

A report is required where "any person at work is incapacitated for routine work for more than seven consecutive days (excluding the day of the accident) because of an injury resulting from an accident."

Read the two operative phrases carefully.

"Incapacitated for routine work" is not the same as "off sick". A nurse who comes in every day but cannot restrain, cannot lift and cannot handle sharps is not doing her routine work. Practices routinely miss reports because the person was present.

"Seven consecutive days, excluding the day of the accident" counts calendar days, not working days. Weekends and days off count. A Thursday injury that keeps someone off routine duties until the following Friday has crossed the line.

The deadline is set in the same regulation: reporting must be "as soon as practicable and in any event within 15 days of the accident." Fifteen days sounds generous until you notice the clock starts at the accident, not at the point the seven days elapse — which leaves roughly a week to notice, decide and file.

Trigger two: specified injuries

Regulation 4(1) lists injuries that are reportable regardless of time off. The ones that realistically occur in practice:

• "any bone fracture diagnosed by a registered medical practitioner, other than to a finger, thumb or toe"
• amputation of a limb or digit
• a crush injury to the head or torso causing damage to the brain or internal organs
• loss of consciousness caused by head injury or asphyxia
• an injury from working in an enclosed space requiring resuscitation or hospitalisation for more than 24 hours

The fracture entry is the one to commit to memory. A fractured wrist from a fall in the prep room is reportable; a fractured finger is not. That distinction turns on a diagnosis by a doctor, which means the practice needs to follow up on what the hospital actually said rather than filing on the basis of what the injured person reported back.

Trigger three: the one written for our sector without naming it

Regulation 9 covers occupational disease, and its second limb is the provision veterinary practices most often do not realise applies to them.

A report is required where the responsible person receives a diagnosis of "any disease attributed to an occupational exposure to a biological agent."

The regulation does not use the word zoonosis. It does not have to. A confirmed diagnosis of a disease acquired from an animal at work — leptospirosis, ringworm, psittacosis, campylobacter, orf, a Salmonella infection traced to practice exposure — is a disease attributed to occupational exposure to a biological agent, and it is reportable.

Two practical consequences:

The trigger is a diagnosis, not a suspicion. The obligation starts when the responsible person receives a diagnosis. That means someone has to be told, which means staff need to know to tell you — a nurse who mentions in passing that her GP thinks the rash is ringworm has just started a clock nobody heard start.

Your COSHH assessment and your reporting duty are the same subject. Biological agents are substances hazardous to health, so the same exposures sit in your COSHH assessments and in regulation 9. If zoonoses are not named in your COSHH assessment, they will not be recognised when a diagnosis arrives either.

The record duty is separate from the report duty

Regulation 12 requires a record of reportable incidents and diagnoses — and, importantly, of work-related injuries incapacitating someone for more than three consecutive days, which is below the reporting threshold.

So there is a band of incidents that must be recorded but not reported: four to seven days of incapacity. Practices that only keep records of things they reported have a gap in exactly that band.

That band is a Great Britain feature. In Northern Ireland it does not exist — those incidents are reportable, for the reason set out in the next section.

Records "must be kept for at least three years from the date on which it was made", at the workplace or the responsible person's usual place of business.

Three years, and a threshold below the reporting one. Both are easy to get wrong and both are visible in a file.

Northern Ireland runs a different instrument

RIDDOR 2013 is made under the Health and Safety at Work etc. Act 1974, and section 84(1) of that Act is explicit: "This Act, except— ... does not extend to Northern Ireland."

A practice in Northern Ireland reports under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (Northern Ireland) 1997, which the 2012–13 Great Britain reforms did not touch. Two differences change the decision:

The time-off trigger is more than three days, not more than seven. Regulation 3 catches an accident where "a person at work is incapacitated for work of a kind which he might reasonably be expected to do... for more than three consecutive days (excluding the day of the accident but including any days which would not have been working days)".

The deadline is 10 days, not 15. The responsible person "shall as soon as practicable and, in any event, within 10 days of the accident send a report thereof to the enforcing authority on a form approved for the purposes of this regulation."

HSENI states the duty in the same terms: the 1997 Regulations "place a legal duty on employers, self-employed people and people in control of premises to report work-related deaths, major injuries or over-three-day injuries, work related diseases and dangerous occurrences (near miss accidents)."

The practical consequence for a Northern Irish practice is the one that costs money if it is missed: a four-day absence is a report there and a record-only entry in Great Britain. Reports go to HSENI, not the HSE, on the NI2508 form.

A decision sequence worth writing down

For any injury or diagnosis — steps 3 to 5 below are the Great Britain tests; a Northern Irish practice substitutes the RIDDOR (NI) 1997 triggers set out above:

1. First aid and clinical advice. Always first, always before the paperwork question.
2. Accident book entry, same day. Every incident, whatever its severity.
3. Is it a specified injury under reg 4(1)? If yes — report, and do not wait to see how it develops.
4. Has the person been off routine work more than seven consecutive days? Count from the day after the accident, including non-working days. If yes — report within 15 days of the accident. (In Northern Ireland the trigger is more than three consecutive days and the deadline is 10 days.)
5. More than three days but not more than seven? In Great Britain, record it under reg 12 — no report. In Northern Ireland this band is reportable, and within 10 days: see the section above.
6. Diagnosis of a disease attributed to occupational exposure to a biological agent? Report.
7. Whatever the answer — what control failed, and what changes? An incident that produces a report and no control change will recur.

Step 7 is the one an inspector is most interested in and the one most often missing. The HSE's RIDDOR pages set out the reporting mechanics; the review is yours.

Who is the responsible person

For an employing practice, it is the employer. In day-to-day terms that responsibility usually sits with the practice manager or the named health and safety lead, and it needs to be written down — including who acts when that person is on leave. A reporting deadline that runs while the only person who knows about it is away is a deadline that gets missed.

This belongs in the same place as the rest of your health and safety evidence: the written policy, the risk assessments that identified the hazard, the training records showing staff knew the control, and the accident book. When an inspector arrives after an incident, they will look at all five together — and the question they are answering is whether the incident was foreseeable and controlled, not whether the form was filed.

What to do this month

• Write down who the responsible person is, and who deputises
• Check your accident book captures days off routine work, not just days absent
• Brief the team that a doctor's diagnosis of an animal-acquired infection needs telling to the practice, not just to the GP
• Confirm zoonoses appear by name in your COSHH assessments
• Check your records go back three years and include the three-to-seven-day band
• Add a review step to your incident process, so every entry ends with a control decision rather than a signature

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This is general guidance based on the published Regulations as they stood at the review date above. The HSE (in Great Britain) and HSENI (in Northern Ireland) are the authorities on what is reportable from your practice — where an injury or diagnosis is borderline, check the HSE's own guidance or contact them, and report rather than assume.

Sources:

• RIDDOR 2013, reg 4 — non-fatal injuries to workers — legislation.gov.uk
• RIDDOR 2013, reg 9 — occupational diseases — legislation.gov.uk
• RIDDOR 2013, reg 12 — recording — legislation.gov.uk
• Health and Safety at Work etc. Act 1974, s.84(1) — extent — legislation.gov.uk
• RIDDOR (Northern Ireland) 1997, reg 3 — notification and reporting of injuries and dangerous occurrences — legislation.gov.uk
• RIDDOR — reporting of injuries, diseases and dangerous occurrences — HSE
• Accident reporting — HSENI