Could making serious collisions RIDDOR reportable change the culture of UK roads for the better? asks Louise Cole
Safety campaigners are trying to persuade the government to make work-related road collisions reportable under RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations). It was a notable gap in the recently published road safety strategy, and the Transport Select Committee has recently heard evidence as to why this this gap should be filled.
The Health and Safety Executive (HSE) is currently consulting on changes to RIDDOR until 30 June, and operators can also send comments directly to RIDDORconsultation2026@hse.gov.uk.
The biggest win, say campaigners, would be accurate data about the causes of collisions. Currently the police investigate collisions at the roadside but with an eye to culpability, not causation. And, although collision report STATS19 has space for journey purpose, up to half of responding officers do not complete it.
“That’s the core gap,” says Caitlin Taylor, road safety manager and Scottish Occupational Road Safety Alliance (ScORSA) project lead. ScORSA works with RoSPA to deliver the Scottish Road Safety Framework 2030.
She goes on: “Work-related road risk falls squarely within the Health and Safety at Work Act, yet because road traffic law and the police take the lead, it sits outside the work-related reporting, data and enforcement architecture that has reduced almost every other category of workplace harm.”
You cannot target or manage what you can’t see, say campaigners, meaning that zero-harm strategies will never fulfil their potential without accurate data to support them.
“RoSPA strongly supports giving work-related road risk the prominence it deserves,” says Taylor. “Driving for work is the single most dangerous activity most workers do. ScORSA research found that counting work-related road deaths in the official figures would roughly double Scotland’s work-related fatality total - and nearly treble it once commuting deaths are added.”
Jamie Hassall, chief executive of the Parliamentary Advisory Council for Transport Safety (PACTS), concurs, saying that many fleet operators do not present collision data to their boards because it is not RIDDOR reportable. He says that the Ministry of Defence and the police have both discovered that road traffic collisions are very significant killers of their staff (usually behind suicide and ill-health). For instance, the MoD has lost two serving personnel to hostile action since 2016, but 97 in land transport collisions.
This initial proposal is about data, not enforcement. HSE shows no indication of wanting to involve itself with roads enforcement, police rarely refer incidents which occur off-site, and the police already have the power to investigate and prosecute employers under corporate manslaughter or ‘cause and permit’ charges. In practice, this rarely happens.
However, robust data on serious work-related collisions could reshape the road-risk landscape providing a more comprehensive map of significant hazards, and change the culture of fleet-using sectors which are not as tightly regulated as logistics.
Driving for Better Business estimates that half of the vehicles on the road are driven for work. Currently the Highway Code places the highest responsibility on the largest vehicles, and successive waves of London regulation have targeted HGVs as the most dangerous vehicles. Yet the PACTS report What kills most on the road? showed that, by mileage, vans are the most dangerous vehicles to other road users. In the capital, Transport for London (TfL) has shown that the current data gap about work-related collisions most seriously under-estimates the fatalities caused by at-work cars and vans.
The logistics industry has invested heavily in driver training, cameras, ADAS, telematics, routeing software and managing road risk. Meanwhile, HGV drivers share the roads with 4 million vans, and up to 10 million grey fleet cars, for whom training standards, regulation and risk management is far lower, yet whose risk to the public is arguably far greater, because they are so numerous.
Policy and safety initiatives are based on data but, as the PACTS and TfL work shows, the biggest road safety risks may remain unaddressed.
It is not only an operation’s own collisions which cost time and money. As well as being human tragedies, serious collisions cause delays, congestion, and road closures, risking customer disappointment and lost productivity. Government data suggests that collisions in 2024 cost the UK £55bn - £3bn of which was borne by the NHS.
For many logistics companies, RIDDOR reporting would make little difference to operations, as they already report on-premises health and safety incidents, and significant collisions to their insurers. PACTS suggests RIDDOR reporting could be linked to filing a police report to eliminate duplication of effort.
Effectively many safety-conscious fleet operators already treat road collisions and near misses as though they were RIDDOR-reportable, and investigate internally to reduce incidents in line with their own safety targets.
There could be considerable benefits to road safety and to the road transport industry if RIDDOR was extended to all driving for work. Accurate data could provide a more level playing field for logistics, as policy could focus on the less managed sectors of commercial road users, and not only the most salient.
What is RIDDOR?
RIDDOR applies to all workplaces, rail and tram passenger transport systems, and anyone engaged in on-road work which isn’t driving, such as recovery or road laying. In other words, it applies pretty much everywhere except driving. All fleet operators still have a legal duty under the Health and Safety at Work Act to identify work-related road risk and take reasonable measures to minimise and mitigate it, yet no official body enforces this or measures compliance.
This gap means that two identical collisions, one at a depot and one on the road, will be treated and recorded completely differently. Equally two medical incidents behind the wheel will be handled and recorded differently depending upon where they occur.
PACTS’ Hassall has written to the secretary of state for work and pensions requesting that collisions are recorded, including:
• fatalities and specified/serious injuries arising from work-related vehicle use, on public roads or private premises
• work-related collisions resulting in hospital treatment, significant time off work, or a medically diagnosed injury developing after the incident
• serious near-miss events involving commercial vehicles (including loss of control, vehicle fires, load instability, unroadworthy vehicles, incidents with vulnerable road users) where there was a genuine risk of fatal/serious harm
Why the data gap?
The police have responsibility for road traffic enforcement, alongside Driver and Vehicle Standards Agency (DVSA, formerly VOSA) and HSE for on-site occupational safety. In policy terms successive governments felt that H&S law should not be enforced where worker and public safety was adequately covered by other laws. Legislation states that police can and should refer cases to HSE if they believe a collision may indicate management failings, but in practice they very rarely do.
It’s hard to find out how rarely. An FOI request to HSE asking how many collision referrals it received from police forces, was refused on the basis that the data is “not retrievable”. The police forces contacted also said the data would be buried in individual case files. Only the Metropolitan Police Service gave a meaningful response, saying that most collisions were the direct result of driver/rider actions, but that where a vehicle was unroadworthy, the driver was undocumented or systematically in breach of drivers’ hours, a wider investigation would take place. Additionally they refer on-site incidents to HSE, but “we cannot say how often because there are limited records kept of HSE referrals”.
When trains, trams or planes crash, there are in-depth investigations into all the elements which could have contributed to the safety failure with the aim of ensuring it doesn’t happen again. For road transport there is nothing comparable.
Mark Cartwright, head of National Highways’ Commercial Vehicle Incident Prevention, said on LinkedIn: “Before Friday’s (19 June) tragic rail crash, it had been six years since the last train driver was killed at work. Seventeen HGV occupants (most, if not all, would be drivers) died on our roads in 2024 alone.
“Every rail fatality triggers investigations, inquiries and a collective drive to prevent the next one. Road deaths get a roadside investigation and a closed file. The HSE may never even know they happened — because unlike rail, there’s no legal requirement to report them as workplace deaths.
“Both are tragedies. Both deserve the same response. Seventeen people went to work in an HGV in 2024 and didn’t come home. Most, if not all, would have been drivers. If fatigue, vehicle condition or scheduler pressure played a part, we may never know. That’s the gap. And it’s one we must close.”
The Road Safety Strategy
The road safety strategy, published earlier this year, promised two significant steps. The first was a data-led Road Safety Investigation Branch, similar to those attached to rail and aviation, but examining overall trends rather than individual collisions. The second was a National Work-Related Road Safety Charter for all businesses which require employees to drive. The government said that it would leave the door open to new legislation if the charter failed to produce results.
However, a huge question then arises. How can a data-led investigation branch operate effectively when there are such gaps in our collision data? Current data focuses on numbers injured or killed and the mode by which they were travelling – it’s far weaker on which vehicles did the damage. Causation rarely goes further than an officer’s best surmise on the ‘road safety factors’ present at the scene; not all collisions are attended or reported; and not all police forces collect data in the same way. And we know that work-related and journey data is often missing.
Going further, how will government assess the success of a charter, if it does not know the extent of work-related collisions to begin with? Without accurate data, there is neither a baseline nor any way to measure progress.
RIDDOR is a cheap solution for both in governmental terms, say campaigners. Adding data collection and analysis to HSE’s portfolio is a relatively minor ask, requiring only a tweak of the regulations.
Would RIDDOR make a difference?
In 1980s, prior to the introduction of RIDDOR, there were around 500 on-site work-related fatalities each year. RIDDOR has been instrumental in systematically reducing this death toll year on year, to reach 124 in 2024/25. It has been a steady decline, driven by the power of data collection and the high level of awareness RIDDOR engenders in employers and HSE. Once it was properly measured, it was managed, and we are still enjoying year-on-year reductions forty years later.
Some H&S professionals correctly note that RIDDOR has not eliminated workplace injuries or fatalities. However, if we apply the RIDDOR improvement figures to the 500+ work-related road deaths, assuming the same results as with workplace fatalities, we would save almost 11,000 lives over the next four decades, and many thousands more who suffer life-changing injuries.
Currently those 500+ work-related road deaths annually go relatively unrecorded, and the lessons these tragedies could give us are too often lost.
The goal
Making injury or fatal at-work road collisions RIDDOR reportable would:
- Provide invaluable data about the causes of collision
- Force a change in culture on those car and van fleets who currently do not manage road risk
- Help shape policies which address the genuine risk of at-work collisions, and recognise driving as the most dangerous activity most employees undertake in their day
- Make all road users safer by underlining fleet-using employer’s duty of care
