ESRS S1 Own Workforce reporting standard Disclosure Requirement – Health and safety indicators. Where applicable they have to be broken down between employees and non-employees
Non-Employees refer to contractors in the context of these requirements.
(a) the percentage of own workers who are covered by the undertaking’s health and safety management system based on legal requirements and/or recognised standards or guidelines;
(b) the number of fatalities as a result of work-related injuries and work-related ill health;
(c) the number and rate of recordable work-related accidents;
(d) the number of cases of recordable work-related ill health; and
(e) the number of days lost to work-related injuries and fatalities from work-related accidents, work-related ill health and fatalities from ill health.
Requirement a)
This one is pretty straightforward, you have to indicate % of employees under H&S management system. Unless you have excluded part of the business from your system scope, most likely 100% of employees will be covered.
When the health and safety management system, or certain parts thereof, has been subject to an internal audit or external certification, you may state this fact, or absence thereof, and the underlying standards for such audits/certifications, as applicable.
Requirement b)
This requirement seems straightforward, but "fatality" has not been defined, which means they have not specified a timeframe after which a death is counted as a work-related fatality. If someone dies, for example, after few weeks from the injury, you should decide yourself if to count this. As a rule of thumb I would use 6 months as a timeframe.
Fatalities may be reported separately for those resulting from work-related injuries and those resulting from work-related ill health.
Work-related injuries and work-related ill health arise from exposure to hazards at work.
Notwithstanding, other types of incidents can occur that are not connected with the work itself.
For example, the following incidents are not considered to be work related:
(a) a worker suffers a heart attack while at work that it is not connected with work;
(b) a worker driving to or from work is injured in a car accident (when driving is not part of the work and where the transport has not been organised by the undertaking); and
(c) a worker with epilepsy has a seizure at work that it is not connected with work.
With regard to travelling for work purposes, injuries and ill health that occur while a worker is travelling are work related if, at the time of the injury or ill health, the worker was engaged in work activities “in the interest of the employer”. Examples of such activities include travelling to and from customer contacts; conducting job tasks; and entertaining or being entertained to transact, discuss, or promote business (at the direction of the employer). If the undertaking is responsible for the transport commuting, incidents occurred while commuting are considered to be work-related. Nonetheless, incidents which arise during travel, outside of the undertaking’s responsibility (i.e. regular commuting to and from work), may be reported separately provided that the undertaking has such data available across the undertaking.
With regard to working from home, injuries and ill health that occur when working from home are work related, if the injury or ill health occurs while the worker is performing work from home; and the injury or ill health is directly related to the performance of work rather than the general home environment or setting.
With regard to mental illness, it is considered to be work related, if it has been notified voluntarily by the worker and it is supported by an opinion from a licensed healthcare professional with appropriate training and experience; and if such opinion states that the illness is work related.
Health issues resulting, for example, from smoking, drug and alcohol abuse, physical inactivity, unhealthy diets, and psychosocial factors unrelated to work are not considered work-related.
Occupational diseases are not considered work-related injuries but are covered under work related ill health.
Requirement c)
This one is an interesting one as the rate must include both injuries and ill-health, whereas most organisations in their rates include only injuries, e.g LTIF or similar.
Standard states that an incident that results in injury or ill health is often referred to as an “accident” (see Annex II)
Recordable work-related injury or ill health is a work-related injury or ill health that results in
any of the following:
- death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness; or
- significant injury or ill health diagnosed by a physician or other licensed healthcare professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.
This aligns with OSHA requirements.
In computing the rate of work-related injuries, your organisation must divide the respective number of cases by the number of total hours worked by your own workers and multiply by 1,000,000. Thereby, these rates represent the number of respective cases per one million hours worked. A rate based on 1,000,000 hours worked indicates the number of work-related injuries per 500 full-time workers over a one-year timeframe. For comparability purposes, a rate of 1,000,000 hours worked should also be used for organisations with less than 500 workers.
If your organisation cannot directly calculate the number of hours worked, it may estimate this on the basis of normal or standard hours of work, taking into account entitlements to periods of paid leave of absence from work (e.g., paid holidays, paid sick leave, public holidays) and explain this in its disclosures. Therefore, you can calculate hours from the FTEs worked.
You must include fatalities as a result of work-related injury in the calculation of the number and rate of recordable work-related injuries.
Requirement d)
This one needs interpretation of ill-health. I suggest always referring here to the ILO List of Occupational Diseases.
Work-related ill health can include acute, recurring, and chronic health problems caused or aggravated by work conditions or practices. These include musculoskeletal disorders, skin and respiratory diseases, malignant cancers, diseases caused by physical agents (e.g., noise induced hearing loss, vibration-caused diseases), and mental illnesses (e.g., anxiety, posttraumatic stress disorder). For the purpose of the required disclosures, you can, at a minimum, include in your disclosure those cases outlined in the ILO List of Occupational Diseases.
In the context of this Standard, work-related musculoskeletal disorders are covered under work-related ill health (and not injuries).
The incidents to be disclosed relate to cases of work-related ill health notified to you or identified by you through medical surveillance, during the reporting period. You might be notified of cases of work-related ill health through reports by affected workers, compensation agencies, or healthcare professionals. The disclosure may include cases of work-related ill health that were detected during the reporting period among former workers.
Requirement e)
You must count the number of days lost as such that the first full day and last day of absence should be included. Days on which the affected individual is not scheduled for work (e.g. weekends, public holidays) do not count as lost days.
My general thoughts about H&S reporting in ESG can be found in this article: https://www.safetainability.com/2025/02/health-and-safety-and-esg-reporting.html.