CSRD Health & Safety (ESRS S1-14)
ESRS S1-14 requires companies to disclose health and safety performance metrics — fatalities, injury rates, lost time, and work-related illness. These are among the most scrutinised social metrics in CSRD reports, with direct implications for regulatory compliance, insurance, and investor ESG ratings.
ESRS S1-14 requires companies to disclose health and safety performance metrics — fatalities, injury rates, lost time, and work-related illness. ESRS S1-14 requires disclosure of the following health and safety metrics, separately for employees and supervised workers (contractors under your supervision):.
The ESRS S1-14 metrics — what you must disclose
ESRS S1-14 requires disclosure of the following health and safety metrics, separately for employees and supervised workers (contractors under your supervision):
Fatalities: Total number of work-related fatalities during the reporting period. Zero must be disclosed explicitly — the absence of fatalities is itself a disclosure.
High-consequence injuries: Number of work-related injuries other than fatalities that result in permanent disability or long-term loss of function — permanent partial disability, loss of limb or organ function.
Recordable injuries: Total number of recordable work-related injuries — any injury requiring medical treatment beyond first aid, restricted work, days away from work, or loss of consciousness. Also expressed as a rate per million hours worked (Total Recordable Incident Rate — TRIR).
Lost days: Total number of working days lost due to work-related injuries and ill health.
Work-related ill health cases: Number of recordable cases of work-related ill health — occupational disease, work-related stress, musculoskeletal disorders. Also expressed as a rate.
Health and safety management system coverage: Percentage of employees and supervised workers covered by a health and safety management system (ISO 45001, OHSAS 18001, or equivalent).
Calculating injury rates — the per million hours basis
ESRS S1-14 uses a rate per million hours worked — different from GRI 403 which uses per 200,000 hours. The million-hour basis makes comparisons easier for large companies.
TRIR (Total Recordable Incident Rate) = (Number of recordable incidents × 1,000,000) ÷ Total hours worked.
LTIR (Lost Time Injury Rate) = (Number of lost time injuries × 1,000,000) ÷ Total hours worked.
Fatality rate = (Number of fatalities × 1,000,000) ÷ Total hours worked.
Hours worked calculation: Total contracted hours for all employees and supervised workers during the reporting period. Include overtime. For contractors, use contracted hours from contractor management system or estimate from headcount × average weekly hours × working weeks.
For companies that previously used GRI 403 per-200,000-hour basis: multiply your GRI rate by 5 to get the ESRS S1-14 per-million-hour equivalent. Disclose the rate basis to avoid confusion in year-on-year comparisons during the transition.
Contractor H&S data — the most common gap
ESRS S1-14 requires H&S metrics separately for employees AND supervised workers — contractors working under your supervision, on your sites, using your equipment or procedures.
The data gap: Most companies track employee H&S incidents through HR systems. Contractor incidents are frequently not captured — contractors may report to their own employer's H&S system without notifying the client company, particularly for minor injuries.
Building contractor H&S data: Require all contractors working on your sites to report incidents to your H&S management system as a condition of site access. Include contractor H&S incident reporting in your contractor management procedures and pre-qualification questionnaire. Establish a site incident log that captures all incidents regardless of employment status.
For first-time ESRS reporters: if contractor H&S data is genuinely unavailable for the first reporting year, disclose this limitation with a plan to collect it going forward. Assurers can accept first-year data gaps where they are disclosed transparently and a data collection plan exists. Do not estimate contractor incident rates without a documented methodology.
Frequently asked questions
Do we include commuting accidents in ESRS S1-14?
No — ESRS S1-14 covers work-related injuries only. Commuting accidents (travelling between home and workplace) are not work-related under most national H&S definitions and should be excluded from ESRS S1-14 metrics. In-scope travel includes business travel between work locations and travel as part of the job (delivery drivers, field service engineers).
What if we had zero recordable incidents — do we still report S1-14?
Yes — zero must be reported explicitly. A company with no recordable incidents should disclose: zero fatalities, zero high-consequence injuries, zero recordable injuries (TRIR = 0), zero lost days, and the H&S management system coverage percentage. The zero is itself meaningful information that readers should be able to confirm.
How does ESRS S1-14 interact with mandatory national H&S reporting?
National H&S reporting requirements (RIDDOR in UK, national accident reporting registers in EU member states) use different definitions and rate bases than ESRS S1-14. Your national regulatory filings are the primary source data for ESRS S1-14 — but the metrics must be recalculated to the ESRS format (per million hours, including supervised workers) rather than copied directly from regulatory submissions.