ESRS S1-14 Health & Safety

The full ESRS S1-14 metric set

ESRS S1-14 requires the following metrics separately for employees and supervised workers (non-employees working under company supervision):

Fatalities: Total number of work-related fatalities during the reporting period. Even zero must be explicitly disclosed — the absence of fatalities is itself a meaningful data point.

High-consequence injuries: Work-related injuries other than fatalities resulting in permanent disability or long-term loss of function — amputations, loss of sight, permanent partial disability. Expressed as both a count and a rate per million hours worked.

Recordable injuries: All work-related injuries requiring medical treatment beyond first aid, restricted work assignment, days away from work, loss of consciousness, or diagnosis of a significant injury. Expressed as Total Recordable Incident Rate (TRIR) = (recordable incidents × 1,000,000) ÷ hours worked.

Lost time injuries: Subset of recordable injuries involving at least one day away from work. Lost Time Injury Rate (LTIR) = (lost time injuries × 1,000,000) ÷ hours worked.

Lost days: Total calendar days lost due to work-related injury and ill health — counting from the day after the injury until the worker returns. Also expressed as a rate per million hours.

Work-related ill health cases: Recordable cases of occupational disease and work-related illness — musculoskeletal disorders, occupational skin disease, noise-induced hearing loss, respiratory disease, work-related stress leading to absence. Count and rate per million hours.

H&S management system coverage: Percentage of employees and supervised workers covered by a certified or otherwise systematic H&S management system (ISO 45001, national equivalent).

Hours worked — the denominator that determines your rate

Every ESRS S1-14 rate is calculated per million hours worked — making the hours worked figure the most important number in the entire H&S disclosure. Errors in hours calculation directly distort every published rate.

Hours worked definition: Total hours actually worked — contracted hours minus absence (sick leave, holiday, parental leave) plus overtime. Do not use contracted hours alone — they overstate actual hours for employees on extended absence and understate for those working significant overtime.

Data sources for hours: Payroll systems (most accurate — record actual pay periods and hours); time and attendance systems (most granular — site-level actual hours); HR estimates using contracted hours minus absence rates (acceptable for companies without time-tracking systems but less accurate).

For supervised workers: hours worked data must be obtained from contractors, agencies, and service providers. Include in site access records or contractor management system. Request annual hours worked certificates from all agencies and contractors providing supervised workers.

Common errors: Using 260 working days × 8 hours for all employees regardless of actual absences (overstates hours for high-absence workforces and understates for overtime-heavy operations); failing to include supervised worker hours (understates denominator and overstates rate); using different hours definitions for TRIR and LTIR calculations (creates internal inconsistency).

Rate cross-check: Once calculated, sense-check rates against sector benchmarks. EU manufacturing sector average TRIR is approximately 8–15 per million hours worked. Construction average is 15–25. If your rate is dramatically different from sector norms without explanation, investigate the calculation before publication — a zero TRIR for a large manufacturing operation is almost certainly an undercount.

Building H&S data infrastructure for assurance

ESRS S1-14 H&S metrics are consistently among the first data sets assurers test — the combination of regulatory significance, financial materiality (insurance, liability), and public interest makes H&S data quality a priority.

Incident recording system: Every recordable incident must be entered into a centralised incident management system — not managed locally by site H&S teams without central visibility. Systems should capture: incident date, location, employee or supervised worker status, injury type, severity (first aid, recordable, lost time), lost days, and investigation status.

Near-miss reporting: Leading companies also track near-misses — incidents that could have caused injury but did not. Near-miss rates are not required by ESRS S1-14 but are leading indicators of incident risk. High near-miss reporting rates actually indicate a positive safety culture (workers report near-misses without fear); low rates may indicate under-reporting.

Supervisor worker incident capture: The most common H&S data gap is supervised worker incidents. Require all contractors and agencies to report incidents involving their workers on your sites to your central incident system within 24 hours. Include incident reporting obligations in contractor agreements. Conduct monthly reviews of contractor incident reports against your site incident log.

Annual H&S data audit: Before finalising ESRS S1-14 data, conduct an internal audit — compare incident management system data to: RIDDOR reports (UK); national accident registers (EU countries with mandatory reporting); insurance claims related to occupational injury; workers' compensation claims. Discrepancies between these sources indicate under-reporting in one system or another.

Assurance evidence pack: Prepare in advance for assurance: incident register extract; hours worked calculation methodology; H&S management system certification documents; supervised worker coverage confirmation from agencies; and year-on-year reconciliation explaining significant changes in rates.

Frequently asked questions