Governments and other bodies regularly consult IOSH on policy issues relating to occupational safety and health. Our Consultation process looks to present policymakers with IOSH members’ opinions about what affects them the most
A matter of principles: The future of corporate reporting – discussion paper
About this consultation
The UK’s Financial Reporting Council (FRC) has issued a discussion paper proposing The future of corporate reporting founded on a principles-based framework. The paper outlines a model for what FRC describe as “a more agile approach to corporate reporting which challenges existing thinking about how companies can more effectively meet the information needs of investors and other stakeholders.”
FRC highlight that companies and society face significant challenges, heightened by the Covid-19 pandemic, and that stakeholders are increasingly interested in companies’ wider actions and the reporting that supports these.
The paper considers a common criticism that corporate annual reports are too lengthy, and that information is difficult to access. FRC intends that its proposals are tested with stakeholders and stimulate discussion about the future landscape of corporate reporting.
Please view FRC’s supporting literature review and the results of the FRC’s initial survey.
The UK’s FRC regulate auditors, accountants and actuaries, and set the UK’s Corporate Governance and Stewardship Codes. It seeks to promote transparency and integrity in business, with its work aimed at investors and others who rely on company reports, audit and corporate risk management.
The FRC is working towards becoming the Audit Reporting and Governance Authority (ARGA), which will require primary legislation. It is looking to implement the recommendations of the Independent Review of the FRC; The Competition and Markets Authority (CMA) review; and Sir Donald Brydon’s review into the quality and effectiveness of audit, using six workstreams as one holistic programme.
The six workstreams are: setting up the new regulator; audit scope & regulation; corporate regulation; corporate reporting; corporate governance; and market reform. Activities include a new governance structure, due in January 2021; enhanced complaints handling processes; and engagement with prospective signatories of the revised UK Stewardship Code, which took effect from 2020, with reporting due in 2021.
The FRC discussion paper proposals include:
- unbundling the existing purpose, content, and intended audiences of the current annual report by moving to a network of interconnected reports;
- a new common set of principles that applies to all types of corporate reporting;
- objective-driven reports that accommodate the interests of a wider group of stakeholders, rather than the perceived needs of a single set of users;
- embracing the opportunities available through technology to improve the accessibility of corporate reporting; and
- a model that enables reporting that is flexible and responsive to changing demands and circumstances.
FRC believes that these proposals are consistent with the themes in the independent Kingman and Brydon reviews. FRC assert that to build trust in the system for corporate reporting, it needs to be supported by a framework for audit and assurance and regulation.
We invite IOSH members to send us comments on FRC’s discussion paper on The future of corporate reporting to email@example.com, to help inform an IOSH submission, by 05 January 2021.
Response to UN Business and Human Rights
About this consultation
On 7 July 2020, the UN Working Group on Business and Human Rights (UNWG) launched a new global project, ‘Business and human rights: towards a decade of global implementation.” Also known as “UNGPs 10+ / Next Decade BHR,” the project is centred around the upcoming tenth anniversary of the UN Guiding Principles on Business and Human Rights (UNGPs), the global authoritative framework on business and human rights that was unanimously endorsed by the UN Human Rights Council in June 2011. See the UN open call for input on UN Guiding Principles on Business and Human Rights – towards a decade of global implementation.
The project is taking stock of practice to date, identifying gaps and challenges, and developing a vision and roadmap for scaling up implementation of the UNGPs over the course of the next decade. The project’s consultation process is being carried out in collaboration with OHCHR, UN Development Programme, and others. The UN Working Group seeks to hear perspectives from a wide range of stakeholders from all regions, including government actors, international organizations, national human rights institutions, industry organizations, businesses, consumer associations, investors, trade unions, representatives of affected communities, indigenous peoples, human rights defenders, civil society organizations, professional associations and groups, academia, and others.
The unanimous endorsement of the Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework by the UN Human Rights Council in June 2011, represented a watershed moment in efforts to address adverse impacts on people resulting from business activities in all sectors. For the first time there was a globally recognized and authoritative framework for the respective duties and responsibilities of Governments and business enterprises to prevent and address such impacts. The Guiding Principles outlined the steps to take in order to meet existing State obligations and normative standards for business, set out under three pillars:
- The State duty to protect against human rights abuses by third parties, including business, through appropriate policies, regulation and adjudication;
- The corporate responsibility to respect human rights, which means to avoid infringing on the rights of others and to address adverse impacts with which a business is involved, by adopting appropriate policies, exercising human rights due diligence and enabling remediation of harms that occur; and
- The need for access to effective remedy for rights-holders when abuse has occurred, through both judicial and non-judicial grievance mechanisms.
All interested stakeholders are invited by the UNWG to:
- Respond to the UN via the “Have your say!” written input survey, to help inform the stocktaking exercise and the roadmap for the next decade. Deadline: 30 November 2020.
- Share brief summaries (2 pages) of relevant materials (e.g., reports, research, other relevant publications). Deadline: ongoing basis until end of February 2021.
All interested stakeholders are invited by the UNWG to address the following questions:
- Where has progress taken place in UNGPs implementation over the course of the last decade? What are the promising developments and practices (by governments, businesses, international organizations, civil society organizations, etc.) that can be built on?
- Where do gaps and challenges remain? What has not worked to date?
- What are key obstacles (both visible and hidden), drivers, and priorities that need to be addressed to achieve fuller realization of the UNGPs?
- What systemic or structural challenges need to be tackled to realize sustainable development based on respect for human rights?
- In concrete terms, what will be needed in order to achieve meaningful progress with regard to those obstacles and priority areas? What are actionable and measurable targets for key actors in terms of meeting the UNGPs’ expectations over the coming years?
- Any other comments?
Psychological health and safety at work: managing psychosocial risks — Guidelines
Please note: You must be an IOSH Member to access the full consultation.
About this consultation
Following the development and publication of ISO 45001: 2918 Occupational health and safety management systems – Requirements with guidance for use, a draft guidance standard on its requirements in respect to Managing psychological health and safety/psychosocial risk within an OHSMS is now available for stakeholder comment.
IOSH, as a Category A Liaison Body to ISO TC 283, will submit feedback comments directly to ISO TC 283 WG2, where we are represented, as well as to the BSI HS/1 Committee for consideration as part of the UK response.
In recognition of the growing need to improve the management of work-related psychosocial risks worldwide, a new work item proposal was agreed by ISO TC 283 and a work group established (WG2), to produce a supporting guidance standard to ISO 45001.
The initial drafting drew on existing work such as BSI / PAS 1010: 2011 Guidance on the management of psychosocial risks in the workplace; CAN/CSA-Z1003-13/BNQ 9700-803/2013 – Psychological Health and Safety in the Workplace; Safe Work Australia 2019 – Work-related psychological health and safety – A systematic approach to meeting your duties; and Australian Human Rights Commission 2010 – Workers with mental illness: a practical guide for managers.
This new psychosocial risk standard aims to provide systematic guidelines for employers that will enable them to promote, develop, and continually improve the management of psychosocial risks, contributing to safer and healthier working environments.
The draft guidelines format reflects the ISO high-level structure for management systems, to align to ISO 45001 and covers scope, normative references, terms and definitions and then context of the organisation, leadership and worker participation, planning, support and operation. The document closes with sections on performance evaluation and management review and improvement.
We invite IOSH members to send us feedback comments on the draft, using the response template provided by 18 September 2020 – these can be general, technical or editorial. The draft is strictly ISO copyright protected and is only accessible to IOSH members for consultation purposes.
Members need to log into MyIOSH for access to the draft guidelines for review and comment. When using the comment template, please include your name and all the relevant details related to your comment, including clause and paragraph number, why you’re proposing a change and what the suggested change is.
Respondents should note that the overall structure and top-level headings of the standard are now agreed, and no further changes will be made to these. Also that, unfortunately, we’re unable to consider comments submitted after the stated deadline or not on the comment template.
Comments should be sent to firstname.lastname@example.org.
A renewed Trade Policy for a stronger Europe – Consultation note
About this consultation
In June 2020, the European Commission launched a major review of EU Trade Policy, including a public consultation seeking input from the European Parliament, Member States, stakeholders and civil society. It provides a paper ‘A renewed trade policy for a stronger Europe – consultation note', which includes 13 consultation questions. The results of the consultation will feed into a communication, to be published towards the end of the year.
The European Commission aims to build consensus around fresh medium-term direction for EU trade policy, responding to a variety of new global challenges and taking into account the lessons learned from the coronavirus crisis.
The European Commission’s aims include a trade and investment policy that supports economic recovery, the creation of quality jobs, protection from unfair practices and coherence related to sustainability, climate change, the digital economy and security. The consultation covers all relevant topics to EU trade policy, with a stated special focus on the following:
- Building a resilient and sustainable EU economy after the coronavirus
- Reforming the World Trade Organisation
- Creating global trade opportunities for businesses and in particular SMEs
- Maximising the contribution of trade policy to addressing key global challenges, such as climate change, sustainable development or the digital transition
- Strengthening of trade and investment relationships with key trading partners
- Improving the level playing field and protecting EU business and citizens
There are 13 consultation questions from the European Commission, as follows:
- How can trade policy help to improve the EU’s resilience and build a model of open strategic autonomy?
- What initiatives should the EU take – alone or with other trading partners - to support businesses, including SMEs, to assess risks as well as solidifying and diversifying supply chains?
- How should the multilateral trade framework (WTO) be strengthened to ensure stability, predictability and a rules-based environment for fair and sustainable trade and investment?
- How can we use our broad network of existing FTAs or new FTAs to improve market access for EU exporters and investors, and promote international regulatory cooperation ̶ particularly in relation to digital and green technologies and standards in order to maximise their potential?
- With which partners and regions should the EU prioritise its engagement? In particular, how can we strengthen our trade and investment relationships with the neighbouring countries and Africa to our mutual
- How can trade policy support the European renewed industrial policy?
- What more can be done to help SMEs benefit from the opportunities of international trade and investment? Where do they have specific needs or particular challenges that could be addressed by trade and investment policy measures and support?
- How can trade policy facilitate the transition to a greener, fairer and more responsible economy at home and abroad? How can trade policy further promote the UN Sustainable Development Goals (SDGs)? How should implementation and enforcement support these objectives?
- How can trade policy help to foster more responsible business conduct? What role should trade policy play in promoting transparent, responsible and sustainable supply chains?
- How can digital trade rules benefit EU businesses, including SMEs? How could the digital transition, within the EU but also in developing country trade partners, be supported by trade policy, in particular when it comes to key digital technologies and major developments (e.g. block chain, artificial intelligence, big data flows)?
- What are the biggest barriers and opportunities for European businesses engaging in digital trade in third countries or for consumers when engaging in e-commerce?
- In addition to existing instruments, such as trade defence, how should the EU address coercive, distortive and unfair trading practices by third countries? Should existing instruments be further improved or additional instruments be considered?
- What other important topics not covered by the questions above should the Trade Policy Review address?
IOSH has been pleased to respond, based on our recent submission to the UN-WTO Policy Hackathon on Trade.
Response to the European Commission White Paper on Artificial Intelligence
About this consultation
Aiming to promote the uptake of artificial intelligence (AI) while at the same time, addressing the risks associated with its use, the European Commission has proposed a White Paper with policy and regulatory options “towards an ecosystem for excellence and trust”. This document was published on 19 February 2020, along with an online survey, focusing on three distinct topics:
- Specific actions for the support, development and uptake of AI across the EU economy and public administration;
- Options for a future regulatory framework on AI;
- Safety and liability aspects on AI (as outlined in the relevant report)
As digital technology becomes an ever more central part of every aspect of people’s lives, people should be able to trust it. Artificial Intelligence will change our lives by improving healthcare (e.g. making diagnosis more precise, enabling better prevention of diseases), increasing the efficiency of farming, contributing to climate change mitigation and adaptation, improving the efficiency of production systems through predictive maintenance, increasing the security of Europeans, and in many other ways that we can only begin to imagine.
At the same time, Artificial Intelligence (AI) entails a number of potential risks, such as risks to safety, gender-based or other kinds of discrimination, opaque decision-making, or intrusion in our private lives.
The current public consultation comes along with the White Paper on Artificial Intelligence - A European Approach aimed to foster a European ecosystem of excellence and trust in AI and a Report on the safety and liability aspects of AI. The White Paper proposes:
- Measures that will streamline research, foster collaboration between Member States and increase investment into AI development and deployment;
- Policy options for a future EU regulatory framework that would determine the types of legal requirements that would apply to relevant actors, with a particular focus on high-risk applications.
These are the key consultation questions from the European Commission that IOSH has contributed to:
Section 1 - An ecosystem of excellence
- Are there any other actions to strengthen the research and innovation community that should be given a priority?
Section 2 - An ecosystem of trust
- In your opinion, how important are the following concerns about AI; Do you have any other concerns about AI that are not mentioned above?
- Do you think that the concerns expressed above can be addressed by applicable EU legislation? If not, do you think that there should be specific new rules for AI systems?
- If you think that new rules are necessary for AI system, do you agree that the introduction of new compulsory requirements should be limited to high-risk applications; If you wish, please indicate the AI application or use that is most concerning (“high-risk”) from your perspective.
- What is the best way to ensure that AI is trustworthy, secure and in respect of European values and rules?
Section 3 – Safety and liability implications of AI, IoT and robotics
- The current product safety legislation already supports an extended concept of safety protecting against all kind of risks arising from the product according to its use. However, which particular risks stemming from the use of artificial intelligence do you think should be further spelled out to provide more legal certainty?
- Do you think that the safety legislative framework should consider new risk assessment procedures for products subject to important changes during their lifetime?
For more information, please download IOSH's consultation response references.
Response to the European Commission Europe’s Beating Cancer Plan
About this consultation
Every year, 3.5 million people in the EU are diagnosed with cancer, and 1.3 million die from it. Over 40% of cancer cases are preventable. Without reversing current trends, it could become the leading cause of death in the EU. On 7 February 2020, The European Commission under the stewardship of the Commissioner for Health and Food Safety launched a public consultation on Europe’s beating cancer plan. This initiative aims to reduce the cancer burden for patients, their families and health systems. It will address cancer related inequalities between and within Member States with actions to support, coordinate and complement Member States’ efforts.
The Commission intends to design the plan to cover the entire cycle of the disease. Actions should span all steps of the disease, including prevention, early diagnosis, treatment, and the social dimension of cancer (encompassing life after cancer, return to work after cancer…)
The Commission would like to hear views on laws and policies currently in development in this area, for that purpose they published a roadmap describing their approach to the issue.
Drawing on the input provided, the Commission will go on to complement this initial public consultation with further targeted interactions with specific stakeholder groups.
In the responses that are attached to this consultation, IOSH focuses on the need to reduce exposures to work-related carcinogens and prevent occupational cancers.
There are 7 consultation questions from the European Commission, as follows:
- What do you think citizens can do to help beat cancer?
- What do you think health professionals can do to help beat cancer?
- What do you think public authorities / national governments can do to help beat cancer?
- Do you support the idea that the EU should do more to address cancer?
- Do you know or have experience of any particularly good practice in supporting cancer survivors, or so you have any suggestions as to how this could be done?
- How can your organisation contribute to the EU plan on cancer?
- Is there anything else that you would like to add that has not been covered in this consultation?
IOSH has been pleased to respond, based on the advocacy work through its No Time to Lose campaign at www.notimetolose.org.uk , which highlights the need for action to reduce the estimated 742,000 global annual deaths due to work-related cancers and focuses on raising awareness of practical steps to reduce exposures to four major occupational carcinogens: diesel engine exhaust emissions, solar radiation, silica dust and asbestos.
WBG Environmental, Health and Safety (EHS) Guidelines revision
Human Capital Indicators
The ONS is reviewing how it measures human capital in the UK and is seeking views on its proposals for a new indicator-based, dashboard approach, focusing on possible measures, rather than existing data.
It defines human capital as a measure of the skills, knowledge and experience of an individual or population which can be applied in the economy or in society at large. And it explains that human capital is widely recognised as a driver of productivity and helps people achieve their needs and wants and improve their well-being.
The ONS proposes taking an indicator-based approach, supplementing existing human capital estimates with a wider suite of indicators. This is intended to allow a broader consideration of the factors that impact on people’s skill and knowledge development throughout their lives, as well as starting to consider the impact human capital has on other outcomes, such as on health and well-being.
Raising the Bar: Improving competence, Building a safer future
Raising the Bar is an interim report and responds to Dame Judith Hackitt’s competence recommendations in Building a Safer Future, published in May 2018 in the wake of the Grenfell Tower tragedy. It presents what it intends as a blueprint for improving the competence of those involved in designing, constructing, inspecting, assessing, managing and maintaining Higher Risk Residential Buildings (HRRBs), and other buildings in scope, to ensure they are safe for all who occupy them.
Advancing our health: prevention in the 2020s
About this consultation
The commitments outlined in this Green Paper are intended to signal a new preventive approach for the health and care system in England. It aims to ensure that Government, both local and national, works with the health and care system, to put prevention at the centre of all their decision-making. The Government urges that for it to succeed, and for the NHS to be transformed and the nation's health improved over the next decade, individuals and communities must play their part too. It emphasises that health is a shared responsibility and only by working together can the vision of healthier and happier lives for everyone be achieved.