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       Hazards, number 155, 2021
SUICIDAL | HSE must recognise, record and investigate work-related suicides
Announcing new, higher work fatality figures, Health and Safety Executive (HSE) boss Sarah Albon noted “every loss of life is a tragedy.” But work-related could suicides kill many more, and Albon insists it is not HSE’s job to record or investigate these deaths. Hazards editor Rory O’Neill explores why, for HSE, not every tragedy counts.

 

The problems at work were not going away. Chloe English, 24, from Brighouse, West Yorkshire, was on the edge. The call centre worker went missing on 14 May 2021. She was seen by a passerby climbing a fence and jumping from Halifax’s North Bridge. She died instantly in the fall from the Victorian iron and stone structure.

Chloe's GP told a September 2021 inquest: “It appeared she was suffering from increasing stress at work and had put in a formal grievance against the team leader and felt the relationship had broken down. She felt work was worsening her anxiety and going into work made her feel nauseous.”

Chloe’s work-related suicide was a tragedy – but not a rarity. Research suggests hundreds of suicide deaths in the UK each year could be related to work factors. High on the list would be management pressure and unfairness, job insecurity, bullying, stress, long hours, trauma and a lack of support (Hazards 141).

But unlike other workplace fatalities that would trigger an immediate Health and Safety Executive (HSE) probe, the government safety regulator has refused repeatedly to change its practices to record and investigate suicides linked to work.

Deathly silence

The US does it. France does it. And Japan does it. But HSE continues to give a flat no to calls for it to recognise, record and investigate work-related suicides.

Leeds University professor Sarah Waters, who has studied and written extensively on the issue, told Hazards “it is standard practice cross most European systems for suicides in the workplace to be recorded in the interests of public health and workplace safety. Such data have been collected in the United States since 1992.”

The US Bureau of Labor Statistics’ Census of Fatal Occupational Injuries (CFOI) released in December 2020 records 307 work-related suicide deaths in the most recent reporting year, topping the previous year’s ‘historic high’ of 304 deaths.

For a workplace suicide to be included in the US CFOI, the suicide must have occurred on the work premises or off the work premises but with a ‘definitive’ link back to work.

The US system is conservative. The BLS says an example of a definitive link to work would be a suicide note that mentions work was a factor in the suicide. But it says: “Suicides are usually considered to be multicausal, meaning that a number of factors (eg. health, personal life, professional life, etc) factor into suicide. For this reason, suicides that occur off the work premises need to be conclusively linked to work to be included in CFOI.”

Nonetheless, this US approach, using a very restrictive definition of work-related suicide, suggests there is likely to be a large problem at work in the UK that remains unseen and unaddressed.

Waters has urged HSE repeatedly over several years to revise its policy on reporting and investigation (Hazards 137), by learning from practices elsewhere and adapting existing approaches to incorporate suicides. But whatever proposal Waters put to HSE, the regulator’s response was no. It’s reason? It’s ‘complex’.

Desperate picture

In France, five defining criteria determine whether a suicide should be classified as work-related: a suicide in the workplace; a suicide note blaming work; a victim in work uniform; testimonies of the bereaved pointing to work-related factors; and known difficulties at work prior to the suicide.

A 2021 study from the French ministry of health that investigated 1,135 suicides found 10 per cent of all suicides examined were, using these official recognition criteria, potentially work-related. In cases where the employment status was known, 28.3 per cent were employed at the time of the suicide. Of these, work appeared to have played a role in 42 per cent [see: One in 10 suicides in France is work-related].

If UK suicides followed the same pattern as the French, the 10 per cent figure would equate to over 400 suicides in working age people meeting those work-related qualifying criteria, with around 140 of those currently in work – around the same number as reportable work fatalities each year in Great Britain.

“Work factors could be the difference between transitory depression and terminal despair”

The more restrictive US system would translate to around between 50 and 60 cases a year, but this would still make suicide by far the most common single cause of work-related traumatic death in Great Britain, ahead of workers falling from height, being struck by a moving vehicle or being struck by a moving object.

Suicide rates by occupation in the UK show a similar pattern to fatalities, with ‘managers, directors and senior officials’ having the lowest rate, and ‘unskilled occupations’ the highest, approaching three times the rate for the top grades.

Leeds University research published in July 2021 and co-authored by Waters with Hilda Palmer, examined in detail 12 UK recent suicide cases from different occupations and sectors.  In 11 of the 12 suicides investigated, organisational or managerial workplace factors were identified as “a dominant causal factor.”

This and the occupational class gradient in suicides may not be conclusive proof, but it is certainly suggestive evidence that work-related risks are a significant contributory factor.

It is a notion lent credibility by recent US studies. An August 2021 paper published in the Annals of Work Exposures and Health found: “Workers in occupations with higher injury and illnesses rates and more job insecurity had higher rates of deaths of despair, especially opioid-related deaths. Rates of deaths of despair increased most rapidly for occupations with increasing prevalence of workers employed in non-standard work arrangements.”

It concluded “efforts should be made to address these factors, which also represent known or suspected hazards for other adverse health outcomes.”

And a 24 January 2020 US government report on suicide rates by industry and occupation, published in the Centers for Disease Control’s Morbidity and Mortality Weekly Report, noted a sharp class gradient in suicide risk, with blue collar workers at highest risk of death by suicide.

Death watch

The UK could, by failing to prioritise work-related suicide recognition and prevention methods, be standing by and watching as workers die.



ACTION! Use the Hazards e-postcard to tell the HSE to recognise, record and take action to prevent work-related suicides. www.hazards.org/hsesuicide

It is prevention deficit specialist US organisations are seeking to address. In 2019 national guidelines, a trio of US advocacy groups – the American Association of Suicidology (AAS), the American Foundation for Suicide Prevention and United Suicide Survivors International – called on employers to take a proactive role in suicide prevention in the workplace.

American Association of Suicidology executive director Colleen Creighton said: “We aim to change the culture of workplaces to reduce elements that cause job strain like sleep disruption, job insecurity and low job control – things shown to be connected to suicide risk,” adding: “We know these guidelines will not only save lives, but will also alleviate intense emotional suffering by making changes to systems while helping individuals in the workplace.”

These are also straightforward workplace risk factors that should be subject to scrutiny by workplace safety regulators, and action to ensure they are addressed.

HSE’s operational guidance to its inspectors on responding to ‘Matters of Evident Concern and Potential Major Concern’ – MECs and MPMCs – gives explicit instructions to this effect. This HSE Operational Circular (OC) notes: “This OC contains instructions for FOD staff that require them to consider at site visits whether there are risks normally requiring immediate formal enforcement action (MECs) or other risks present that could lead to multiple fatalities or multiple causes of ill-health and, if so, take appropriate action. These high consequence events are designated as MPMCs.”

The safety regulator envisages a broad application of this requirement. HSE’s inspection guidance on dermatitis, for example, says: “In addition during inspection visits, inspectors should proactively consider if there are hazards which have the potential to cause multiple cases of dermatitis (Matter of Potential Major Concern or MPMC).”

The same approach could be used to trigger investigations of work-related suicides, suicide patterns or evidence of suicide ideation (suicidal thoughts), enabling action to prevent the fatal and non-fatal work-related causes. HSE already has an extensive library of internal guidance for inspections, broken down by topic, from the specific – “lightning protection at onshore hazardous installations” –  to the general – Dermal exposure to hazardous substances: Prevention of dermatitis. So, why not add work-related suicides to the list? It would seem reasonable to expect saving someone’s neck to be at least as high a priority as saving someone’s skin.

You don’t have to look too hard to find examples where these interventions could be justified. In 2019, Unite warned that the Hinkley Point nuclear power station, Europe’s biggest construction project, was grappling with a mental illness crisis. The union said it was raising its concerns following a ‘surge’ in suicide attempts that year, adding there had been several attempted suicides since work began in 2016.

In 2018, accountancy lecturer Dr Malcolm Anderson left two notes before he fell from the university building in which he worked – one to his family and another referring to work pressures and long hours (Hazards 146). The lecturer’s death at 48 prompted more than 600 members of staff to sign an open letter to the university's vice-chancellor, executive board and council, urging them to safeguard others from pressures of excessive workloads. Internal surveys had found a third of staff reported having to work unreasonable hours to fulfil their job requirements.

The university responded by putting locks on windows, causing consternation among staff. “We need action and fundamental change, none of it can be changed unless we do,” one lecturer told Wales Online in 2019. “It's just the futility and ridiculous nature of it, it's just tokenistic. It's insulting to the memory of Mr Anderson.” The staff member, who asked not to be named, added: “It's quite shocking really. They've installed these locks but they've not addressed the reasons behind it.”

Dr Anderson’s death was not the first lecturer suicide on Cardiff University premises to be linked to work factors. Eminent entomologist Dr Mark Jervis, 62, who had struggled with problems at work and a spiralling workload, killed himself in his 6th floor office of the university’s School of Biosciences on 11 March 2014. Medical evidence to the inquest confirmed the respected scientist, who cut his wrists at his desk, was suffering from work-related stress and anxiety.

Both deaths would have to be reported, recorded and counted as work-related under the US and French systems. Investigating and addressing the endemic work pressures at Cardiff University implicated in Dr Jervis’s death might have helped prevent Dr Anderson’s suicide less than four years later.

Doing nothing

Prof Waters has been corresponding with HSE for several years, urging the regulator to revise its approach to work-related suicide. HSE has remained resolute in its determination to give no ground.

Late in 2019, Waters asked HSE to forward to its independent Workplace Health Expert Committee (WHEC) – HSE serves as the secretariat – a Statement to HSE on work-related suicides authored by a panel of researchers from 16 universities and occupational and public health research agencies in seven countries. Waters was one of the signatories. The expert statement called on HSE “to rectify a grievous blindspot that excludes suicide from the list of work-related accidents that are subject to reporting and inspection requirements” (Hazards 148).

HSE refused. In a 14 January 2020 response to Waters, the HSE secretariat wrote “we are not offering to refer this matter to WHEC at the present time.”

Waters then bypassed the secretariat and approached WHEC’s independent chair, Professor Sir Anthony Newman Taylor, directly. He agreed immediately to “undertake an investigation of the evidence linking work and suicide.”

“Work suicide
should not be treated less seriously by HSE than skin rashes, asthma or strains”

HSE chief executive Sarah Albon, however, continues to insist that addressing workplace suicide is not in its remit. In a 9 August 2021 response to Waters on amending the list of deaths reportable by employers under the RIDDOR regulations to incorporate suicides, Albon noted there were “significant complexities.”

The letter stated suicides should be left to coroners “who can look at a wide range of factors and can fully consider the often-complex circumstances surrounding someone taking their own life.” Albon noted “in these tragic instances” the coroner has the key role “in identifying the reasons why an employee may have taken their own life.”

But coroners investigate other work fatalities, says Waters, “which nonetheless are still reportable by employers under RIDDOR, and which unlike workplace suicides are included in the reporting systems informing HSE’s investigation and prevention priorities.”

Adapting HSE’s already established formal agreement with coroners to better identify and record work-related suicides wouldn’t be complex.

HSE’s enforcement guide notes: “It is important that HSE and the Coroner benefit from an effective working relationship, which is now underpinned by the Memorandum of Understanding between HSE and the Coroners' Society.” A tweak to this MOU could incorporate criteria defining potential work-related suicide – based on the already established French or US systems for example – and triggering a ‘preventing future deaths report’ to HSE.

This only happened in three of the 12 studies considered in the Leeds University study, despite the analysis finding organisational or managerial workplace factors were a “dominant causal factor” [see: Dying from neglect].

Even under the existing system, ‘complexities’ don’t obviate a work-related contribution which could and should have been addressed by the employer and by HSE. Work factors could be the difference between transitory depression and terminal despair.

Further, some jurisdictions, like the state of Victoria in Australia, use data from both coroners and other sources to determine work-relatedness. The criteria for classification of a death as a work-related suicide must include at least one of: Suicide means was work related; work stressors were identified in police reports to the Coroners or the Coroner's finding; the suicide method involved another person's work (eg. rail suicide, heavy vehicle) or; the suicide location was a workplace.

Having coronial involvement need not be an alternative to an HSE role; Victoria-style coding in coroners’ database could complement HSE’s involvement and feed into the regulator’s fatality statistics.

A similar split system already exists for the asbestos cancer mesothelioma, where figures are sourced from death and cancer registrations but published by HSE.

Driven to suicide

Waters’ proposal that HSE include suicides in the joint Work-Related Deaths Protocol signed by HSE, other regulators, police and prosecution authorities was also swiftly despatched by the HSE chief executive. Albon’s letter noted the protocol was concerned with “criminal investigations” and “suicide is not a crime in law.”

It is true to kill yourself is no longer a crime – people no longer ‘commit’ suicide – but to drive someone through work pressure or brutal management practices to take their own life certainly could be.

It was a role recognised by the French courts in 2019, when three former bosses of a privatised French telecoms giant were jailed for crimes related to a spate of worker suicides. Didier Lombard, the ex-CEO of French Telecom, and two former executives were convicted over a restructuring policy linked to suicides among employees (Hazards 149).

A second French case is pending. Four hospital managers in Paris are to stand trial for ‘harcèlement moral’ – 'moral harassment', or management bullying – in relation to the suicide of Jean-Louis Mégnien. On 17 December 2015, the 54-year-old cardiology professor  threw himself from a seventh floor window of the Georges-Pompidou European Hospital (HEGP).

This is not a French disease. Amnesty International ‘dissolved’ its senior leadership team in 2019, with five top managers, some based at its London HQ, departing. The move was in response to a report that concluded they had created a ‘toxic workplace’. Amnesty commissioned the independent review following two staff suicides.

“For Sarah Albon, there are ‘significant complexities; preventing work-related suicides from being reported,” said Waters. “The HSE's intransigence means that opportunities to prevent avoidable deaths are being missed.”

Sarah Waters isn’t the only one perplexed by the nothing doing response from HSE’s chief executive.

Steve Tombs, professor of criminology at the Open University, also believes HSE has got it wrong on both reporting and on investigations and related enforcement action. He said despite the “international exemplars” on reporting, prior experience made it inevitable “HSE will still resist doggedly.”

He cited HSE’s ongoing refusal to add work-related road traffic fatalities to the official workplace death count. Tombs said his sense was HSE’s resistance was “about protecting scare resources (mostly investigative). More latterly I suspect this is simply the fact that HSE has in effect given up being – or having to maintain the pretence of being – an enforcement body.”  HSE’s MOU with the Coroners’ Society makes explicit mention of HSE’s ‘limited resources’.

Prof Tombs was similarly concerned by the interpretation of the work-related deaths protocol by both HSE and the police. He said the institutional reluctance to bring manslaughter charges after workplace deaths meant “it is almost unimaginable (to me) that a suicide would find its way into the organisational mindset of HSE or the police as a potential ‘serious criminal offence’.”

Bad business

Business as usual should not be an option for HSE. HSE estimates in 2019/20 there were 828,000 workers in Great Britain suffering from work-related stress, depression or anxiety, far-and-away the most common work-related health problem in Great Britain. Cases are at a record high and rising sharply. Fail to deal with it and the desperation will, at least for some, become too much.

“Because suicides are not reported or investigated, the factors that have led to one suicide continue to pose a serious risk to all other employees in the same organisation,” said Waters. “We will continue to campaign at local, national and international level until the HSE takes responsibility for regulating work-related suicides and preventing further deaths.”

HSE’s expert committee WHEC also sees the value of preventive action at work, falling squarely on HSE’s patch.

Work-related suicide, WHEC’s September 2021 report – the result of an investigation proposed by Waters but opposed by HSE – concluded: “Given that employers have a responsibility to assess and manage psychosocial risks and prevent psychological as well as physical harm, it would seem appropriate to suggest that any worker’s suicide should be a prompt for their employer to conduct an additional investigation of psychosocial workplace risks and control mechanisms.

“Alongside ‘postvention’ activities and minimising access to means of suicide, this could be a way to reduce risk of suicide and other psychosocial harm to the late worker’s colleagues.”

Every work-related suicide is a tragedy, but lessons could at least be learnt to protect others.  That would require HSE to accept work factors contributing to suicide should not be treated less seriously in its reporting and investigation processes than those that cause skin rashes, asthma or strains.

But HSE remains resolute that’s the way it should be, with unconscionable consequences.

Resources

Work and suicide: A TUC guide to prevention for trade union activists.
‘Don’t despair’, Hazards’ pin-up-at-work suicide prevention poster.
Hazards work-related suicide webpages.
National Guidelines for Workplace Suicide Prevention, American Association of Suicidology (AAS), the American Foundation for Suicide Prevention and United Suicide Survivors International, October 2019.






 


One in 10 suicides in France is work-related

One in 10 suicides in adults in France is related to work, a new government study has found, with the proportion much higher in those in work. The report from the French ministry of health, Santé publique France, also provides a definition of ‘work-related suicide’ for the purposes of identifying cases for further investigation by workplace health and safety inspectors.

Any of five criteria is used to identify a potential work-related suicide that is automatically subject to investigation: A suicide in the workplace; a suicide note blaming work; a victim in work uniform; testimonies of bereaved pointing to work-related factors; and known difficulties at work prior to the suicide.

Information on 1,135 suicides was collected by eight participating coroner’s offices (Instituts médico-légaux) between 1 January and 31 December 2018. The newly published findings reveal 10 per cent of all suicides examined were potential work-related according to the five defining criteria. Of those whose employment status was known, 28.3 per cent were employed at the time of death. Of these, work appeared to have played a role in 42 per cent of suicides.

• Surveillance des suicides en lien potentiel avec le travail, Santé publique France, August 2021.

Dying from neglect

There is concerning evidence of a high and growing contribution of work to overall suicide rates. Leeds University research co-authored by Sarah Waters with Hilda Palmer and published this year analysed 12 UK suicide cases over the period 2015 to 2020 from different occupations and sectors. In 11 of the 12 suicides investigated, organisational or managerial workplace factors were identified as a dominant causal factor.

The study, funded by Research England, found that employee suicides are still largely treated as an individual mental health problem that has no direct relevance for work or the workplace.

It points to serious regulatory gaps, noting: “There are no Health and Safety Executive (HSE) inspections of workplaces following a single suicide or multiple suicides by employees linked to factors at their workplace; there is no information collected on suicides that occur in the workplace or that are identified as work-related; and that suicide is excluded from the Joint Protocol on Work-related Deaths.”

The authors added: “Employers are not obliged to undertake an investigation following a suicide, implement any changes to workplace policies or practices or put suicide prevention measures in place.” The employer launched an independent investigation into the suicide(s) to identify and address underlying causes in only 4 of the 12 suicide cases investigated.

A coroner’s Preventing Future Deaths report was only issued in three of the cases, despite material evidence of work-related causality in all 12 cases. In nine of the cases, the employer was aware of work-related problems affecting the employee prior to the suicide, as these had been reported to managers or colleagues or documented in staff appraisals.

The paper recommends including suicide in the list of work-related deaths that must be reported to the HSE under the RIDDOR reporting requirements. The report also calls for explicit and enforceable legal requirements that oblige employers to take responsibility for suicide prevention and to undertake a full and transparent investigation in the aftermath of a suicide in the workplace or where there is evidence the suicide could be work-related.

University of Leeds news release and report, Work-related suicide: a qualitative analysis of recent cases with recommendations for reform, Sarah Waters and Hilda Palmer, University of Leeds, July 2021.

 

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SUICIDAL

Announcing new, higher work fatality figures, Health and Safety Executive (HSE) boss Sarah Albon noted “every loss of life is a tragedy.” But work-related could suicides kill many more, and Albon insists it is not HSE’s job to record or investigate these deaths. Hazards editor Rory O’Neill explores why, for HSE, not every tragedy counts.


Contents
Introduction
Deathly silence
Desperate picture
Death watch
Doing nothing
Driven to suicide
Bad business
Resources

Other stories
One in 10 suicides in France is work-related
Dying from neglect

Hazards webpages
Hazards news
Suicide
Mental health