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       Hazards, number 148, 2019
SUICIDE NOTE | Global experts tell HSE to address work-related suicide risks
The Health and Safety Executive insists work-related suicide is too difficult to recognise, record or prevent. Really? Hazards editor Rory O’Neill reveals how an international panel of experts warned HSE it is failing “lamentably" on work suicide prevention and is leaving UK workers at risk of death by despair.

HSE TO HAZARDS  Read HSE’s blow-by-blow refusal to record, intervene, investigate or take enforcement action on work-related suicides or suicide risks.
• HSE work-related suicide brief

It is a long list. What the Health and Safety Executive (HSE) says it can’t do to reduce the devastating impact of work-related suicide is all encompassing.

Asked to address criticism of its explicit exclusion of suicide from its investigation guidelines and official reporting requirements (Hazards 146), HSE told Hazards that "incidents of suicide and/or self-harm do not meet the reporting requirement," adding “acts of deliberate harm are not considered ‘accidents’," so are not “reportable."

In its 9 October 2019 written response to Hazards, HSE adds there is a problem of “‘demonstrability," making “building a case for intervention / investigation / enforcement extremely difficult."

The regulator charged with protecting workers from unbearable pressures at work, which can in some cases lead tragically to “work-related suicide", says it won’t even count the bodies because it has problems with the language. “We are aware of varying estimates but disagree with the term," HSE says.

Despite its opposition to recording, investigating, enforcing or even saying “work-related suicide," HSE – in a footnote to the letter to Hazards – states “this does not mean the general provisions of the HSW Act [Health and Safety at Work etc Act] do not apply. The enforcing authority may, depending on the circumstances, decide that it is appropriate to investigate such incidents. This is more likely to arise where serious management failures were a contributory factor."

NIGHTMARE JOB  Nursing manager Leona Goddard killed herself after struggling to cope with work stress and long shifts. She had suffered ‘nightmares about work’. more

It ‘may’. It just never has – because for HSE taking the easy way out means doing nothing. This at a time HSE’s own figures, released on 20 October 2019, reveal the number of workers affected by work-related stress, anxiety or depression is at an all-time high.

While HSE believes any action to address workplace suicide would be “extremely difficult", a panel of experts from 16 universities and occupational and public health research agencies in seven countries takes the polar opposite view.

HSE’s ‘grievous’ mistake

In a Statement to HSE on work-related suicide, emailed to the regulator’s chief executive Sarah Albon on 22 October 2019, the international panel calls on “the HSE to rectify a grievous blindspot that excludes suicide from the list of work-related accidents that are subject to reporting and inspection requirements."

EXPERTS TO HSE  Read the document emailed to HSE chief executive Sarah Albon on 22 October 2019 by a panel of experts from 16 occupational and public health universities and research agencies in seven countries.
• Statement to HSE on work-related suicide

The panel, which includes top UK researchers on suicide risks professors Sarah Waters of the University of Leeds, David Gunnell of Bristol University and Martin McKee of London School of Hygiene and Tropical Medicine, notes: “This exemption exposes UK workers to risks to their health and safety that could be rectified by improved regulatory procedures.

“Existing international studies have established the causal connections between work, working conditions, work-related stress and suicide ideation."

The statement, which is also signed by Nick Pahl, the chief executive of the UK Society of Occupational Medicine, notes these studies “point to a rise in suicides that have been linked to working conditions and in particular, the impact of precariousness, work intensification, declining social protection, digital surveillance, indebtedness and management bullying."

Among a string of examples of more protective practices by regulators in other countries, some leading to a drop in suicide deaths, the statement notes: “In France, when a suicide takes place in the workplace, it is immediately investigated by safety inspectors as a work-related accident and the burden of proof is on the employer to prove that it is not work-related."

It adds: “Incidents of work-related suicide are generally followed by an in-depth investigation of working conditions at a company (by independent occupational health experts) to ensure that other employees are not at risk." That amounts to a lot of potentially lifesaving interventions, as 1-in-5 suicides reported to the social security authorities in France “is officially recognised as being work-related."

Since the early 1990s, both the US and Japan have monitored and recorded work-related suicides. The experts’ statement to HSE notes government agencies in both the USA and France have clear criteria defining ‘work-relatedness’ in suicides, a task seemingly beyond the comprehension of the UK regulator [see: Global lessons for HSE on suicide ‘work-relatedness’].

HSE TO EXPERTS Read HSE’s repeat refusal to address work-related suicide and suicide ideation risks.
• Letter to the expert panel from HSE senior psychologist Peter Kelly

‘Fatal occupational injuries’ figures released by the US Bureau of Labor Statistics on 17 December 2019 show an upward trend is continuing, with recorded suicides increasing from 250 in 2011 to a high of 304 in 2018.  This would translate to about 60 reported work-related suicides each year in Great Britain.

It would put work-related suicide at the top of the UK fatal workplace injuries table, compared with ‘falls from height’ with 40 deaths and ‘struck by moving vehicle’ with 30 deaths the main causes identified in HSE’s 2018/19 figures.

HSE, though, isn’t shifting. Professor Sarah Waters, the contact person for the expert group letter to HSE chief executive Sarah Albon, received an emailed response from HSE senior psychologist Peter Kelly dated 10 December 2019. The letter, the great majority of which presented verbatim or near verbatim arguments to those in HSE’s response to Hazards two months earlier, stuck with the nothing doing line.

HSE did though add some extra fudge. It ducked a request to add specific mentions of work-related suicide and suicide ideation in the HSE stress management standards and stress guidance. “Work-related stress, anxiety and depression, are a key priority within our Health and Work Strategy," Kelly notes in his response to this point. “We are working collaboratively with industry, professional bodies and other government departments to ensure a cohesive approach to preventing workplace ill-health."

The easy way out

HSE’s convoluted case against action on work-related suicide sits uneasily alongside the  evidence presented by the global experts’ panel. It also appears to contradict the regulator’s stated line on work-related mental health.

HSE, in its cut-and-paste responses to both Hazards and the expert panel, noted: “We expect employers to assess risks from work-related stress and put in place control measures. More generally we are encouraging the creation of mentally healthy workplaces through supporting government initiatives around implementation of the Farmer Stevenson core standards."

HSE says it defines stress as
‘the adverse reaction people
have to excessive pressures or other types of demand placed
on them’. It doesn’t get more adverse than suicide.

These core standards, spelled out in the government-commissioned October 2017 Thriving at Work report (Hazards 141), call for employers to “routinely monitor employee mental health and well-being" and “produce, implement and communicate a mental health at work plan."

If HSE was really intent on “building a case for intervention", how employers respond or fail to respond to these HSE-supported core standards and its own long-established stress management standards would be a good start. In the case of a work-related suicide, it could be the smoking gun. It could be evidence critical in pursuing either a prosecution or a compensation case.

But the workplace safety police aren’t interested in following the evidence. In response to the experts’ call for HSE to support efforts to get work-related suicide recognised for common law compensation, Kelly writes: “Whilst it may be possible to demonstrate that it was a contributary factor, directly linking suicide to issues solely in the workplace is not usually possible."

ALARM BELLS  In an 11-day period in November 2019, in what a whistleblower had described weeks earlier as a ‘toxic’ workplace with a ‘risk of suicide’, Luke Wright became the third employee of the East of England Ambulance Service (EEAS) to die in a suspected suicide. more

This is evidently outside of Kelly’s area of expertise. Common law cases do not require a condition – whether it is work-related lung disease, cancer or mental health problems like suicide – to be ‘solely’ the cause of work factors, just that these factors contributed to the condition and that contribution was the result of employer negligence. The courts consider the relative contributions and adjust the settlement accordingly. Relatedness and a failure in the duty of care are the deciding factors.

And Kelly goes out of his way to anticipate difficulties employers might face, noting “work-related stress is subjective, what affects one individual would have no negative affect on another individual. In addition, people can have an increased susceptibility to stress due to pre-existing mental or other health factors. It is not reasonable to expect an employer to be able to diagnose such conditions."

It’s complicated?

Central to HSE’s argument that suicide should not be on its job sheet is that establishing causation can be complicated. “Evidence linking suicide to activity in the workplace is generally not clear/without an element of uncertainty," its response to Hazards notes.

It adds, in a line repeated verbatim in its responses to both Hazards and the expert panel: “It is rarely possible to identify a unique link between work activity/action and suicide as most suicides generally arise out of a very complex and often subjective, range of factors."

NUCLEAR MELTDOWN  When Unite revealed in 2019 the new Hinkley Point nuclear power station was grappling with a mental illness crisis, it led to action. The union discovered there had been several attempted suicides since work began three years earlier on Britain’s biggest construction project. See ‘Death wish’, Hazards 147.

True, but this uncertainty applies to any manifestation of work-related stress, depression or anxiety, Britain’s top workplace health problem and one that HSE readily accepts falls within its remit. And something HSE readily accepts should be subject to both its own stress management standards and the Farmer Stevenson core standards on mental health at work.

HSE’s online guidance on Mental health conditions, work and the workplace notes: “By taking action on work-related stress, either through using the HSE Management Standards or an equivalent approach, employers will meet parts of the core standards framework. 

“Although stress can lead to physical and mental health conditions and can aggravate existing conditions, the good news is that it can be tackled. By taking action to remove or reduce stressors, you can prevent people becoming ill and avoid those with an existing condition becoming less able to control their illness."

HSE’s final insult

The expert statement to HSE raises questions about the UK regulator’s reasoning in refusing to take this entirely practicable action when it comes to suicide, the most devastating consequence of exposure to these work stressors. It notes: “The HSE’s failure to record and investigate work-related suicides means that the UK falls lamentably short of best practice and that this poses risks to the health and safety of UK workers."

The statement also calls on HSE “to make explicit mention of suicide ideation and work-related suicide in its Stress Management Standards and guidance on work-related stress and work-related mental ill-health." As with every other recommendation from the expert group, HSE chose to just say no.

Admitting work-related suicide is a real and deadly consequence of bad work would require no more than a change of attitude from HSE, a recognition that those driven to contemplate killing themselves as a consequence of work-related stress deserve the same consideration as those made ill. That those bereaved by a work-related suicide or those workers who have seen a workmate driven by job pressures to take their own life have a right to expect more from HSE.

All it would take is for HSE to invoke the same protective approach already employed for the less-than-fatal work-related stress, anxiety and depression it considers within its job spec. Stress. Anxiety. Depression. Suicidal thoughts. Suicide. For those struggling in a psychologically toxic work environment, one can lead inexorably to another.

In HSE’s own words: “HSE defines stress as ‘the adverse reaction people have to excessive pressures or other types of demand placed on them’." It doesn’t get more adverse than suicide.

For HSE to discount the most tragic outcomes of work-related stress, depression and despair is arbitrary and cruel. To dismiss a plea to remedy this “grievous blindspot" from some of the world’s leading experts on suicide causation is arrogant and irresponsible.

But for HSE ‘work-related suicide’ isn’t a thing. And that’s final.


Lessons for HSE on suicide 'work-relatedness'

France and the USA have clear criteria defining 'work-relatedness' in suicides, a task beyond the comprehension of the UK regulator.

In French jurisprudence, suicide is identified as a ‘workplace risk’ (Court of Appeal, 22 February 2000). Any fatality that occurs in the workplace, including suicide, is immediately investigated as a workplace accident (Article L.411-1 Code de la Sécurité sociale).The burden of proof is on the employer to prove that the suicide is not work-related. Even in cases where a suicide takes place outside of work, it is still investigated as work-related where the employee (in an attempted suicide) or the family can prove a causal link to work.

The presumption of causality is meant to protect the employee (in an attempted suicide) or the family and circumvent the need for them to engage in legal action to prove that an employer is liable. Hence, one in five employee suicides reported to the authorities (Sécurité sociale) in France is officially recognised as being work-related. A family can pursue a claim for liability against an employer for gross negligence in the case of a work-related suicide.

Attempted suicide may also be recognised as a workplace accident. The Court of Cassation (decree of 22 February 2007) officially recognised as a ‘workplace accident’, an attempted suicide by an employee who was on sick leave following a depression that was linked to deteriorating working conditions and the behaviour of his employer.

In a high-profile case at the telecommunications company France Télécom (rebranded Orange in 2013), , the company’s ex-boss Didier Lombard and two former executives were jailed on 20 December 2019 over a restructuring policy linked to suicides among employees in the 2000s. Lombard, the company’s former president and chief executive officer, was jailed for a year, as were Louis-Pierre Wenès and Olivier Barberot, although eight months were suspended. The company was fined €75,000 ($83,000; £64,000).

The court examined 39 cases of employees, 19 of whom had taken their own lives and 12 who had attempted suicide. The others had lived with depression or had been otherwise unable to work. It happened during a major restructuring of the company that affected thousands of employees.

Four other executives were found guilty of complicity and given four-month suspended sentences and €5,000 fines. Lombard, his deputy Wenès, and Barberot, the former director of human resources, were each fined €15,000. Lombard's lawyer, Jean Veil, said his client would appeal against the conviction. It was the first time that a French court has recognised "institutional harassment".

All suicides that are declared as a workplace accident in France are recorded by the public authorities. (Régime général de Sécurité sociale). As part of a national suicide prevention strategy, the French Ministry of Social Affairs and Health launched a major government funded project to improve systems for monitoring and recording work-related suicides nationally. As part of this project, work-related suicides were defined according to the following criteria:

• Suicides in the place of work or on the journey to and from work
• Suicides officially recognised as workplace accidents
• Suicides where there is circumstantial evidence of a link to work (a suicide letter or witness statement)
• Suicides where a work implement or tool was used (including firearm or medication)
• Suicides where work clothes are worn.

In the United States, the Bureau of Labor Statistics has recorded workplace  suicide  rates since  1992  and  this  data  is  collected  in  the  Census  of Fatal Occupational Injuries (CFOI). Suicide is recognised by American occupational health experts as the focus of a workplace safety crisis.

Suicide statistics (alongside other workplace fatality counts) are registered according to characteristics including gender, race, occupation, event and state of incident. Such data is a critical source of public health information, providing data on the economic sectors, age groups and ethnicity of employees who take their own lives.

For a workplace suicide to be included in the US CFOI, at least one of the following criteria must be met: (1) the death arose from an injury at the decedent’s work premises while the decedent was there for work; (2) the death occurred away from the work premises, but the decedent was engaged in work activity (eg. performing work at a client’s premises); or (3) the death was related to the decedent’s work status (eg. a suicide at home that can be definitively linked back to work).

Suicide in the workplace, a BLS report in the December 2016 issue of its Monthly Labor Review notes: “Suicide is a relatively small, but growing, occupational concern. From 2007 to 2009, a period that included the Great Recession, fatal work injuries declined rapidly, yet workplace suicides increased and have remained elevated.”

CFOI ‘fatal occupational injuries’ figures released by BLS on 17 December 2019 show the upward trend is increasing, with recorded work-related suicides up from 250 in 2011 to a high of 304 in 2018.

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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


Shifts and job stress linked to nurse’s suicide

A dedicated NHS nurse who had ‘nightmares about work’ killed herself after the stress of working 12-hour shifts left her unable to lead a normal life, a November 2019 inquest has heard.

Leona Goddard, 35, struggled to have a social life after being burdened with unpredictable work hours and extra responsibilities at Prestwich Hospital in Manchester. Although her work colleagues rated her as ‘outstanding’ Miss Goddard, a nursing manager who worked in a mental health unit, had developed low self-esteem due to the long hours.

On 3 October 2018, just six months after she got a promotion, Miss Goddard was found hanged at her family home. She left a hand-written note across two pages of A4 paper detailing her “negative feelings, a downward spiral and feelings of self-loathing."

A doctor’s report read to the hearing said Miss Goddard had been to see her GP in the weeks leading up to her death. She said she felt ‘unsupported’ and ‘had nightmares about work’ and was offered anti-depressants, which she refused saying if work “got sorted out she would feel better."

Recording a conclusion of suicide, coroner Angharad Davis said: “Colleagues describe her as a bright, clever, caring nurse but it is clear from the evidence that the job role was causing Leona stress because of the difficulties working and the stress of the job itself."

The coroner concluded: “Having considered all the evidence read and heard it seems that Leona was under a great deal of stress going on for a long time. She had very low self-esteem and did not recognise in herself the person that everybody else saw."
In another November 2019 inquest, Plymouth senior coroner Ian Arrow concluded Adam Reed took his own life. The inquest heard Mr Reed's partner Jason Boddy had received a call from him at around 3.40pm on the afternoon of 29 May 2019, saying that he had had a “bad day at work" at Smart Estate Agents Torbay branch and that “it wasn't the end of the world but the end of Smart." Mr Boddy found his partner hanged in their home later that day.

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Alarm bells after ambulance worker suicides

Ambulance staff are being urged to speak up about the job’s stresses after the November 2019 suicide of a 24-year-old ambulance worker employed at what a whistleblower had weeks earlier described as a ‘toxic’ workplace presenting ‘a risk of suicide’.

Luke Wright was one of three members of the East of England Ambulance Service (EEAS) to die in suspected suicides in a 11-day period in November 2019. Ambulance dispatcher Mr Wright, 24, and paramedics Christopher Gill, 41, and Richard Grimes were found dead between 11 November and 21 November 2019.

The Ambulance Staff Charity (ASC) said since May 2019 it has taken 35 calls from EEAS workers seeking support. Following the three deaths, EEAS said it would “always offer support" to staff in need. The ACS was set up in 2015 to support paramedics and ambulance technicians and back-room staff.

Chief operating officer Karl Demian said it had supported 1,000 people in the three years to October 2018, rising sharply to 1,200 in the following 12 months. He said the increase could be because of greater awareness but acknowledged paramedics’ jobs, while always “fraught", were becoming “more complex." He added: “The nature of the incidents that they have to deal with has changed, but I think it's fair to say that the pressures on them are much greater than they were."

Speaking in November 2019 after the news of Luke Wright’s death, Sam Older, a regional organiser with the union UNISON, said: "While we don't want to speculate on the causes of these deaths, we recognise how important it is for staff to receive the mental health support they need at work, particularly in such a stressful and potentially traumatic job in the ambulance service."

He added: “UNISON is pushing the trust to do more to look after the health and well-being of its staff, as a result of which employees now have access to a dedicated helpline with dedicated trauma therapists, and we will do everything we can to look after our members."

On 1 October 2019, a letter from an anonymous whistleblower to the website Ambulance News Desk, which was reported in the local and national media, warned EEAS was a “toxic" workplace where workers faced "psychological abuse" and there was “a risk of suicide".

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Suicide note

The Health and Safety Executive insists work-related suicide is too difficult to recognise, record or prevent. Really? Hazards editor Rory O’Neill reveals how an international panel of experts warned HSE it is failing “lamentably" on work suicide prevention and is leaving UK workers at risk of death by despair.

HSE’s ‘grievous’ mistake
The easy way out
It’s complicated?
HSE’s final insult
Global lessons for HSE on suicide ‘work-relatedness’

Related stories
Shifts and job stress linked to nurse’s suicide
Alarm bells after ambulance worker suicides

Hazards webpages
Work-related suicides
Stress and mental health
TUC guide
Work and suicide: A TUC guide to prevention for trade union activists.


Use the Hazards e-postcard to tell the HSE to recognise, record and take action to prevent work-related suicides.