Barbara Strozzilaan 336
1083 HN Amsterdam
The Netherlands
info@gssb.globalreporting.org

Basis for Conclusions for GRI 403:
Occupational Health and Safety 2018
Summary of Public Comments on the Exposure Draft of
the Standard, and GSSB Responses
Date

28 June 2018

Description This document sets out the significant issues raised by respondents on the
exposure draft of GRI 403: Occupational Health and Safety (GRI 403), during theconsultation period from 10 August to 9 October 2017. It incorporates publiccomments received via the GRI Standards Consultation Platform and official
feedback submissions received via email, as well as input from stakeholder
workshops carried out in select regions.
All individual comments received, together with an analysis of the significant
issues raised, were first provided to the Project Working Group (PWG) for
review and discussion, and their recommendations were later shared with the
Global Sustainability Standards Board (GSSB) for review and approval. This
document provides a summary of how the GSSB has responded to the significant
issues raised during the public comment period. The full set of individualcomments received via the consultation platform and via email are available todownload from the GSSB website.
The final GRI 403: Occupational Health and Safety 2018 Standard published on 28
June 2018 can be downloaded here.

© GRI 2018

Contents
About this document ................................................................................................................................................. 3
Introduction ................................................................................................................................................................. 3
Background and objectives for the revision of GRI 403 ............................................................................... 3
Scope of the public consultation ......................................................................................................................... 4
Overview of official public comment submissions .......................................................................................... 4
Stakeholder workshops ........................................................................................................................................ 5
Basis for Conclusions................................................................................................................................................. 6
General themes ....................................................................................................................................................... 6
Scope of workers ............................................................................................................................................... 6
Additional content suggested for inclusion .................................................................................................. 7
Themes by disclosure ............................................................................................................................................ 7
Management approach disclosures................................................................................................................. 7
Disclosure 403-1 Workers covered by an occupational health and safety management system ... 8
Disclosure 403-2 Work-related injuries....................................................................................................... 8
Disclosure 403-3 Work-related illnesses ................................................................................................... 10
Disclosure 403-4 Workers’ access to occupational health services.................................................... 11
Disclosure 403-5 Worker health promotion ............................................................................................ 11
Annexes ...................................................................................................................................................................... 12
1. Overview of questionnaire questions ......................................................................................................... 12
2. Overview of respondents .............................................................................................................................. 13
3. Public comment submissions by representation, constituency, and region ....................................... 16
4. Full list of Stakeholder Workshops ............................................................................................................. 17

Page 2 of 17

About this document
This document sets out the significant issues raised by respondents on the exposure draft of GRI
403: Occupational Health and Safety (hereafter GRI 403), during the public comment period, which ran
between 10 August and 9 October 2017. It summarizes:•

comments received through the GRI Standards Consultation Platform (including
questionnaire responses as well as detailed comments on the exposure draft);•official feedback submissions received directly via email;•feedback received from seven stakeholder workshops held during this period.

All individual comments received, together with an analysis of the significant issues raised, were firstprovided to the Project Working Group (PWG) for review and discussion, and theirrecommendations were later shared with the Global Sustainability Standards Board (GSSB) for
review and approval. This document provides a summary of how the GSSB has responded to thesignificant issues raised during the public comment period.
The full set of individual comments received via the consultation platform and via email are available
to download from the GSSB website.

Introduction
Background and objectives for the revision of
GRI 403
The proposal for the review of GRI 403 was approved in October 2016 by the Global Sustainability
Standards Board (GSSB), GRI’s independent standard-setting body. The primary objective of thisproject was to review the content of GRI 403 in order to represent and align with internationallyagreed best practice and recent developments in occupational health and safety management andreporting. Key references for revising the content included intergovernmental authoritative
instruments, such as ILO Conventions, and other relevant standards and developments.
The revision of GRI 403 was carried out in line with the GSSB’s Due Process Protocol. In
accordance with this protocol, a multi-stakeholder PWG was formed to develop content for thereview of GRI 403.
The following specific objectives were established by the GSSB when commencing the revision of theStandard, and were considered throughout the project:•revising, and where needed, expanding on the existing Background context information within
GRI 403;•reviewing the existing management approach disclosures section within GRI 403, including:orevising the existing content;owhere appropriate, developing new requirements, recommendations, and/or
guidance;

Page 3 of 17

o•ensuring the revised management approach disclosures are compatible fororganizations to use together with GRI 103: Management Approach;reviewing the existing topic-specific disclosures for occupational health and safety (alongwith their related reporting requirements, recommendations, and/or guidance) including:orevising the existing content;owhere appropriate, developing new disclosures, requirements, recommendations,
and/or guidance in order to address areas not currently covered;•revising and updating the existing References related to occupational health and safety;•

revising relevant definitions in the GRI Standards Glossary and, where applicable, developing
new ones.

Scope of the public consultation
The exposure draft of GRI 403 was open for public comment from 10 August to 9 October 2017.
Respondents were asked to provide feedback on the feasibility of reporting against the proposed
disclosures, their meaningfulness for communicating an organization’s impacts on the health andsafety of workers, and their completeness and clarity, as well as to provide feedback on specificcontent-related questions.
During this consultation period, the GSSB asked for feedback on the following specific areas:•

Clarity of the scope of workers covered in the Standard.

•

Relevance of the management approach disclosures for occupational health and safety.

•

Clarity of how to report on high-potential incidents.

•

Feasibility of reporting work-related illnesses for workers who are not employees.

Any comments relating to areas out of scope for the revision of GRI 403 (such as requests todevelop sector guidance) will be considered by the GSSB separately to help inform future work
priorities.

Overview of official public comment
submissions
Stakeholders were able to give feedback on the exposure draft via the GRI Standards Consultation
Platform (hereafter Consultation Platform), and/or directly via email.

GRI Standards Consultation Platform
The Consultation Platform was the main channel for stakeholders to access, review, and commenton the exposure draft. The Consultation Platform included a short questionnaire (see Annex 1 foran overview of the questions) and the exposure draft with the possibility to leave detailed comments
directly on the PDF document.

Feedback via email
Although stakeholders were encouraged to utilize the Consultation Platform wherever possible,
respondents who wanted to provide additional feedback on the exposure draft, or an official letteror statement, were able to submit this via email to standards@globalreporting.org orPage 4 of 17

ohs@globalreporting.org. This feedback was reviewed and analyzed along with the comments
received through the Consultation Platform.

Total participation during the public comment period
In total, 55 individuals and organizations submitted feedback on the exposure draft.
48 submissions were received via the Consultation Platform, from individuals and organizations
across 21 countries. Of these, 37 were submissions on behalf of an organization or groups oforganizations (such as an industry association or trade group), and 11 were personal submissions.
10 individuals or organizations submitted feedback via email; three of these respondents also
submitted comments through the Consultation Platform. Out of the remaining seven email
submissions, six were on behalf of an organization or groups of organizations, and one was apersonal submission.
For more detail, see the following:•

The full set of individual comments received via the online Consultation Platform and via
email, available to download from the GSSB website.

•

Annex 2 for an overview of respondents who provided feedback via the Consultation
Platform and via email.

•Annex 3 for a breakdown of public comment submissions by representation, region, andconstituency.

Stakeholder workshops
As part of the public consultation process, the GSSB and GRI Standards Division also carried out
seven in-person stakeholder workshops between September and October 2017. See Annex 4 forthe list of workshops by location. The workshops were stand-alone events and were addressed to alimited number of participants in order to encourage robust dialogue.
These workshops were designed to give participants an overview of the changes in GRI 403, and tosolicit their feedback on specific areas of the exposure draft through small group work anddiscussion.
Each small group was provided with excerpts from the exposure draft and asked to answer specificquestions relating to the relevance, feasibility, and clarity of the contents. Each group was asked torecord their feedback for discussion with the full group. Each participant was also given an individual
response sheet where they could leave additional comments, concerns, or suggestions.

Page 5 of 17

Basis for Conclusions
In line with the Due Process Protocol, this section summarizes the significant issues raised byrespondents during the public comment period, and the GSSB’s responses to these issues. Everycomment received was first reviewed individually by the GRI Standards Division to identify significant
issues. All individual comments received, together with an analysis of the significant issues, were thenprovided to the PWG for review and discussion, and their recommendations were shared with the
GSSB in turn for review and approval.
The significant issues are organized into the following sections:••

General themes
Themes by disclosure

General themes
Scope of workersa) Scope of workers unclear
Many respondents requested clarifications on the subset of workers to be used when reporting thedisclosures in GRI 403, such as the distinction between ‘employee’, ‘worker, ‘contractor’, and‘supplier’. Respondents also requested examples of the types of worker to be included and the
explicit inclusion of certain types of worker (e.g., temporary, agency, cross border workers).
GSSB response: The section on scope of ‘workers’ in the Standard has been clarified and a table with
examples has been developed as guidance. Explanations about control of work and workplace (previously
included in the list of defined terms) have been revised and included in this section. Additional examples oftypes of worker, such as agency workers, have been included, although it has been clarified that the worker
type does not determine whether the worker is to be included by the organization in its reported data.
b) Not feasible to report data for workers who are not employees, including cases of sharedcontrol
Many respondents mentioned that it is difficult to report data for workers who are not employees.
The scope of ‘workers’ was considered too broad and not representative of an organization’s sphereof influence, since it includes cases of shared control of work or workplace and temporary workers.
Respondents indicated it would be particularly challenging to report the following required data forthese workers: recordable work-related injuries and illnesses, and the number of hours worked.
GSSB response: The feasibility of reporting data for workers who are not employees was evaluated, with theconclusion that if the organization has some degree of control, it should be possible to obtain these data (i.e.,
if the organization controls the work or the workplace, or shares control with one or more organizations,
there will normally be a contractual obligation through which the organization can require the reporting ofwork-related injuries and ill health, and the number of hours worked). Thus, the scope of workers and therelated requirements have been maintained. Additional clarifications and examples have been provided, suchas the following:•

When the reporting organization does not have data available for all the workers specified in adisclosure, it is required to identify the types of worker excluded and explain the reasons for this - all
topic-specific disclosures include the requirement to report ‘whether and, if so, why any workers havebeen excluded from this disclosure, including the types of worker excluded’.

Page 6 of 17

••When the organization cannot directly calculate or estimate the number of hours worked (e.g.,
because the workers performed non-routine work during an emergency situation, or because theperformed work was not paid for by the hour), it is required to provide a reason for this omission as
set out in GRI 101: Foundation.
In situations where an organization might not be able to collect or publicly disclose data on workrelated ill health, for example due to privacy regulations, it is required to provide a reason for thisomission as set out in GRI 101: Foundation.

Additional content suggested for inclusion
Some respondents stated that the exposure draft did not cover leading indicators sufficiently, andsuggested some indicators for inclusion, such as the frequency of health and safety inspections or
audits.
Additionally, a few respondents suggested the inclusion of certain topics within the Standard, such as
mental health, gender, nutrition, road safety, commuting, public safety, return-to-work programs,
governance, and non-compliance with regulations.
GSSB response: It has been clarified that leading indicators are often unique and tailored to a specificorganization, and therefore, no additional leading indicators have been added as requirements within theStandard. However, additional examples of leading indicators have been included in the guidance for clause
1.3.2 (clause 1.2 in the final Standard).
The disclosures and definitions have been revised to clarify how to report on some of the suggested topics.
The following are some examples:••••

Clarification has been provided that commuting incidents are not included except in the case where
the transport has been organized by the organization; nevertheless, the organization can reportthese incidents separately.
Clarification has been provided that injuries and cases of ill health involving members of the public
as a result of a work-related incident are not included; nevertheless, the organization can reportthese separately.
The recommendations to provide a breakdown of data on work-related injuries and ill health incases where reported numbers are significantly higher for certain worker demographics have been
amended, citing the following criteria as examples: sex, gender, migrant status, age, worker type.
Guidance for reporting on mental illnesses has been included, and examples of mental illnesses andpsychosocial hazards have been provided.

Themes by disclosureManagement approach disclosuresa) Management system standards
One respondent suggested that an organization might choose to follow all or part of one, or many,
standards in developing its occupational health and safety management system, and that thedisclosures should be amended accordingly.
GSSB response: Clause 1.2.1 (Disclosure 403-1-a in the final Standard) has been revised to require theorganization to report ‘a statement of whether an occupational health and safety management system has
been implemented, including whether:•

the system has been implemented because of legal requirements and, if so, a list of therequirements;

Page 7 of 17•the system has been implemented based on recognized risk management and/or management
system standards/guidelines and, if so, a list of the standards/guidelines.’

Disclosure 403-1 Workers covered by an occupational health and safety
management systema) Recognized standards/guidelines
One respondent suggested that Disclosure 403-1 focuses on management systems that are based onnationally or internationally recognized standards or guidelines, in order to produce better
benchmarks, consistent with global safety management systems and techniques.
GSSB response: Disclosure 403-1 (403-8 in the final Standard) has been revised to focus on occupational
health and safety management systems based on legal requirements and/or recognized standards/guidelines,
as reported in the Management approach disclosures section (under Disclosure 403-1 in the final Standard).
b) Basis for reporting the coverage of the management system
One respondent suggested that Disclosure 403-1 require reporting of the percentage of sites
covered by the management system instead of the percentage of workers, as the latter may bedifficult to implement since it is the sites or organizations that are accredited/certified, and not
people.
GSSB response: Given the focus of the Standard to understand the organization’s impacts on the health andsafety of workers, Disclosure 403-1 (403-8 in the final Standard) continues to use ‘workers’ as basemeasurement. The percentage of sites covered might not account for large groups of workers, for example ifthey are all working in just a few of many operation sites. However, the guidance has been expanded to
explain that organizations can additionally report the number and percentage of sites covered by the
management system if they wish to do so.

Disclosure 403-2 Work-related injuriesa) Reporting on impairments
Some respondents asked for clarification on whether the term ‘impairment’ would include both
temporary and permanent impairments, and requested examples. A couple of respondents did notsupport the use of ‘impairment’ as a severity criterion, and suggested including the reporting of lostday rate, absentee rate, and injury severity rate instead. It was also suggested to separate the rates
of fatal and non-fatal impairments.
GSSB response: The use of ‘impairment’ as a criterion for determining the severity of a work-related injury
has been replaced with the concept of ‘recovery time’. The term ‘fatal and non-fatal impairments’ has in turnbeen replaced with ‘high-consequence work-related injuries’. A high-consequence work-related injury has been
defined as a ‘work-related injury that results in a fatality or in an injury from which the worker cannot, does
not, or is not expected to recover fully to pre-injury health status within 6 months’. Additional guidance andexamples have also been added.
The rates of fatal and non-fatal impairments have been separated. This disclosure now requires the ‘number
and rate of fatalities as a result of work-related injury’ and the ‘number and rate of high-consequence workrelated injuries (excluding fatalities)’.
Metrics such as ‘lost-day rate’ or ‘absentee rate’ have not been included as requirements, given that these
are indicators of the loss of productivity for an organization as a result of a work-related injury; they do notnecessarily indicate the extent of harm suffered by workers, which is the focus of this Standard. It has also
been explained that organizations can additionally report these metrics if they wish to do so.

Page 8 of 17b) Reporting on high-potential incidents
Many respondents found it challenging to understand the concept of ‘high-potential incidents’, andsuggested including more guidance and examples. They also considered the concept to be subjective,
as it varies across different organizations and depends on the industry or sector in which anorganization operates, thus undermining comparability, and penalizing the most mature organizations
with better reporting systems.
Respondents suggested a number of changes, such as making this disclosure a recommendation, or
replacing it with a combination of narrative and quantitative information (e.g., about programs for
tracking and analyzing high-potential incidents, near-misses, and hazardous situations, and thepercentage of accidents or incidents that were analyzed and for which root causes were identified).
GSSB response: The requirement for reporting the ‘number of high-potential incidents’ has been changed to a
recommendation. In its place, organizations are required to report work-related hazards that pose a risk ofhigh-consequence injury (explained in the earlier theme), which includes those hazards identified as a resultof a high-potential incident. In relation to this, an additional requirement has also been included within theManagement approach disclosures section (Disclosure 403-2-d in the final Standard), asking organizations toprovide ‘a description of the processes used to investigate work-related incidents, including the processes to
identify hazards and assess risks relating to the incidents, to determine corrective actions using the hierarchyof controls, and to determine improvements needed in the occupational health and safety management
system’.
c) Reporting the causes and actions taken in response to work-related injuries that were fatal
and non-fatal impairments, and to high potential incidents
One respondent suggested limiting the disclosure to a description of predominant causes, as it was
not clear if a list of causes for all specific events was required; such a list would be too detailed.
Another respondent mentioned that it should be allowed to explain cases in which cause
investigation or actions are still underway.
GSSB response: The disclosure on ‘causes and actions taken’ (403-2-d in the exposure draft) has beencombined with the disclosure on ‘hazards’ (403-2-e in the exposure draft), to avoid duplication. The new
disclosure (403-9-c in the final Standard) requires reporting the work-related hazards that pose a risk ofhigh-consequence injury, including how these hazards have been determined, which of these hazards havecaused or contributed to high-consequence injuries during the reporting period, and actions taken or
underway to eliminate these hazards and minimize risks using the hierarchy of controls. Additionally, theguidance clarifies that this does not require reporting which work-related hazards have caused or contributed
to which high-consequence injury during the reporting period; it requires the aggregate analysis of all workrelated hazards that resulted in high-consequence injuries. The guidance also explains that if an incident isunder investigation, this can be stated in the report. The same revision has been made to the disclosure on
work-related ill health (Disclosure 403-10 in the final Standard).
d) Reporting on safety hazards
One respondent suggested the inclusion of a requirement to report a description of safety hazards(instead of a list), and to require that this description focus on the most significant hazards that are
typically present within the organization’s workplaces, in particular hazards that could result indisability or loss of life if not properly contained and/or controlled. This would make it morepractical for large companies, which engage in a diverse range of operations, to focus on lifethreatening hazards.
GSSB response: The disclosure has been revised to cover work-related hazards that pose a risk of highconsequence injury if not controlled, even when there are control measures in place. In addition, thedisclosure has been revised so it does not require a list format. The same revision has been made to thedisclosure on work-related ill health (Disclosure 403-10 in the final Standard).

Page 9 of 17e) Reporting the types of work-related injury
One respondent suggested including a requirement to report the main types of work-related injury.
GSSB response: A requirement to report the ‘main types of work-related injury’ has been included, which isconsistent with the same requirement in the disclosure on work-related ill health, and examples have been
provided in the guidance.
f) Methodology for calculating injury rates
A few respondents mentioned it would be preferable to allow reporters to use other methodologies
for calculating injury rates than the one required; for instance, respondents noted that instead ofusing 1,000,000 hours worked to calculate injury rates, 200,000 hours worked may be more
appropriate for small organizations.
GSSB response: The disclosure has been modified to permit the use of either 200,000 hours worked or
1,000,000 hours worked for calculating the injury rates; and requires the organization to state in the reportwhich of the two options it has used.
g) Rates vs. absolute data
Respondents were divided on the benefits of requiring absolute data (e.g., numbers) on work-related
injuries (in addition to rates). On the one hand, it was indicated that absolute data enables
meaningful comparison across companies; on the other hand, it was mentioned that absolute data
can be manipulated by third parties.
GSSB response: The requirements for both absolute data and rates of injury have been maintained. As
mentioned by respondents, absolute data is important to enable comparisons over time, or between reportingorganizations. This allows for easy recalculation of rates using different methodologies if necessary, for the
analysis of reported data.

Disclosure 403-3 Work-related illnessesa) Not feasible to report work-related illnesses (for both employees and other workers)
Many respondents indicated that it is not feasible to report work-related illnesses for both
employees and workers who are not employees, though it is especially challenging for workers who
are not employees. They mentioned reasons such as the following:••••

Privacy regulations may limit the possibility to share information with other employers (e.g.,contractors) or to report details publicly.
Long-latency illnesses might be unveiled years after exposure, and are often not reported
back to the reporting organization.
When workers work for different employers, it becomes difficult to identify if the illness isdue to exposure while working for the reporting organization.
Psychosocial and behavioral work-related illnesses are difficult to report.

Respondents suggested that reporting data on work-related illnesses for workers who are not
employees should be a recommendation, or should, for example, only be a requirement for longterm contractors.
GSSB response: It is acknowledged that accurately capturing work-related illnesses/ill health is a challenge.
However, this is not dependent on the status of the worker (whether an employee or not an employee,
temporary or long-term, present or former), but on the complexity of diagnosing the illness, determining
whether it is work-related, and that the organization gets notified of it. Despite these challenges, whenever
the organization identifies or is notified of a case of work-related ill health (for either an employee or aworker who is not an employee, but whose work and/or workplace is controlled by the organization), it isPage 10 of 17

expected to report it. Therefore, these requirements have been maintained, and additional guidance has
been developed on how to report work-related ill health.

Disclosure 403-4 Workers’ access to occupational health servicesa) Specificity of the disclosure and additional content suggested
Some respondents commented that the information required by this disclosure was too general andsubjective to each organization. They suggested including more specific requirements, such as listing
the types of occupational health service provided or explaining how the organization ensures thequality of these services. They also mentioned that this information may be challenging to report forworkers who are not employees.
GSSB response: The requirement to report the ‘percentage of workers that have access to occupational
health services’ has been substituted with the requirement to provide ‘a description of the occupational
health services’ functions that contribute to the identification and elimination of hazards and minimization ofrisks, and an explanation of how the organization ensures the quality of these services and facilitates
workers’ access to them’.
Additionally, this disclosure has been moved to the Management approach disclosures section, as it relates to
how occupational health services are managed (Disclosure 403-3 in the final Standard).

Disclosure 403-5 Worker health promotiona) Distinction between occupational health and safety and non-work-related healthpromotion
A couple of respondents considered the separation between occupational health and safety and nonwork-related health promotion inappropriate, considering that they are interrelated and should bemanaged together as part of a continuum of care for workers. On the other hand, one respondent
noted that this disclosure, as it was defined, should not be part of this Standard, given the limited
evidence demonstrating the effectiveness of health promotion programs.
GSSB response: This disclosure has been kept within the Standard, since it is becoming common practice totreat non-occupational health issues as workplace issues, and since the topic of health promotion is notmature enough to justify developing a specific standard of its own. Additionally, it is valuable to keep thisdisclosure in the Standard given the guidance developed on respecting workers’ right to privacy, nondiscrimination, and on the fact that occupational health and safety cannot be substituted with healthpromotion programs.
b) Specificity of the disclosure and additional content suggested
A few respondents commented that the information required by this disclosure was too general, andsuggested some specific metrics for inclusion, such as information about the programs and the healthrisks they address, and metrics to assess their effectiveness.
GSSB response: The requirement to describe the voluntary programs to address major non-work related
health risks has been expanded to include reporting of the specific health risks addressed. The requirement
to report the percentage of workers that have access to these voluntary programs has been substituted witha description of how the organization facilitates workers’ access to them.
Additionally, the contents of this disclosure have been moved to the Management approach disclosuressection, as they relate to how worker health promotion is managed (Disclosure 403-6-b in the final
Standard).

Page 11 of 17

Annexes
1. Overview of questionnaire questions
Number

Question

Question 1

The GRI Standards are designed to help organizations communicate about their impacts on theeconomy, the environment, and society. GRI 403: Occupational Health and Safety covers anorganization’s impacts on the health and safety of workers, including how these impacts aremanaged.
In your opinion, do the disclosures in GRI 403: Occupational Health and Safety adequately
cover an organization’s main impacts on the health and safety of workers, or are there any
critical contents missing?

Question 2

The GRI Standards are intended to be applicable for organizations of all types, sizes, sectors andlocations.
Do you believe the disclosures in GRI 403 are feasible for all organizations to report?

Question 3

Are there any sections in this draft Standard where the content or wording is unclear?

Question 4

The GRI Standards are designed to help organizations disclose meaningful and comparable
information about their economic, environmental, and social impacts. This information can then be
used by stakeholders such as investors, civil society organizations, and others, to make informed
decisions.
Are the disclosures in GRI 403 adequate to allow report users to make informed decisions
about an organization’s occupational health and safety impacts?

Question 5

Throughout the Standard, guidance is included to help users better understand and apply thereporting requirements.
Are there any sections in GRI 403 where additional guidance is needed to help organizations
understand and compile the required information?

Question 6

Do you have any other comments or suggestions related to this draft Standard?

Question 7

With respect to ‘The scope of ‘workers’ in this Standard’, is it clear which subset of workers is
to be used for reporting the disclosures within GRI 403? (See explanation in lines 172-191)
What additional guidance would be useful?

Question 8

The management approach section in GRI 403: Occupational Health and Safety now includes new
specific requirements for organizations to report on how they manage occupational health andsafety. These requirements focus on management systems, hazards and risks, and worker
participation, consultation, information and training. This section is designed to complement, not toreplace, the content in GRI 103: Management Approach.
With respect to the management approach requirements in GRI 403 (see clauses 1.2.1 –1.2.7), are there any requirements you think that are not critical for reporting themanagement approach for occupational health and safety?

Question 9

With respect to Disclosure 403-2 Work-related injuries, is it clear how to report on ‘highpotential incidents’? (See Disclosure 403-2-c and related definition in lines 617-622) What
additional guidance would be useful?

Question
10

With respect to Disclosure 403-3 Work-related illnesses, is it feasible to report work-related
illnesses for workers who are not employees? (See Disclosure 403-3-b)

Page 12 of 17

2. Overview of respondents
The table below provides an overview of the public comment respondents. Those who provided feedback via email are highlighted in gray. Those who
provided feedback via both the Consultation Platform and email are highlighted in orange.
First nameLast name

Representation

Organization

Country

RegionConstituency

DianahBrown

Organizational

Safe Work Australia

Australia

Oceania

Other

LeonoreAdams

Organizational

Amcor Limited

United States

Northern America

Business Enterprise

HabibaAl Marashi

Organizational

Arabia CSR Network

United ArabEmirates

Asia

Other

HelenaBartonOrganizational

GRI Stakeholder Council

United States

Northern America

Civil Society OrganizationA

Belezinis

Personal

GreeceEuropeBusiness Enterprise

Edris

Boey

Personal

Singapore

Asia

Business Enterprise

DanielBrauneOrganizational

Germany

EuropeCivil Society Organization

Mark

Brownlie

Personal

CanadaNorthern America

Business Enterprise

Cristiana

Ciaraldi

Organizational

WBCSD- Cement Sustainability
Initiative

Switzerland

Europe

Other

David

Cliff

Organizational

Global Road Safety Partnership(International Federation of Red
Cross and Red Crescent Societies)

Switzerland

EuropeCivil Society Organization

Valérie

CoustetOrganizational

SAINT-GOBAIN GROUP

FranceEuropeBusiness Enterprise

Erich

Cuaz

Organizational

Clariant

Switzerland

EuropeBusiness Enterprise

StevenDe Regter

Organizational

BASF SE

Germany

EuropeBusiness Enterprise

Lee ann

Disponett

Organizational

Lexmark International, Inc.

United States

Northern America

Business Enterprise

John

Dony

Organizational

National Safety Council

United States

Northern America

Other

Janharmen

Drost

Organizational

Aidsfonds

Netherlands

EuropeCivil Society Organization

Kate

Fileczki

Organizational

Anglo American plc

South Africa

AfricaBusiness Enterprise

ProVeg Deutschland e.V. (ProVeg
International)

Page 13 of 17

First nameLast name

Representation

Organization

Country

RegionConstituency

Tim

FisherOrganizational

ASSE

United States

Northern America

Other

Wolfgang

FroschOrganizational

BASF SE

Germany

EuropeBusiness Enterprise

NadineGalvinOrganizational

Lockheed Martin

United States

Northern America

Business Enterprise

DanielaGramerOrganizational

respACT

Austria

EuropeCivil Society Organization

BirgitHaberl-Arkhurst

Personal

Austria

EuropeBusiness Enterprise

BelindaHall

Personal

United States

Northern America

Business Enterprise

Haslayati

HashimPersonal

Malaysia

Asia

Other

Ben

Heisler

Organizational

UPS

United States

Northern America

Business Enterprise

Elizabeth

Holleman

Organizational

BoeingUnited States

Northern America

Business Enterprise

Johan

Holmquist

Personal

SwedenEuropeBusiness EnterpriseMaria angeles

Horna

Personal

Spain

EuropeBusiness EnterpriseRichard

Jones

Organizational

Institute of Occupational Safety
and Health

United Kingdom ofGreat Britain andNorthern Ireland

EuropeMediating Institution

ArtemisKostareli

Organizational

IPIECA

United Kingdom

EuropeMediating Institution

Janae

Lindsley

Organizational

American Association of
Occupational Health Nurses, Inc.
(AAOHN)

United States

Northern America

Other

Suman

Majumdar

Organizational

JSW Steel Ltd.

India

Asia

Business Enterprise

SugumarMariappanadar

Organizational

International Sustainable HRM
Network

Australia

Oceania

Civil Society Organization

Rob

Mcdonald

Organizational

BHP

Australia

Oceania

Business Enterprise

Fernando

PaulonOrganizational

Grupo Sancor Seguros

Argentina

Latin America

Business Enterprise

Gianluca

Principato

Personal

Italy

EuropeBusiness EnterpriseJan

Prof. Dr.
WirsamOrganizational

Germany

EuropeCivil Society Organization

HTW Berlin

Page 14 of 17

First nameLast name

Representation

Organization

Country

RegionConstituency

RobertRamer

Organizational

UBS Group AG

Switzerland

EuropeBusiness Enterprise

Braeunig

Rene

Organizational

Glencore

Netherlands

EuropeBusiness Enterprise

Simon

Roberts

Personal

Australia

Oceania

Other

Carolyn

Rodehau

Organizational

Jointly submitted by the MeridianGroup International and theDanish Family Planning Association

United States

Northern America

Civil Society Organization

Rolf

Schwery

Organizational

Schwery Consulting

Switzerland

EuropeBusiness EnterprisePeg

Seminario

Organizational

AFL-CIO

United States

Northern America

Labor

Gustavo

SinnerOrganizational

AG Sustentable

Argentina

Latin America

Mediating Institution

Shaun

Subel

Organizational

Discovery Limited

United Kingdom

EuropeBusiness Enterprise

SureshTanwarOrganizational

Tata Buisness Excellence Group (Adivision of Tata Sons Ltd)

India

Asia

Business Enterprise

Gabriella

Tóth

Organizational

RTG Corporate Responsibility Ltd

Hungary

EuropeMediating Institution

VictorToy

Organizational

U.S. Technical Advisory Group(TAG) To The American National
Standards Institute (ANSI)

United States

Northern America

Mediating InstitutionPeter

Truesdale

Organizational

Corporate Citizenship

United Kingdom

EuropeMediating Institution

NormanUmberger

Personal

United States

Northern America

Other

Deborah

Vallance

Organizational

Australian Manufacturing Workers
Union

Australia

Oceania

Labor

Kathleen

Vandamme

Organizational

Bekaert

Belgium

EuropeBusiness Enterprise

PierreVincensini

Organizational

IOE

Switzerland

Europe

Other

PamelaVossenas

Organizational

UNITE HERE International Union,
Worker Safety & Health Program

United States

Northern America

Labor

Qi

Zhang

Personal

China, mainland

Asia

Business Enterprise

Page 15 of 17

3. Public comment submissions byrepresentation, constituency, and region
Breakdown of the Consultation Platform and email submissions combined by representation,
constituency, and region:

Public comment submissions, byrepresentation
Personal
22%

Public comment submissions, byconstituency*
Other
18%

Civil Society
Organization
15%

Labor 5%MediatingInstitution
11%
Organizational
78%

Business Enterprise
51%

Public comment submissions, byregionOceania9%

Africa 2%
Asia 11%

Northern
America29%

Latin
America4%

Europe45%*There were no submissions received from the ‘investment’ constituency.

Page 16 of 17

4. Full list of Stakeholder Workshops
Location

Date

Number ofparticipants

Hong Kong

6 September 201716

Taipei7 September 2017

49

Beijing

13 September 201725

New York

20 September 20174

São Paulo

25 September 201712

Johannesburg

28 September 201716

Toronto4 October 2017

8

Total

130

Page 17 of 17