Disclosure focus
This disclosure asks an organisation to report on work-related injuries in a way that shows the real scale of the issue across its operations. In practice, that means looking beyond a single site or headline figure and considering where injuries happen, who is affected, and whether the reporting covers the organisation’s full operational footprint or only selected locations.
The practical focus is on completeness and comparability: the information should help readers understand the extent of injuries across the business, not just at flagship sites or the best-performing parts of the organisation. A useful report will make clear the scope covered and present the injury information consistently so trends and hotspots can be understood.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show GRI 403-9 sub-elements (LRA working checklist)
Check that you have described the actions already taken, or still in progress, to remove other job-related dangers and reduce risk by applying the control hierarchy.
Check that you have described the actions already taken, or still in progress, to remove job-related dangers that could lead to severe injury and reduce risk by applying the control hierarchy.
Include any background needed to make the figures understandable, such as the methods, assumptions, and other reporting rules used to compile them.
State the calculation basis used for the rates.
Identify the people covered as staff and other workers.
Say whether any workers were left out of this disclosure.
Explain how you identified the job-related dangers that could lead to severe injury.
Set out the main categories of job-related injury.
Report the number of deaths caused by job-related injury.
Report the number of severe job-related injuries, excluding deaths.
Report the total hours worked.
Report the number of recordable job-related injuries.
State the death rate from job-related injury.
State the rate for severe job-related injuries, excluding deaths.
State the rate for recordable job-related injuries.
Explain why any workers were left out, and identify the kinds of workers excluded.
Identify which job-related dangers that could lead to severe injury caused, or helped cause, severe injuries during the reporting period.
Identify the job-related dangers that could lead to severe injury.
How to prepare it
1Set the reporting boundary first. Decide which people are in scope, then keep that scope consistent across the whole disclosure so the figures and narrative all refer to the same worker population.
2Define the measures you will use before you start counting. Separate the different injury categories, the related rates, the main injury types, the hours worked figure, and the hazard descriptions so each item is captured in the right form.
3Gather the source records that support each figure and statement. Use incident logs, investigation notes, payroll or time records, and risk assessments to back up the counts, rates, hazard descriptions, and control actions.
4Compile the disclosure content in one place. Include the numbers, the rate calculations, the main injury types, the hazards linked to serious harm, how those hazards were identified, which ones led to serious injuries in the period, and the actions taken or in progress to reduce risk.
5Record any exclusions and explain them clearly. If any workers are left out, state who they are and why they were omitted, and add any context needed to make the compilation method understandable, including the standards, methods, and assumptions used.
6Check the final draft against the source requirements. Confirm that every required item is covered, the rate basis is explained, the scope is consistent, and the wording matches the underlying evidence without adding or omitting anything.
Request the data
Request the incident and exposure data from EHS
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What injury and exposure data do we need to summarise work-related harm, the hours behind the rates, and the control actions for the reporting period?
Use your organisation’s own incident, injury, case, and hours-worked terms first, then map them to the reporting fields. Keep the ask in the language your EHS, site, or operations teams already use, and check the source material before sign-off.
Weak request
Please provide the GRI 403-9 data for the year, including all required injury metrics and narrative disclosures.
Why it fails: It uses framework language only, gives no boundary, no source system, no internal case terms, and no guidance on how the rates were built. That makes it hard for the owner to pull the right data or explain exclusions and assumptions.
Better request
Please send the site incident and case data for [period] from [system], covering [boundary]. Include our internal case counts for fatal, severe, and recordable injuries, the hours worked used for the rates, the main injury types, the hazards linked to severe cases, the control actions in place or underway, any excluded worker groups, and a short note on how the figures were compiled.
Industry examples
Draft your disclosure
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
State how the organisation defines the people covered, how it counts each injury category, how it calculates the rates, and what it includes in the hours-worked figure used as the exposure basis.
Context note
Explain what the figures indicate about safety performance, including whether the organisation had any deaths, serious injuries, or other reportable injuries, which injury types were most common, and which hazards needed the most attention.
Fluctuation statement
If the numbers changed materially, note whether the movement was driven by changes in headcount, hours worked, incident patterns, hazard exposure, reporting practices, or the effect of new or strengthened controls.
Content index entry
GRI 403-9 Work-related injuries — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for GRI 403-9 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
A percentage is stated without the underlying counts (numerator and denominator).The denominator — what the figure is a share of — is not explained.Partial scope is reported as if it were complete coverage.One-off activities are counted as if they were ongoing programmes.Boundary or period changes that move the figure are not flagged.Exclusions from the reported scope are not listed or explained.
Common gaps
Mistakes to avoid when collecting the data
Wrong data owner
Chasing the wrong team for injury figures means the numbers come from a group that does not hold the incident logs, payroll hours, or case notes needed to build the disclosure.
Framework language only
Asking for the data in reporting jargon instead of the organisation’s own terms leaves local teams unsure which incident records, case types, or worker groups they should pull.
Scope not pinned down
Failing to define which sites, entities, and worker groups are in scope leads to a mixed dataset that cannot be traced back to a clear boundary.
Wrong period basis
Using a different date range for incidents, hours worked, and case counts creates a mismatch that makes the rate calculations unreliable.
Counting bases mixed up
Combining raw counts with rate inputs from different methods, such as one team using calendar-year totals and another using live system extracts, produces figures that do not reconcile.
Source labels lost
Copying data into a new file without keeping the original case IDs, incident categories, and system labels makes it hard to prove where each figure came from.
Populations merged
Putting employees, agency staff, and other worker groups into one bucket when they should be tracked separately hides differences in the underlying injury data.
Evidence trail missing
Collecting the figures without saving the supporting reports, assumptions, and sign-off record leaves no clear path to show how the numbers were built.
Where judgement is often needed
Set the reporting perimeter after acquisitions and disposals
Decide whether to include injury data only for sites and teams under control at period end or to bring in bought-in and sold-off operations for the time they were in scope, and explain the cut-off used.
Align injury categories where local rules differ
Where country systems label or count incidents differently, map them to one internal set of injury types, state the mapping, and note any local exceptions that affect the totals or rates.
Handle agency, contractor and other near-boundary workers consistently
Make a clear call on which non-employees sit inside the dataset, describe the rule used to include or leave out each worker group, and disclose any exclusions with the reason.
Choose one hours-worked basis and keep it stable
Use a single method for the hours figure behind the rates, such as payroll time, rostered time or an estimate, and say if the approach changed during the year or differs by country or business unit.
State how late reports and reopened cases are treated
Explain whether incidents are counted when they happen, when they are logged, or when they are confirmed, and disclose how later corrections, reclassifications and backdated cases were handled.
Explain when estimates are used instead of direct counts
If some figures are built from sampling, extrapolation or management judgement, identify which parts are estimated, why that was needed, and how the estimate was checked against source records.
Be explicit about rounding and rate precision
Set out the rounding rule for counts and percentages, apply it consistently across all injury measures, and make sure the published rates still reconcile to the underlying hours and incident totals.
Protect privacy when small teams could be identified
If a site, team or country is so small that naming the injury mix could identify people, aggregate the data further and say what grouping rule was used and why.
Describe how mixed reporting systems were normalised
Where different parts of the business use different incident logs, medical classifications or safety systems, explain the conversion steps used to produce one group-wide view and any assumptions behind them.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food processing
We report injury outcomes for our own workforce and other people working under our control, using hours worked as the exposure base. During the period, we recorded no work-related deaths, one severe injury, and four other recordable injuries; the main injury patterns were cuts, strains and slips. The main severe-risk areas were moving machinery, vehicle movements, and manual handling; we identified them through task risk reviews, incident investigations, and site inspections, and we are acting through elimination, guarding, traffic separation, redesign of tasks, training, and other controls.
Synthetic illustration only. It shows how to present injury counts and rates, the main harm patterns, the exposure base, the severe-risk hazards, how those hazards were identified, which ones contributed to severe harm in the period, and the controls used to remove or reduce risk.
Illustrative (synthetic) example — Warehousing and logistics
We summarise safety performance for our employees and agency workers using total hours worked as the basis for the rates. There were no deaths, two severe injuries, and six recordable injuries; the main injury types were sprains, crush injuries and falls. The severe-risk issues were forklift interaction, loading dock falls, and lifting tasks, identified through near-miss trends, supervisor checks, and formal risk assessments; we are addressing them with removal, engineering changes, segregation, work redesign, maintenance, and targeted training.
Synthetic illustration only. It demonstrates a concise disclosure covering the people included, the exposure measure, injury counts and rates, the main injury patterns, the severe-risk hazards, how those hazards were determined, which ones led to severe harm in the period, and the hierarchy-based actions taken or underway.
Company reports
How companies report GRI 403-9
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Grupo Cibest S.A.
Banks / Diverse Financials / Insurance · Colombia · 2025
Grupo Cibest S.A.'s 2025 Management Report provides partial information on work-related accident injuries, mentioning incidents with major consequences and identifying main hazards on page 201. The report also references work-related illnesses and some measures taken, including issues related to dynamic load and prolonged postures, on page 203. However, the report lacks clear narrative or numeric data for most other required disclosure items, with no quotable evidence found for several key narrative and numeric datapoints.
Indra Sistemas, S.A.
Software and Services · Spain · 2025
Indra Sistemas, S.A.'s Sustainability Report 2025 provides several covered datapoints related to work-related injuries and fatalities, including numeric values for work-related injuries and fatalities on page 126 and percentage values on page 233. The report also includes a narrative on risk reduction before work commencement on page 122 and references to cases related to competition on page 159. However, several narrative items such as (c-i), (c-ii), (c-iii), and (d) are not found, and some narrative items like (a-iv) and (g) on page 204 provide supporting context but lack headline values, while narrative item (e) remains unclear with no quotable evidence.
Delta Electronics, Inc.
Technology Hardware and Equipment · Taiwan · 2024
Delta Electronics, Inc.'s 2024 ESG Report provides detailed numeric and percentage data on work-related injuries and fatalities, reporting zero fatalities due to work-related ill health and fire incidents (p.228, p.230), a total of over 2010 million work hours (p.227), and a recordable work-related injury frequency rate (TRIFR) of 0.50, meeting their 2024 target (p.227). The report also mentions a fine imposed for work-related hazards prior to operation (p.102). However, several narrative disclosures, including items (a-iv), (a-v), (c-i) to (c-iii), (d), and methodology-related narratives (e) and (g), are not found or unclear in the report.
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Check your understanding
Scenarios to work through
A site team logs one fatal incident, two serious injuries that led to long absences, and six other reportable injuries during the year. The reporting pack also shows 120,000 hours worked across employees and agency staff.
QWhich injury figures and work-time basis should you pull together so the disclosure is complete and the rates can be checked?
Reveal model answer →Hide answer ↑Bring together the headcount group covered, the fatality count, the count of serious non-fatal injuries, the count of other reportable injuries, and the total hours worked. Those figures are the core inputs for the related rates, so the hours basis must be clear and consistent with the injury counts.
Why this matters · Use one coherent set of injury counts and hours worked so the rate calculations can be traced.
A contractor injury review finds that a machine-guarding failure caused a severe hand injury, while repeated slips on a wet loading bay caused several less serious cases. The draft narrative only says “safety incidents were reduced” and does not separate the causes.
QHow should you describe the main injury patterns and the hazards that led to the serious case?
Reveal model answer →Hide answer ↑State the main injury types in plain language and identify the hazard that caused or contributed to the serious injury, rather than using a vague summary. If a particular hazard led to the severe case, it should be named, and the broader injury pattern should still be described.
Why this matters · The narrative should show both the injury pattern and the specific hazard link where a severe case occurred.
The health and safety team calculated injury rates using only permanent staff hours, even though temporary agency workers were included in the injury log. They also excluded one overseas depot because its records were incomplete, but this is not mentioned in the draft.
QWhat extra explanation do you need to add so readers can understand the figures and any exclusions?
Reveal model answer →Hide answer ↑Explain the basis used for the rate calculation, including whose hours were counted, and say whether any worker group was left out. If anyone was excluded, identify the type of worker and the reason, so the scope of the data is transparent.
Why this matters · Readers need to see the calculation basis and any exclusions that affect the figures.
A draft disclosure lists the injury numbers and rates, but the safety manager says the team used internal incident logs, a 12-month reporting window, and a local severity classification that differs from the insurer’s wording. None of that is currently explained.
QWhat contextual detail should be added before sign-off?
Reveal model answer →Hide answer ↑Add enough context to show how the data were assembled, including the main method used, any assumptions, and any classification choices that affect the figures. That way, a reviewer can understand why the numbers look the way they do and compare them on a like-for-like basis.
Why this matters · Include the method and assumptions behind the data so the disclosure is understandable and comparable.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
Occupational health and safety management system → Guide ✓Work-related ill health → Guide ✓Hazard identification, risk assessment, and incident investigation → Guide ✓Occupational health services → Guide ✓Worker participation, consultation, and communication on occupational health and safety → Guide ✓Worker training on occupational health and safety → Guide ✓Show all 9 related disclosures →
FAQ
Questions this page answers
How do I use the GRI 403-9 page to prepare the disclosure from scratch?+−
Start with the plain-language explainer and the step-by-step ‘how to prepare’ section, then work through the datapoints to prepare and the draft-output section. The page is designed to help you move from scope and data collection to a draft disclosure, not to replace your own internal process.
What data do I need to collect for GRI 403-9 Occupational Health and Safety?+−
The page lists the datapoints to prepare, including worker population covered, injury counts and rates, hours worked, hazard information, exclusion details and compilation notes. Use that list as your collection checklist so you can build the disclosure and the evidence pack in a structured way.
How should I decide the scope for GRI 403-9 and what worker exclusions need to be shown?+−
The page tells you to capture the worker population covered, a worker exclusions flag and exclusion details, so scope needs to be set before you finalise the numbers. Keep the scope decision and any exclusions clear in your working papers and compilation notes.
How do I calculate the injury rates for GRI 403-9 in a way that is consistent with the page?+−
The page includes a rate calculation basis datapoint, so you should document the basis you used and keep it consistent across the injury metrics you report. The workbook and compilation notes are there to help you show how the figures were built.
What should I include in the evidence pack for GRI 403-9 if I want to be assurance-ready?+−
The page says there is an evidence pack with five items for assurance readiness, and it also lists six assurance claims to verify with claim, risk and evidence. Use those materials to assemble support for the figures, the scope decisions and the hazard information before review.
What are the most common mistakes to avoid when drafting GRI 403-9?+−
The page includes a section on common reporting gaps and mistakes, so it is worth checking your draft against that before sign-off. In practice, the main risk is leaving scope, exclusions, calculation basis or supporting notes too vague for review.
How do I use the Prep & Assurance workbook for GRI 403-9?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is meant to support preparation and assurance readiness. Use it to organise the datapoints, track evidence and capture the notes you will need for the draft.
What can I use the printable Library Card PDF for on GRI 403-9?+−
The Download Centre also includes a printable Library Card in .pdf format, which is useful as a quick reference while you are preparing the disclosure. It can help you keep the key datapoints and process steps in view without working from the full page.
Are there example disclosures I can use to see what a GRI 403-9 draft might look like?+−
Yes — the page includes synthetic illustrative example disclosures, including a quantitative data table. They are there to show how the information can be presented, so treat them as examples only and keep your own figures internally consistent.
How does the GRI 403-9 page relate to ESRS S1 Own Workforce, and can I reuse the data?+−
The page says the closest ESRS correspondence is ESRS S1 (Own Workforce), so the same underlying data may be reusable across both reporting exercises. That does not mean the requirements are identical, so you still need to check the specific disclosure needs for each framework.
More questions this page can help with
GRI 403-9 Occupational Health and Safety workbook download how to use itGRI 403-9 evidence pack what documents are needed for assuranceGRI 403-9 worker exclusions flag and exclusion details how to reportGRI 403-9 hours worked total and rate calculation basis guidanceGRI 403-9 serious hazard list and hazard identification method examplesGRI 403-9 hazards behind serious cases and serious hazard controls what to includeGRI 403-9 common reporting gaps mistakes to avoid before assuranceGRI 403-9 draft output narrative starters and content index lineGRI 403-9 synthetic illustrative example disclosure table how to readGRI 403-9 from company reports table where to find published examplesGRI 403-9 closest ESRS S1 own workforce data reuseGRI 403-9 compilation notes what should be documented
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