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GRI 403: Occupational Health and Safety · 2018
Disclosure GRI 403-8

Workers covered by an occupational health and safety management system

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.

Dr Ross Kurinko, GRI Certified Trainer
Reviewed by Dr Ross Kurinko · GRI Certified Trainer LRA educational guidance · Not issued or endorsed by GRI
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to explain how much of its workforce is actually covered by a formal occupational health and safety management system. In practice, the focus is on the extent of coverage, not just whether a system exists somewhere in the business. You should describe the workers included, the parts of the organisation or activities covered, and whether coverage applies across the whole operation or only to selected sites, functions, or worker groups.

The practical question is whether the system reaches the places and people where health and safety risks arise. A report that only refers to flagship sites or head office would not give the full picture if other operations are outside the system. The emphasis is therefore on scope and completeness: who is covered, where coverage applies, and any material gaps or exclusions that affect the organisation’s overall health and safety management.

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

Datapoint What to capture Evidence hint Owner
Safety system in place Whether the organisation has put in place a workplace health and safety management approach that is built on applicable law and/or recognised guidance. Policy or management-system documentation, implementation records, and any internal approval showing the approach is in use. Health and safety / Operations
Basis for safety system The specific legal duties and/or recognised guidance used as the basis for the workplace health and safety management approach. Register of applicable legal duties, standards list, or internal mapping that shows which external basis was used. Health and safety / Legal / Compliance
Worker count The number of workers covered by the disclosure, using the organisation’s chosen counting basis consistently. HR or workforce headcount report, payroll extract, or contractor roster used for the count. HR / People analytics
Worker share The percentage share for the reported group, calculated from the same population and period as the related count. Calculation workbook showing numerator, denominator, and the source population used for the percentage. HR analytics / Reporting
Excluded workers flag Whether any workers were left out of this disclosure. Disclosure scope note, population reconciliation, and any exclusion log or sign-off. HR / Reporting / Compliance
Exclusion explanation Why any workers were left out, and which worker types were left out. Exclusion register, scope memo, and supporting notes naming the excluded worker categories. HR / Reporting
Compilation notes Any extra context needed to understand how the figures were assembled, including key assumptions, filters, or aggregation steps. Method note, calculation workbook, and sign-off comments that explain the compilation approach. Reporting / Data owner
＋ Show GRI 403-8 sub-elements (LRA working checklist)

How to prepare it

1Set the boundary first: decide which parts of the business, sites, and worker groups are in scope for this disclosure, and make sure the same boundary is used throughout the figures and narrative.
2Confirm the basis for the safety system: record whether it is built on statutory duties, recognised guidance, or both, and keep the source documents that support that basis.
3Count and calculate carefully: gather the underlying workforce records needed to show the number covered and the share covered, and check that the percentage is derived from the same population as the count.
4Check for any exclusions: identify whether any workers are left out of the disclosure, then explain who they are and why they are outside the reported scope.
5Add the context needed to read the data: note any assumptions, definitions, timing choices, or consolidation rules that affect how the information was compiled.
6Review the final pack against the source material: verify that the reported answer, supporting text, exclusions, and context all match the official disclosure basis and that nothing material is missing or inconsistent.
Request the data

Request the site safety coverage data from EHS / Operations

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

Which parts of the workforce sit inside the organisation’s safety management arrangements, and what share of the total workforce does that represent for the reporting period?

Use your organisation’s own terms first, then map them to the reporting disclosure. For example, you may talk about site safety, H&S coverage, safety certification, or local safety programmes rather than framework language. Keep the boundary, worker groups, and calculation basis aligned to how your business actually tracks safety oversight.

Weak request

Can you send the GRI 403-8 data showing whether we have an occupational health and safety management system, the legal or recognised basis for it, the number and percentage covered, any exclusions, and contextual information?

Why it fails: It uses framework wording that many operational teams do not track day to day, so the owner may not know which internal report to pull. It also bundles several different asks without telling the team how they record coverage, what boundary to use, or which source system should be treated as the reference point.

Better request

Please send the current safety coverage extract for [reporting period] from [source system/file]. We need the worker groups your team counts as covered by the site safety arrangement, the total in scope, the number covered, the percentage covered, any groups left out with reasons, and a short note on the basis used to compile the figures. Please use your normal internal terms and include the boundary and counting method.

Formal email template
Subject: Request for safety coverage data for [reporting period]

Hi [name/team],

We are preparing the sustainability reporting pack and need your help with the safety coverage figures for [reporting period].

Please send a short table showing:
- the worker groups you include in your safety coverage view;
- the total number of workers in scope under your method;
- the number of workers covered by the current safety management arrangement;
- the percentage covered;
- any worker groups left out, with a brief reason;
- any notes needed to explain how the figures were built.

Please use the terms your team normally uses, and include the source system or file, the boundary used, and the counting basis. If you have more than one version of the data, please indicate which one should be used for reporting.

A possible LRA training template only — please adapt this to your organisation and check the official source before sign-off.

Thanks,
[preparer name]
Short Teams / Slack version
Hi [name/team] — could you share the safety coverage figures for [reporting period]?

Please include the worker groups in scope, total workers, covered workers, % covered, any exclusions with reasons, and the source file/system. Use your team’s usual terms and note the counting basis. Thanks.
Industry examples
Manufacturing

Context. A multi-site plant operator tracks safety coverage by factory, warehouse, and maintenance teams in an EHS dashboard.

Adapted request. Please share the latest site safety coverage report for [reporting period]. Include each plant and warehouse group, the total workers in scope, the number covered by the safety programme, the coverage percentage, any groups excluded, and the reason for each exclusion. Please also note the source system, the counting basis, and any site-level assumptions.

Example response. The EHS team returns a table from the safety dashboard showing 4,820 workers in scope, 4,560 covered, and 94.6% coverage. It notes that 120 agency workers at one temporary overflow site were excluded because the site was outside the managed safety programme during the period.

Professional services

Context. A services firm tracks office-based staff and contractors through a central H&S register and local office safety leads.

Adapted request. Please send the office safety coverage summary for [reporting period]. We need the staff groups your team includes, the total number of people in scope, the number covered by the office safety arrangements, the percentage covered, any exclusions, and a short explanation of how the figures were compiled from the register.

Example response. The facilities and EHS team provides a register extract showing 2,140 people in scope, 2,090 covered, and 97.7% coverage. It explains that 50 short-term contractors were excluded because they were managed under a client-controlled site process rather than the firm’s own office safety arrangement.

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 defined the worker population, what counted as coverage by a health and safety system, and which legal or recognised references were used as the basis for the approach.

Context note

Explain what the count and percentage show about the reach of the safety system across the workforce, and note any exclusions so readers understand the scope of the figures.

Fluctuation statement

If the coverage level, excluded groups, or basis used changed from the prior period, briefly explain what drove the change, such as a revised scope, a different workforce mix, or updated reporting assumptions.

Content index entry
GRI 403-8 Workers covered by an occupational health and safety management system — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for GRI 403-8 — 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.

Free · Community members
01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧
Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We can show the coverage figure was built from a defined set of workers and sites, using a documented method for deciding who was in and who was out.The assurer will test whether the population behind the figure was chosen consistently, whether any exclusions were justified, and whether the method could change the result.Population definition note; inclusion/exclusion rules; site or workforce list used for the calculation; management sign-off on scope decisions; reconciliation between the source population and the reported figure.
We prepared the figure using our own internal records and any external references we relied on, and we kept evidence of the rules or benchmarks used to support the approach.The assurer will probe whether the basis for the figure is traceable, whether the supporting references are current and relevant, and whether the team relied on unsupported judgement.Policy or procedure describing the calculation basis; copies or links to the legal or recognised guidance used; source data extracts; version-controlled working papers; review notes showing how the basis was applied.
The number reported was taken from a controlled calculation file, with the arithmetic checked before publication and any manual adjustments explained.The assurer will look for calculation errors, broken formulas, unsupported overrides, and weak controls over spreadsheet or system outputs.Calculation workbook or system report; formula checks; audit trail for any manual edits; reviewer checklist; evidence of independent recalculation or sample testing.
Where we reported a percentage, we used the same underlying population for both the numerator and denominator and kept the method consistent with the rest of the report.The assurer will test whether the percentage is mathematically sound, whether the denominator is appropriate, and whether the method is applied consistently across periods or entities.Working paper showing numerator and denominator; calculation logic; prior-period comparison; explanation of any changes in method; sign-off confirming consistency.
We identified any workers left out of the disclosed figure and recorded the reason for each exclusion before the report was finalised.The assurer will ask whether exclusions were complete, whether the reasons were valid, and whether omitted groups could materially affect the result.Exclusion log; workforce lists showing omitted groups; rationale for each exclusion; approval from the report owner; evidence that exclusions were reviewed for completeness.
Our explanation for exclusions names the worker groups affected and sets out why they were not included in the count.The assurer will check whether the explanation is specific enough, whether the excluded groups are described accurately, and whether the narrative matches the underlying records.Draft disclosure text; supporting HR or operational records; mapping of excluded groups to the reason given; review comments confirming the wording matches the data.

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 owner
Chasing the H&S team alone can miss the person who holds the headcount, contractor, or site roster used to build the figures.
Using framework language with the business
Asking for the data in disclosure terms instead of the organisation’s own job, site, or workforce labels can leave teams unsure which population to pull.
No clear boundary
If you do not define which entities, sites, or worker groups sit inside the count, different teams may each include a different slice of the workforce.
Wrong period basis
Pulling a snapshot from the wrong date, or mixing year-end and average-period records, can make the count and percentage refer to different populations.
Mixed counting method
Combining full-time, part-time, agency, and contractor records without one agreed counting rule can distort both the number and the percentage.
Source labels lost
Copying figures into a summary sheet without keeping the original file names, report titles, or system labels makes it hard to trace where each figure came from.
Separate groups merged
Putting included workers and excluded workers into one pool can hide which types of worker were left out and why.
Missing evidence trail
Saving the final numbers without the supporting extract date, source owner, and approval record leaves no clear path back to the underlying evidence.
No sign-off trail
If the draft is not checked and signed off by the data owner before it moves on, later changes can be made without anyone knowing who agreed the figures.

Where judgement is often needed

Newly bought or sold businesses during the year
Set a clear cut-off for acquisitions and disposals, then explain whether you counted people only for the period they were in the group or on a year-end basis, so the coverage figure can be read in the right context.
Different country rules and local safety schemes
Where local law or a recognised framework is used in some places but not others, describe the basis used in each country and how you combined them into one group-wide view.
People on the boundary of the workforce
State upfront how you treated agency staff, contractors, interns, and other near-boundary groups, and list any groups left out with a short reason.
Sites with partial safety-system coverage
If only some locations, business units, or job families sit inside the safety system, explain the scope rule you used and how you turned that into the number and percentage reported.
Using estimates where records are incomplete
When headcount or coverage data are not fully measured, say which parts were estimated, what source data or assumptions were used, and whether the estimate changed the reported percentage.
Timing of the population count
Choose and disclose the date or period used for the worker count, especially if staffing moved materially during the year, so readers can compare the numerator and denominator on the same basis.
Rounding and percentage presentation
Apply one rounding rule consistently across the disclosure, and if rounding changes the displayed percentage, note that the underlying figures were calculated before rounding.
Protecting small-team privacy
If a small group would make individuals identifiable, aggregate the data to a safer level and explain the grouping approach so the omission or roll-up is understandable.
Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Food manufacturing

Synthetic example only: we say our health and safety arrangements are built on national legal duties and an external management framework, and we note the share of workers covered by that approach. We also state whether any worker groups are left out, and explain the exclusion and the data-collection basis used for the figures.

This example shows how to describe the management approach, the coverage rate, any exclusions, and the method used to compile the numbers without naming a real organisation.

Illustrative coverage of workers under the health and safety management approach (people)
Employees4200
Agency workers355
Contractors1812
Illustrative (synthetic) example — Logistics and warehousing

Synthetic example only: we report that our safety system is aligned to legal duties and a recognised framework, then show how many workers fall inside and outside that scope. We also clarify that some outsourced drivers are left out because their employer reports them separately, and that the counts come from the latest site roster and contractor register.

This example shows a second way to present the same disclosure, with a different sector, a different coverage pattern, and a clear note on excluded workers and the source records used.

Illustrative coverage of workers under the health and safety management approach (people)
Direct employees2600
Agency staff223
Outsourced drivers015
Company reports

How companies report GRI 403-8

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

Aleatica
Ground Transportation — Highways and Railtracks · Mexico / Spain · 2024
Open report →
Aleatica’s Sustainability Annual Report 2024 covers several relevant aspects, including references to Health and Safety Management Systems and certifications such as ISO 14001 and ISO 39001 on page 94. The report also provides data on the percentage of employees covered by collective bargaining agreements by country on page 207 and discusses prioritised sustainability topics on page 57. However, there are notable gaps with several narrative items not found or unclear in the report, limiting a full understanding of the company’s approach in some areas.
KGI Financial Holding Co., Ltd.
Banks / Diverse Financials / Insurance · Taiwan · 2024
Open report →
KGI Financial Holding Co., Ltd.'s 2024 ESG Report covers its Occupational Health and Safety Management System, noting implementation of ISO 45001:2018 since 2021 (p.97), and provides data on work-related injuries and safety training, including zero severe occupational injuries and mandatory safety training every three years (pp.80, 101). The report also references governance structure related to diversity and inclusion (p.127) and mentions contract termination policies for unethical behavior, though without headline values (p.107). However, the report lacks clear percentage values or comprehensive narrative details on some aspects of occupational health and safety, with several datapoints not found or only partially addressed.
SITC International Holdings Company Limited
Water Transportation · Hong Kong · 2025
Open report →
SITC International Holdings Company Limited’s 2025 Environmental, Social and Governance Report shows that the company has implemented an occupational health and safety management system covered with the ISO 45001 standard (p.143). It also reports the percentage of employees trained by gender and employee category, as well as the average training hours completed per employee (p.178). However, there is no clear or quotable evidence regarding other specific health and safety metrics or detailed methodology in the report.
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Check your understanding

Scenarios to work through

A manufacturer has one safety framework for its main plant, but contractors at a separate warehouse are managed under a different site rulebook and are not included in the central count. The reporting team is deciding whether the warehouse group should be counted in the coverage figure.

QShould the team include those warehouse contractors in the number and percentage, or explain why they are left out?
Reveal model answer →

A services group has a company-wide safety framework built around UK legal duties, plus an internal standard used across all offices. The preparer is unsure whether to describe both or only the legal basis in the disclosure.

QWhat should be stated about the basis of the safety system?
Reveal model answer →

A group has 1,200 workers in total. Of these, 900 are covered by the safety system and 300 agency workers are not included because their host employer manages their health and safety arrangements. The draft currently shows only the 900 and 75%, with no explanation.

QWhat else needs to be added so the disclosure is understandable?
Reveal model answer →

A preparer has the headcount and coverage percentage ready, but the source files are spread across HR, site safety logs and a contractor register. The team is unsure whether a short note about how the data were assembled is needed.

QShould the disclosure include context on how the figures were compiled?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 403-8
within GRI 403: Occupational Health and Safety
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

How do I use the GRI 403-8 page to prepare the disclosure draft from scratch?+
What data do I need to collect for GRI 403-8 on occupational health and safety?+
How should I decide the scope for GRI 403-8 worker coverage?+
What should I put in the ‘basis for safety system’ field for GRI 403-8?+
Who should own the GRI 403-8 data collection and sign-off process?+
What evidence pack should I build for GRI 403-8 assurance readiness?+
What are the common mistakes to avoid when reporting GRI 403-8?+
How do I use the Prep & Assurance workbook for GRI 403-8?+
What can I take from the synthetic example disclosures for GRI 403-8?+
Can I reuse my GRI 403-8 data for ESRS S1 Own Workforce reporting?+
More questions this page can help with
GRI 403-8 occupational health and safety: what datapoints should I gather before drafting?GRI 403-8: how do I document excluded workers and the reason for exclusion?GRI 403-8 evidence pack: what should I include for assurance?GRI 403-8 workbook download: how do I use the .xlsx file in practice?GRI 403-8 draft output: what narrative starters and visualisation ideas are on the page?GRI 403-8 common mistakes: what reporting gaps does the page flag?GRI 403-8 how to prepare: what is the step-by-step process on the page?GRI 403-8 compilation notes: what should I record and why?GRI 403-8 assurance claims: how do I verify the six claims on the page?GRI 403-8 from company reports: how can I use the linked published examples?GRI 403-8 printable Library Card PDF: when should I use it?GRI 403-8 and ESRS S1 Own Workforce: what can be reused across reporting?