OSH Metrics in Sustainability Reporting – LTIFR, TRIR and ESRS S1

OSH leaves the binder – accident rates in the ESG report

Only a few years ago, workplace accident statistics lived mainly in two places: the statistical accident card sent to Statistics Poland (GUS) and the annual review of occupational safety and health (OSH), which the management board read and then put on the shelf. Today, the same figures go into the sustainability report – a document read by investors, banks, customers and, increasingly, job candidates.

This is a qualitative shift. The accident rate is no longer an internal matter for the OSH department; it becomes information about how the company treats people and how it manages risk. A bank granting an ESG-linked loan may ask about the LTIFR trend, and a major customer about the number of fatal accidents among contractors. The OSH service (służba BHP), which until now prepared data “for itself”, must deliver it in a way that is consistent, comparable and able to withstand an auditor’s questions.

ESRS S1, GRI 403 and the Omnibus – which rules apply

The basis for OSH reporting in the European Union is the European Sustainability Reporting Standards (ESRS), specifically standard S1 “Own workforce”. Alongside them, many companies still use GRI 403 – the standard dedicated to occupational health and safety, which for years set the market benchmark and on which the ESRS draw heavily.

The last two years, however, have brought considerable change. The Omnibus package narrowed the scope of the reporting obligation: the amended CSRD has applied since March 2026 and covers primarily companies with more than 1,000 employees and a turnover above EUR 450 million. Member States have until March 2027 to transpose the changes. In July 2026, the European Commission adopted the simplified ESRS, which are to apply from the 2027 financial year, and the number of mandatory data points has fallen by more than 60%.

For OSH services, one thing matters most: workplace safety metrics have survived the simplification. Their definitions, however, have been revised – including those of a recordable work-related accident, work-related ill health and workers present on site. This means the figures may change even if the actual level of safety stays the same. Companies outside the scope of the CSRD often report voluntarily anyway, because banks and customers expect it.

Which OSH metrics are reported under ESG

The set of core metrics is similar regardless of the standard. It answers three questions: how many people are covered by the OSH management system, how many incidents there were and how serious their consequences were.

LTIFR and TRIR – how to calculate the accident frequency rate

The key is conversion to hours worked. The number of accidents alone says little – ten incidents in a company employing a hundred people is something entirely different from ten in a plant with five thousand workers. That is why reports and investor discussions are dominated by frequency rates such as LTIFR (lost time injuries) and TRIR (all recordable incidents), calculated using a simple formula:

In Poland, this requires a certain change of mindset. National statistics have long relied on the accident frequency rate per 1,000 employees, whereas the sustainability report needs hours worked. Data from HR and working-time systems therefore becomes as important as post-accident reports.

The most common problems with OSH data in the ESG report

On paper, the metrics look simple. In practice, most difficulties start with definitions. Polish law, Statistics Poland, the ESRS and GRI do not always understand an “accident” in the same way. Is an incident without absence, requiring only first aid, an accident to be reported? Does an accident on the way to work count? Is a lost day a calendar day or a working day? If someone answers these questions differently at each plant of a corporate group, the consolidated rate loses its meaning.

The second challenge is contractors. In many industries – steel, energy, chemicals, construction – it is the employees of external companies who perform the most dangerous work. A report that shows only the company’s own workforce may look very good while leaving out the most serious incidents. That is why the standards require fatalities to be disclosed also among other workers on site. Collecting this data requires contract clauses and discipline in incident reporting by contractors.

The third problem is data quality. The sustainability report is subject to assurance by a statutory auditor, who will ask where every figure comes from. A spreadsheet emailed between plants is not enough. What is needed is a procedure describing data sources, how data is collected, responsibilities and controls – and an OSH audit is a good way to check whether such a procedure works in practice.

Finally – the temptation of nice numbers. When the accident rate goes into a report for investors, and sometimes into bonus schemes as well, the pressure grows for there to be fewer incidents on paper. Every experienced OSH specialist knows this mechanism: moving an injured worker to “light duties” instead of sick leave, or an incident that suddenly “is not an accident”. A low rate built this way is worse than a high but honest one.

Leading indicators – not just counting accidents

All mandatory metrics share one feature: they are lagging. They describe what has already happened. That is why more and more companies supplement their reports with leading indicators, which show what the organisation is doing to prevent accidents. These may include the number of reported near misses, the percentage of corrective actions closed on time, the number of safety walks involving management or OSH training hours per employee.

Such metrics are not required, but they tell the company’s story well. A growing number of near-miss reports alongside a falling number of accidents is a clear signal that the safety culture is maturing. It is important that the report also includes a commentary: what has changed, why, and what actions the company took after the most serious incidents.

In all of this, the OSH service gains a new role. It is no longer merely a data supplier for the ESG department; it becomes the subject-matter owner of that data. It knows how to interpret definitions, where errors may lurk and how to explain a sudden jump in a metric to the auditor. Good cooperation between OSH and the HR, finance, procurement and ESG departments determines whether the report will be credible.

Summary

OSH metrics in the sustainability report are more than moving accident statistics into a new document. They are a public statement about how the company looks after people – including those employed by contractors. Despite the simplification of the ESRS, workplace safety has remained at the heart of social reporting, and the revised definitions require existing methods to be reviewed. Companies that ensure consistent definitions, reliable data sources and an honest commentary will gain credibility with investors and banks. And the OSH service will gain a voice in discussions where it has often been missing.