What DOSH and GRI 403 both want from your safety data

Health and safety is the ESG topic where Kenyan companies most often already have the data and least often have it in a form they can report. The Directorate of Occupational Safety and Health requires accident registers, workplace audits and incident notification under the Occupational Safety and Health Act 2007. Multinational customers and lenders ask for the same events expressed as GRI 403 rates. The events are identical. The reporting rarely is.

The numbers both sides want

Strip away the terminology and there are five figures.

1. Fatalities, work-related, employees and contractors separately.
2. Lost time injuries, defined consistently, with the days lost.
3. Hours worked, because every rate depends on it.
4. Near misses and high-potential incidents, which show whether the reporting culture is honest.
5. Training coverage, meaning the share of workers who completed the safety training relevant to their role.

From those five you can produce the lost time injury frequency rate per million hours that GRI 403-9 asks for, the incident notifications DOSH requires, and the safety table that appears in every customer questionnaire.

Where companies go wrong

The most common failure is inconsistent definitions across sites. One plant counts a first-aid case as an injury, another only counts cases with a medical certificate. When the numbers roll up, the group rate means nothing, and an auditor will find the difference in an afternoon.

The second failure is contractors. DOSH holds the occupier responsible for everyone on site. GRI 403 asks for workers who are not employees to be reported separately. Many companies simply do not collect contractor hours, which makes both disclosures impossible to substantiate.

The third is hours worked. Payroll knows the number, but it rarely reaches the safety team in a form that can be reconciled to the incident register. Without it, no rate is defensible.

A practical fix

Write one definition set for the group and publish it to every site. Collect the five figures monthly by site, from the same register the DOSH inspector will see, with the safety officer submitting and the plant manager approving. Attach the incident report to each lost time case as evidence. Reconcile hours worked to payroll quarterly.

That is a maker-checker process, and it is the same discipline that finance already applies to revenue. Safety data deserves it, because a fatality figure that cannot be substantiated is a reputational risk in its own right.

How AfriESG helps

The platform carries the health and safety metrics preloaded with GRI and DOSH references, collects them by site and period with an approver on every value, flags a month that moves sharply against the prior period, and holds the incident report as evidence behind the number. The rate is calculated from hours worked, not typed. When the customer questionnaire arrives, the table is already there.