Safety Metrics — LTIFR + Fatalities Disclosure — BRSR Core Attribute

What this attribute is

Safety Metrics (LTIFR + fatalities + recordable injuries + work-related ill-health) is part of the nine BRSR Core attributes that SEBI requires every Top-1,000 listed entity to subject to independent reasonable assurance under SAE 3000 (Revised). It sits within NGRBC Principle 3 — Employees + Workers Wellbeing and is the most operationally-sensitive Core attribute — safety numbers are visibility metrics for the audit committee, lender ESG covenants, and ESG-rating agencies, with material reputational + commercial consequences for adverse trends.

The attribute captures multiple numbers for each of three cohort groups (employees, workers, value-chain partners — the last typically as a Leadership Indicator):

1. LTIFR (Lost Time Injury Frequency Rate) per million person-hours
2. Number of recordable work-related injuries
3. Number of fatalities
4. Number of cases of work-related ill-health (including high-consequence occupational illness)
5. Number of safety-related complaints + their resolution rate

The BRSR Core attribute is employees + workers LTIFR + fatalities + recordable injuries. The sibling Spend on Wellbeing covers the financial-input side (health insurance, EAP, ergonomics, wellness programmes); this attribute covers the safety-outcome side.

Formula and units

LTIFR

LTIFR = (Number of lost-time injuries × 1,000,000)
      ÷ Total person-hours worked

The convention is per million person-hours worked, matching GRI 403-9 + ICAI BRSR guidance. The output is a rate (e.g., LTIFR of 0.5 = 0.5 lost-time injuries per million person-hours worked).

Separately calculated for:

• Employees (own payroll, including permanent + contractual + temporary)
• Workers (not on payroll, working at the entity’s premises: security, housekeeping, contract production)

Lower LTIFR = better safety performance. Industry benchmarks vary materially (financial services typically 0.1-0.5; chemical / cement / steel manufacturing 0.5-3.0; construction 3-8).

Fatality Rate

Fatality Rate = (Number of work-related fatalities × 1,000,000)
              ÷ Total person-hours worked

Reported as a separate metric from LTIFR. Fatalities are NOT included in the LTIFR numerator.

Other reported counts

• Recordable injuries — absolute count; includes lost-time + non-lost-time recordable injuries. Lost-time subset feeds LTIFR.
• Work-related ill-health cases — absolute count of occupational disease / mental health cases newly diagnosed in the FY; rate per million person-hours optional.
• High-consequence work-related injuries — injuries resulting in permanent disability or > 6 months of recovery; separately disclosed.

Cohort definitions — employees vs workers

The most consequential definitional distinction in safety reporting.

Employees

Persons on the entity’s own payroll — permanent, contractual (direct), temporary (direct), apprentices, trainees. Excludes contract workers engaged through a manpower agency.

Workers

Persons not on the entity’s payroll, working at the entity’s premises:

• Manpower-agency-supplied staff (security, housekeeping, drivers, contract production line)
• Direct-engagement contractors (e.g., specialist welder hired on a per-day basis)
• Sub-contractor employees on the entity’s premises

Why the split matters

LTIFR for workers is often 2-5× higher than for employees in industries with significant contractor workforce (cement, steel, construction, oil + gas, infrastructure). This is because:

• Worker turnover is higher → less safety training time per person
• Worker compensation structures often don’t reward time-out for safety
• PPE issuance + maintenance may be sub-contracted to the manpower agency, which can deprioritise quality
• Hazardous tasks are often the ones contracted out

The split disclosure surfaces this gap to the audit committee + ESG-rating agencies. Industries with a flat employees+workers LTIFR (no gap) often face follow-up questions during assurance — either the contractor population has been mis-classified as employees, or the safety culture is genuinely consistent (which is rare in manufacturing-intensive operations).

Worked example

Mid-size cement entity for FY 2025-26.

Employee data

Item	Value
Total employees	1,200
Total employee person-hours worked	24,00,000
Recordable employee injuries	3
Lost-time employee injuries (subset of recordable)	2
Employee fatalities	0

LTIFR (employees) = (2 × 1,000,000) / 24,00,000 = 0.83 per million person-hours Recordable injury rate (employees) = (3 × 1,000,000) / 24,00,000 = 1.25 per million person-hours Fatality rate (employees) = 0

Worker data

Item	Value
Total workers (contract)	1,800
Total worker person-hours worked	32,40,000
Recordable worker injuries	9
Lost-time worker injuries (subset of recordable)	6
Worker fatalities	1 (work-related road traffic accident on transport from quarry to plant)

LTIFR (workers) = (6 × 1,000,000) / 32,40,000 = 1.85 per million person-hours Fatality rate (workers) = (1 × 1,000,000) / 32,40,000 = 0.31 per million person-hours

Combined narrative

LTIFR for workers is 2.2× that of employees — consistent with cement-industry benchmarks where contract operations (quarry, transport, kiln maintenance) carry higher hazard. The single worker fatality requires a separate root-cause analysis disclosed under Principle 3 EI 5 narrative + Section 88 notice filed with the Chief Inspector of Factories.

Evidence the assurance partner checks

Document	What it evidences	Source
Form 17 register (Factories Act)	Accident register at the factory	Entity’s EHS register
Form 18 register	Notice of accident filed with Inspector of Factories	Entity’s EHS register + Inspector ack
Section 88 notice to Chief Inspector	Notice of fatal / serious accident	Inspector of Factories office
ESIC IP-7 claim trail	Lost-time injury claims under ESI	ESIC portal
Workmen’s Compensation Act claim trail	LTI / fatality claims under WC Act	Insurance carrier
EHS database / SAP-EHS / iAuditor logs	Internal injury reporting + investigation	Entity’s EHS system
Contractor attendance / muster register	Person-hours denominator for workers	Manpower agency / contractor
Time-keeping system (HRMS)	Person-hours denominator for employees	HRMS / SAP HR
Doctor’s certificate / fitness certificate	Lost-time vs recordable classification	Treating doctor / company medical officer
Internal injury investigation reports	Root-cause analysis + corrective action tracking	Entity’s EHS process
Insurance loss runs	Independent cross-check on claim frequency	Insurance carrier

Common audit findings

1. Person-hours denominator inconsistency. Numerator counts all injuries but denominator only counts permanent employees; or numerator counts contractor injuries but denominator excludes contractor person-hours. Numerator + denominator must be on the same cohort scope.
2. First-aid case misclassified as recordable. Minor cuts / abrasions treated on-site shouldn’t be in the recordable count. ICAI BRSR follows GRI 403’s distinction — first aid is excluded from BRSR Core safety metrics.
3. Lost-time vs recordable classification gap. Some entities count any medical treatment as lost-time. The correct classification: lost-time requires ≥ 1 day away from work (beyond the day of the incident).
4. Contractor LTIFR consolidated under “employees”. Mis-classification that hides the contractor-vs-employee gap. The disclosure is mandated separately.
5. Fatality narrative + root-cause missing. Per ICAI guidance, each fatality requires a separate narrative (date, location, root cause, corrective action) in the Principle 3 EI 5 disclosure. Aggregated count without narrative typically attracts an assurance qualification.
6. Work-related ill-health under-reported. Long-tail occupational illnesses (silicosis, hearing loss, repetitive strain injury) often surface late + go unrecorded if the medical surveillance programme is weak. Annual occupational health screening + the resulting case logs are part of the assurance scope.
7. Section 88 notice non-compliance. Fatal / serious accidents require notice to the Chief Inspector of Factories within 48 hours — non-compliance flags both BRSR and Factories Act consequences.
8. Value-chain incidents over-claimed. Some entities include upstream supplier incidents in their LTIFR — but BRSR Core scope is employees + workers AT the entity’s premises. Value-chain partner safety is a Leadership Indicator, not Core.

Connection to the Spend on Wellbeing Core attribute

Spend on Wellbeing is the financial-input side of safety + health + wellbeing — covers health insurance, accident insurance, EAP, ergonomic upgrades, safety training spend. This attribute (LTIFR + fatalities + recordable injuries) is the safety-outcome side. The audit committee tracks both:

• High wellbeing spend + improving LTIFR → effective programme
• High wellbeing spend + flat / worsening LTIFR → input-output mismatch; investigate
• Low wellbeing spend + low LTIFR → potentially under-reporting or low-hazard industry
• Low wellbeing spend + high LTIFR → safety underinvestment

Both attributes feed the same NGRBC Principle 3 disclosure under BRSR Section C, with cross-references in the cover note’s Principle 3 narrative.

XBRL filing

This attribute is filed in the BRSR XBRL instance document under the Principle 3 Essential Indicator 5 elements from the MCA-published BRSR taxonomy module. Per-cohort LTIFR + recordable injuries + fatalities + work-related ill-health cases are filed as separate elements with employee + worker context references. Verify element names + unit references against the current MCA taxonomy version.

Both current-year and previous-year context references must be populated. The narrative section + each fatality’s root-cause analysis are filed as text disclosures in the BRSR Section C Principle 3 area.

See XBRL Taxonomy for BRSR for the structural overview.

How this attribute rolls up into the BRSR Core engagement

This attribute is one of the BRSR Core attributes under Principle 3 (alongside POSH + wellbeing). The signed BRSR Core assurance report attests these numbers to reasonable assurance under SAE 3000 (Revised). Workpapers retained by the assurance partner cover:

• Vouching of each recorded injury to Form 17 + ESIC / WC Act claim trail
• Reconciliation between EHS database + insurance loss-runs
• Person-hours denominator reconciliation to HRMS + contractor attendance registers
• Fatality root-cause analysis review
• Section 88 notice compliance check
• Sample testing of first-aid vs recordable vs lost-time classification

For the engagement that produces the signed assurance opinion, see BRSR Core Assurance.

Related reading

• NGRBC Principle 3 — Employees + Workers Wellbeing — parent pillar
• Spend on Employee Wellbeing — sibling Core attribute (financial input side)
• POSH Complaints Disclosure — sibling Core attribute (workplace dignity)
• Document Evidence Requirements — full evidence checklist including safety documents
• XBRL Taxonomy for BRSR — XBRL filing structure
• BRSR Core Assurance — service