Where Does Your Site Sit?

There is a particular kind of unhelpful number that circulates in health and safety.

A multi-million pound fine, reported widely, discussed at conferences, quoted in board papers. The numbers are real and the cases behind them matter. But they are the extreme tail of a distribution, and almost nobody's site is in the extreme tail.

If you are a safety manager trying to work out whether your organisation's exposure is reasonable, or trying to explain to a finance director why a control is worth funding, an outlier is close to useless. You cannot benchmark against it. The question you actually want answered is a quieter one: is what we are seeing normal for a site like ours?

That question is answerable, because the underlying information is public. The Health and Safety Executive maintains open registers of convictions and enforcement notices. What the registers do not do is present themselves as a distribution — they are searchable case by case, which is useful for looking up one company and not much use for asking where the middle is.

So we did that arithmetic, and this is what the middle looks like.

The method, stated first

We have put this before the findings deliberately, because a benchmark is only worth as much as its method.

One caution that matters, and which is easy to get wrong: recent years look artificially cheap. Cases take years to reach court, so the most recent offence years contain only the subset that has already been sentenced. The 2024 cohort shows a lower median than 2015 — that is an artefact of incomplete data, not evidence that fines are falling. Anyone reading a downward trend into the recent end of this register is reading a reporting lag.

The middle

The median corporate fine is £50,000.

Half of all fined cases sit below it. That is the number worth carrying into a budget conversation, rather than the one from the headlines.

The distribution around it is wide, and the width is part of the point:

That spread is why the mean — £190,950 — is a misleading figure to quote. It is dragged upward by a small number of very large cases: 109 of the 2,493 fined cases exceeded £1m, while 1,173, nearly half, came in under £50,000. The mean describes almost nobody.

Costs are usually awarded on top, and are modest by comparison: the median costs award is around £6,350.

By industry

Different sectors sit in genuinely different places, both in how often enforcement action is taken and in what it costs when it reaches court.

Sector Enforcement notices Of which prohibition Convictions Median fine Top decile
Manufacturing 15,666 12% 862 £60,060 £508,451
Construction 7,071 47% 751 £36,000 £333,266
Service industries 4,450 26% 637 £60,000 £500,000
Extractive & utilities 1,562 21% 183 £130,000 £1,200,000
Agriculture, forestry & fishing 244 22% 49 £20,000 £200,000

Two things in that table are worth sitting with.

Construction is treated differently in kind, not just in degree. Nearly half of all enforcement notices served in construction are prohibition notices — stop this activity now — against 12% in manufacturing. Manufacturing is more often told to improve something within a period; construction is more often stopped. That is a reasonable regulatory response to work that is temporary, changes daily, and where the hazard is frequently a fall rather than a process. But it means a construction site and a factory are not experiencing the same enforcement environment, and a benchmark that averages them together tells neither one anything.

The highest fines are in the sector where vehicles are the problem. Extractive and utilities — quarries, waste, ports and utility work — carries a median of £130,000, more than twice the register median, and a top decile of £1.2m. Its two commonest breach themes are vehicles and pedestrians. Nowhere else in the data do those two appear as the top two: manufacturing's commonest themes are chemicals, dust, machinery and guarding; construction's are working at height and dust.

By region

Region Notices Of which prohibition Convictions Median fine
Midlands 5,577 19% 440 £66,000
London 3,374 36% 222 £64,834
Wales & South West 4,235 20% 263 £60,000
Yorkshire & North East 3,554 25% 363 £56,695
East & South East 6,092 26% 498 £53,500
North West 3,672 19% 365 £40,000
Scotland 2,320 22% 295 £30,000

It would be easy, and wrong, to read this as some regions enforcing more harshly than others. The far more likely explanation is composition: what industries sit where, what size of employer, what kind of work. London's high prohibition share sits alongside a large volume of construction activity, and Scotland's figures reflect a different industrial mix and a separate legal system with its own sentencing practice.

Treat the regional cut as context rather than as a finding. It is useful for knowing roughly what the environment around you looks like; it is not evidence about any individual inspector or office.

The cut that is hardest to see any other way

Here is the finding we think earns the most attention, presented with its limitation attached.

Filtering convictions to those where the mechanism involved vehicles and pedestrians — people struck by, or working alongside, moving plant and vehicles — gives 28 cases. That is just over 1% of all corporate convictions in the register.

Those 28 cases carry a median fine of £193,350 — close to four times the register median of £50,000. The largest fine on the entire register is one of them.

The caveat, plainly: 28 is a small sample. A median drawn from 28 cases is indicative, not precise, and it should not be quoted as though it were a stable statistic. We would not build a business case on that number alone.

What the number does support, even allowing for the sample size, is a more modest and more durable observation. Vehicle–pedestrian incidents are rare in the enforcement record and severe when they occur. That combination is genuinely awkward for how most organisations prioritise. Risk is usually ranked by what appears in the incident log, and a hazard that produces very few entries will sit low on that list — right up until the one event that is categorically worse than everything above it.

This is the practical value of a public register. It lets you see the shape of a risk that your own site, by good fortune, may never have generated data about.

What this cannot tell you

A benchmark that oversells itself is worse than none, so it is worth being clear about the limits.

The register records enforcement, not harm. It tells you what HSE acted on and what courts decided. It does not tell you how many incidents occurred, how many were near-misses, or how many sites are managing a hazard well. A sector with few convictions may be genuinely safer, or may simply be less inspected.

Sentencing practice has also changed over the period covered. The Definitive Guideline for health and safety offences, introduced in 2016, tied penalties more explicitly to turnover and culpability, which affects comparability across years.

And the commonest breach themes are a reminder of proportion. In manufacturing they are chemicals, dust, machinery and guarding. Those are the everyday substance of industrial safety, and no single lens — including ours — sees all of them.

Using it well

The most useful thing to do with a benchmark is not to compare yourself to it once. It is to ask a better version of a question you were already asking.

Given our sector, our region and the kind of work we actually do — what does the enforcement record suggest we should be paying attention to, and is that where our effort is going?

If your commonest hazards match your sector's commonest breach themes, your effort is probably well aimed. If your sector's severe cases cluster around a mechanism that barely appears in your own records, that is worth a conversation — not because an incident is likely, but because the absence of data is not the same as the absence of risk.

None of this is an argument for alarm. The overall picture in the register is of a regulatory system that acts proportionately far more often than it acts dramatically: mostly improvement notices, mostly fines well below the headline numbers, mostly organisations correcting something and carrying on. That is a system working roughly as intended.

It is simply easier to work inside a system when you can see where you stand in it. That information has been public all along. It has just never been arranged in a way that answered the question people actually have.

Common questions

What is the average HSE fine? The median corporate fine on HSE's public register is £50,000 — half of all fined cases sit below it. The mean is £190,950, but that figure is a poor summary: it is pulled upward by a small number of very large cases, with 109 fines above £1m and 1,173, nearly half, below £50,000.

Which industry gets the largest HSE fines? Extractive and utility supply industries — quarries, waste, ports and utility work — carry the highest median fine at £130,000, more than twice the all-sector median, and the highest top decile at £1.2m. Its two commonest breach themes are vehicles and pedestrians.

Why does construction receive so many prohibition notices? Around 47% of enforcement notices served in construction are prohibition notices, against 12% in manufacturing. Prohibition notices stop an activity immediately, which is a proportionate response to work that is temporary, changes daily, and where the commonest hazard is a fall rather than a process.

Are HSE fines falling? No — that impression is a reporting artefact. Cases take years to reach court, so recent offence years contain only the subset already sentenced and show artificially low medians. A downward trend at the recent end of the register is a reporting lag, not a change in sentencing.

Do enforcement figures tell you how safe an industry is? Not directly. The register records enforcement, not harm. It shows what HSE acted on and what courts decided, not how many incidents occurred or how many sites are managing a hazard well. A sector with few convictions may be genuinely safer, or simply less inspected.


Contains public sector information published by the Health and Safety Executive and licensed under the Open Government Licence v3.0

Figures derived from HSE's public registers of convictions and enforcement notices. Corporate defendants only; convictions naming individuals are excluded. No organisation is identified. This article is general information, not legal advice.

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