In its response to Ragnar Löfstedt's call for evidence, the IOSH will also suggest some regulations could be merged, as long as they do not weaken the responsibility employers have to protect their staff from injury and ill health.
The minister for employment, Chris Grayling, announced Löfstedt would chair the independent review of health and safety legislation back in March.
To help inform his research, the academic requested evidence from key stakeholders, which was due on Friday (29 July).
As part of the evidence it is submitting, IOSH is including the results of a survey canvassing members' views on current law and its fitness for purpose.
IOSH executive director of policy Luise Vassie said: "We don't see cuts as the answer - previous reviews of health and safety legislation have already weeded out redundant rules.
"Our research, evidence and member survey all confirm our view that health and safety law itself isn't at fault - it's the way it's sometimes interpreted and applied that's the problem.
"We know that current health and safety legislation does a good job in affording hard-working people in the UK the right standards of protection. But we are telling Löfstedt that we see scope for merging some laws. Simplifying, not changing, some regulations would streamline what we already have, cutting down the number of laws and arguably making it easier for bosses to understand what they need to do."
The results of the IOSH survey emphasise the important part legislation has to play in a well-managed organisation. For example, over a third of respondents lauded the Management of Health and Safety at Work Regulations as a piece of law that had significantly improved health and safety over the years.
The IOSH survey questioned members on whether the legislation imposed an unnecessary burden on business. Almost 40% suggested regulations that could be merged, but only around a sixth felt any laws could be abolished without negatively impacting people's safety and health.
IOSH head of policy and public affairs Richard Jones said: "The central principles at the heart of our legal system need to stay. Our members are telling us that current laws allow employers a balanced, flexible approach to health and safety. But carefully selecting regulations for merging, and simplifying the language, will go a long way towards reversing the misguided view that health and safety law is over the top.
"In the long term, we think the solution to the perceived 'burden' of health and safety is education and the creation of a 'risk intelligent' society. That means giving businesses - especially smaller firms - simpler, more definitive guidance and access to good advice. It also means delivering better risk education. This needs to start in our schools and run through to colleges, universities and into the workplace."
IOSH is already taking action, providing tools and tips to make risk management easier. But it would like Prof Löfstedt's review, as well as the Government, to emphasise the benefits of good health and safety management, which are too often overshadowed in the current debate. It's also pressing for promotion of the business case for health and safety, set out in its new Li£e Savings campaign.
In its response to Löfstedt, IOSH has called for work-related road traffic accidents to be reported under RIDDOR, for positive directors' duties to be made explicit in terms of their responsibility to protect staff, and for GPs' fit notes to include reminders to encourage employers to report work accidents.
In its own submission The Royal Society for the Prevention of Accidents (RoSPA) has urged the Löfstedt Review team to take a broad and evidence-based approach to its task and look for practical solutions which could help all businesses, including small firms, to meet their health and safety duties.
RoSPA has submitted evidence to the team cautioning against reducing the number of regulations by merger purely for cosmetic reasons, and has made a number of proposals for practical measures that could be taken, including:
- Giving lower-risk small and medium-sized enterprises (SMEs) the option of producing simple health and safety action plans based on the combined safety policy and risk assessment template already offered by the HSE
- Encouraging third party "semi-regulators" (such as clients, insurers, investors, and training funders) to implement mediation procedures enabling firms to appeal against what they see as over-the-top requirements
- Looking at lessons that can be learned from what has worked well in other industrialised countries and link this to wider efforts to promote effective health and safety regulation worldwide.
While accepting that there may be a case for removing repetitious duties in certain regulations (such as on risk assessment, information and training), RoSPA has urged the team to also look at where there may still be significant gaps in health and safety law (e.g. accident investigation and work-related road risk).
Roger Bibbings, RoSPA's occupational safety adviser, said: "There may be a case for better regulatory housekeeping, but owners and managers in small firms do not read raw, undigested health and safety law. What they need is good guidance and above all competent advisers to point them in the right direction. The Löfstedt team needs to take a wider view of current challenges in health and safety and suggest imaginative solutions.
"Health and safety law and standards are important and are essential to safeguard people's lives and health. The existing legal structure and the underpinning guidance has been based on literally hundreds of thousands of hours of detailed research, development and consultation."
RoSPA has also urged that the review should encompass analysis of the health and safety aspect of the Government's Red Tape Challenge and the HSE's major programme for revising its inventory of more than 1,300 pieces of key guidance.