Enforcement Management Model (EMM): Framework for drafting enforcement guidance

Formerly OC 130/4


This guidance advises on drafting enforcement guidance in a manner that makes it readily compatible with the EMM. The appendix details a suggested framework for the production of guidance and criteria that authors should include to ensure enforcement decisions are made in accordance with policy aims.


This document describes a common framework for HSE authors to follow when preparing enforcement guidance in line with the Enforcement Management Model (EMM). The framework is described in the Appendix.

Enforcement guidance assists inspectors in making consistent enforcement decisions. It should be distinguished from other guidance that does not include enforcement advice.


Authors of enforcement guidance should follow the framework set out in the Appendix.


The EMM was designed to help inspectors exercise their judgement when making enforcement decisions in line with HSE's Enforcement Policy Statement. A fundamental principle is that enforcement action should be proportional to the health and safety risks and the seriousness of the breach of law. In addition, the EMM helps managers monitor the fairness and consistency of inspectors' enforcement decisions and helps less experienced inspectors in making these decisions. It can also assist others (eg those directly affected) in their understanding of the principles that inspectors follow when deciding on a particular course of action.

The latest Operational version 3.2 of the EMM was introduced in 2014 to accommodate changes to the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) and to better define consequence descriptors.


Not applicable

Further References

Enforcement Management Model (EMM) Operational version 3.2 {confirm link}

Operational Guidance - Enforcement Management Model (EMM): Application to Health Risks

Operational Guidance - Enforcement Management Model (EMM): Application to Hazardous substances

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Updated 2022-08-16