What Manchester City's Verdict Teaches Us About Lying in Health and Safety

This week an independent commission found Manchester City guilty of all of the 115 Premier League charges they faced.
The panel found breaches of the league's financial rules across nine seasons, along with most of the charges about failing to co-operate with the league's investigation.
City say they are disappointed, maintain their innocence and intend to appeal, and sanctions are still to be decided.
But I'm not here to talk football. What struck me about the case is that almost none of it is about what happened on the pitch. It's about records: financial information that didn't reflect reality, payments that weren't fully disclosed, and an organisation accused of making life difficult for the people trying to check.
After almost 28 years in health and safety, that sounds very familiar.
In our world, the records are the safety system. In football, the cost of cheating is measured in points, trophies and fines. In health and safety, it's measured in people.
A risk assessment, an inspection certificate or a training record isn't admin for the sake of it. It's the evidence that a control actually exists. Everyone downstream trusts it. The operator trusts that the lifting chains were examined. The manager trusts that the new starter was trained. The fire service trusts that the alarm was tested.
When that record is false, the rule isn't just broken, the safety net is quietly removed, and nobody knows it's gone until something falls through it.
Where cheating hides in the workplace, it is rarely dramatic. In my experience it usually looks like this:
• Pencil-whipped checklists – forklift pre-use checks ticked in the canteen, not at the truck.
• Backdated or invented inspections – LOLER thorough examinations, PAT testing, fire alarm and emergency lighting tests "done" on paper.
• Fake competence – training certificates signed for courses nobody attended, or cards bought rather than earned.
• Hidden injuries – incidents kept off the books to protect a bonus or the "days without an accident" board, and RIDDOR reports that never get made.
• Copy-and-paste paperwork – risk assessments lifted from the internet with another company's name still in the footer.
• Driver hours and tachograph manipulation – tired drivers on paper-perfect schedules.
Each one feels small. Each one is a lie that someone else will rely on.
The law takes it seriously. The Health and Safety at Work etc. Act 1974 doesn't treat dishonesty as a paperwork issue. Section 33 makes it an offence to intentionally make a false entry in a required record, to knowingly or recklessly make a false statement, and to obstruct an inspector. Section 37 means directors and managers can be personally prosecuted where an offence is committed with their consent, connivance or neglect.
Under the sentencing guidelines, fines are unlimited and scaled to turnover, and imprisonment is available for individuals.
Falsifying documents and deliberately concealing wrongdoing are treated as aggravating factors, which push the penalty up. In short, a lie can turn a manageable failing into a very serious one.
A big chunk of the City case was about not co-operating with investigators. That should make every employer think.
When the HSE or a local authority inspector arrives after an incident, how you respond matters. Withholding documents, "losing" records or getting your story straight with staff doesn't make the problem go away. It adds a second problem on top of the first, and it destroys any credibility you had left.
Being open early is almost always cheaper, legally, financially and reputationally.
Where lies in safety systems end up.
The starkest example in recent UK history is Grenfell Tower. The Inquiry's final report in 2024 found dishonesty by product manufacturers around fire testing and how their products were marketed. Seventy-two people died.
That is where manipulated safety information ends up when nobody challenges it: not in a fine or a points deduction, but in lost lives.
So why do people cheat, and how do you stop it?
Most people who falsify a safety record aren't villains. They're under pressure. The usual drivers are:
• targets and bonuses tied to "zero accidents"
• not enough time or resource to do the job properly
• a belief that "it's always been fine"
• fear of being blamed if they report a problem.
The fix is cultural as much as procedural:
1. Reward reporting, not silence. Measure near misses and actions closed, not just injury-free days.
2. Remove perverse incentives. Never link bonuses to a lack of reported accidents.
3. Make checks real and quick. If a checklist takes 20 minutes, people will skip it. Make it practical.
4. Verify, don't assume. Spot-check records against reality: walk to the equipment and look.
5. Adopt a just culture. Ask "what went wrong?" before "who did it?", while being clear that deliberate falsification is never acceptable.
Manchester City's case took years to reach a verdict and the appeal will take longer still. But the principle holds: the truth tends to come out in the end.
In the workplace, it usually comes out after someone has been hurt. Far better to find it yourself first.
If you're not sure whether your records would stand up to scrutiny, KSH Safety Services can carry out an honest, independent audit and help put things right.
And if competence is your gap, our courses at kshsafetyonline.com are a quick way to make sure your training records reflect real learning.
Because in health and safety, honesty isn't just the best policy. It's the only safe one.


