IMCA’s own numbers are telling it something awkward On the surface they can say things are improving LTIFR and TRIR are drifting down and the graphs look tidy yet in the same year fatalities more than double, line‑of‑fire dominates the injury picture again, and safety observations drop away That is not just “how the data turned out” it is a sign of how the system is set up The statistics package is built around hours, LTIFR, TRIR and FAR so the story that gets told is rate driven Leaders are nudged to chase smaller numbers rather than fewer people put in front of high‑energy hazards When four of seven fatalities can be reported without real detail it shows how limited the learning expectation really is and how easy IMCA is prepared to be with members who under‑share As an advisory body IMCA could shift this quite simply Start by leading with serious and fatal risk not with frequency rates Every fatality should carry a short, anonymised learning story what was being done, what failed, what has changed Use the banding data and line‑of‑fire trend to talk plainly about where the real risk lives and who is struggling, especially in the smaller contractor bands There is also a bigger structural thing in the background Most of the richer guidance and analysis sits behind member access That means the companies most in need of help often see the least of it, and the wider industry cannot easily challenge or learn from the same evidence For a body that wants to speak for the whole sector that is a built‑in weakness Perhaps the question IMCA has to consider is this Does it want to be mainly a keeper of benchmarks for paying members Or does it want to be a place where uncomfortable lessons about fatal risk are shared openly even when that makes some of those members uneasy