INSPECTION PACK

WORKPLACE
TRANSPORT

September 2007

Contact: Jayn Johnson, Services, Transport and Safety Unit

1 Background information

2 Guidance on the management of the topic area

2.1 Management
2.1.1 Assessment of WT risks and control measures
2.1.2 Supervising & monitoring workplace transport issues
2.1.3 Deliveries and (un)loading

2.2 Safe site

2.2.1 Pedestrian/vehicle separation
2.2.2 Access by members of the public (MoPs)
2.2.3 Eliminating / minimising reversing
2.2.4 Speed limits

2.3 Safe driver

2.3.1 Training
2.3.2 Drivers as a vulnerable group
2.3.3 Work-related road safety

2.4 Safe vehicle

2.4.1 Vehicle selection and maintenance
2.4.2 Overturning vehicles
2.4.3 Falls from vehicles
2.4.4 Objects (including the load) falling off vehicles
2.4.5 Parking vehicles and trailers

2.5 Further advice

3 Aide-memoire on inspection

4 Sector enforcement guidance, legal requirements, references and

national enforcement expectations

4.1 Agriculture and Food Sector

4.1.1. Agriculture
4.1.2 Food

4.2 Services, Transportation & Safety Unit (STSU)

4.2.1 Air transport industry
4.2.2. Docks
4.2.3 Road haulage

4.3 Construction

4.4 Local Authority Sector

4.4.1 Leisure
 4.4.2 Warehousing

4.5 Manufacturing Sector

4.5.1 Engineering
4.5.2 Concrete and brick factories - sheeting & unsheeting
4.5.3 Paper
4.5.4. Quarries
4.5.5 Scrap metal, recovered paper and waste management sites
4.5.6 NEE for workplace transport issues in woodworking premises

4.6 Education, nursery schools and play schemes

4.7 Legislation on workplace transport

4.7.1 Workplace Health, Safety & Welfare Regulations 1992
4.7.2 Provision & Use of Work Equipment Regulations 1998
4.7.3 Supply of Machinery (Safety) Regulations 1992
4.7.4 Health and Safety (Safety Signs & Signals) Regulations 1996
4.7.5 Work at Height Regulations 2005

4.8 National Enforcement Expectations – General

5 Cross-sector references on workplace transport

6 Notice templates

7 Checklist for dutyholders

Appendix 1 Causal information on workplace transport incidents

Appendix 2 Reporting of good practice

Appendix 3 Inspection template and technical guidance from the “Struck

by” project
1 Background information
(NB: throughout this document, bold text is to aid scanning of the document when used as a memory-
jogger).

Workplace Transport (WT) covers the use of all types of vehicles and powered
mobile work equipment in workplaces. It does not include vehicles travelling on
the public highway. Vehicles are a part of everyday life, not only at work but
elsewhere, and as a result the associated dangers are often overlooked -
complacency is a real problem. WT is the second biggest cause of fatal
accidents in HSE enforced workplaces (after falls from a height).

In 2004/5 there were 70 fatal and 2021 major injuries in HSE/LA enforced
workplaces. The main cross-industry causes of WT fatals and major injuries are:

- being struck by a moving vehicle (60% of WT fatals, 37% MI))

- people falling off a vehicle or its load (17% WT fatals, 42% MI)
- loads falling off vehicles (14% WT fatals, 10% MI)
- vehicles overturning (9% WT fatals, 3% MI)

It is likely that WT will be a significant hazard for many duty holders. Any
workplaces where a fork lift truck is used or where large goods vehicles make or pick
up deliveries certainly warrant detailed examination of WT control measures. Even
apparently low risk premises such as offices may well have associated staff car
parking areas, and may receive deliveries by lorry or van. Risks from these WT
activities are easily overlooked by duty holders and inspectors alike, but may be
significant.

WT is one of the most "multi-factoral" risk control issues duty holders have to cope
with. Adequately controlling the risks from WT, especially the vehicle movement
risks, depends on duty-holders establishing and sustaining control over a wide
range of matters which could contribute to accidents, broadly falling into the 3
categories of safe site, safe vehicle and safe driver. These 3 categories are
reflected in the 3 Risk Control Indicators (RCIs) for Workplace Transport :-

Safe site: “Well defined traffic routes free from obstruction, firm and even surfaces.
Every effort made to separate pedestrians from vehicles. Pedestrian crossing
points. Effective one-way system for HGVs”.

Safe vehicle: “Effective maintenance of steering, brakes and lights. ROPS and seat
belts fitted when appropriate. Reversing aids fitted when appropriate”.

Safe driver: “Fork lift truck drivers trained and competent in accordance with ACoP,
similar raining for drivers of other types of vehicle. Active supervision of driver
behaviour”.

Neglecting any one of these controls may result in a fatality, even if most other
aspects of WT control are reasonable - even the best driver in the best laid out
workplace is likely to have a serious accident if his vehicle's brakes fail due to lack
of preventative maintenance. Similarly, even if a workplace is well designed and
laid out, vehicles are properly selected and maintained, and drivers receive adequate
training, if there is inadequate supervision and monitoring of actual working
practices, bad practices are likely to develop.

The financial costs to a business of an incident involving WT can be very high, even
if no-one is hurt. If a reversing lorry hits a support pillar in a yard, damage can easily
run into thousands when the costs of vehicle parts, labour and downtime, building
repair costs including labour and downtime, disruption etc are added up. It is worth
reminding duty holders of these economic incentives.

Key reference - HSG 136 “Workplace Transport Safety” and HSE website
2 Guidance on the management of the topic area

Many industrial sectors have their own particular WT problems which may differ from
most other industries these are described in the Section 4. However, certain themes
are common to a wide range of industrial Sectors, and this section outlines those
cross-industry issues which it will be most worthwhile considering at visits where WT
matters are to be addressed.
Appendix 1 gives a 2-page summary of causal factors in workplace transport
accidents from a 2 year study. These are:
no or inadequate risk assessment ;
poor workplace design & layout, especially poor vehicle / pedestrian segregation;
poor system for detecting & correcting unsafe behaviour (linked to people knowingly
not following rules / procedures);
poor driver training.
The above causal factors give rise to the four principal accident types (12 year
aggregate statistics – 1993/4 – 2004/5)):
people struck by vehicle (about 76% WT fatals, 42% of WT major injuries);
people falling from vehicles (7% WT fatals,42% WT major injuries);
people hit by object falling from vehicle (8% WT fatals,11% WT major injuries); and
collapse / overturn of vehicles (6% WT fatals, 2% WT major injuries)

2.1 Management

2.1.1 Assessment of WT risks and control measures

Failure to adequately assess and control WT risks contributed to 70% of WT

accidents in a recent HSE study (Appendix 1). Many SMEs remain completely
unaware of risk assessment requirements for this topic. Even employers who know
they must assess risks often overlook assessing WT risks, especially from vehicle
movements. Carrying out a risk assessment with the aid of HSE guidance should
focus the duty holder’s mind on potential WT risks not only to people, but to valuable
vehicles, stock, storage racking, buildings etc. The WT Checklist in Section 7 will
help duty holders assess WT risks.
2.1.2 Supervising & monitoring workplace transport issues

Duty holders often fail to monitor standards and detect and correct unsafe behaviour
of their own employees as well as visiting drivers. Employers often assume that if
they train their drivers, maintain their vehicles and install some pedestrian / vehicle
separation measures, they have complied. They fail to set up any simple system for
checking whether people actually follow the site rules and procedures expected eg
on vehicle / pedestrian segregation, loading, speeding (though for some vehicles a
simpler solution to speeding is possible, by mechanically restricting their speed).
Employers in control of sites need a simple system for monitoring behaviour,
investigating underlying reasons for unsafe actions, and correcting unsafe
behaviours, including appropriate disciplinary procedures. Sections 1 & 6 of the
Checklist contain useful pointers. A template IN is included in the pack for situations
where most WT issues appear reasonable, but there are inadequate arrangements
for controlling / supervising / monitoring the behaviour of drivers and others in
relation to moving vehicles at the site.
“Individuals violating known rules” is a contributory factor in a significant
proportion of WT accidents. If employers have taken reasonable steps to enforce
sensible WT precautions but some individuals (especially drivers, but sometimes
pedestrians) still create dangers by for instance refusing to follow known site rules on
pedestrian / vehicle segregation, employers should follow appropriate disciplinary
procedures (ultimately including dismissal). For flagrant disregard of sensible,
clearly understood and enforced rules, prosecution of individuals under s7 HSWA
should be considered (HSE see OC 130/8(Rev 2006) Prosecution of individuals). For
background on some of the complex "human factors" involved, see HSG65
"Successful health and safety management" at Appendix 5, box 11 on monitoring,
and HSG48 "Reducing error and influencing behaviour" pages 16-18 on rule
breaking.
Good monitoring of housekeeping standards should also help control WT and
many other risks. Many work sites now use fixed site (as opposed to vehicle) CCTV
cameras for security and other purposes. There is potential for using site CCTV to
help monitor safe behaviour by drivers and pedestrians e.g. in showing “offenders”
what they did wrong and why it was dangerous. They can also be used for
monitoring speeds by marking a measured distance on the roadway. The time for
travelling this distance at the speed limit can be calculated and then drivers timed
with a stop-watch.
2.1.3 Deliveries and (un)loading

Many premises have to deal with lorries and other delivery vehicles and the accident
rate for people employed in haulage and distribution is higher than that for
agriculture or construction. This is a key area for action by Inspectors. See
“Delivering Safely” which is now Information Sheet WPT06 as well as the
checklist in Section 7.
The inspection template and technical guide produced for the “Struck by” project
in 2006/7 is reproduced at Appendix 3 which may also be helpful. Additional
information on inspecting deliveries as part of a supply chain can also be found in
SIM 05/2007/01.
Useful guidance on site design is also contained in the Hazardous Installations
Directorate (HID) Technical Measures document "Roadways / site traffic control /
immobilisation of vehicles" on the web.
WT accidents often occur during (un)loading operations, as they often bring together
movement of the vehicle being unloaded and the FLT unloading it; danger from
passing vehicles if segregation is poor; potential for people (often the driver) to fall
off the load/vehicle if he goes onto it; potential for loads which may have moved in
transit falling off etc. (Un)loading activities are high risk activities and give a good
indication of how well WT risks are being managed. " Any (un)loading activities
involving WT near or on the public highway or pavement just outside a workplace
involves a high risk interface with the public (both pedestrians and vehicles) and
requires particular attention. See OM 2003/103 "Work related road traffic
incidents: an explanation of circumstances where HSE may have a role to play",
especially boxes 1 and 2 of the Appendix to the OM. Employers should be asked to
justify the need for any (un)loading involving WT taking place on or near the public
highway or pavement (by risk assessment). Risks can usually be reduced by
requiring (un)loading to take place within the premises, away from the public, in a
designated, demarcated, supervised area. Freeing-up such space may require
significant reorganisation of the site (for instance sacrificing some coveted staff car
parking spaces?). OC 789/5 “Risks to the public from un/loading vehicles on the
highway” contains more detailed advice.
Drawing up and enforcing simple written site rules for (un)loading can make it
clear to all what’s expected. Such site rules (perhaps one A4 sheet) may be copied
by fax/electronically to suppliers when ordering goods, or to customers when taking
orders for deliveries. The Freight Transport Association (FTA) have produced some
example forms in their Health and Safety Compliance Guide “Managing visitors,
visiting vehicles and deliveries” due to be published in 2007. They can then be
passed to the delivery driver with the other in-cab paperwork for a delivery/collection.
These simple, practical procedures can help site controllers and haulage companies
fulfil their duties to co-operate in ensuring safety.

2.2 Safe site

2.2.1 Pedestrian/vehicle separation

76% of WT deaths (12 year aggregate) are "struck by vehicle" accidents, and
inadequate pedestrian / vehicle segregation is a contributory factor to a large
proportion. The main vehicle groups involved are lorries, construction vehicles,
tractors, forklift trucks.
On some sites complete separation of vehicles and pedestrians will be achievable
(apart from the need, for example, for drivers themselves to get to and from their
vehicles), but not on all. Reg 17 of the Workplace Regulations applies. See also
PUWER ACoP paras 45 to 48 concerning the need to control risks to pedestrians
and establish traffic rules where self-propelled mobile work equipment (paras 318
and 319) operates. IEE (Initial enforcement expectation) - If at a particular site
pedestrian / vehicle segregation is clearly inadequate, consider enforcement
by IN. The IN in the Notice Templates section gives one possible form of wording.
For main issues to be considered, see paras 159 to 182 of the Workplace Regs
ACoP / guidance in booklet L24, and the WT Checklist.
2.2.2 Access by members of the public (MoPs)

Retail and wholesale premises obviously have the additional problem of access by
MoPs. Every effort should be made to provide separate delivery areas. This is not
always possible at existing sites and vehicles may have to reverse through the shop
car park - it may be possible to time deliveries outside opening hours. If there is no
alternative, adequately trained banksmen should be used as a last resort.
MoPs should not be permitted in lift truck operating areas (see HSG 76). Where a lift
truck needs to access the shop floor during opening hours there should be a written
procedure outlining precautions to be taken – barricading off aisles used by the truck
and giving broadcast announcements warning the shoppers.
Where delivery vehicles have to (un)load on the public highway see section 2.2.1
above.

2.2.3 Eliminating / minimising reversing

Reversing causes about a 12% of all WT deaths. All reasonably practicable steps
should be taken to eliminate reversing in workplaces (Workplace Regs ACoP para
167) or, where elimination is not feasible, to reduce the need for reversing.
Reversing can be eliminated or reduced by one-way systems and eg. drive through
loading / unloading areas. Some practical ways of reducing workplace reversing
risks are listed HSG136 paras 666 to 698.
Vehicle routes and points of delivery should be assessed to determine where
reversing has to take place and what needs to happen to either minimise or control
the activity eg bin lorries and pub deliveries.
When considering reversing, inspectors should not forget that there are important
links with the vehicle’s design and whether any vision aids such as mirrors etc have
been maintained and kept clean, as these affect the driver’s ability to see danger
areas. Also see HSG 136 paras 550 to 567. Reversing is intrinsically dangerous
because rearwards visibility is often very restricted. In the longer term,
improvements in international standards should lead to workplace vehicles being
better designed in terms of visibility from the driver’s position. At present Inspectors
need to be aware that technical and legal aspects of driver visibility on workplace
vehicles such as telehandlers and earth moving machinery design are complex and
undergoing change. For more detail on the "initial integrity" aspects, see the
summary of WT supply law at the end of Section 4.
Many reversing accidents involve large road going vehicles, especially articulated
and rigid lorries. Reversing such vehicles is both potentially dangerous and very
costly (the cost of replacing a large rear light cluster crushed whilst reversing with
inadequate vision can exceed the cost of fitting a CCTV system to avoid such
incidents). CCTV can pay for itself within a year by drastically reducing reversing
incidents and associated damage costs. Inspectors should consider requiring the
provision of on-vehicle CCTV where the site specific risks justify it – this is likely to
be necessary where pedestrians are not segregated from frequent reversing
movements. For more detail see OC 803/70 “Closed circuit TV on roadgoing
vehicles”. Radar or sonar based rear-scanning devices on the rear of vehicles can
reduce reversing risks in some situations, but have limitations. In most situations, a
well set up CCTV system used by a driver instructed in its proper use will be
preferable to such scanning devices.
In considering visibility from the driver’s position Inspectors should not forget the
simple things. Site and vehicle lighting should be adequate – see HSG38 "Lighting
at work" Tables on p38 and p41. See possible IN template in Section 6. Site rules
requiring the wearing of high visibility clothing should help reduce risks. Adequate
mirrors need to be provided, kept properly adjusted (specific instruction on proper
adjustment is beneficial), and kept clean. Modern convex mirrors can significantly
improve a driver’s ability to see some areas. Windscreen wipers and washers need
to work properly.
Fork lift drivers should not have to travel with loads so large that they obscure
forward vision. Inspectors should also challenge circumstances where drivers
routinely reverse long distances to overcome this problem, asking duty holders to
demonstrate by risk assessment that such practices are justified. Some FLT
manufacturers have innovative FLT designs aimed at reducing these risks eg
rotating 2100 cabs, raised seats, seats which turn through 45o.

2.2.4 Speed limits

Speed limits should be imposed on larger industrial sites to limit the possibility and
severity of accidents. Suitable site speed limits should be determined based upon
consideration of what is a safe speed on-site accounting for the type of vehicles
using the roadway and its layout, bends, visibility at junctions etc. Limits of 10, 15 or
20 mph may be appropriate. Where pedestrians cannot be segregated, lower speed
limits may be needed, near to the average pedestrian walking speed of 3mph. To
be effective the limits should be clearly signed and enforced by site security and
supervisors. Speed limits should be included in the Site Rules with appropriate
disciplinary action taken as necessary.

2.3 Safe driver

2.3.1 Training

Driver training was a significant factor in 21% of the accidents in a recent study (App
1). Even safe vehicles in a well laid out workplace are likely to seriously injure people
if those driving them are not competent. The employer’s risk assessment should help
determine competence requirements and hence the level and amount of training
needed.
No-one should be allowed to drive (operate) a workplace vehicle unless their
employer has authorised them in writing to drive that type of vehicle. The
employer should not authorise a driver unless they are satisfied that the driver is
competent for that vehicle type. For fork lift trucks see the FLT driver training ACoP
in booklet L117, OC 790/16 on the ACoP, HSG6 "Safety in working with lift trucks"
and the template IN on FLT driver (and other) training in Section 6. For other
vehicle types training should be to a similar standard using the AcoP as a
benchmark.
Some industries have industry-specific driver competence schemes, and inspectors
should consider any such schemes if concerned that a duty holder’s arrangements
for ensuring competence are inadequate. HSE Sector staff should be able to advise
on any Sector specific schemes. Employers should have considered the need for
periodic reassessment and refresher training if needed, though there is no set
frequency - see para 17 of OC 790/16. Key reference on driver training - HSG 136
paras 642 to 665.

2.3.2 Drivers as a vulnerable group

Risks to drivers of vehicles in workplaces warrant particular attention as drivers

themselves are often the victims of WT accidents. Frequently drivers are hurt when
their vehicle overturns or strikes something, or when they fall off it. They may be
struck by their own vehicle after it runs away (see section above). In particular, lorry
drivers may be struck by FLTs (un)loading their lorry as they "assist" or watch, or by
other passing vehicles as they secure or sheet their load. All non-essential people
should be excluded from (un)loading areas whilst other vehicles are operating there.
If observation of loading is essential (it usually isn’t) a safe area for the driver to
stand should be designated and the FLT driver instructed remain stationary if the
LGV driver moves out of it. The lorry cab may be a safe place to stay as long as the
loading activity does not endanger the cab.
The best place for drivers is a rest area with access to toilets and refreshments.

2.3.3 Work-related road safety

The DfT/HSE leaflet INDG382 “Driving at work” gives detailed advice on this.

2.4 Safe vehicle

2.4.1 Vehicle selection and maintenance

Vehicle selection is vital - a vehicle must be suited for the actual conditions of use.
No amount of maintenance can make a conventional FLT suitable for operation on
rough terrain.
The extent and complexity of vehicle maintenance required for safety will depend on
the type of vehicle and its conditions of use, but should generally be in accordance
with the manufacturer’s instructions. Some potentially dangerous vehicle faults may
not become apparent until they cause an accident. Duty holders therefore need a
simple documented system for checking each workplace vehicle’s mechanical
condition at specified intervals of time, mileage or hours used, using manufacturer’s
instructions as a guide. If there is confusion between the requirements for inspection,
maintenance and thorough examination Inspectors can use the analogy of servicing
and the MOT system for cars – the difference between defect spotting and integrity.
Usually involves a checklist for completion by a competent mechanic.
Inspectors should also be aware that if the dutyholder has an Operators or “O”
licence for their vehicles, that under the terms of the licence a regime of vehicle
maintenance will also be imposed. More information on this aspect can be found in
SIM 5/2007/02.
IEE - HSWA and Reg 5(1) of PUWER may be used to prohibit the use of any
workplace vehicle which is evidently unsafe (Stark v The Post Office can be used
to support enforcement if challenged - absolute nature of duty to maintain in a safe
condition). IEE - If an employer has no system for maintaining vehicles in a safe
condition, inspectors should consider enforcement by IN (see a possible
template in the pack). Inspectors and duty holders are sometimes confused by the
various maintenance / inspection / examination requirements under PUWER and
LOLER for lift trucks. The BITA Guidance Note 28 is an example of a pragmatic way
of dealing with these issues.
Drivers often do not see it as "their job" to help ensure that the vehicles they drive
are kept in a safe condition. Duty holders therefore need to explicitly require
drivers to report any defects they become aware of using a defect reporting
system which can then be actioned. A driver’s daily checklist (with a copy in the
cab for easy access) can help, together with checks by management that such
checklists are in fact used. Encouraging the right attitude is important - drivers
should be confident that if they find and report serious vehicle defects, their employer
will take the report seriously and support them even if this means that the vehicle is
immediately taken out of use pending repair. It is wise for employers to have a
contingency plan for dealing with this sort of foreseeable problem. A spare on-site
vehicle may not be a realistic option, but quick, easy access to a competent
mechanic for repairs and/or prior arrangements with a local hire company for an
alternative vehicle can reduce the risk of employers "taking a chance" by using
unsafe vehicles in order to keep production running. Key reference on vehicle
maintenance: HSG 136 paras 601 - 610.
Provision of safe access to vehicles – legal summary
Roadgoing vehicles:
Section 6 HSWA and PUWER can be applied to road-going vehicles although their
design and manufacture is largely governed by the Road Vehicle (Construction &
Use) Regulations which Department for Transport (DfT) have the lead for. New
vehicle type standards will be introduced in 2008, but these will not cover access to
vehicles. This area must be covered by risk assessment by suppliers/users under
health and safety requirements. It is important to note that the EHSRs do not apply
to vehicles designed for normal road use (Schedule 5 of SMSR - vehicles mainly
travelling on the road are exempted from SMSR with the exception of those vehicles
used in the mineral extraction industry).

• Manufacturers of road-going vehicle bodies, trailer units etc often do not give
adequate thought to providing safe means of access and slip resistant
surfaces on parts of their vehicles/bodies where people have to work (see
RR437 listed below). If access onto the vehicle is unavoidable, the means of
access, including pedestrian walk ways should be safe.
• Persons responsible for purchasing vehicles should specify appropriate
means of access where necessary. If drivers have no choice but to clamber
 up on the wheel or perhaps the under-run protection bars to access the load
areas of artic trailers, flatbeds or box vans the NEE is that an IN should be
considered. Simple solutions / aids such as designed hand and footholds,
fixed / hinged / sliding / stowable steps or ladders are available and cheap
compared to the total vehicle cost, but are often not specified by the user and
as a result they are not provided.. Similarly, unless the purchasing haulier /
user specifies them, vehicle bodybuilders may supply vehicle bodies lacking
mechanical sheeting aids etc.

Workplace vehicles supplied for use mainly off the road, section 6 HSWA and
the Supply of Machinery (Safety) Regulations 1992 (SMSR) apply, and hence such
workplace vehicles are subject to the Essential Health and Safety Requirements
(EHSRs). The following EHSRs are relevant to falls from vehicles:

1.5.15 re risks of slipping, tripping or falling (as on any other machine)

3.4.5 re ergonomics of handholds and steps, avoiding accidentally operating
controls
3.2.3 for access by people other than the driver,
(Note that SMSR do not apply to agricultural tractors).

Two standards are relevant to vehicle access on off road plant, and should be taken
into account by designers, namely BS 5395-3:1985 and BS 4211:2005. BS EN ISO
2867: 2006 is aimed specifically at access to earth moving machinery, but has much
relevance to other mobile plant.
In summary, work vehicle users should consider the need for safe access and
include this in their vehicle specification. Work vehicle manufacturers and
bodybuilders should similarly ensure that their products are provided with safe
means of access to reduce foreseeable fall risks, irrespective of whether they are
specifically asked by the purchaser.

2.4.2 Overturning vehicles

Vehicle overturns cause 6% of WT deaths (12-year average see Section 2).

Vehicles commonly involved are FLTs, compact dumpers and tractors. The
increasingly widespread provision and use of Roll Over Protective Structures
(ROPS) is reducing the risk of injury following an overturn, but ROPS is not fully
effective unless the driver is wearing an appropriate seat belt or other restraint.
ROPS is normally fitted to vehicle with a risk of 180 degree or more overturn.
The two key risk control measures are:
a) reduce the likelihood of overturn. Vehicles should only operate where the
ground conditions are suitable. Excessive gradients, potholes, edges and slippery
substances may cause drivers to lose control, increasing both overturn and collision
risks. Select stable vehicle designs and train drivers.
b) mitigate the consequences if an overturn occurs. Ensure any vehicles which
have to operate in areas/conditions where overturn is likely have ROPS and restraint
fitted, and monitor the wearing of restraint (seat belt etc).
Inspectors (and duty holders) are sometimes confused by the legal requirements on
ROPS & restraint, due to their risk-based nature. To summarise a complex legal
area, if using a vehicle (whether it’s old or new, owned or hired) on a particular
site presents significant risks of overturn, the vehicle needs ROPS and a
seatbelt / restraint, unless this would not significantly reduce the risk of injury from
overturn (for instance ATVs). IEE - PN is appropriate – see notice template 5 in
Section 6. If it's not technically feasible for a particular vehicle (for instance an old
dumper) to have ROPS and seatbelt retro-fitted, that vehicle must ONLY be used on
sites and in ways where there is no significant risk of overturn
Drivers of dumpers and other common vehicles have been killed when their vehicle
with ROPS and seat belt overturned because they were not wearing the seat belt
provided. In many situations, the seat belt / restraint is simply to prevent the driver
trying to jump off an overturning vehicle. Where ROPS and restraint are needed,
employers need simple arrangements for monitoring the wearing of restraint, and
appropriate disciplinary procedures (see section 2.4.2). If employers have taken
reasonable steps to enforce the wearing of restraint in high risk areas, but some
drivers still refuse to wear it, prosecution of drivers under s7 HSWA should be
considered.
Note: Masted lift trucks are unlikely to go over more than 90 degrees and are not
fitted with ROPS, any frame above the seat is normally a Falling Object Protective
Structure (FOPS). For full details of the legal complexities on ROPS and restraint,
see para 360-363 of the PUWER 98 AcoP, the Note on PUWER part III in Section
4.7.2 of this Pack and the following free HSE Information Sheet:
MISC 175 “Retrofitting of roll-over protective structures, restraining systems and their
attachment points to mobile work equipment”, and MISC 241 “Fitting and use of
restraining systems on lift trucks”.

2.4.3 Falls from vehicles

Falls from vehicle accidents occur across a range of industry sectors where goods
are transported and delivered. 42% of WT major injuries and 7% fatals are due to
falls from vehicles (12-year average see Section 2). Work at height is often viewed
as incidental to the main activity and so the risks are not properly considered. More
than 75% of major falls from vehicles incidents occur during loading and unloading
activities.

There is a “Falls from vehicles campaign” included as a workstream of Moving

Goods Safely 3 and workplace transport campaign in October 2007 (see LAC 85/13
or SIM 05/2007/01 Appendix 6). There are 6 Information sheets:

WPT01 Preventing slips, trips and falls from vehicles: The basics

WPT02 Safe access to road-going vehicles: Specifying the right equipment

WPT03 Selecting flooring materials to avoid falls from vehicles

WPT04 Selecting the right footwear to avoid falls from vehicles

WPT05 Managing work to avoid falls from vehicles

WPT06 Delivering Safely: co-operating to prevent workplace vehicle accidents

Also 12 case studies and more information, all on the campaign website from mid
September 2007 .

Fall prevention must be an integral part of the risk assessment for (un)loading.
Vehicle selection and specification will play a part in this, see section 2.4.1.

Work at height – the basics

The principles for working at height on a vehicle are the same as those followed for
any other work at height as defined in the Work at Height Regulations 2005. Work at
height means “work in any place where a person could fall a distance likely to cause
personal injury if no precautions are taken”. It includes gaining access to or egress
from a place of work.
There is no distinction between high and low falls. 90% of the injuries reported to

HSE resulting from falls from vehicles were as a result of a fall from below head

height. The most common areas of the vehicle for people to fall from is the load area,

followed by the cab access steps and then the fifth wheel catwalk. Maintenance

activities e.g. maintenance of over-cab mounted refrigeration units is also a fall from

vehicle risk activity.

Those in control of the work must:

• Avoid the need for work at height where they can;

• Use work equipment to prevent falls where work at height cannot be
eliminated.
9 First choice – vehicle-based systems
9 Second choice – site-based systems
• Where the risk of a fall cannot be eliminated, use work equipment to minimise
the distance and consequences of a fall should one occur;
• Always consider measures that protect all those at risk ie collective protection
measures ( eg platforms/scaffolds, gantries, nets, soft landing systems)
before measures that only protect the individual, ie personal protection
measures (eg safety harness.)
For some work at height on a vehicle there may not be a single, simple solution, but
a range of options will have to be considered as part of the process of planning the
loading/unloading activity or maintenance operation. Using the hierarchy as the
basis, the best solution or combination of solutions in the specific circumstances can
be applied. Selection of the most appropriate vehicle for the task or specification of
essential access equipment may reduce the need for working at height and reduce
the risk of falls.
The Work at Height Regulations are looking for the application of the hierarchy to
provide reasonably practicable solutions to manage the risk of work at height on a
vehicle. (NEE template INs 9 & 10.)

Some practical examples of solutions within the hierarchy of controls:

• Avoid working at height unless it is essential - positioning of plant controls

for equipment such as lorry loader cranes, refrigeration units (see case
studies 3 and 4) and tanker controls at ground level to avoid the need to climb
up; the use of ground based sheeting systems instead of manually sheeting.
Use of palletised loads that can be unloaded by lift truck, and loading facilities,
e.g. loading bays. In many cases installing such systems not only reduces
risks, it increases efficiency and in the long term saves money.

• Prevent falls by using work equipment

(a) that protects all those at risk – Working with delivery vehicle and
equipment suppliers to determine the optimum design and means of access.
Platforms with handrails and access steps - vehicle based controls are better
than site based controls as they travel with the vehicle and are reliably
available (guardrailed platforms for accessed areas on vehicles eg tanker
tops). Site based platforms may prevent falls or mitigate against the effect of
a fall depending on their height. (eg Case study 10 William Hare)
Assessment of loading and delivery locations to determine where site-based
controls exist or where vehicle-based controls will be needed.
There may be problems guaranteeing such off-vehicle equipment will always
be available when access is needed, especially as vehicles usually visit sites
controlled by other duty holders on a one off basis.
(b) that protects the individual – work restraint systems ie a harness and
lanyard that make it impossible for a person to get to a fall position.

• Mitigate falls by using work equipment to minimise the distance and

consequences of a fall
(a) that protects all those at risk – soft landing systems, nets
(b) that protects the individual – a personal fall arrest system with the
anchorage point sited above the head. Any PPE solution relies heavily on
good training, instruction and supervision. A company who distribute concrete
products trialled a vehicle based PPE system, but found it interfered with the
operation of the lorry mounted crane and so did not take the solution forward
in the long term.

• Mitigate falls through training, instruction or other means eg ensure

access equipment is inspected regularly, apply sensible housekeeping
 measures, adopt safe working practices to cover work at height activities eg
un/loading, cleaning and maintenance. Providing training to drivers in the
basics of safe access eg ensuring three points of contact when climbing can
be helpful. (See toolbox talk for drivers on Falls from vehicles campaign
website.) Supervision to make sure fall precautions are actually taken is
important.

Preventing slips and trips on vehicles

A significant number of falls from vehicles are as a result of an initial slip or trip. If
access to a vehicle is unavoidable, then consideration must be given to preventing
slips and trips. There are many reasons why people slip, trip and fall at work. The
main causes are :

1 Flooring- including slipperiness of the surfaces of load areas and

ramps, poor design of access steps and changes of level (see
Information sheet WPT03 and Case study 2, Multiserve – improved
access to flat bed and fifth wheel)

2 Contamination such as rainwater, diesel, oil, mud or ice getting on to

surfaces and not being cleaned up properly - making surfaces slippery
or poor house keeping on the vehicle.( [Link] study 3, 3663
refrigerated vehicles )

3 Footwear – selecting the right sole for the surface and contamination
type can prevent many slips. Conversely, inappropriate footwear can
increase the risk of slips and trips.( See Information sheet WPT04;
Case study 5, Shanks waste, and Slips and trips website ).

4 Environment – such as poor lighting or glare, working in high winds,

condensation on surfaces, or even loud noises can contribute to slip or
trip injuries.

5 Human Factors – tiredness, lack of concentration or rushing about can

make things worse. Job design (for example, task and finish etc) can
play an important part in the emphasis on speed of operations. Also the
way the job is done – e.g. having to lift, carry, push/pull loads etc. (See
Human factors toolbox.)
There is detailed information on selection of slip-resistant materials in Research
Report 437 some of which is summarised in the Information Sheets produced to
support the campaign (Information sheets 1-6). See also further information and the
Slips and trip topic pack for enforcement guidance.
Topic pack Section 2.4.1 gives a summary of the supply requirements for access on
vehicles
Specific examples of cross-cutting problems

1 Cleaning or maintenance of vehicles

The WAH hierarchy should be applied to the cleaning or maintenance of

vehicles where there is a risk of injury as a result of a fall eg. repair of roof
mounted beacons or air conditioning units, routine servicing of refrigeration
units. Dutyholders should be looking for the safest way to do the job.
Positioning plant at ground level (Case study 4, Morrisons underslung
refrigeration units) may be a longterm solution, but interim solutions may be
necessary. The available solutions will depend on the type of vehicle, eg 55
tonne excavator compared with a roadgoing vehicle, and where the activity is
being carried out:

a) Service depot based - They should have access to something like

aircraft steps or even a decent stepladder which could be worked from. A
mobile tower or podium step with guard rails would be better. A simple
scaffold system may be used back at base, creating a gantry which goes over
the top of the vehicle.
b) Customer depot based - as above, but will involve
communications/co-operation with the site operator if equipment is needed
regularly and will be kept on site. If visits are less frequent then equipment will
need to be portable and suitable for use by the engineer possibly on his own.
c) Roadside or emergency repair -
If a roadside repair can't be done safely ie no access equipment suitable or
available, then it should be done back at base.

Modern earthmoving machines are often equipped with guardrails, which

prevent falls, but for older machines simple tower scaffolds, podium steps or
aircraft steps may be able to be used. The relevant plant should be positioned
on good ground capable of supporting such equipment prior to the engineer’s
visit. Can the engineer utilise an existing loading bay or platform with
guardrails, which the equipment could be parked alongside?

If guardrails are not available, could work restraint, which prevents the user
reaching an edge from which they could fall be used? This has benefits over fall
arrest equipment in that it prevents a fall.

Consider also the trivial types of maintenance which involve risk of falling – for
example, we have had falls from earth moving machines whilst adjusting
mirrors.

Fall protection systems should only be used if the anchorage point can be
mounted above the worker, which may not possible out on site (See Falls topic
pack).
Access/egress to large plant (eg cranes) on low loaders where the vehicle fills
the space on the trailer and the steps finish in open space are likely to be a
problem that may require guardrails or access walkways built on, or need
mobile steps/platform.
2. Work on Tanker tops –

Access to tanker tops (and other vehicles such as tipper lorries) has been a
concern for many years and will be relevant to those in the food, agriculture and
manufacturing sector as well as Hazardous Installations Directorate (HID). As
always the rule is risk assessment with the hierarchy of controls outlined in the
WAH regulations to be followed.

All of this should be backed up by training, and where needed cooperation

between carrier and site managers.

In addition inspectors may see an increased use of tank containers. HSE has
been working with the International Tank Container Organisation (ITCO) to
develop a protocol illustrating the key requirements for reducing the risks of
working at height on tank containers.

Containers are traded world wide, and owned / managed by companies who
could be based anywhere. Tank Containers also present more challenges to
the engineering of access and fall prevention. The hierarchy is still valid though
and is part of the ITCO protocol.

The protocol is currently being revisited and will be slightly revised in due
course.

The enforcement expectation for HID inspectors is outlined in

SPC/Tech/Gen/04. The references are outdated but the advice for tankers and
tank containers remains sound.

3. Delivering freight containers or Portacabins to site

The practice of climbing on the container roof to attach slings is not acceptable.
(See Case Study 8, Shepherd Group)

There are a number of points to consider:

• If this is a regular drop, then some form of gantry around the vehicle
might be appropriate to prevent falls when attaching the chains.
• If it is a frequent operation then a dedicated container reachstacker
would be safer and more efficient, though careful consideration is
required on WT issues.
• With a less frequent drop, the chains could be attached from alongside
the container (e.g. using MEWP, wheeled step-platform or similar)
• Fixing the chains from a ladder might be acceptable, though they would
struggle to do this whilst maintaining a secure handhold and securing
the ladder would be difficult.
• If the container is full it should not be lifted by a four legged sling (see
table 4 of ISO 3874: 1997)
 • There is a better method of unloading a freight container that involves
a purpose built trailer with two cranes one on each end and attaching
the lifting chains to the bottom corner castings - see demo at
Containerlift website.

4. Use of unsuitable working platform on Fork truck

(NEE is PN for unsuitable working platform in use see Notice 7 in section 6 and
also Falls topic pack.)

[Link] lifts – The relevant European Standard (BS EN 1756 -1) requires that
taillifts that lift over 2 m in height must be fitted with suitable handrails to prevent
falls. There is also some guidance in Tail lift: Specification guide for road
vehicles via SOE.
For other tail lifts, the risk of falls must be assessed and appropriate preventive
measures taken. Many manufacturers have handrail options that can be
customised to the delivery requirements of the user. When fitted, edge
protection has the additional benefit of preventing the load from falling off the
tail lift during the lifting and lowering of the platform and injuring others in the
vicinity. Bolt-on slip-resistant fibreglass sheets can sometimes be used to
improve the slip resistance of the lift, but be aware that the edges can create a
trip hazard.

6. Double decker trailers Some trailers have double decks and consideration
of access to the second deck should be made.

Responsibilties on site

There is sometimes uncertainty regarding the legal duties of site and vehicle
operators (and vehicle manufacturers) regarding falls from vehicles. The following
paragraphs summarise HSE Services, Transportation & Safety Unit’s (STSU)
understanding.

For all parties, HSWA and MHSWR will obviously apply. HSE Solicitors advice on
MHSW Reg 11, Co-operation and co-ordination where two employers share a
workplace, is that it will not apply when one company visits another for a short period
to perform one task such as delivery. Nevertheless co-operation and co-ordination
are both essential features of safe delivery operations. Reg 12 on workers from
outside undertakings will apply, as well as the requirement for both employers to
carry out Reg 3 risk assessments. What should be clear is that it is unacceptable
to pass risks off site eg drivers should not be made to correct insecure loads in a
lay-by or be sent off site to trim a load or manually sheet a lorry etc.

Re the vehicle operator, PUWER will apply. See especially reg 4 re suitability of
equipment for the work – this means in effect that vehicle operators should ensure
that the vehicle is selected and equipped so that fall risks are adequately controlled.
There should be management of off-site risks to employees.
Work at Height Regs See section 4.7.6. OC 200/31 contains some general
guidance as do the training presentations on the Regs which can be found on the
falls website. If no assessment of this risk has been carried out the NEE is an IN 9,
or if the assessment has not used the hierarchy appropriately use IN 10. Also look
at the Falls Topic Pack Section 6 notice 1)

If the vehicles involved stay in one duty-holder’s premises, the legal issues are
relatively straightforward. Where vehicles leave the vehicle owner/operator’s site
and travel elsewhere, disagreements often occur about which duty holder will
provide fall protection measures. Where vehicle fall risks could be significant,
inspectors should examine whether the parties involved have agreed what fall
prevention/protection measures will be taken, and by whom. Some site controllers
have contractually required all vehicles delivering to their site to be equipped with
automatic sheeting aids or other fall prevention equipment.

Further information
Supply issues - See Section 2.4.1 of the WT Topic pack
Falls from height topic pack and web pages
Slips and trips topic pack and web pages
Information sheets 1-6 I and Case Studies 1-12 in support of WT campaign 2007 on
Campaign website

Contract Research Report 305/2000 "Sheeting and unsheeting of non-tipper

lorries - a health and safety scoping study" (115 pages) on HSE’s Website
Research Report RR437 – “The underlying causes of falls from vehicles associated
with slip and trip hazards on steps and floors”
SIM 05/2007/03 “Car transporters"
HID semi permanent circular SPC/Tech/Gen/04 sets out the enforcement
expectation for HID inspectors. The references are outdated but the advice for
tamkers and tank containers remains sound and includes some draft INs.

FTA/ HSE leaflet Preventing Falls from vehicles (2005)

IRTE Tail lifts: Specifcation Guide for Road vehicles
The Carriage of Dangerous Goods Manual

2.4.4 Objects (including the load) falling off vehicles

Objects (usually the load) falling from vehicles cause about 8% of WT deaths and
11% of WT major injuries. Loads can fall from FLTs - poor ground conditions with
potholes may dislodge loads, or wide loads may be carried on FLTs without properly
adjusting fork spacing (vehicle selection is also important - for regular handling of
wide loads a sideloader should be considered). Instruction & training in load
security is important for FLT operations and for those loading vehicles, especially
road-going vehicles. Insecure loads on vehicles cause danger in workplaces and,
perhaps more importantly, when the vehicle is on the road.
The security of loads on vehicles on the public highway is a matter for the police but
Inspectors should ensure that employers have safe systems of work for preventing
loads falling off vehicles in workplaces, and in particular for dealing with any loads
which arrive in an insecure state. The security of loads on roadgoing vehicles is
addressed in the Dept of Transport publication "Safety of loads on vehicles" (Free
download from DfT website). Following the guidance in booklet HSG 6 "Safety in
working with lift trucks" should minimise the risk of loads falling off FLTs. There is
also some sector specific guidance see section 4.

2.4.5 Parking vehicles and trailers

Accidents occur due to drivers leaving vehicles and trailers in an unsafe condition;
usually due to drivers failing to set brakes properly, especially on articulated
tractors and trailers. Drivers of workplace vehicles should be instructed on how to
park each vehicle type they use, as there can be significant differences and
misunderstandings are common. Trailer parking and cab hand brakes should
always be used – there have been a number of fatal accidents recently caused by
not using these. See “Code of Practice – Coupling or uncoupling & parking of large
goods vehicle trailers SOE IRTE 2006.
Immobilisation should usually involve removing any ignition or starter switch key to
help prevent unauthorised use, especially by younger staff who often find excuses to
move vehicles if keys are left in. More innovative solutions such as PIN code vehicle
access systems linked to training databases are becoming more common in bigger
employers.

2.5 Further advice

LA Inspectors can often access specialist traffic engineers within their own local
authority: the Highways section can advise on road layouts, signs, appropriate speed
limits for sites etc; the Road Safety section can advise on traffic calming and
normally has a speed gun available.
HSE Inspectors requiring specialist advice on site layout issues to minimise
workplace transport risks should submit a request to their local SG Civil Engineering
discipline. Vehicle and driver training issues should request help from SG
Mechanical Engineering discipline.
LA Inspectors can also access specialist HSE advice via their Enforcement Liaison
Officer (ELO).
3 Aide-memoire on inspection

This section can be used in conjunction with the more detailed Checklist (section 7)
to guide especially newer inspectors in one way of approaching WT at a site visit.
Bold text is to aid scanning the document as a memory-jogger.

Before the visit:

Note: HSE Safety Unit recommend that inspectors usually wear suitable high
visibility clothing at workplace visits (even if any HSE industry-specific Health &
Safety Policy Supplements do not “require” it), unless in their judgement risks from
moving vehicles during the visit are unlikely to be significant. Routinely wearing high
visibility garments reduces risks to the inspector, sets a good example, and should
help encourage duty holders to view high visibility clothing as the “norm” where
workplace vehicles are used. In many cases a lightweight high visibility tabard will
suffice.

• Inspectors should be familiar with the:

1 duty holder Checklist (section 7)

2 Delivering safely – on the HSE website) and
3 the Technical guide and template produced for the “Struck by” project in
2006/7 (Appendix 3).

On arrival at the premises:

• Immediately on arrival outside a workplace you can form a valuable

impression of WT control measures. This will help you decide from the outset
whether / how deeply you may need to examine WT controls. For instance:

• As a site visitor, is it clear to you where you should go (whether in your car
or on foot)? Are there clear signs telling you where to go, where you should
park, where you can / cannot walk, where vehicles/pedestrians are not
allowed, any speed limit, where any Reception is etc?

• Would an unfamiliar delivery driver arriving at the site with a load know
where to go, where to safely park, how to make contact with someone at the
premises?

• Are pedestrian visitors kept segregated from vehicles?

• Are there any obvious signs of vehicle damage to structures / workplace

vehicles?

• Clear one-way system, pedestrian/vehicle entrance/exit, or blank expanse of

potholed, patched tarmac with pedestrian / vehicle “free-for-all”?

• What categories of goods are being carried? Is Carriage of Dangerous

Goods (CDG) an issue?
During the visit:

• Does WT need addressing here? Remember - safe site, safe vehicles, safe
drivers.

• Ask the manager in control of the site / activity for a verbal explanation of
whether/how they have assessed and are controlling WT risks.

• Ask to see the assessment of WT risks (if there are 5 or more employees). Use
this pack and in particular the Checklist to help decide whether their controls are
adequate. Is there a risk assessment for deliveries?

Workplace aspects

• Get any site map or plan, to help discussion of vehicle / pedestrian areas,
potential for possible one-way systems etc.

• Use any map / plan as a lead-in to questions about internal and external traffic
movements and pedestrian interfaces (section 2 of the Checklist).

Maintenance issues

• In warehouses is there a procedure for closing aisles to FLTs when racking is

being repaired

• How are contractors controlled when they visit to repair FLTs, tail-lifts etc? Is a
traffic free area designated for maintenance?

Vehicle aspects

• Make a list of vehicle types & vehicle tasks. List any vehicles on site at
present, then any other vehicles which may visit. Pay particular attention to
high risk vehicles such as FLTs and lorries

• Use this list of vehicle types and tasks as a lead-in to the questions in sections
3, 4 & 5 of Checklist.

• Pick an individual workplace vehicle and run through sections 3, 4 & 5 of

Checklist.

• Is there any daily/pre-use checklist in the vehicle or elsewhere? If so has it

been properly completed? Have any evident faults been reported?

• Note the vehicle details & follow its maintenance record trail
Driver aspects

• Get any list(s) of authorised drivers for particular vehicle types. Use the list (or
lack of) as a lead-in to questions sections 1, 6 & 7 of the Checklist, especially
about the system for supervision & monitoring.

• Pick a driver of a workplace vehicle. Remind them drivers are a vulnerable

group. Check:

• authorised in writing to drive / operate that vehicle?

• training history including refresher training?
• system of “before use” / daily vehicle checks?
• knowledge of site rules on WT?
• system for dealing with breaches of WT rules?
• Is driver confident that faults they report will be dealt with?
• Do they have any ideas for reducing workplace vehicle risks?
4 Sector enforcement guidance, legal requirements, references and
national enforcement expectations
4.1 Agriculture and Food Sector

4.1.1. Agriculture

"Struck by vehicle" is the largest single cause of fatal injuries (35% in 2004/5) in
agriculture and forestry.

Targets for action

Extensive advice in EMM guidance section on following pages.

Agriculture - WT References

Priced:

Tractor Action - Video and Training guide.

Fatal Traction - Video.
Safe driving on slopes - Video and training guide.
Riding for a fall - ATV video

Free Leaflets:

AIS 33 Safe use of all-terrain vehicles in agriculture and forestry

AIS 36 Carriage of passengers on farm trailers
AIS 37 Operator seat restraints for mobile work equipment in agriculture and forestry
AS22 Prevention of tractors overturning.
INDG 185 Tractor Action
INDG 279 Fatal Traction
MISC 165 Farmwise

SIM:
SIM 01/2004/08 – Farm self assessment software

Industry guidance:

BAGMA/NFU code of practice for vehicle maintenance (issued to all band 2’s
and is freely available from the BAGMA website in PDF format).
Agricultural Vehicles on the road - a guide to legislation by Andrew McMahon
(issued to all inspectors dealing with agriculture as at June 2001)
Safety on farms: a shared responsibility - Industry guidance for farmers, growers,
drivers, contractors and other commercial visitors. UKASTA guidance leaflet.
Machinery Risk Gap Targets of National Mitigating / Confounding Factors
(Bench Mark) Action Enforcement
Expectation Examples of factors which may suggest particular
courses of action
Activity ...... .....................and

1. Transport - site

1.1 Machines inadequate regard to Extreme Farmer, PN/PR Where immediate danger exists i.e. stacking bales
used capable of risk Manager, under OHPLs, lorry tipping areas under OHPLs,
contacting (Bench Mark = Contractor Forest machinery operations
overhead power NIL)
lines
1.2 Machines inadequate regard to Extreme Farmer, PN Where no action has been taken to eliminate/control
used capable of risk Manager, the risk and/or where no planning, training,
contacting (Bench Mark = Contractor instruction or consideration of vehicle heights has
overhead power NIL) taken place.
lines
1.3 Moving inadequate Moderate Farmer, IN Where foreseeable hazards exist e.g. around potato
vehicles and traffic/pedestrian Manager, grading lines, control of the public at forest work sites,
loading/unloading control (Bench Mark = Contractor at his child access to farm yards, materials handling areas
vehicles SPI/R) own premises including timber and bale stacking/de-stacking.
/worksite
1.4 Moving inadequate Moderate Farmer, IN Significant surface defects in areas of high traffic use
vehicles and maintenance of traffic Manager e.g. loading areas, silage clamp aprons, timber
loading/unloading routes (bench Mark = stacking areas, forest roads to active sites
vehicles SI/R)

1.5 Grain no grid over grain Extreme Farmer, PN a) no grid to allow safe opening and closing of trailer
store/drier intake intake pit (Bench Mark = Manager, doors
pit NIL) b) Where pit has no effective means of preventing
access by children or of preventing them sinking into
the pit far enough to sink under the grain.
1.6 Slurry store No vehicle barrier at Extreme Farmer PN (deferred Absent or ineffective barrier to prevent scraper tractor
scraping in (Bench mark = Manager for animal driving over edge into slurry store
points/ramps NIL) welfare
reasons if
necessary)

2. Transport - driver

2.1 Carrying no provision for Extreme Farmer, PN + PR Where risk of serious personal injury is probable eg
passengers on carrying passengers (Bench Mark = Manager, passenger on trailer drawbar, tractor linkage, cab
mobile equipment safely NIL) Contractor, steps or forks/buckets of materials handling
Operator equipment, single seat quad bikes
2.2 ATV, FLT or lack of formal training Moderate Farmer, IN Where an operator can be shown by lack of
Telescopic for new users or (Bench Mark = Manager, experience or accident to be in need of formal
handler use others in need of SPI/R) Contractor training. e.g. cannot explain how to use load indicator
training chart on telescopic loader / only recently started
using an ATV /doesn’t know ATV tyre pressures etc
2.3 ATV use lack of head protection Extreme Farmer, PN Where no head protection is provided.
(Bench Mark = Manager,
NIL)
2.4 ATV use lack of head protection Extreme Farmer, PN/PR Where no head protection provided and ATV in use
(Bench Mark = Manager
NIL)
2.5 ATV use lack of head protection Extreme operator PN Head protection provided but not used
(Bench Mark =
NIL)
2.6 Operating inadequate training Extreme Farmer, PN Where a driver can be shown to have had little or no
vehicles on steep Manager, previous experience of driving on slopes, has had no
slopes (Bench Mark = Contractor training for driving on slopes and is, or will shortly be
NIL) expected to, have to drive on slopes where, due to
the slope or operations involved, overturning is
possible e.g fertiliser spreading, forest operations
2.7 Operating inadequate training Substantial Farmer, IN As above but operations are not imminent.
vehicles on steep (Bench Mark = Manager,
slopes NIL) Contractor
3. Transport – Vehicle

3.1 Vehicle inadequate hand and Extreme Farmer, PN/PR Where maintenance can be shown to be inadequate
brakes foot brake (Bench Mark = Manager, from simple physical examination and by lack of
maintenance NIL) Contractor evidence of a program of maintenance or where
braking systems are absent e.g. road-going trailers
3.2 Visibility – Broken or missing Extreme Farmer, PN Includes mirrors and windscreen wipers. Consider
Telehandlers and visibility aids (Bench Mark = Manager, PR if vehicles are normally operating in vicinity of
tractors towing NIL) Contractor pedestrians
large trailers
3.3 Visibility – all inadequate visibility Moderate Farmer, IN Where foreseeable hazards exist which could be
vehicles aids or audible Manager, reduced by the fitting of such aids.
warning aids on (Bench Mark = Contractor
vehicle SI/R)

3.4 Operating inadequate Extreme Farmer, PN + PR PTO shaft is easily accessible and there is
mobile PTO driven PTO or PIC Manager, foreseeability of leaving machine with shaft running,
equipment (1) guards (Bench Mark = Contractor eg for static use or blockage (slurry tanker, baler etc).
NIL)
3.5 Operating inadequate Extreme Farmer, PN (deferred if PTO shaft is not easily accessible and little
mobile PTO PTO or PIC Manager, necessary) foreseeability of leaving machine for blockage. eg
driven equipment guards (Bench Mark = Contractor close fitting linkage mounted sprayer.
NIL)
3.6 Operating inadequate Extreme Operator PN + PR No justifiable grounds for working with an unguarded
mobile PTO PTO or PIC shaft. PTO shaft is easily accessible and there is
driven equipment guards (Bench Mark = foreseeability of leaving machine with shaft running,
NIL) eg for static use or blockage (slurry tanker, baler
etc).
3.7 Operating inadequate Extreme Operator PN If damaged guard already reported to management
mobile PTO PTO or PIC and employee required to continue work (PR
driven equipment guards (Bench Mark = employer)
NIL)
3.8 Operating no operator roll over Extreme Farmer, PN/PR To prohibit the use of the vehicle where there is
vehicles on protection (Bench Mark = Manager, significant risk of roll over until a roll over protective
steep slopes NIL) Contractor structure and a restraining device have been fitted.
PR especially if Tractor Cabs Regulations breached
(Some vehicles will require specialist advice
regarding suitability of ROPS)

3.9 Operating only a roll bar or Moderate Farmer, IN To require the fitting of a restraining device.
vehicles on incomplete cab is fitted (Bench Mark = Manager,
steep slopes SI/R) Contractor
3.10 Supply of Tractors over 560 kg Substantial Manufacturer, PN(supply) Clear breach of Agriculture (Tractor Cabs)
equipment not fitted with (Bench Mark = Importer, PR if cab fails regulations 1974.
approved cab SI/R) Supplier to meet
supplied/hired to required
agriculture standard for
approval
3.11 Supply of Inadequate hardware Substantial Manufacturer, PN (supply) Hazards relating to mobility not adequately
equipment on other mobile (Bench Mark = Importer, /PR addressed e.g. visibility, ROPS, controls and contact
equipment NIL) Supplier with dangerous parts.

4. Transport – Child safety

4.1 Driving tractor 1. Under age of Extreme Farmer, PN/PR PACAR and ACOP apply
thirteen (Bench Mark = Manager,
NIL) Contractor,
Employee
4.2 Driving tractor 1. Lack of formal Extreme Farmer, PN/PR PACAR and ACOP apply
over age of training (Bench Mark = Manager,
thirteen 2. Using trailed NIL) Contractor,
equipment Employee
prohibited by PACAR
3. Vehicle exceeds
their capability
4. No close
Supervision
4.3 Carrying 1. Child under thirteen Extreme Farmer, PN/PR PACAR and ACOP apply
Passengers on is the passenger (Bench Mark = Manager,
tractor 2. Child over 13 is the Contractor,
driver NIL) Employee

4.4 ATV use at 1. Non-Adherence to Extreme Farmer, PN/PR PACAR and ACOP apply
work manufacturers age (Bench Mark = Manager,
restrictions NIL) Contractor,
[Link] age of Employee
thirteen
3. No formal training
4. Lack of head
protection
5. Passengers on sit
astride ATVs or in
trailed equipment
4.1.2 Food
Targeting
In the food industry, all the usual WT hazards occur but particular additional problems in this
industry are:-
- overturning of tipping lorries (tipping grain, flour etc)
- tipping lorry tailgate accidents when loads stick and suddenly slide violently, forcing the
gate open or removing it altogether
- FLTs falling off loading bays
Milk delivery staff fall from vehicles occasionally.

Sector specific references

Food Information Sheet 21 “Workplace transport safety in food and drink premises”.
NIGM 05/B/1997/13 “Access to the top of milk tankers - update” (not current - copy available
by request from Food and Entertainment Sector - Food Section) and
NIGM 05/B/1997/21 “Access to the top of tank containers and swap tanks used for the
transport of milk and milk products” (not current - copy available by request from Food and
Entertainment Sector - Food Section) both give advice on milk tankers, and similar principles
can be applied to oil tankers.

4.2 Services, Transportation & Safety Unit (STSU) - Transportation section

Transportation section shares all the common cross-sector WT issues, but has the following
Sector-specific WT targets for action :

4.2.1 Air transport industry

Aircraft turnround

The highest risks at airports occur during aircraft turnround, when large numbers of vehicles and
workers may be around the aircraft, and there is pressure on all concerned to ensure the aircraft
is not delayed. Vehicles include baggage carts and tugs, catering high loaders, fuelling vehicles,
cleaners vans etc.

The key areas are:

• Traffic control and speed limits on ramps and roadways – should be enforced by airport
bye-laws and aerodrome operator;
• Driver training and airside permits – overseen by aerodrome authority;
• Vehicle maintenance – responsibility of vehicle owner or operator;
• Airport layout and design, vehicle and pedestrian routes, signage and lighting –
responsibility of aerodrome operator;
• Co-ordination and communication in aircraft turnround involving service providers, airline
and aerodrome operator;
• Supervision of passengers on the ramp.

Key guidance is in HSG209 Aircraft Turnround – A guide for aerodrome operators, airlines
and service providers on achieving control, cooperation and coordination.
CAA also have responsibilities for aircraft safety and there is further guidance on aspects of
training, vehicle maintenance and safety management in CAP642 Airside Safety Management.

GoSkills are the Sector Skills Council for passenger transport and they have developed training
and National Occupational Standards (NOSs) for the aviation industry

Enforcement responsibilities of HSE and CAA in relation to health and safety at airports is
explained in a Memorandum of Understanding between HSE and CAA

Links to CAP642 and a wide range of guidance and information relevant to airports can be
found on the HSE Air Transport web pages and the Air Transport Community of Interest (CoI) ,
where there are also sample Notices and letters. If you are not a member of the CoI, contact the
Transportation Section.

Falls from vehicles

Access to aircraft is governed by design and the emphasis on avoiding damage to the aircraft.
There is a risk of falls from vehicles and equipment such as catering high loaders, Ambulifts,
access steps, fuelling and de-icing vehicles, as well as during maintenance.

References.

SIM 05/2002/52 Preventing falls from height during aircraft maintenance

SIM 05/2003/58 Preventing falls from height during maintenance of helicopters
SIM 05/2004/13 Safe access to aircraft for catering operations
SIM 05/2004/53 Designing in health and safety at airports
SIM 05/2004/55 Leader Ports and airports (2004/05 project)
SIM 05/2005/05 Preventing falls from height from, or when opening or closing, aircraft doors
SIM 05/2005/07 Aircraft turnround inspection

4.2.2. Docks

Inspectors are encouraged to introduce themselves to their local Maritime and Coastguard
Agency (MCA) surveyor to establish local liaison. In 2004-2006 there was a successful
inspection initiative on joint visits with HSE inspectors and MCA surveyors targeting workplace
transport and falls from height and problem ships. Although there are now no specific targets for
HSE inspectors for joint visits, contact is encouraged, and joint visits may be useful where
issues of common interest are identified.
Information on the responsibilities of HSE, MCA and MAIB in docks, at the water margin and
offshore can be found in the Memorandum of Understanding (MoU). Contact details for local
MCA offices can be found in the Annex to the MoU or from the Sector.

Industry information on training of casual/contract workers or Non-permanent employees can be

found on the Port Skills and Safety Ltd (PSSL) website

PSSL represent the industry on skills, training and health and safety issues and have also
published National Occupational Standards (NOSs) for Port Operations, which can also be
found on the above website.

General guidance on inspection of ports can be found in SIM 05/2007/05

Loading and unloading of vehicles. This is a high risk activity in docks. Concerns include:
• safe areas for sheeting and securing of loads, access to tankers etc;
• pedestrian access and segregation for drivers and others around trailer parks and
loading areas;
• falls from vehicles during sheeting and securing of loads;
• loads secured during movement around the dock;
• parking and coupling/uncoupling in trailer parks;
• Control and restricted access at container terminals.

General guidance in the WPT and Work at height Topic Packs will apply. Guidance on specific
loads such as paper reels, steel or timber is available from relevant sectors.
Tank containers cannot be fitted with permanent guard rails as they have to comply with
container design requirements for stacking on board ships. The ITCO guidance referred to in
the section on work on tanker tops is relevant where drivers have to access tank containers in
ports. The port should provide a safe area for any access, and the general guidance applies.
Specific guidance on work at height on car transporters is in SIM 05/2007/03

Traffic flow management.

Issues include:
• segregation in high risk areas;
• marked and signposted walkways;
• restricted access for private vehicles, delivery vehicles, taxis etc ;
• driver training for on-site mini-buses etc.;
• adequacy of lighting;
• vehicle visibility.

Ship/shore interface.
• Control and supervision of vehicle/ pedestrian access to Ro-Ro bridge and vessel ramp.
• Pedestrian segregation and gangway/ ladder or ramp access.

Ro-Ro vessels.
• Pedestrian routes marked and segregated; restricted pedestrian access to internal ramps
during vehicle movements; signalling system.
• Tween deck lifts not for pedestrian use when loaded; vehicle drivers to remain in cab with
brakes applied during descent/ ascent; edge protection at openings; interlocked gates or
barriers; audible warnings.
• Problems on decks due to congestion on decks and reversing vehicles; High noise
levels; poor lighting levels. Need signaller for each gang; whistle stop system as part of
safe system of work; high quality PPE and high vis with retro reflective strips on jacket
and legs.

Vehicle issues.
• Target areas include FLTs, clamp trucks etc moving between dockside/ MAFFIS/ sheds
including moving inside sheds and eg timber stacks. General guidance on workplace
transport safety applies, including adequacy of control measures, lighting etc.
• Drivers of large vehicles should have adequate visibility from the driver’s position. Risk
assessments for each kind of vehicle are required. Visibility aids to be used in
conjunction with good practice. SIM 05/2004/55 refers to a 2004/05 project on use of new
technology in ports. Guidance for other sectors such as quarries may be applicable.
• The Sector is currently working with PSSL and IRTE on assessing systems for work for
coupling and uncoupling of tugs. In some cases the IRTE guidance (Code of Practice on
 coupling and uncoupling large goods vehicles can be accessed via WPT site) may not
be applicable – if you encounter issues in this area please contact the Sector.

References

HID SLC/2006/04 The prevention of falls from ISO tank containers

Sector has copies of International Container Handling Coordination Association (ICHCA)

guidance on Safe working at Ro-Ro terminals and Container Terminal safety.

The ILO Code of Practice on Safety and Health in Dockwork is available on loan from the HSE
Library.

NEE for Ports and Airports on following page

National enforcement expectations for ports and airports

Activity Issue Bench Risk gap NEE

mark
Airports
Catering high loader at aircraft a) guard rails on platform not SPI/R Substantial PN/Pr
in place and/or
b) Loose bridge plate across
gap between platform and
aircraft
such that there is a risk of
operative falling a distance
likely to cause injury.
Ambulift at aircraft Inadequate guard rails or SPI/R Substantial PN/Pr
guard rails not in place
High level access from refuelling/ Inadequate guard rails or SPI/R Substantial PN/Pr
deicing etc vehicles guard rails not in place
Lack of management of turnround Poor control of vehicle SPI/R Moderate IN
activities (consider airline, airport movements and access
and ground handler
responsibilities)
Vehicle maintenance Evidence of no/poor SPI/R Moderate IN
maintenance, including
operator checks
Ports
Load being transported around Load not secured SPI/R Substantial PN
dock
Control of access to container No/inadequate precautions to SPI/R Substantial IN
terminal prevent/control pedestrian
access
Working in container terminal No safe place for driver SPI/R Substantial IN
Sheeting/securing loads: tank No safe area/ no means of SPI/R Substantial IN
container access. access provided.
Access to ro-ro ramp No controls/supervision SPI/P Moderate IN
4.2.3 Road haulage

In the 2004/05 workyear, there were 11 fatalities, 1487 major injuries and 6654 over-3 day
reports. The total accident rate in this industry is worse than both the construction and
agriculture sectors. In addition, accident rates have worsened significantly over the past 3
years.

The Moving Goods Safely project is the main initiative aimed at tackling the high accident
rates within the haulage industry. Further information on MGS can be found in SIM 05/2006/03
& SIM 05/2007/01. STSU Transportation Sector is also engaged with other industry work,
including through the HSE-run safety forum, the Road Distribution Action Group (previously
known as the Road Haulage Liaison Group).

A Sector Information Minute providing further background information on the road haulage
industry is now available (SIM 05/2007/02).

Health and Safety legislation (apart from the Workplace Regulations) applies whilst the vehicles
is driving on the road as well as whilst it is involved in operations at the workplace. However
road risk is largely dealt with by the Police, so inspectors should focus efforts on risks at the
workplace. You may draw attention to the Driving at Work document INDG382. OM2003/103
and OM2003/109 give more details on work-related road risk.

More information on road haulage can be found on the HSE website.

Carriage of dangerous goods (CDG) issues
Carrying goods by road or rail involves the risk of traffic incidents. If the goods carried are
dangerous, there is also the risk of an incident, such as spillage of the goods, leading to
hazards such as fire, explosion, chemical burn or environmental damage.
Whilst most goods are not considered sufficiently dangerous to require special precautions
during carriage some do have properties which mean they are potentially dangerous if carried.
There are regulations to deal with the carriage of dangerous goods, the purpose of which is to
protect everyone either directly involved (such as consignors or carriers), or who might become
involved (such as members of the emergency services and public). Regulations place duties
upon everyone involved in the carriage of dangerous goods, to ensure that they know what they
have to do to minimise the risk of incidents and guarantee an effective response.
Further details may be found at the following site:
[Link]
References
INDG379 Health and safety in road haulage

SIM 5/2001/16 Passenger Transport will be revised and updated in 2007

SIM 5/2001/5 (SSP3) has been withdrawn
SIM 05/2007/02 The road haulage and distribution industry – overview
SIM 05/2007/03 Car transporters
The Carriage of Dangerous Goods Manual
4.3 Construction

Every year, construction vehicle incidents cause about 15 deaths and more than 200 major
injuries. Compact site dumpers, excavators and goods delivery vehicles feature prominently in
accidents. The Sector emphasise the need for transport risks to be properly addressed during
the design and planning of construction work, and for contractors to put in place robust site
transport controls which they then vigorously enforce.
Particular problems in the industry include:

• lack of or inadequate site specific transport management plan / transport risk

assessment;
• inadequate pedestrian/vehicle segregation;
• Poor standards of fall prevention when unloading vehicles;
• Lack of adequate driver training;
• inadequate precautions for vehicles working near overhead lines;
• poor edge protection to prevent vehicles going over edges;
• lack of ROPS / FOPS / driver restraint;
• poorly maintained vehicles;
• inadequately prepared ground to support the movement of cranes, MEWPs, piling rigs
etc.

The Construction Transport Campaign is aimed at promoting effective planning and

management of construction transport risks. Sector guidance is available in HSG 144 The safe
use of vehicles on construction sites. Advice can be sought from the Construction Sector
where inspectors experience difficulties or have specific questions.
During site visits inspectors should consider the influence exerted by relevant duty holders on
site transport operations and, if applicable, whether or not they have complied with their duties
under Construction Design and Management Regulations 2005 (CDM). The majority of
immediate enforcement action often falls on the Principal Contractor; however where the
inspector believes that other duty holders have failed to comply, back tracking to designers,
planning supervisors and clients should be followed up.
There are four main parties that have duties under CDM. If these duties are not fulfilled
correctly they could influence work place transport safety on the site.

(1) Principal contractor: Where site vehicle movements present significant risks,
measures to reduce them should be set out in the Health and Safety Plan (CDM reg 23).
Site rules should ensure compliance with the requirements of CDM regarding the separation
of pedestrian and vehicles and the provision of suitable traffic routes (Reg 36); and the safe
use of vehicles (Reg 37). The plan should also state how this information is to be passed on
to other contractors. Where the need for reversing vehicles has not been eliminated, then
the risk assessment required by MHSW Reg 3 and associated method statements should
define safe systems of work to be followed including the fitting of reversing aids. Where there
is serious risk of injury a PN should be considered under CDM regs 36 & 37. The PC should
ensure that ground where cranes, MEWPs, piling rigs are used or manoeuvred is adequately
prepared. Where the transport related information in the plan is inadequate then an IN under
CDM Reg 23 should be considered. The PC should also give a suitable induction to every
worker on their site, (this should include delivery drivers) under CDM reg 22 (2).

(2) Client: Most Clients, particularly those who only occasionally commission construction
work, will not be experts in the construction process and for this reason they are not required
 to take an active role in managing the work. However, clients must check that,
arrangements that the contractor agreed to make to control key issues on site such as
producing a transport management plan, have been implemented. Also, particularly on
occupied sites, clients need to provide information (reg 10) on their own undertaking which
will affect construction work. Such as:

• traffic routes,
• visibility,
• segregation,
• delivery times, etc. Therefore co-ordinating their own work with the construction
work.

If contact is before the construction phase begins, then an IN could be considered if

important information is lacking. If the construction phase has begun and the site conditions
are poor, a PN may be warranted. However, this would have to be under CDM Regulations
36 or 37 in relation to the site, or the Workplace (Health, Safety and Welfare) Regulations
1992 Reg 17 in respect of the client.

(3) Designer: Designers are required under CDM to avoid forseeable risks, therefore
transport issues should be considered during the design process. Issues that should be
considered include:
• location of site access;
• associated driver visibility;
• size of materials used;
• how they will be delivered;
• phasing of build program in order to segregate workers from the majority of vehicle
movements; and
• allowing adequate room for traffic routes around the site (see HSG 144).

The hierarchy set out in CDM Reg 11(4) should be followed and information provided as
required by CDM Reg 11(6). Failings resulting from the lack of suitable management
systems should result in an IN under the MHSW Reg 4 requiring arrangements to be
introduced for complying with their duties under CDM, or an IN under MHSW Reg 11
requiring training of the designer. Information for designers can be found in the CIRIA
Publication CDM Regulations-Work sector guidance for designers and Designing for Health
and Safety in Construction.

CDM Co-ordinator: Has duties to assist the client in complying with their duties under CDM
Reg 10, ( & 15 where the project is notifiable), including that they ensure the client has
provided the Principal Contractor and Designer with pre-construction information. The Co-
ordinator has a duty to identify and collect this information and ensure that it is provided in a
convenient form (CDM Reg 20 (2)) and then liaise with the Principal Contractor regardig the
contents of the Health & Safety Plan and File for the project. If the relevant information is
not provided because of poor management systems then an IN could be considered under
MHSW Reg 4 or the above CDM Regs.

References on WT in construction
HSG 144 The safe use of vehicles on construction sites.
HSG150 Health & Safety in Construction (2006) 3rd Edition, pages 38 – 44.

CIRIA Publication CDM Regulations-Work sector guidance for designers

Designing for Health and Safety in Construction.
SIM 2/2007/02 Assessing field of vision for operators of earth moving machinery on
construction sites

L144 Managing Health & Safety in Construction- Construction (Design & Management)
Regulations 2007.

4.4 Local Authority Sector

4.4.1 Leisure

See Agriculture and Food Sector information (Section 4.1) for advice on use of agricultural-type
vehicles. In addition at leisure sites segregation of pedestrians members of the public from
vehicles is important. Speed limits should be set and enforced (eg by speed bumps) where
necessary.
Golf courses

Targets for action:

• unsafe tipping operation during sand replenishment of steep sided bunkers
• ensure safe working practices near to water features such as lakes/ponds/reservoirs
• adequacy of training to green keeping staff who undertake in house maintenance of
transport machinery
• safe usage of golf buggies by club members and visiting golfers
• training provision fro use of ATV’s as personal transport or specific work activity
(spraying) on golf course

Leisure references
Priced
HSG79 Health and safety in golf course management and maintenance
LA Guidance
Holiday Caravan Parks – Workplace transport campaign - Gwynedd Council
Industry guidance
• Health and safety on your park - British Holiday & Home Parks Association (Available
free to members only)

• National Code of Practice and Guidance for operators of tractors and machinery in
the amenity and horticultural sector - British Agricultural & Garden Machinery
Association (BAGMA)

• Vehicle health check scheme downloadable from BAGMA web site

• Greenkeepers Training Committee (GTC)

4.4.2 Warehousing

HSG76 “Health and Safety in Retail and Wholesale Warehouses” is out of print. This publication
is under review and it is expected that a second edition will be published in 2007. In the mean
time, the Sector consider the content of the first edition of HSG76 to still be current when read in
conjunction with HSG136 'Workplace Transport Safety - An Employers Guide'.

Reference

Health and Safety at Work – Warehouse Safety - London Borough of Barking and Dagenham

Mobile (un)loading ramps

These ramps are commonly used at warehouses which do not have a loading bay – which is a
safer way of unloading . They are most often used for (un)loading containers situated on the
back of a LGV. They may be used frequently throughout the day and the question can be raised
as to whether a loading bay may be required as a reasonably practicable measure.

Concerns with ramps are:

1 Selection issues

(i) Width of ramp needs to be sized in relation to the width of the trailer, to reduce
or minimise the likelihood of the FLT misaligning with the ramp

(ii) Maximum ramp height – to ensure the slope is not too steep. A slope of about
15% or less is recommended as this is the parking brake limit on most FLTs

(iii) Means by which ramp is raised / lowered. Most modern ramps use a hand-
operated hydraulic pump and jacks to raise the ramp to the required height.

(iv) Means of attachment of the ramp to the vehicle or loading bay. The ramp should
be secured in position either by chains or wheel chocks.

(v) Movement of the ramp - if intended to be towed then this should be with a
suitably designed tow bar.

2 Operational issues

(i) Pedestrians should be kept out of the area where lorries are manoeuvring
and unloading is taking place.

(ii) A safe system of work or physical restraint mechanism should be provided

to prevent the lorry from driving away before (un)loading is completed eg keys
from HGV driver
.
(iii) FLT operator instruction and training eg the FLT should be driven with the
heaviest end facing up the slope

(iv) Suitability of the trailer / container for the FLT – floor loadings see paras
104-105 of HSG 6 “Safe working with lift trucks”. Note: trailer safety jacks are
available to support the front of uncoupled trailers

3 Maintenance of ramps

The ramps should be subject to:

(i) Pre-use daily checks

 (ii) Periodic maintenance and inspection of all parts

4.5 Manufacturing Sector

4.5.1 Engineering

Engineering Sector shares all the common cross-sector WT issues. The additional Sector-
specific WT target for action is:

Safety in the storage and handling of steel (and other metal) stock

Fatal and major accidents occur during loading and offloading of steel and other metal stock, as
well as vehicle movements, in metal stockholders, metal stock haulage operators and
engineering premises that use steel and other metal stock.

Industry specific guidance is available in HSE leaflet INDG313 ‘Safety in the

Loading/Unloading of steel stock’ and in more recent guidance issued by the National
Association of Steel Stockholders ‘Safe delivery and unloading of steel products’ (January
2007) which updates and supersedes INDG 313. The NASS guidance is available as a free
download from the NASS website and/or the UK Steel website. HSG 246 'Safety in the
storage and handling of steel/other metal stock' also contains useful information on handling
and lifting.

Particular attention should be paid to:

• the preparation of written Safe Delivery Plans;

• that stockholders have adequate arrangements in place to ensure safe deliveries of stock
and safe loading/offloading of vehicles in accordance with the Safe Delivery Plans;
• the responsibilities and competencies of those who prepare the Safe Delivery Plans;
• that drivers are adequately instructed and trained;
• that suitable offloading equipment and facilities are available so that “barring off” of loads
and manual offloading of loads can be avoided;
• how they make sure Safe Delivery Plans are followed.

Where Stockholders use contract hauliers, inspectors should, additionally ensure that
stockholders and hauliers co-operate in the preparation of written safe delivery plans and that
such plans accompany the load at all times.

There are particular difficulties, due to the nature of metal stock with load security on vehicles,
which may affect safety during vehicle movement and at the commencement of offloading.
Guidance is given in Section 8 of the DfT Code of Practice ‘Safety of Loads on Vehicles’.
References

INDG313 ‘Safe unloading of steel stock’.

‘Safe delivery and unloading of steel products’ (NASS / UK Steel Guidance see above)
HSG 246 'Safety in the storage and handling of steel/other metal stock'
‘Safety of Loads on Vehicles’ DfT Code of Practice (Section 8)
SIM 03/2002/34 ‘Safe Delivery of metal stock – Written Delivery Plans’

4.5.2 Concrete and brick factories - sheeting & unsheeting

In common with many other industries, there is a need for securing and covering loads in the
concrete and brick industries. The risks of falling from the loads are similar. Load securing and
covering may be undertaken by employees or non employees (independent hauliers) and for
every loading operation there is a corresponding unloading operation at the end of the journey,
frequently on a construction site.
Factors which may differentiate concrete and brick industries from others include
- A large number of simultaneous loading operations taking place (which can limit the
applicability of sheeting gantries);
- The complexity of some loads (mixed products with different dimensions which can limit the
applicability of automatic sheeting systems).
The reasonably practicable measures to be taken will differ according to the load, site
circumstances and the vehicle being used. Some measures include specially designed vehicles,
lorry mounted lifting aids, automated sheeting systems and the provision of gantry / harness
systems.
Work is currently underway to examine the overall problem, and to identify reasonably
practicable measures and industry best practices for the various types of load and produce
industry specific guidance.
References
CRR 305/2000 “Sheeting and unsheeting non-tipper lorries”

Cement

Mobile Plant Reversing & Visibility Aids published by British Cement Association in Jan 2006.

Concrete blocks

SIM 03/2002/53 (previously 6/2002/09) "Securing and Covering Loads in the Concrete Products
Industry"
Code of Practice: For producers, hauliers and customers on the safe loading, consignment and
offloading of concrete blocks published by the Concrete Block Association in April 2006.
(Details responsibilities of the players)

Good Practice Guide: For producers, hauliers and customers on the safe loading, consignment
and off-loading of concrete blocks published by the Concrete Block Association in April 2006.
(Provides practical advice)
Concrete pipelines

Recommendations for load security of concrete drainage products published by the Concrete
Pipeline Systems Association.

Guide for offloading deliveries from CPSA members published by the Concrete Pipeline
Systems Association.

4.5.3 Paper

Please note INDG 386 “Transporting paper safely” has been withdrawn please see SIM
03/2006/14 for an explanation of why the leaflet was withdrawn and important information on
how dutyholders should operate in the interim before new guidance is produced.
4.5.4. Quarries

High-risk Reasonably practicable Sector and other guidance

processes/ measures
equipment
1. Visibility for Fit CCTV, wide angle mirrors, SIM 2/1999/05 Visibility for
drivers of mobile radar to try and achieve operators of mobile earth moving
plant 1mX1m around equipment equipment. (no longer on
intranet - paper copies available
from Sector on request)
Hard Target: Quarry Health and
Safety, Cutting Accidents by
50%

2. Road widths 1) Single track roadways Quarry Fact File 33, June 2005
should be 2X width of largest
vehicle using the road
2) Two way roads should be Hard Target: Quarry Health and
3.5X the width of the largest Safety, Cutting Accidents by
vehicle using the road. 50%

OR
Traffic lights/passing places
with effective management
and an action plan set out in
the health and safety
document to achieve the
above standard in a set time
frame.
3. Brake failure Daily/weekly testing using QPTC Brake testing guidance
check sheets and standard available from EPIC and
road length/speed on level currently (10/06) being revised
ground (10m / 8mph; 12m /15 and updated for republication
mph) and static test of park
brake on ramp and periodic Inspectors should note that a
(e.g. after 250 running hours) Simret meter is available for their
test using electronic device use in RSG offices.
such as Beaumonk or Simret
Hard Target: Quarry Health and
meter, as set out in H&S
Safety, Cutting Accidents by
document.
50%
4. Vehicles going Edge protection 1.5m or See edge protection guidance in
over tip and road radius of largest wheel on Quarry Factfile no. 25, December
edges compacted ground, as set 2001, Quarry Fact File 33, June 2005
out in H&S document. Look
for minimum distance of Hard Target: Quarry Health and
edge protection on tips set Safety, Cutting Accidents by 50%
out in tip rules.

5. Overturn Seat belts fitted to all Seatbelts/overturn guidance is given

vehicles, Full harness belts in Quarry Factfile no. 17, June 1997.
preferred. Check control
measures set out in H&S
document. Hard Target: Quarry Health and
Safety, Cutting Accidents by 50%

HSE Research Report 406

6. Access to Provision and maintenance Don't fall for bad access, Quarry
mobile plant of suitable access for a Factfile no. 19, June 1998
daily workplace – ideally
staircase access to ground Ten ways to vehicle safety, Quarry
level or a plan to achieve Factfile no. 20 December 1998
this in short to medium
Falling from vehicles, Quarry Factfile
term (plant modification
no. 16, December 1996
and replacement
programme). Handrails Hard Target: Quarry Health and
and platforms for drivers Safety, Cutting Accidents by 50%
and maintenance activities.
Ground based
maintenance points.
Control measures set out in
the H&S document .

4.5.5 Scrap metal, recovered paper and waste management sites (land fill etc)

INDG359 “Waste industry safety and health: Reducing the risk”

[Link]
Particular WT risks in these industries include:-
Scrap - sheeting / unsheeting of vehicles; site layout especially vehicle / pedestrian
segregation; large vehicle use. See British Metals Federation Health and Safety Manual. See
SIM 03/2002/56 (previously SIM 6/2002/13) “Vehicle sheeting at scrap metal yards”
Landfill - similar vehicle risks to quarries - apply similar standards. See SIM 03/2002/57
(previously SIM/2002/12) “Vehicle sheeting at waste management sites”.
Recovered paper – see “Guidance for the recovered paper industry” INDG392
4.5.6 NEE for workplace transport issues in woodworking premises
Targets for action

Effective segregation of pedestrians and vehicles

Effective management of unavoidable reversing activities

Effective management of delivery and despatch activities

Training provision for FLT and side loader operators

Presence of rear facing CCTV on large plant such as shovels, grabs etc

Activity Issue (s) Benchmark Risk gap NEE

Operation of FLTs Uncontrolled pedestrian SPI/ Remote Moderate IN*
– especially in access to these areas
warehouses
Reversing of 1) Absence of one way SPI/ Remote Moderate IN*
HGVs system where one is
possible,
2) No SSOW for
unavoidable reversing,
3) Uncontrolled pedestrian
access to these areas

Operation of FLT/ No operator training NIL Extreme PN/ IN

side loader
Operation of Absence of rear facing SPI/ Remote Moderate IN
mechanical CCTV to cover the blind
loading shovels/ spot
grabs, all FLTs
over 6 tonnes and
other relevant
vehicles that
reverse during
work activities
Loading/ unloading Absence of SSOW SPI/ Remote Moderate IN*
during delivery/ including control of
despatch pedestrians including the
vehicle driver
Vehicle Inadequate segregation of SPI/ Remote Moderate IN
movements pedestrians and vehicles
Vehicle Inadequate signage, road SPI/ Remote Moderate IN
movements markings, crossings etc
Deliveries to site Absence of effective SPI/ Remote Moderate IN*
cooperation/ coordination
of work activities between
the site and visiting
hauliers

* A PN may also be appropriate depending on the circumstances and the immediacy of the risk
of injury.
4.6 Education, nursery schools and play schemes

Significant risks can arise on school premises due to inadequate segregation of vehicles and
pedestrians. Inspectors should always query the practice in some schools (particularly rural
schools) of using parts of the playground area or site roads for car parking. Whatever
systems are said to be in place to ensure children are not in the vicinity when cars enter and
leave the premises it is likely they will not be followed in practice.

Some schools may have significant numbers of coaches and buses delivering children direct
onto the site. Reversing should be avoided. The design and layout of suitable drop off and
collection areas will require considerable thought and investment and supervision of the
loading areas may be required. Schools and bus operators should have systems in place to
ensure reversing, where unavoidable, is supervised by a trained banksman. Arrangements
should be in place to deal with late arrivals.

Inspectors should not become involved in assessing the risks to pedestrians off the school site
but should be sympathetic to legitimate concerns that are raised by employees and parents.
Such concerns should be directed to the relevant Road Safety officer at the Local Authority. If
the behaviour of motorists causes problems e.g. poor parking on public roads, such matters
should be referred to the Police.

See OM 2003/103 regarding work-related road traffic incidents

4.7 Legislation on workplace transport

The general requirements of HSWA, MHSWR, PUWER, and the Workplace Regs apply to
controlling WT risks. However there are some regulations and ACoPs aimed specifically at
workplace transport topics. This section highlights the most useful general regulations and gives
some guidance on WT-specific requirements.

4.7.1 Workplace Health, Safety & Welfare Regulations 1992 & AcoP (L24)

Regulation 8 – Lighting “Every workplace shall have suitable and sufficient lighting”
Regulation 12 - Condition of floors & traffic routes. Keep vehicle routes in a safe condition i.e.
no holes, slippery areas, not too steep. Keep clear of obstructions.
Regulation 17 - Organisation etc of traffic routes. Adequate traffic routes for both vehicles and
pedestrians. Sufficient separation between vehicles and pedestrians. Signing. See detailed
ACoP re layout etc.

4.7.2 Provision & Use of Work Equipment Regulations 1998 and AcoP (L22)

Regulation 4 – Suitability of Work equipment

Regulation 5 – Maintenance
Regulation 9 – Training - Paragraph 194 of AcoP refers to driver training
Regulation 21 - Lighting
The whole of Part III of PUWER Regulations 26 to 30 relates to " mobile work equipment”, –and
are now in force
The requirements in Part III deal, for the most part, with the risks due to its mobility which arise
when mobile work equipment is travelling. The requirements of Part III are in addition to the
other requirements of PUWER (L22 para 314). .
Vehicles designed primarily for use on the public roads will normally comply with Part III, if they
comply with the Road Vehicles (Construction and Use) Regulations 1986, where these contain
similar provisions (L22 para 317).
The actual risks during use need to be considered when determining the precautions necessary
for mobile work equipment.
The regulations in part III for the most part refer to ‘employees’. Where members of the public
are at similar risk, HSW Act can be applied.
Regulation 25 - Employees carried on mobile work equipment. Vehicles should not carry
people unless suitable - possible need for seats, cabs, falling object protective structures
(FOPS), restraint, limiting speed, wheel / track guards.
Regulation 25(a) is an explicit and absolute requirement to ensure that employees are not
carried on mobile work equipment unless it is suitable for carrying persons. Any measures to
reduce other risks to employees when equipment is travelling are covered by reg 25(b).
Regulation 26 - Rolling over of mobile work equipment. Minimise roll over risks, by maximising
stability. Provide Roll Over Protective Structure (ROPS) and restraint eg seat belt where
overturn a significant risk (see detail of regulation).
Measures should always be taken to reduce the risk of mobile work equipment rolling over, but
where such risks cannot be eliminated, reg.26 requires risks from the equipment rolling over to
be minimised. (Note: stabilising the equipment, in fact, reduces the risk of rolling over.)
There are certain classes of mobile work equipment which, experience shows, are particularly
likely to roll over, (though this does not mean that they will be at risk in all circumstances of
use). For the following, ROPS are the most practical solution:
(1) tractors (where no cab is/can be fitted);
(2) compact dumpers;
(3) all-terrain vehicles (sit-in type); and
(4) rough terrain variable reach trucks (telehandlers).
However, even for these classes of equipment, the risks when they are in use may not be
sufficiently serious to justify formal enforcement or other action.
There are also situations in which individual items of mobile work equipment are at risk of rolling
over, because of where and how they are being used, eg grass cutting machines used on steep
slopes. For the sit-astride type of all-terrain vehicle (ATV or quad bike), see guidance in
Agriculture Information Sheet No 33 The safe use of all-terrain vehicles (ATVs) in agriculture
and forestry.
In practice, with most vehicle types, the most likely measure to take to reduce the
consequences of roll over will be provision of a roll-over protective structure (ROPS). For
tractors this will normally take the form of a cab, but for some small or very old tractors, the only
structure available will be a roll bar.
Where a ROPS cage or roll bar is used, rather than a cab, there is usually a risk of anyone on
the mobile equipment being crushed in event of its rolling over. In such cases, reg 26(2)
requires a restraining system in addition to a ROPS, or other device, and this will most often
be a seat belt.
There may be situations where there is a serious risk of rolling over because of the location and
conditions under which the mobile work equipment is in use. In such situations only equipment
that complies with reg.26 should be used.
For new equipment, there should be no difficulties regarding the provision of ROPS for most of
the classes listed above. However, for new compact dumpers, supplied without ROPS, or any
second-hand CE-marked dumpers which are not capable of having a ROPs fitted and which are
in use where there is a serious risk of rolling over, NO FORMAL ENFORCEMENT ACTION
should be taken without first consulting HSE Safety Unit so that any necessary safeguard action
can be put in hand at the same time.
For several years, new rough terrain variable reach trucks (telehandlers) should have been
supplied with ROPS. Where a ROPS is fitted to a telehandler, then seat restraints will also be
required and this should be enforced where there is a risk of rolling over.
Counter-balanced, seated, centre-controlled, fork-lift trucks do not need ROPS (because they
have a mast), however, seat restraints will be required where this is necessary because of the
risk of overturning. However there may be some difficulties in fitting restraints to certain older
fork-lift trucks, particularly those that are battery powered.
Regulation 27 - Overturning of fork lift trucks. Forklifts with vertical masts or ROPS to have
restraint eg seat belt where appropriate, to prevent crushing driver.
Regulation 27 requires restraining systems to be fitted to certain fork-lift trucks if there are risks
(particularly crushing between the truck and the ground), should the truck overturn. This applies
in particular to seated, centre-control, counterbalanced fork lift-trucks. Where such a
counterbalanced truck is to be used in a high risk situation but, because of the age and design
of the truck, there are technical difficulties in fitting attachment points for a restraining system,
the selection of suitable alternative equipment may be the only solution. This may be a
particular problem with some older battery powered fork-lift trucks. For further information on the
fitting and use of restraining systems on fork lift trucks, see HSE Information Sheet MISC 241.
Regulation 28 - Self propelled work equipment. Vehicle controls including brakes; adequate
vision for driver, provide vision aids (eg extra mirrors, CCTV) where needed; vehicle lights.
It deals with a variety of additional measures on self-propelled work equipment, ie equipment
that has its own engine or motor. However, little, if any, action may be needed for vehicles used
primarily for travel on public roads where they comply with similar provisions in the Road
Vehicles (Construction and Use) Regulations 1986. The extent of any such overlap (and also
the gaps) is being looked into and the action necessary is under consideration.
Regulations 28(e) and 17 (3) (a) Driver vision
There is an overlap between the requirements in reg 17(3)(a) and those in reg 28(e) driver
direct field of vision. For self-propelled mobile work equipment, the same measures, for
example additional mirrors or CCTV, can be used to meet the requirements of both regulations
(see also para 64 regarding on-the-road use).
Regulation 17(3)(a) can be used in relation to 'a driver’s direct field of vision' where there is a
significant risk resulting from the use of mobile work equipment, particularly where this is
established sector policy. Inspectors should be aware however that in some situations it may
be more appropriate to use reg 28(e) as this permits risk to be reduced by means other than
improving the driver’s vision, for instance the use of radar or other sensing aids to assist safe
vehicle manoeuvring (this may be relevant for example where very dusty conditions severely
limit the usefulness of visual systems).
For visibility issues on earth moving equipment, see SIM 02/2007/02 “Assessing field of vision
for operators of mobile earth moving machinery used on construction sites”. See OC 803/70
“Closed circuit TV on road going vehicles” for guidance on the application of CCTV to lorries
and other large road going vehicles.
Regulation 28(g) - The requirement for appropriate fire-fighting appliances should only be
applied where escape from self-propelled work equipment cannot be achieved easily.
Regulation 29 - Remote controlled self-propelled work equipment. Rare equipment - if
encountered see ACoP.
Regulation 30 - Drive shafts. Safeguard any drive shafts (though not strictly a WT topic).

4.7.3 Supply of Machinery (Safety) Regulations 1992

The legal requirements for the initial integrity of workplace vehicles are not simple, but are
summarised below.
For workplace vehicles supplied for use mainly off the road, section 6 HSWA and the Supply
of Machinery (Safety) Regulations 1992 (SMSR) apply, and hence such workplace vehicles are
subject to the Essential Health and Safety Requirements (EHSRs). The main EHSRs regarding
vehicle movements are contained in SMSR Schedule 1, section 3 "EHSRs to offset the
particular hazards due to the mobility of machinery". (Note that SMSR do not apply to
agricultural tractors).
However, roadgoing vehicles such as lorries also come into workplaces, and it is important to
note that the EHSRs do not apply to vehicles designed for normal road use. Schedule 5 of
SMSR specifically excludes from the requirements of SMSR "...vehicles and their trailers
intended solely for transporting passengers by...road...as well as means of transport...designed
for transporting goods on public road...networks", though "vehicles used in the mineral
extraction industry shall not be excluded". Therefore, vehicles mainly travelling on the road are
exempted from SMSR with the exception of those vehicles used in the mineral extraction
industry (Metals & Minerals Sector can advise on vehicle safety issues in this industry).

4.7.4 Health and Safety (Safety Signs & Signals) Regulations 1996

Regulation 4(6) - where a sign is needed to control risks from vehicle movements on a work a
work site, and a "public highway" design of sign exists for that purpose, such a "public highway"
sign should be used rather than any alternative design (it is more likely to be understood).
Information on signs for the public highway can be found in the Traffic Signs Regulations and
General Directions 1994 (SI 1994/1519) and the Highway Code.

4.7.5 Work at Height Regulations 2005

Regulation 3 – Application - these regulations apply to all work at height where there is a risk of
a person falling a distance liable to cause personal injury. In workplace transport this is most
likely to arise during (un)loading when people have to access the load area of vehicles.

Regulation 4 – Organisation and planning -every employer should ensure that work at height is
properly planned, appropriately supervised and so far as is reasonably practicable safe.

Regulation 4(3) – the effect of weather eg strong winds, should be taken into account when
working at height eg (un)loading activities outside if there is a risk of injury due to adverse
weather conditions.

Regulation 6 – Requires a risk assessment so that risks are avoided when working at height.
Reg 6 includes a hierarchy of precautions which should be applied to vehicles:

• avoid the need to work at height where possible (eg provide ground -based systems for
sheeting, valves etc);

• where work has to be carried out at height on a vehicle, where reasonably practicable
provide platforms, guard rails and suitable ladders on the vehicle or if impracticable
provide them at the site;

• where measures do not eliminate the risk of a fall, equipment should be provided to
minimise the distance and consequences eg mats, airbags, fall protection PPE or where
this is not reasonably practicable;

• provide additional training instruction or take other additional and suitable measures to
prevent so far as is reasonably practicable, any person falling a distance liable to cause
injury

Regulation 10 – Falling objects –eg items falling when (un)loading vehicles

Suitable and sufficient steps should be taken to prevent items from falling on people.

There is other Sector specific legislation applicable to WT including the Docks Regulations
1988, the Quarry Vehicles Regulations 1970, the Agriculture (Tractor Cabs) Regulations 1974
and the Agriculture (Avoidance of Accidents to Children) Regulations 1958. For detailed advice
on Sector specific WT law contact Sector staff.
____________________________________________________________________________
4.8 National Enforcement Expectations – General

(See also sector specific guidance in Section4). Numbers in final column refer to template notice
numbers in section 6

Activity Issue Bench Risk Gap NEE

Mark *
Driving vehicles (inc Lack of formal training SPI/R Moderate IN
shunters) 4/6
Moving vehicles & a) Inadequate segregation SPI/R Moderate IN
pedestrians in same a) 1
area b) Insufficient lighting b) 8
Manoeuvring vehicles, Vehicles have inadequate SPI/R Moderate IN
pedestrians not visibility or devices for
excluded improving vision indirectly
Raising person on No suitable working SPI/R Substantial PN/ PR
unsuitable platform or platform (for exceptional 7
forks of FLT use only)
Unsafe driving Behaviour unchallenged SI/R Moderate IN
behaviour observed by management ie 2
(inc driver using hand inadequate supervision
held mobile phone)
No maintenance No system SI/R Moderate IN
schedule for vehicles 3
Driving vehicle where No ROPS or restraint SI/R Substantial PN
there is a significant fitted 5
risk of overturn
ATV use Lack of head protection SI/R Moderate IN
6
Use of lifting parts eg No thorough examination Admin - Defined IN
FLT, tail lift standard / Absent
Poorly loaded vehicle Inadequate strapping SI/R Moderate IN
Carrying passengers No adequate seats NIL Extreme PN
on vehicle
Unloading vehicle on No safe plan for delivering SI/R Moderate IN
highway in a public area
Access to trailers No safe means of access SI/R Moderate IN 9
/10
(Un)coupling No safe system, SI/R Substantial IN
articulated lorries unchecked by
management
5th wheel area Cluttered with ropes, tarps SI/R Moderate IN
etc
Pedestrian surface on Poor / contaminated NIL Moderate IN
vehicle slippery surface
* NB: This does not preclude prosecution where appropriate
5 Cross-sector references on workplace transport

Note: Sector specific references are generally given in Section 2

• Workplace transport safety - An employers’ guide HSG 136 HSE Books 2005 ISBN 0-
7176 –6154-7
• Workplace transport safety - An overview INDG 199(rev1) HSE Books 2005, ISBN 0
7176 0982 0
• Driving at work INDG382 HSE Books 2003
HSE Information sheets (on website from mid Sept 2007):
o WPT01 Preventing slips, trips and falls from vehicles: The basics

o WPT02 Safe access to road-going vehicles: Specifying the right equipment

o WPT03 Selecting flooring materials to avoid falls from vehicles

o WPT04 Selecting the right footwear to avoid falls from vehicles

o WPT05 Managing work to avoid falls from vehicles

o WPT06 Delivering Safely: co-operating to prevent workplace vehicle accidents

• Health and safety in road haulage INDG 379 HSE Books 2003
• Safety in working with lift trucks HSG6 HSE Books 2000 0-7176-1781-5
• Health and safety in retail and wholesale warehouses HSG76 HSE Books (revision due
Spring 2007)
• Rider operated lift trucks - operator training Approved Code of Practice and guidance
L117 HSE Books 1999 ISBN 0-7176-2455-2
• Rider-operated lit trucks: Operator training Approved Code of Practice L117 HSE Books
2000
• Tail lift: Specification guide for road vehicles SOE IRTE 2005, 22 Greencoat Place,
London, SW1P 1PR
• Code of practice: Coupling or uncoupling & parking of large goods vehicle trailers –
Guidance for managers, supervisors & trainers SOE IRTE, 22 Greencoat Place, London,
SW1P 1PR
• Health and safety in motor vehicle repair HSG67 HSE Books 1991 ISBN 0-7176-0483-7
• Lighting at work HSG 38 HSE Books 1997 ISBN 0-7176-1232-5
• “Preventing falls from vehicles” Freight Transport Association (FTA) 2005
• Code of Practice - Safety of Loads on Vehicles (third edition) 2002 Department of
Transport ISBN 0 11552547 5 - free download at website:
• HSE Info Sheet MISC 175 "Retrofitting of roll-over protective structures, restraining
systems and their attachment points to mobile work equipment".
• HSE Information Sheet MISC 241 "Fitting and use of restraining systems on lift trucks"
 • Contract Research Report 305/2000 "Sheeting and unsheeting of non-tipper lorries - a
health and safety scoping study" on HSE Website
• Research Report RR 038 “Review of workplace control measures to reduce risks arising
from the movement of vehicles“
• Research Report RR437 – “The underlying causes of falls from vehicles associated with
slip and trip hazards on steps and floors”
• BS 5395-3:1985 "Code of practice for the design of industrial type stairs, permanent
ladders and walkways"
• BS 4211: 1994 “Specification for ladders for permanent access to chimneys, other high
structures, silos and bins”
• BS EN ISO 2867 – 1999 “Earth-moving machinery - access systems”
• Guidance from HSE Hazardous Installations Directorate on site traffic control and related
issues
• Safety Signs and signals - The Health and Safety (Safety Signs and Signals) Regulations
1996 Guidance on Regulations L64 ISBN 0-7176-0870-0, HSE Books
• The Highway Code 2004 DfT DSA ISBN 0-11-5526986
• The Traffic Signs Regulations and General Directions 2002, SI 2002 No. 3113, Road
Traffic, HMSO. (TSR & GD)
• The Highways Act 1980
• The Road Traffic Regulation Act, 1984 and amendments
• The Building Regulations 1991 – Approved Document K “Protection from falling, collision
and impact”, section K3 contains requirements on vehicle barriers and loading bays. See
Communities and local government
• BS 6180: 1999 “Barriers in and about buildings Code of practice”
• Metric Handbook Planning and Design Data – 2nd edition. Edited by David Adler, 1999
• Stokvis - “The Loading Bay Design Handbook” (for use by designers, see Stertil-Stokvis
website)
• "Designing for Deliveries - including a planner’s guide to truck turning and manoeuvring"
Freight Transport Association 1998 (£80 FTA members, £100 non-members) ISBN 0
902991 66 3. Tel 01892526 171
"Safety inspections of industrial lift trucks - BITA Guidance Note 28"

HSE internal cross-industry guidance (available to LA Inspectors on HSE extranet)

• FOD / HID Band 4 self-study "Training Topic Pack on Workplace Transport" useful. It can
be found on the HSE intranet Personnel / FOD Learning and Development.
• OM 2003/103 "Work related road traffic incidents: an explanation of circumstances where
HSE may have a role to play"
• OC 789/5 “Risks to the public from un/loading vehicles on the highway”
• OC 790/16 "Rider operated lift trucks : operator training Approved Code of Practice"
• OC 803/70 "Closed circuit TV on road going vehicles".
• HID Semi Permanent Circular SPC/Technical/General/04 "Prevention of falls from road
tankers - enforcement standards".
6 Notice templates
This section contains possible outlines for Notice templates on common workplace transport
topics, as listed below.

For Sector guidance see Section 4, for general NEE guidance see end of that Section.

These are only suggestions please take care to make them relevant to individual circumstances
and consider changes in legislation which may post-date this guidance.

1 IN on separation of vehicles and pedestrians

2 IN on supervision & monitoring of workplace vehicle use

3 IN on vehicle maintenance arrangements

4 IN on fork lift truck driver training

5 PN on lack of ROPS / restraint where overturn likely

6 IN(s) on ATV training and ATV head protection

7 PN person on forks of FLT (no working platform)

8 IN for inadequate lighting for movement of people and vehicles

9 IN to identify work at height risks and appropriate precautions

10 IN on poor planning and application of hierarchy for work at height on vehicles

1. IN on separation of vehicles and pedestrians

...you are contravening ... the following statutory provisions:

Health and Safety at Work etc Act 1974 sections 2 (1) and 3 (1) , Management of Health and
Safety at Work Regulations 1999 regulation 5 (1), Workplace (Health, Safety and Welfare)
Regulations 1992 regulations 4(1) and17

...the reasons for my said opinion are:

the (....................................................................... area of the) workplace is not organised in
such a way that pedestrians and vehicles can circulate in a safe manner

Schedule:

To comply with this Notice you should complete

EITHER items 1 AND 2 AND 3 AND 4 AND 5,
OR item 6

1. You should provide a system in the workplace which, so far as is reasonably practicable,
restricts the movement of vehicles to areas which are demarcated from areas where
pedestrians have access. So far as is reasonably practicable, vehicles should be prohibited
from entering the pedestrian accessed areas, and pedestrians should be prevented from
entering the vehicle movement areas. Vehicle movement areas should preferably be
demarcated from pedestrian accessed areas by physical barriers such as railings. If providing
physical barriers such as railings is not reasonably practicable, other measures such as vehicle
exclusion bollards, kerbing, pedestrian pavements or a system of painted lines on the floor,
combined with appropriate signing, should be used.

2. So far as is reasonably practicable, separate traffic routes should be provided for

pedestrians and vehicles. Where separate routes are not reasonably practicable, and vehicles
and pedestrians use the same route, the route should be wide enough to enable any vehicle
likely to use it to pass pedestrians safely (for any routes in existence before 1 January 1993
where it is not practicable to make the route wide enough, passing places or traffic management
systems should be provided as necessary).

3. Where pedestrian and vehicle routes have to cross, appropriate designated crossing
places should be provided. Where necessary, barriers or rails should be provided to prevent
pedestrians crossing at any particularly dangerous points, and to guide them to designated
crossing places. At designated crossing places there should be adequate visibility for
pedestrians and vehicle drivers.

4. You should draw up and implement a system for informing and instructing employees
and other people who come onto the site, including visitors (both pedestrians and people in
vehicles) about the site rules concerning pedestrian / vehicle separation.

5. You should set up a system for checking compliance with your site rules for pedestrian
/ vehicle separation. The system should include reference to:

- which named individual(s) is/are responsible for monitoring compliance,

- how (including how often) they should monitor compliance,

- what they should do if non-compliance is found (including investigating any reasons

for non-compliance; any need for further precautions including further information, instruction,
training and supervision; reference to any disciplinary procedures),
 -what records they should keep of non compliance

OR

6. Any other equally effective means of complying with the Notice may be used.

2. IN on supervision & monitoring of workplace vehicle use

...you are contravening ... the following statutory provisions:

Health and Safety at Work etc Act 1974 sections 2 (1) and 3 (1) , Management of Health and
Safety at Work Regulations 1999 regulation 5 (1)

...the reasons for my said opinion are:

you have not made and given effect to such arrangements as are appropriate for the effective
control and monitoring of preventive and protective measures necessary for safe vehicle
movement at the above location

Schedule:

To comply with this Notice you should complete EITHER item 1 OR item 2.

1. You should set up a system for checking the extent to which vehicle drivers and
pedestrians on your site are complying with safe practices (including your own site rules) in
relation to risks from vehicle movements on the site.

The system should include a description of arrangements for checking the behaviour of:

- vehicle drivers (including drivers employed by you and other drivers, including visiting
drivers).

- pedestrians (including your own employees and other pedestrians, including visitors to
site)

The system should address in particular arrangements for checking :-

- whether drivers and pedestrians are staying within any designated areas (and, if not,
any reasons for this)

- whether any site rules or prohibitions on vehicle reversing are being followed (and, if
not, any reasons for this)

- whether a seat belt or other restraint is being worn where necessary (and, if not, any
reasons for this)

- whether vehicle drivers are following the safe working practices they have received
training and instruction in (and, if not, any reasons for this)

The system should include reference to:

- which named individuals (or post-holders) are responsible for carrying out checks on
workplace driver and pedestrian behaviour
 - how (including how often) the named individuals / post holders should monitor
compliance

-what action the named individuals / post holders should take if non-compliance is
found (including arrangements for investigating any reasons for non-compliance; any need for
further precautions including further information, instruction, training and supervision; reference
to any disciplinary procedures),

-what records should be kept of the checks made, especially any non-compliance.

OR

2. Any other equally effective means of complying with the Notice may be used.

3. IN on vehicle maintenance arrangements

...you are contravening ... the following statutory provisions:

Health and Safety at Work etc Act 1974 sections 2(1) and 3(1) , Provision and Use of Work
Equipment Regulations Regulation 5(1)

...the reasons for my said opinion are:

you have not ensured that work equipment namely (vehicle).is maintained in an efficient state ,
in efficient working order and in good repair.

Schedule:

To comply with this Notice you should complete EITHER item 1 OR item 2.

1. You should establish a system for maintaining those parts of workplace vehicles under
your control where failure or deterioration could lead to safety risks.

The system should take account of any instructions from the manufacturer about maintaining
the vehicle in a safe condition.

The system should, so far as is reasonably practicable, detect significant deterioration or

failures before they lead to danger.

The system should address in particular how deterioration or failures in the following vehicle
components and systems will be detected and dealt with:-

-braking system
-tyres
-steering
-mirrors and any other driver vision aids including lights
-windscreen washers and wipers
-warning devices
-any specific safety systems such as interlocks to prevent unintended
movement of the vehicle and / or the equipment on it

OR

2. Any other equally effective measures may be used to comply with the Notice.
4. IN on driver training

(READ 4.1 AND 4.2 BEFORE TAKING ACTION)

...you are contravening ... the following statutory provisions:

Health and Safety at Work etc Act 1974 sections 2(1) and 3(1)
Provision and Use of Work Equipment Regulations 1998 regulation 9(1)

...the reasons for my said opinion are:

persons using the (………vehicles) at the above location have not been adequately trained in
their safe use

4.1 Schedule for FLT drivers:

To comply with this Improvement Notice, EITHER complete items 1 AND 2 AND 3, OR item 4:-

EITHER

1. All operators of the fork lift truck(s) should be assessed as to their competence and
adequately trained to operate the types of lift truck used.

AND

2. Training should be in accordance with the Approved Code of Practice - Rider-operated

Lift Trucks: Operator Training.

AND

3. A record should be kept for each person who has satisfactorily completed basic training
and testing in accordance with the Approved Code of Practice - Rider-operated Lift Trucks:
Operator Training.

OR

4. Any other equally effective means of complying with the Notice may be used.

4.2 For drivers of vehicles other than FLTs

Ask for support eg Specialist Group (SG) Mechanical Inspector, to give an opinion and report on
existing driver training within the company. If they will support it, issue IN based on front of
notice detailed above with no schedule.

In an accompanying letter detail any SG recommendations and include a paragraph such as:
“A review of the training programme, content and duration for (………..vehicle) operators should
be undertaken to ensure that it is of sufficient length to enable trainees to acquire the basic
skills and knowledge required for safe operation. The model being applied to training of
operators on counterbalanced lift trucks should be used as the basis for comparison. Typically
courses of X days (get SG advice) duration are provided for novices on these types of vehicle
by other organisations. Further information on operator training of rider-operated lift trucks is
contained in the Approved Code of Practice and Guidance, titled, “Rider-operated lift trucks:
operator training,” ISBN 0-7176-2455-2. The publication is available from HSE Books. “
5. PN on lack of ROPS / restraint where risk of overturn significant

...hereby give you notice that I am of the opinion that the following activities namely:

operation (including driving) of the (manufacturer) (vehicle type eg site dumper), serial number /
identifying mark...

...which are being carried on by you etc...

at the above location

...involve or will involve a risk of serious personal injury, and that the matters which give
rise to the said risks are:

the vehicle is being used on a site in conditions where there is a significant risk of it overturning,
and no Roll Over Protective Structure (ROPS) is provided and / or effective operator restraint is
not provided for use with the Roll Over Protective Structure

...and that the said matters involve contravention of the following statutory provisions:

Health and Safety at Work etc Act 1974 Section 2(1), Provision and Use of Work Equipment
Regulations 1998 Regulations 4, 25 and 26 (and for forklifts with masts or ROPS, reg 27)

...because

there is a significant risk of the vehicle overturning on this site, and the driver of the vehicle may
be fatally crushed by parts of the vehicle if it overturns. (No Schedule)

6. IN(s) on ATV training and ATV head protection

...you are contravening ... the following statutory provisions:

Health and Safety at Work etc Act 1974 Section 2(1)

(& then use as required:

Provision and Use of Work Equipment Regulations 1998 regulation 9(1) (training) and/or
Personal Protective Equipment Regulations 1992 regulation 4 (head protection)

...the reasons for my said opinion are:

that persons are using an all terrain vehicle (ATV) (brand and model number) without having
been adequately trained in the safe use of the vehicle and/or without the provision of adequate
head protection.

Schedule:
To comply with this notice:

AMEND SCHEDULE AS APPROPRIATE TO COVER TRAINING / HEAD PROTECTION / OR

BOTH

EITHER

1. Ensure attendance on a recognised training course on the safe operation of ATVs by all
employees who ride an ATV. The course should be to the standard of those provided by Lantra
(Lantra National Training Organisation, Lantra House, NAC, Kenilworth, Warwickshire, CV8
2LG, Tel: 024 7669 6996, Fax: 024 7669 6732, [Link]/nto).

AND

2. Provide adequate head protection on an individual basis to every employee who uses an
ATV. The head protection should be to a standard giving at least 90J protection to both the top
and sides of the head e.g. BSEN 1384:1997 or BS 6658:1985

OR

Take other equally effective measures to ensure compliance with the legislation.

7 PN for employee raised on forks of a lift truck with no suitable working platform

...I am of the opinion that the following activities namely:

(describe activity…………………………) whilst standing on the raised forks of a lift truck

...which are being carried on by you etc...

at the above location

...involve or will involve a risk of serious personal injury, and that the matters which give
rise to the said risks are:
risk of a person falling a distance likely to cause personal injury

...and that the said matters involve contravention of the following statutory provisions:

Health and Safety at Work etc Act 1974 Section 2(1), Work at Height Regulations 2005,
Regulations 4, 6 & 7

...because
no steps have been taken to prevent a fall whilst working at height

NB This may also be appropriate for a proactive prosecution particularly if there is no suitable
risk assessment for the activity. See also Falls from Height Topic Pack

8 IN Inadequate lighting where pedestrians and vehicles are moving in the same area

...you are contravening ... the following statutory provisions:

Health and Safety at Work etc Act 1974 Section 2(1), Workplace (Health, Safety and welfare)
Regulations 1992 Regulation 8(1)

...the reasons for my said opinion are:

Suitable and sufficient lighting is not provided for the safe movement of people and vehicles in
(describe area)

No schedule. I accompanying letter refer to relevant light levels for area - see the Table on p38
of Lighting at work HSG38. Slightly modified extract reproduced here for convenience:
 Typical
Average Minimum measured
Activity locations/type of
illuminance (lux) illuminance (lux)
work

Movement of people,
Lorry park, corridors,
machines and 20 5
circulation routes
vehicles

Movement of people,
machines and
vehicles in Construction site
hazardous areas, clearance, excavation, 50 20
rough work not loading bays
requiring any
perception of detail

Work requiring
General warehouse
limited perception of 100 50
operations
detail

Work requiring
Offices 200 100
perception of detail

Drawing office,
Work requiring
assembly of small
perception of fine 500 200
components, textile
detail
production

9. IN - Identify work at height risks and appropriate precautions

You .....are contravening the following statutory provisions:

Health and Safety at Work Etc Act 1974 Sections 2 and 3 (delete as appropriate);
Work at Height Regulations 2005, Regulation 6;
Management of Health and Safety at Work Regulations 1999, Regulation 3.

The reasons for my said opinion are:

that a suitable and sufficient assessment of the risk to the safety of your employees (and others
not in your employment - delete / add as appropriate) of falling a distance liable to cause
personal injury when working on vehicle XXX has not been made to identify the preventive and
protective measures needed to ensure their safety so far as is reasonably practicable.

Schedule:

To comply with this Notice:

Either
1. Assess the risk to employees (and non employees - delete / add as appropriate) of falling
a distance liable to cause personal injury. The assessment should;
(a) Identify who is at risk - consider all people (e.g. your employees, contractors, agency
workers, maintenance and cleaning staff, managers, members of the public (delete / add any
others, relevant to the vehicle))
(b) Identify any people who may be particularly vulnerable (eg people who may be unfamiliar
with your premises and any risks posed by your premises and activities).
(c) Identify how people are at risk - look at all work done or likely to be done on vehicles, in the
future at heights from which a person could fall a distance liable to cause personal injury
(e.g.,loading and unloading, cleaning high surfaces, repairing and maintaining should also be
considered (delete / add as appropriate)). Look at how the work is actually done, not how you
think it is being done. Use previous incidents/near misses as well as the law, Approved Codes
of Practice, and other guidance to help your identification process. See covering letter for details
of relevant publications. (provide details of relevant publications in covering letter)
(d) Identify existing preventive/protective measures.
(e) Identify what further action, if any, needs to be taken to reduce risk sufficiently.

And

2 Record the significant findings of the assessment under 1 above.

Or

3 Use any other equally effective means for complying

The following paragraph to be included in the covering letter:

The assessment should consider the hierarchy of controls:
• plan to avoid work at height where you can;
• where you can’t, make sure you use work equipment to prevent falls:
- first choice – vehicle-based systems;
- second choice – on-site systems;
• where the risk of a fall can’t be eliminated, use work equipment to minimise the distance
and consequences of a fall;
• always consider measures that protect everyone at risk (eg platforms and guardrails)
before measures that only protect the individual (eg safety harness).
• provide additional training or instruction or take other additional suitable and sufficient
measures to prevent a fall.
The assessment should also consider arrangements for planning work at height, selecting,
using and maintaining suitable work equipment, ensuring the people doing the work are
competent, and arrangements for managing and supervising the work.

10 IN on poor planning and application of hierarchy for work at height on vehicles

You .....are contravening the following statutory provisions:

Health and Safety at Work Etc Act 1974 Sections 2, 3 or 4 (delete as appropriate);
Work at Height Regulations 2005, Regulation 4, 6 and 7;
Management of Health and Safety at Work Regulations 1999, Regulation 3.

The reasons for my said opinion are:

You have neither planned nor implemented reasonably practicable precautions to prevent or
arrest persons falling from the bed of the xxxx vehicle/load whilst working or whilst accessing
the bed of the vehicle/load.
OR
The hierarchy for work at height has not been properly applied or considered in relation to work
on the xxxxx vehicle during (describe the circumstances).
OR
The most appropriate work equipment and method of work has not been considered for
access/egress or work on the xxxx vehicle bed/load. (delete as applicable)

No Schedule

Or base a schedule on that used for IN 9 above.

The following paragraph to be included in the covering letter:

The assessment should consider the hierarchy of controls:
• plan to avoid work at height where you can;
• where you can’t, make sure you use work equipment to prevent falls:
- first choice – vehicle-based systems;
- second choice – on-site systems;
• where the risk of a fall can’t be eliminated, use work equipment to minimise the distance
and consequences of a fall;
• always consider measures that protect everyone at risk (eg platforms and guardrails)
before measures that only protect the individual (eg safety harness).
• provide additional training or instruction or take other additional suitable and sufficient
measures to prevent a fall.
The assessment should also consider arrangements for planning work at height, selecting,
using and maintaining suitable work equipment, ensuring the people doing the work are
competent, and arrangements for managing and supervising the work.
7 Checklist for dutyholders

Site inspection - workplace transport checklist

• The following checklist has been prepared as a guide to what employers should consider when trying to
reduce the risk from vehicles in the workplace. It will not necessarily be comprehensive for all work
situations
• If the answer to a question is ‘No’, the references under the section heading indicate where further advice
can be found.
• If the question is not relevant to your workplace leave the boxes blank.

1 MANAGEMENT AND SUPERVISION OF WORKPLACE TRANSPORT RISK.

See references 1, 2, 3, 4, 5
Check, in consultation with your employees, that your level of management control/supervision is
adequate

Are site rules documented and distributed?

Yes F No F
Are your supervisors, drivers and others, including contractors and visiting drivers, aware of
the site rules? Are they aware of their responsibilities in terms of helping to maintain a safe Yes F No F
workplace and environment?

Has a risk assessment been completed for all workplace transport hazards?
Yes F No F

Is the level of supervision sufficient to ensure that safe standards are maintained?
Yes F No F

Are sanctions applied when employees, contractors, etc., fail to maintain these standards?
Yes F No F

Are adequate steps taken to detect unsafe behaviour of drivers of both site and visiting
vehicles as well as pedestrians? Are the underlying reasons investigated to correct unsafe Yes F No F
behaviours?

Is there good co-operation and liaison on health and safety matters between your staff and
Yes F No F
those who collect or deliver goods?

Check what your drivers and other employees actually do when undertaking their work
activities
Do drivers drive with care, e.g., use the correct routes, drive within the speed limit and follow
Yes F No F
any other site rules?

Do your drivers and other employees have enough time to complete their work without
rushing or working excessive hours? Do you monitor “job and finish” work to ensure drivers Yes F No F
are not rushing to cut corners?

Are your employees using safe work practices, e.g., when (un)coupling, (un)loading,
Yes F No F
securing loads, carrying out maintenance etc.?

Do managers and supervisors routinely challenge and investigate unsafe behaviours they
Yes F No F
may come across?

Do managers and supervisors set a good example, for instance by obeying

vehicle/pedestrian segregation instructions, and by wearing high visibility garments where Yes F No F
these are needed?
 2 SITE LAYOUT AND INTERNAL TRAFFIC ROUTES.
See references 1, 2, 6, 7, 8, 9, 10
Check that the layout of routes is appropriate

Are the roads and footways suitable for the types and volumes of vehicular
Yes F No F
traffic and pedestrian traffic using them?

Are vehicles and pedestrians kept safely apart?

Yes F No F

Where necessary are there suitable pedestrian crossing places on vehicle

routes? Yes F No F

Is there a safe pedestrian route that allows visiting drivers to report for
Yes F No F
instructions when entering the site?

Are there adequate numbers of suitable parking places for all vehicles and
are they used? Yes F No F

Is there a properly designed and signed one-way system used on vehicle

Yes F No F
routes within the workplace?

Is the level of lighting in each area sufficient for the pedestrian and vehicle
activity? Yes F No F

Check that vehicle traffic routes are suitable for the type and quantity of vehicles, which use them.

Are they wide enough?

Yes F No F

Do they have firm and even surfaces?

Yes F No F

Are they free from obstructions and other hazards?

Yes F No F

Are they well maintained?

Yes F No F
Do vehicle routes avoid sharp or blind bends?
Yes F No F
Check that suitable safety features are provided where appropriate.

Are roadways marked where necessary, e.g. to indicate the right of way at
road junctions? Yes F No F

Are road signs, as used in the Highway code, installed where necessary?
Yes F No F

Are features such as fixed mirrors (to provide greater vision at blind bends),
road humps (to reduce vehicle speeds), or barriers (to keep vehicles and
Yes F No F
pedestrians apart) provided where necessary?
 3 VEHICLE SELECTION & SUITABILITY
See references 1 & 2.
Check that vehicles are safe and suitable for the work for which they are being used.

Have suitable vehicles and attachments been selected for the tasks which are actually
Yes F No F
undertaken?

Do vehicles have good direct visibility or devices for improving vision where reversing can’t
be eliminated and where significant risk still remains eg external and side mirrors; vision Yes F No F
aids such as CCTV; sensing device?

Are they provided with horns, lights, reflectors, reversing lights and other safety features as
necessary? Yes F No F

Do they have effective service and parking brakes? Yes F No F

Do they have seats and seatbelts where necessary? Yes F No F

Are there guards to prevent access to dangerous parts of the vehicles, eg power take-offs,
chain drives, exposed exhaust pipes? Yes F No F

Do drivers have protection against bad weather conditions, or against an unpleasant

Yes F No F
working environment, ie the cold, dirt, dust, fumes and excessive noise and vibration?

Is there a safe means of access to and exit from, the cabs and other parts that need to be
reached? Yes F No F

Are surfaces, where people walk on vehicles, slip resistant? Yes F No F

Is driver protection against injury in the event of an overturn, and measures in place to
prevent the driver being hit by falling objects, provided where necessary? Yes F No F

Are operators involved or consulted on vehicle selection?

Yes F No F

4 VEHICLE MAINTENANCE
See references 1 & 2.
Check the level of vehicle maintenance is adequate.

Is there a regular preventative maintenance programme for every vehicle, carried out at
predetermined intervals of time or mileage? eg in accordance with manufacturers Yes F No F
instructions

Is there a system for reporting faults on the vehicle and associated equipment and carrying
Yes F No F
out remedial work?

Where vehicle attachments lift people or objects, are thorough examinations undertaken by
Yes F No F
a competent person (e.g. your insurance company)?

Do the drivers carry out basic safety checks before using the vehicle?
Yes F No F
 5 VEHICLE MOVEMENTS
See references 1 & 2.
Check that the need for REVERSING is kept to a minimum, and where reversing is necessary that it is
undertaken safely and in safe areas.

Have drive-through, one-way systems been used, wherever possible to reduce the need for
Yes F No F
reversing?

Where reversing areas are needed are they marked to be clear to both drivers and
Yes F No F
pedestrians?

Are non-essential personnel excluded from areas where reversing occurs?

Yes F No F

If risk assessment shows site controls cannot be improved further and you need a
banksman to direct reversing vehicles, are they adequately trained and visible? Yes F No F

6 UN(LOADING) ACTIVITIES
See references 1, 2, 4, 11, 12.
Check that there are safe systems for LOADING and UNLOADING operations.

Are loading/unloading operations carried out in an area away from passing traffic,
Yes F No F
pedestrians and others not involved in the loading/unloading operation?

Are the load(s), the delivery vehicle(s) and the handling vehicle(s) compatible with each
Yes F No F
other?

Are loading/unloading activities carried out on ground that is flat, firm and free from
Yes F No F
potholes?

Are parking brakes always used on trailers and tractive units to prevent unwanted
Yes F No F
movement, eg when coupling vehicles?
Are the vehicles braked and/or stabilised, as appropriate, to prevent unsafe movements
during loading and unloading operations? Yes F No F

Are systems in place to prevent trucks driving away while they are still being (un)loaded? Yes F No F

Are lorry drivers and others kept in a safe place away from the vehicle while (un)loading is
carried out? Yes F No F

Is there a safe area marked where drivers can observe loading (if necessary)?
Yes F No F

Has the need for people to go on to the load area of the vehicle been eliminated where
possible and if not is safe access provided and used? Yes F No F

Is appropriate lifting equipment available for (un)loading vehicles?

Yes F No F

Is loading/unloading carried out so that, as far as possible, the load is spread evenly to
avoid the vehicle or trailer becoming unstable? Yes F No F

Are checks made to ensure the load is adequately secured in line with the Department for
Transport Code of Practice and not loaded beyond their capacity before the vehicle leaves
Yes F No F
the site?
 7 DRIVER COMPETENCE.
See references 1, 2, 13.
Check that your selection and training procedures ensure that your drivers and other employees are
capable of performing their work activities safely and responsibly.

Do drivers possess the necessary licences or certificates for the vehicles they are
Yes F No F
authorised to drive e.g. FLT’s, shunt vehicles, site dumpers etc.?

Do you check the previous experience of your drivers and assess them to ensure they are
Yes F No F
competent?

Do you provide site specific training on how to perform the job, and information about
Yes F No F
particular hazards, speed limits, the appropriate parking and loading areas, etc.?

Do you have a planned programme of refresher training for drivers and others to ensure
their continued competence? Yes F No F

See over the page for Section 8 (Un)sheeting and Section 9 Tipping

References
01) Workplace Transport Safety: Guidance for employers HSG 136 HSE Books 2005 ISBN 0-7176-6154-7

02) Workplace transport safety : an overview Leaflet INDG 199(rev1) HSE Books 2005

03) Five steps to risk assessment INDG 163 (rev 2) Leaflet HSE Books 2006

04) HSE Information Sheet WPT06 Delivering Safely - free download at HSE Website

05) Health and safety in road haulage INDG379 Leaflet HSE Books 2003

06) The Highway Code. Department for Transport 2004 ISBN 0-11-5526986

07) Designing for Deliveries Freight Transport Association 1998 ISBN 0 90299166 3 (£80 to members
£100 to non-members from FTA phone 01892 526171)

08) Lighting at work HSG 38 HSE Books 1997

09) Safety Signs and Signals – Guidance on the Regulations L64 HSE Books 1996

10) The Traffic signs Regulations and general directions 2002

11) Code of Practice: Coupling or uncoupling & parking of large goods vehicle trailers 2006 Institute of
Road Transport Engineers (IRTE) Society of Operations Engineers (SOE), 22 Greencoat Place,
London,SW1P 1PR phone 020 7630 1111 website: [Link]

12) Code of Practice - Safety of Loads on Vehicles (third edition) 2002 Department of Transport ISBN 0
11552547 5 (free download at website:
[Link] )

13) Rider-operated lift trucks: operator training Approved Code of Practice HSE Books L117
 8 (UN)SHEETING
See references 1, 2

Check that sheeting and unsheeting operations are carried out safely

Do you use ground based sheeting methods?

Yes F No F

Are sheeting and unsheeting operations carried out in safe parts of the workplace, away
Yes F No F
from passing traffic and pedestrians and sheltered from strong winds and bad weather?

Are the vehicles parked on level ground with their parking brakes on and the ignition key
Yes F No F
removed?

Are gloves, safety boots and, where necessary, eye and head protection provided, and used
by those engaged in the sheeting/unsheeting operations? Yes F No F

Where manual sheeting is unavoidable, is there a system in place which avoids the need for
a person on to climb on the vehicle or load, ie by providing a platform from which loads can
Yes F No F
be sheeted?

9 TIPPING
See references 1, 2

Check that tipping operations are carried out safely

Do visiting drivers report to the site manager for any relevant instructions prior to
commencing tipping operations? Yes F No F

Are non-essential personnel excluded from tipping areas?

Yes F No F

Are tipping operations undertaken on ground that is level and stable, and a location free
from overhead hazards such as power lines, pipework, etc? Yes F No F

Where sites are not level and stable, are the tipping faces safe for vehicles involved in
tipping operations, eg compacted and no side slopes? Yes F No F

Are suitably sized wheel-stops provided where vehicles need to reverse prior to tipping?
Yes F No F

Are drivers clear about when tailgates should be released or removed?

Yes F No F

Do drivers check that their loads are evenly distributed across the vehicle prior to
commencing tipping operations? Yes F No F

Are the drivers sufficiently experienced to anticipate loads sticking?

Yes F No F

Do drivers always ensure that the body is completely empty, and drive no more than a few
metres forward to ensure the load is clear? Yes F No F
Appendix 1 Causal information on workplace transport incidents

Background information

y This sheet covers key points on the underlying causes of workplace transport accidents from
data gathered at investigations during 1999/2000 and 2000/1 using a structured accident proforma.
y This analysis is of 577 proformas and comprises 68% struckbys, 19% vehicle overturns, 9% falls
from vehicles and 4% falling objects from vehicles. This distribution is not a statistically
representative sample of all accidents reported as different national and local accident selection
criteria were applied across the two work years. Also fatalities are under represented because of
the difficulties in collecting complete data sets of factors underpinning these incidents.
y Overall, 51% of these proformas arose from forklift truck (FLT) investigations.
y Equal numbers of vehicle drivers and site employees were injured persons (IPs).
y More of the accidents investigated were caused by vehicles moving forward1 than those
reversing (53% vs. 36%) and only 4% of all accidents involved vehicles not under power.
y Only 4% of all accidents investigated involved two vehicles colliding.
y The proformas collected specific information under ‘factor’ headings of Management, Vehicle,
Training, Procedural, Behavioural and Workplace.

Headlines from each of the accident factors

Reasons behind each accident were complex, none were reported as having a single cause.

Management y In 70% of accidents, management failed to undertake and implement risk

factors assessments satisfactorily.
y In almost 60% of accidents management were failing to monitor standards
and detect and correct unsafe behaviour satisfactorily.
y The management failures were similar on single and multiple-employer sites.
Workplace y Workplace design and layout were significant in 75% of the accidents and
factors 86% of the issues raised were reasonably practicable to control. “Inadequate
separation of vehicles from pedestrians” was cited most frequently in these
accidents (at 37%).
y In 41% of the investigations where workplace design and layout were
significant contributors to the accident, control measures were in place but had
failed. Mainly this was due to inadequate use of these controls.
Vehicle factors y The predominant issue was all round visibility, with deficiencies being mainly
due to poor design and how the vehicle was used.
1
However as vehicles spend proportionately more time going forward than reversing, the injury rate per unit
time spent reversing is higher

Behavioural y Behaviour of individuals at the time of the accident was significant in just over 80% of all
factors accidents. “Driving without due care and attention”, “inappropriate action by the IP” (where
this is not the driver) and “not following established Systems Of Work (SOW)” were most
frequently cited, in a third or more of all accidents. These three failings were mainly due to
individuals violating known rules in the workplace rather than them not having the
appropriate knowledge.
Procedural y In nearly 80% SOW existed for the task being undertaken, inferring that accidents
factors occurred during routine/familiar activities in these workplaces. In half of these accidents the
SOW was being followed at the time of the accident. 64% of all SOW were not written
down, rather they were adopted through ‘custom and practice’ (this includes the regular
performance of a task in a set manner, adopted by default as the SOW).
Associations between factors
y All accidents had their own combination of factors which had contributed to why the accident
had happened, therefore each can be considered as an individual case study. However two main
associations accounted for 70% of the accidents investigated. These were “pedestrian
separation” (54%) and “loss of control due to ground conditions” (24%). The key points
raised in these associations are shown below (with the % frequency at which they are cited given
in brackets):
Pedestrian separation associations2
Primary risk To pedestrians being struck by forward moving and reversing powered
vehicles
Main management Risk assessment and its implementation (80%)
deficiencies Monitoring and detecting/correcting unsafe behaviour (60%)
Key behavioural issues for Key workplace and vehicle issues
pedestrians and drivers
y Inappropriate action by pedestrian site y Separation of vehicles from pedestrians (71%)
employees (51%) y Areas of specific hazard to pedestrians (50%)
y Driving without due care and attention y Traffic routes (43%)
(48%) y Designated manoeuvring areas (33%)
y Not following established SOW (25%) y Reduced driver visibility due to workplace layout (28%)
y Selection of inappropriate route (20%) y All round visibility from the vehicle driving position (40%)
y Vehicle warning devices (19%)
Note: Where the actions of pedestrian site employees is an issue, pedestrian workplace
transport awareness training could be considered.
Loss of control due to ground conditions associations2
Primary risk To drivers through vehicle overturns during powered movement
Secondary risk To drivers and pedestrians involved in struck by accidents
Main management Risk assessment and its implementation (70%)
deficiencies Monitoring and detecting/correcting unsafe behaviour (60%)
Key behavioural issues for Key workplace and vehicle issues
drivers
y Driving without due care y Ground conditions (57%)
and attention (36%) y Gradient of the traffic route (50%)
y Selection of inappropriate y Areas of specific hazard to vehicles (40%)
route (31%) y Stability of the vehicle being used (32%)
y Not following established y Suitability of the vehicle for the task undertaken (18%)
SOW (25%) y Seat restraints (18%)
y Driver not competent for the y Service & parking brakes (16%)
vehicle being used (21%)
y Driver protection in the event of loss of stability (14%)
Risk control must be addressed at the levels of management, drivers and pedestrians (in
appropriate combinations dependent on the nature of the workplace) if it is to be effective.
2
The bullet points in this association are not in any ranking order
Appendix 2 Reporting of good practice

Good practices

LA inspectors can access the HELA Training Co-ord Website. “The Practice and Procedures”
link is an area where LAs can share knowledge and examples of good practice. It contains
examples of LA initiatives, campaigns, guidance documents and legal case studies, all compiled
by LAs.

HSE Safety Unit invites inspectors to report examples of good practices in relation to workplace
transport. The HSE “Workplace Transport Website” is being developed. This should give
anyone with Internet access the ability to search for practical ideas and examples of good
practices concerning workplace layout, segregation schemes, novel vehicle designs, vehicle
management schemes, sheeting devices etc. On the Website it should be possible to view
“before and after” photographs and illustrations of workplaces, and video clips (if they help
explain how a risk control measure works). Inspectors may assure duty holders that material
will not be released without their permission. Spreading knowledge about good practices
should help reduce risks to the population as a whole.

HSE Safety Unit particularly invite any information on the following:-

- “Before & after” photographs of WT controls

- Proven financial benefits of managing WT risks
- Use of CCTV
- Innovative risk reduction measures on workplace vehicles (new or retro-fits)
- Practical, easily transferable systems for supervising & monitoring WT
- “Human factors” issues in relation to WT, eg. fatigue as a contributory factor
to WT accidents, and ways to counter such risks

Novel enforcement notices, prosecutions etc

Please inform / copy in HSE Safety Unit regarding novel enforcement work. Knowledge about
good enforcement approaches (for instance Notice templates or enforcement initiatives) which
work, and could be distributed nationally.
Appendix 3 Inspection template and technical guidance from the “Struck by” project (SIM
3/2006/08 / LAC 85/11)

During visits to SMEs Inspectors can:

Use the template to guide the inspection where the topic (in column 1) is relevant to that site
Allocate a score to the control of the topic, as described on the bottom of the form, with the
score taking account of all the sub-categories under that topic.
Use the associated technical guidance where a solution is not immediately obvious. This
guidance, includes much information that is available in WT topic pack but in a more accessible
form. (However, some of the guidance will be more relevant to larger sites).
The scores on the inspection template can be used to derive the Risk Control Indicator (RCI)
scores as follows:
Any scores in parts 2, 5 and 6 should be averaged and rounded up or down to the nearest
whole number to become the 'safe site' RCI rating
Any scores in parts 3 and 4 should be averaged and rounded up or down to the nearest whole
number to become the 'safe vehicle' RCI rating
The score in part 7 is the 'safe driver' RCI rating
The score in part 1 feeds into the inspector's overall assessment of H&S management

The guidance in this Appendix relates to “struck by” risks only – for a complete WT inspection
don’t forget the other 3 areas falls from vehicles, vehicle overturns and being hit by objects
falling from vehicles.
‘Look at’ ‘Look for’ Benchmark ‘Rating’ * Legal requirements & possible
content of Notices

1) i) A suitable and sufficient i) Identification of vehicle type, task and i) MHSWR, reg 3
Management risk assessment of the suitability. 1 2 3 4 requiring a suitable and
site-specific WT risks. Numbers of vehicles arriving on site sufficient RA.-NB.
of the
Workplace and identification of peak times. Referring to a specific
transport Identification of at-risk groups (e.g. risk, e.g. vehicle
MoP, children, foreign drivers). movements in the
(WT) risk
Identification of all reversing situations warehouse, may make
and other high-risk operations and compliance checking
areas. easier.
Application of hierarchy to control
solutions.
ii) Allocation of ii) Clarity at all levels, knowledge of the ii) MHSWR, reg 7- subject
responsibility for WT and control hierarchy and/or source of to reg 7(6) and 7(7) -
knowledge of the competent advice. requiring a competent
required standards. person .

iii) Site rules and control iii) Simple site rules brought to the iii) MHSWR, reg 5
over adherence. attention of all drivers and pedestrians. requiring site rules as
Front line managers aware of site part of H&S
rules, control standards and their management system.
responsibility to ensure compliance. See below.

iv) A simple means of iv) System for checking both physical and iv) MHSWR, reg 5
monitoring and review to behavioural control measures are requiring a monitoring
ensure continued complied with. system as part of H&S
compliance with System for investigating WT incidents management system
established control and demonstration of the
measures. implementation of any lessons learnt.
2) Site layout i) Space for safe vehicle i) Pedestrian/vehicle separation with i) HSWA, s2(1) and 3(1),
and internal and pedestrian routes marked and physical barriers 1 2 3 4 MHSWR reg 5(1) and
traffic routes movement. where reasonably practicable. Workplace Regs, reg
Separate pedestrian /vehicle exit. 17 requiring
Traffic routes wide enough for the organisation of traffic
largest vehicle permitted to use them routes/separation.
and wide enough to allow vehicles to
pass oncoming or parked vehicles
without leaving the route- no sign of
damage to verges etc.
Traffic routes with clear sight lines and
no blind areas. Open manoeuvring
areas and planned vehicle parking.
Where risk is high pedestrians may
have to be excluded from vehicle
operating areas.
ii) Pedestrian/traffic routes ii) Housekeeping system to ensure clear ii) HSWA, s2 and
and manoeuvring areas unobstructed walkways, traffic routes, Workplace Regs, reg
are free from manoeuvring and yard areas, both 12. requiring system of
obstruction. internal & external. work to maintain routes.

iii) Good road, yard, and iii) Firm even surface, free from iii) Workplace Regs. reg
walkway surfaces. potholes/ruts, made from tarmacadam, 12 requiring a suitable
concrete or other suitable material. surface material.

iv) Suitable and sufficient iv) All roads, manoeuvring areas and iv) Workplace Regs. reg 8
lighting. yards adequately lit. All lights working requiring suitable and
and clean. Absence of glare and no sufficient lighting.
strong variation of light between the
inside and outside of premises.

v) Clear signage of v) Potential hazards such as junctions, v) Workplace Regs.

potential hazards on crossings indicated by suitable signs & reg17(4) requiring
traffic routes. roadmarkings complying with Traffic suitable signage.
Signs Regs & General Directions 2002
( ie Highway Code road markings and
signs)
3) Vehicle i) Vehicles have space to i) Vehicles of a size and type which can i) PUWER reg 4(2)
selection manoeuvre without manoeuvre and perform all site-based 1 2 3 4 requiring use of suitable
and driving onto pedestrian- tasks without driving into any footway work equipment .
suitability only areas and are or pedestrian only area. Consider
suitable for the terrain. swept path of manoeuvring vehicle.
Vehicle chosen with terrain in mind
e.g. rough terrain, warehouse only.

ii) Vehicles have ii) Vehicles have good direct visibility or ii) PUWER reg 28(e) to
appropriate visibility for adequate devices for improving vision improve driver’s field of
the range of indirectly where a risk exists and the vision on site-owned
manoeuvring they have RA shows site controls cannot be vehicle, but not
to do. improved. eg. external side and rear specifying any
mirrors; vision aids such as cctv; particular vision aid
sensing devices. over any other.
(NB audible warnings are not included (see also OC 803/70)
here as they are not the preferred
option for preventing “struck by”
accidents)
4) Vehicle i) Vehicles are well- i) Maintenance system in place: i) Various aspects:
maintenance maintained e.g. have • Driver start-up checks carried out 1 2 3 4 • PUWER reg 5
effective brakes, clear and defect-reporting procedures in requiring
wind- screens, effective place. maintenance (not
wipers, horn and lights. start-up checks)
• Planned preventative maintenance • P/N PUWER reg 5
scheme and servicing carried out and HSWA s2/3 if
in accordance with manufacturer’s defect gives rise to
instructions. a risk of serious
• Inspection (& thorough personal injury.
examination where applicable) • PUWER reg 6
carried out. requiring inspection
(see OC 234/13)

5) Vehicle i) Elimination of the need i) Knowledge of reversing activities and 1 2 3 4 i) HSWA, s2&3; Workplace
Movements to reverse, particularly in sensible application of the control hierarchy. Regs. reg 7; MHSWR,reg 5
pedestrian areas, and Designated reversing areas with non-essential requiring assessment and
where it cannot be personnel excluded. Essential personnel in application of the control
avoided, minimised. high visibility clothing. hierarchy.
6) i) Un/loading is carried out i) Arrangements to control 1 2 3 4 i) HSWA s2/3 and/or
Un/loading in a controlled manner. volume/timing of deliveries. MHSWR reg 3(1)
activities Procedural or physical control over requiring system of
delivery vehicles. Designated areas work and planning of
for parking up, un/loading and activity.
un/sheeting areas.
ii) Sharing information and ii) Exchanging information and any ii) MHSWR reg 12 &
cooperating with others. simple site rules before the delivery, HSWA s3 requiring
eg restrictions on the type and size of sharing information and
vehicles which the site can safely co ordination between
handle, any procedures the driver all parties in the
needs to follow, who will be in overall delivery process.
charge of un/loading.
iii) Staff involved in iii) All people involved in un/loading know iii) HSWA s2/3 requiring
un/loading have what is expected of them and what safe system of work for
knowledge of what they they should do – especially safe place specific un/loading
should do. for driver, eg in cab or refuge. operations.
Includes visiting drivers whose first
language is not English.
Rules are followed in practice.
7) Driver i) Lift truck and other i) Appropriate licences/certificates held & i)- iii)
competence vehicles, such as planned programme of refresher 1 2 3 4 PUWER reg 9 and
shunters, tugs etc being training. HSAWA, s2(1) requiring
driven by operators with suitable training, with
appropriate licences. reference to ACOP in
the case of FLTs.

ii) No unauthorised use of ii) Authorisation system detailing the

designated vehicles. types of vehicle that a person is
competent to operate. No
unauthorised use of vehicles.- look at
control of keys.
iii) Safe driving practices iii) Drivers have knowledge of the
followed and adequate workplace, routes and higher risk
supervision of site rules. operations. Site rules are complied
with eg not loading if pedestrians in
area, speed limits. Information and
instruction on how to operate the
vehicle e.g. use of any visibility aids.
No obvious signs of impact damage on
vehicles barriers and premises. (NB
damage may also be a reflection of
extensive reversing activity and poor
spacing, not just competence.)
 “Struck by” Project: Technical Guidance

Objective
To give technical advice for the inspection of workplace transport, by giving some practical options that can
be used for assessing safe site, safe vehicle and safe driver issues at different premises, from a goods distribution
centre to a manufacturing site, and to help judge compliance.

The advice is generic and intended to assist inspectors when looking at workplace transport issues relating to
preventing “struck by “ injuries. The sections on the Inspection template dealing with Vehicle movements and
Un/loading have not been covered in this guide. Where technical issues are identified that require further
examination then contact should be made with the relevant discipline in your Specialist Group (Safe site – civil
engineering and safe vehicle/driver – mechanical engineering) or, for Local Authority Inspectors, via your
Enforcement Liaison Officer.
1. Management of the workplace transport risk

Ref Subject Item Technical Details of what practical options are

available
1.1 Management Information at site Nominated persons responsible for traffic
controls Induction inc movements, parking, loading /unloading.
Traffic routes Instructions to visiting drivers at gate house and /or
Loading areas prior contact with goods dispatchers etc
Segregation

Locations where Covered in LOADING AREAS SECTION 2.11

pedestrians and Housekeeping-supervision and maintenance of
vehicles will conflict roads and footways. Workplace Regs –Reg12
(Condition of floors and traffic routes). E.g. road
sweepers/wheel wash, cleaning, internal roadways,
free from potholes.
Monitoring of controls-means of team
communication/feedback to management.
Audit of procedures review & changing system as it
Speed limit- evolves.
enforcement/
supervision
Evidence that vehicles comply with speed limits.

1.2 Risk assessment Number and types of Detailed assessment for each type of traffic
of all types of traffic movement by movement to determine risk to pedestrians, other
traffic movement both pedestrians and vehicles and structures considering location, type
– vehicles and vehicles inside and and number of movements.
pedestrians outside buildings
Scaled plan of the premises showing transport
routes and significant features, e.g. Loading bays,
gradients, machines, racking, should be obtained or
produced by the occupier as this is essential to
control and manage the traffic on their premises.
2. Site Layout and internal routes

Ref Subject Item Technical Details of what practical options are

available
2.1 Site layout Information: Advance At entrance - rectangular sign, clearly visible at a
warning and clear distance, contrasting colours with directional arrows.
direction signing of
entrance off the public -Site map sign with letters large enough to be read
highway into the at appropriate distance
premises -or instructional sign for drivers to report or get
instructions.

2.2 Segregation of Pedestrian routes. Entrance - Segregated footways/ corridors or gates

pedestrians and Pedestrian guardrails or barriers to vehicle routes
vehicles and parking areas.
Road markings showing pedestrian routes
Gap between barriers and racking also improves
sightlines

2.3 Vehicle i) Fixed i) Barriers -metal/concrete

containment Kerbs- as for footways
barriers/ Railings/Fencing
demarcation of Impact barriers to protect the premises and
routes fittings inside the premises e.g. steel columns and
racking.
Floor/road markings

At doorways and openings or other pedestrian

points of access.
ii) Movable/temporary
barriers ii) Posts in concrete drums, plastic demountable
barriers, cones and tape
iii) Road markings-
thermoplastic road iii) Other types of barriers could be spray paint or
markings or road paint sand line on highway or footway surface / tape
suitable for outside or between posts / change in surface colour
inside use

2.4 Crossing points Traffic lights Zebra Pelican style-subject to suitable criteria
Pedestrian crossings, Dedicated-places marked by road studs and
footbridges and signage/ lighting
underpasses Visibility of pedestrians/sightlines-Location to suit
circumstances and other access needs

2.5 Traffic routes / Entrance off public Adequate radii and sight lines based on speed and
Layout highway category of roadway.

Roadways: - Width:
Adequate width, e.g. 5.5 metres –2 way traffic flow
inc. HGV’s.
Radii: at junctions and changes of direction based
on width of load and suitable for vehicles in use

Sight lines at junctions e.g. X dimension 2.4-4.5 m,

Y dimension 33m – 60m. Appropriate for road
speeds.
Gradients and ramps Passing places where roadway is too narrow for 2
way flow

Road ways: Max gradient for type of vehicle in use

Surface and condition e.g. pallet trucks level surface and FLT, LGV
highway gradient (if appropriate),
 Embankments/cuttings

Workplace Regs Reg 12 Condition of floors and

Traffic Management traffic routes: Types e.g. Tarmac; Concrete
Paving/blocks; Hardcore; Timber; Maintenance
Drainage

Maintenance and One-Way systems to eliminate reversing when

drainage appropriate.
Road humps, chicanes, etc to control speed
Priority routing-as Highway Code signs.

Effective draining of water with no ponding or

flooding.
No potholes or breaking up due to wear or abuse to
road surface.

2.6 Features Height Clearances Under structures, pipe bridges, gantries, loading
bays, canopies, and entrances with appropriate
warning signs to Traffic Signs Regulation and
General Directions (TSR & GD).
Car and Vehicle
Parking Clearly marked and signed, adequate size with safe
means for drivers to leave parking area. E.g. car
spaces 2.5m wide x 4.8m deep with aisles adequate
width: lorry spaces appropriate for size of LGV, i.e.
3.5m wide x max length of vehicle.

2.7 Junctions Priority at Give Way Junctions, crossroads and roundabouts- based on
traffic flow and risk assessment.
Give way on side roads, road markings, Diagram
1003, i.e. double 600mm line and 300mm gap,
100mm width of line. Signs in accordance with
TSR&GD (see also Highway Code.)
Traffic lights
When traffic flow is heavy and needs control for
safety. Seek professional advice from Traffic
Engineering Consultants for installation
Mirrors on fixed
structures to aid drivers At blind junctions where STOP line and sign may be
in vehicle i.e. mirrors appropriate but subject to deterioration with weather
conditions.

2.8 Turning areas Dedicated turning area Based on site dimensions and layout. Occupier
using existing road may need professional advice of Consultants for
system, turntable or design.
dedicated reversing
area.

Banksman supervision
Where other alternative physical measures cannot
be used, such as above. Using area from which
pedestrians are excluded. Hand Signals to
Schedule 1, Part IX of SSR Regs, 1996, and PPE.
2.9 Traffic Speed Limits Indicative road speed limit e.g. 5MPH or 10 MPH or
management: NB. walking pace. Included in site rules and
Some measures enforced/supervised
are not suitable Traffic Calming
for FLT’s and Either temporary or permanent arrangements.
other vehicles e.g. Related to walking speed in pedestrian shared
tugs, cages, areas or safe vehicle speed elsewhere
stillages, pallet E.g. Road Humps, Chicanes, Narrowings
trucks etc)

2.10 Car and lorry Adequate car and lorry Car parking spaces clearly marked with broken
parking parking provision with white lines, end- on or 90 degree parking spaces at
suitable pedestrian a minimum 2.4m wide x 4.8m deep, but minimum
access 2.5mx 5.0m preferred to allow for loading at side
doors. Aisle/roadway between parking spaces 5.5m
– 6.0m wide. Angled parking spaces with narrower
one- way aisles or road systems designs possible.
Disabled parking spaces with extra width.
Where car park aisles meet, give- way road
markings and clear directions for routing.

2.11 Road marking and Appropriate Road Road markings/lines full or broken, to indicate
signs Markings routes and priority at junctions. Types-centre line,
edge of roadway, ghost markings, parking places for
LGVs and cars. Lay-bys, junction boxes (as
Highway Code Markings to TSR & GD)

Restricted Access Box junction markings (if justified)

Priority at junctions – give way and stop lines
Signs
Warning Signs –triangular, black lettering on white
background with red border. Height of triangle
600mm for 30MPH. ( see Annex A attached)

2.12 Loading areas Barriers, signs Segregation of drivers from loading /unloading
/markings operations.
Safe system may be In Cab, Not in Cab, Safe
Safe Sheeting and refuge
Roping Area
Gantries, staging, access to vehicle / fall protection
Immobilise vehicles- remove and control keys,” DO
NOT MOVE” sign in front of vehicle, wheel chocks,
hydraulic bollards, captive systems.

2.13 Obstructions Height and width See warning signs

clearances

Natural Chicanes Safely managed, inc signs, road lines, barriers and
hazard marking.

Natural / Artificial Maintenance of roadways, removal of debris, litter,

obstructions. leaves, pallets, drums, waste, etc
Good Housekeeping

2.14 Lighting Suitable lighting types Roads see BS on road light standards on public
for: - highway –silhouette lighting

External Areas- Movement of people, machines and vehicles e.g. for

Roadways, Footways lorry parks, circulation routes – overall average 20
Parking and Other lux minimum 5 lux
Areas
 Interior lighting In hazardous areas rough work not requiring
suitable for task. perception of detail
Average 50 lux, minimum 20 lux see HSG38

Temporary Lighting Temporary situations only, e.g. roadworks on

workplace traffic routes, illuminated for safety.

Lighting on vehicles Most on site vehicles do not have lights unless fitted
Vehicles in roadworks - at customer request as required. Road vehicles do
according to need under Road Vehicles Construction and Use
based on risk Regulations.
assessment taking into
account surrounding WP vehicles according to need, based on risk
lighting i.e. flashing assessment.
amber light on top

3. Vehicle Selection and suitability

Ref Subject Item Technical Details of what practical options are

available
3.1 Road vehicles: Suited to site Vehicle can turn in the available space, and access
the loading dock (vehicle deck height is within range
of the dock leveller) NB Curtain sided vehicles may
avoid the need for reversing, but may pose other
H&S risks
Vehicle can be sheeted Client has risk assessed the operation of sheeting
/ strapped without risk and considered proprietary systems to avoid
to the driver. climbing on vehicle and the operation can be carried
out safely.
Tail-lift vehicles Adequate means are available to prevent the load
falling from tail lift platform as the tail lift is being
operated (e.g. edge protection, brakes on wheeled
trolleys etc.) Tail lifts should be built to BS/EN 1756
Parts 1 and 2. Guidance is available in “Tail Lifts:
Specification Guide”, Institute of Road Traffic
Engineers Copy available in HSE area libraries or
from Society of Engineers, London. (Tel 020 7630
1111)
Reversing Where RA has considered vehicle movements and
where reversing cannot be eliminated vehicle
should be fitted with visibility aids to suit. Can
include CCTV, mirrors and other sensing systems.
See OC 803/70 or LAC 85/10 “CCTV on Road going
vehicles”.
If necessary, seek technical advice from a suitably
qualified Mechanical engineer e.g. in the HSE
Specialist Group or via the Enforcement Liaison
Officer (ELO).
3.2 Site vehicles e.g. Suited to terrain Vehicle has been selected to suit ground conditions
FLTs (small diameter wheels not suited to rough ground).

Suited to slopes Vehicle suitable to travel up and down any slopes

on site (hand brake will hold, forwards or
backwards, on any slope that the vehicle travels
up/down). NB Not good practice to park on slopes,
but vehicle must be able to be parked if necessary
(e.g. running out of fuel)
 Load handling Vehicle is suited to handle the type of load. RA has
considered available special purpose fixtures (e.g.
barrel clamps, squeeze plates) to minimise manual
handling and risk of shedding load.
Any fixtures used are easily interchangeable when
required to minimise chance of operators taking
short cuts.
Speed Vehicle speed is appropriate to site conditions
(Some trucks have programmable maximum speed
settings).
Operator involvement Operators are involved in selection of equipment.
Parking FLTs should be safely parked with the handbrake
applied, on the level with the load lowered
3.3 Visibility Direct visibility Good direct visibility (bearing in mind type of load
carried).
Carrying excessive loads which limit visibility should
be avoided. Consideration should be given to
carrying less, e.g. 1 pallet instead of 2.
Where large loads prevent good forward vision
driving the FLT in reverse is acceptable for short
distance/infrequent journeys. For long
distance/frequent trips consideration should be
given to using an alternative vehicle e.g. reach truck
or side loader; or using an attachment e.g. for
carrying roof trusses.
Indirect visibility Mirrors / CCTV /Radar etc fitted where direct
visibility not possible

Access for cleaning Windows and mirrors can be cleaned without the
need for acrobatics.
Wipers / lights Wipers / lights fitted where necessary for external
work
Reversing alarms / Elimination of reversing is the aim e.g. through site
beacons layout and vehicle selection. NB Reversing alarms
and beacons are low in hierarchy of control
measures as they do not allow the driver to detect
the pedestrian. It can become confusing for people
if there are many alarms sounding on a site. May be
suitable as an additional warning for areas where
MOP’s are present. May conflict with environmental
(noise) issues. Where alarms are fitted they should
be maintained,

4. Vehicle Maintenance

Ref Subject Item Technical Details of what practical options are available

4.1 General condition Impact damage General scuffing on some vehicles, e.g. FLT counterbalance
weight is normal. Impact damage, damage to lights, cab
structure may suggest inappropriate selection, misuse or lack
of competence. Significant impact damage to FOPS or ROPS
should require examination by service engineer or competent
person (if LOLER applies) to determine if vehicle safe to
continue in use. (See remarks below on damage / incident
reporting).

4.2 Functional Vehicle is functional – Brakes – service and parking, wipers, horn, lights, steering,
ask operator to access interlocks if applicable e.g. travel seat switch, parking
demonstrate, but only if brakes, transmission interlock, hydraulic controls interlock
safe to do so. If in across access/egress, load moment indicator and/or limiter.
 doubt ask for support
from suitably qualified
mechanical engineer
e.g. HSE Specialist
Group or via ELO.
4.3 Damage / accident Damage / accidents are reported promptly and the vehicle
reporting inspected by a competent person for non-obvious damage.
Control systems exist which isolate the truck after a collision,
and which require a service technician to reset before the
truck can be re-used. Ensures truck is safe to continue in use,
and avoids night shift being blamed for all damage!

4.4 Maintenance Daily checks Daily checks carried out by operator (e.g. fuel, oil, water,
hydraulic fluid levels; tyres, lights, horn; check for oil leaks and
obvious damage). Checklist audited by supervision and
retained for limited period

Defect reporting System exists for reporting any defects and client can
demonstrate appropriate action on any given defect.

Planned maintenance A planned maintenance schedule exists for each vehicle and
maintenance is carried out to the schedule by a competent
service technician. Planned maintenance is recorded and any
non-critical defects are noted, and appropriate action taken.

Breakdown A system exists for reporting breakdowns and obtaining

maintenance repairs, and breakdown maintenance is recorded. Records of
breakdown maintenance available for inspection.

Emergency In the event of a breakdown on a key vehicle, alternative

arrangements arrangements are in place to enable material to be obtained
from storage and vehicles loaded and unloaded without any
increased risk.

4.5 Thorough LOLER Lifting equipment such as FLTs, tail lifts and HIABs are
examination inspected at appropriate intervals by a competent person.
Records are available for inspection
4.6 Information for Rating plate or load Information provided to enable operator to operate within
USE charts stability limits. Typically information associated with lifting
equipment will either have a rating plate or load charts.
Operator Instruction Manufacturers information available, if required. Handy
handbook/manual reference for operation (dos and don’ts) and maintenance
information
Site Rules Specific to the particular vehicle and its operation e.g.
regarding use of attachments, speed limits, additional
segregation – where different to general rules

Setting Information e.g. for visibility aids, load moment limiters, tyre pressures etc

4.7 Key System exists to prevent unauthorised persons driving

Control/Authorisation vehicles

7. Driver competence

Ref Subject Item Technical Details of what practical options are available

7.1 Driver selection: Selecting drivers for System in place for selecting drivers: ability to do job in a
initial training responsible manner, potential to become competent operators
and physical and mental ability for the task. Physical ability to
 drive must be done on an individual basis. More detail on
medical fitness to drive in HSG 6, pages 43-47 and L117
ACoP, page 5.
DVLA website “At a Glance” guide gives good benchmark
advice.
Recruiting experienced System for assessing competence and fitness – does driving
drivers performance match any Certificates previously obtained by the
driver? Does the evidence show they are competent to drive
the FLTs and attachments in use in the new workplace or will
additional training be needed? Attitude to the job.
7.2 Driver training Fork trucks Training in accordance with ACoP. Should have the following
components:
• Basic training and test – generic
• Specific job training – tailored to specific site and
equipment
• Familiarisation training – specific to the task, on
the job and under close supervision.
Other vehicles Similar principle should be applies to other types of workplace
transport vehicle:
Large goods vehicles: HGV test, but may need additional
training to deal with use of reversing aids etc., safe practice for
coupling/un coupling.
May need refresher training to deal with changes in
technology.
Needs knowledge of site rules – including deliveries.
Shunters & tugs: Suitable training instructions should be
provided by the employer, but there are no nationally agreed
training courses at present. However, the HGV licence is a
good benchmark.
Stand on pallet trucks: ACoP suggests similar to fork trucks
used for stacking. Needs more then an hours familiarisation as
these vehicles are involved in many “Struck by” accidents.

7.3 Driver Drivers authorised in Record of training should be kept by the employer. Drivers
authorisation writing should be authorised in writing after assessing competence to
drive specific vehicle types.

Key control system See safe vehicle guidance. Electronic key pad systems such
as Infolok may be helpful in preventing unauthorised access to
FLTs.
7.4 Safe driving Systems for monitoring Simple site rules can be an effective tool for driver
practices followed driving practice in the management. – need to consider a range of situations e.g.,
workplace visiting drivers who do not speak English as a first language,
children in cabs, unsuitable PPE.
Rules need to be actively monitored:
Are people following the rules – if not why not? Are the rules
unworkable? Is more training needed.
Appoint people to do the monitoring – Training is available for
those who supervise fork truck operations – show what the
key aspects of safe operations are and how to observe and
how to challenge bad practices.
Workload and job Both these can influence driver behaviour e.g. “job and finish”,
design tight deadlines.
Fatigue may be a factor – effects of time ”on shift”, “time of
shift”, shift patterns and shift handovers. Technical help on
human factors can be sourced via Specialist Group or
Enforcement Liaison Officer.
 ANNEX A
SUPPLEMENTARY INFORMATION: ROAD MARKINGS AND SIGNS (AS HIGHWAY CODE).

Road markings and signs Signs Warning Signs –triangular, black lettering on white background with red border.
Height of triangle minimum 600mm for 30 MPH.
E.g. Height or Weight restriction, sign on pipe bridges, gantries, catenaries, foot
and vehicle bridges, overhead service ducts etc and other obstructions in vehicle
routes, e.g. if less than 5m (16 foot 6 inches) clearance.

Use Mandatory or Regulatory Signs (TSR & GD) 2002

E.g. Max speed limit sign, Diagram 670. Black number (not “MPH” lettering) on
white background with a red border. Diameter usually 600mm (varies between
300mm-1500mm depending on location and use) for 30MPH.

The law requires Traffic Signs Regulations and General Directions signs to be
used where there is a hazard

Examples of other regulating signs: -

Sign Type Diagram Diameter

No in
TSR&GD
Width Limit 629 600
629A 750
Length limit 629.1 600mm

Pedestrians 625.1 600mm

prohibited
No 622.4, 600mm
articulated
vehicles
Height limit 629.2, 600mm
prohibition
Note: usual size is 600mm diameter in 30 mph limit.