Increasing concern is being expressed over work-related road risks. UNISON, for example, claim that more of their members are killed as a result of driving as part of their job than due to any other type of work-related accident.
Nationally, over 3,000 people are killed annually on British roads and the Health and Safety Executive estimate that 30% of these deaths are likely to occur while a driver is working. If this estimate is correct, then presently 1000 work-related deaths are being hidden from annual statistics related to work accidents. In addition, 40,000 people are seriously injured in road accidents.
The European Agency for Safety and Health at Work identify that, in the European Union alone, 800 lorry drivers are killed each year in road traffic accidents.
In response to this growing concern, the DETR, as it was then, established a Work-Related Road Safety Task Group which produced a discussion document aimed at preventing at-work road traffic incidents. According to Richard Dykes, Group Managing Director of Mail Services at The Post Office, who headed the Task Group: "Each day of the year in Great Britain, 10 people on average die and over a hundred are badly injured in road traffic accidents. Many victims are at work, either drivers or passengers or those working by or on the road. Many accidents could have been avoided by a more diligent approach to managing risk or by better training to drive with greater care".
The question of work-related road risk and its management needs to be considered from within the much wider context of the Government's Road Safety Strategy Tomorrow's Roads: safer for everyone which sets out to achieve, by 2010, the following targets:
· A 40% reduction in the number of people killed or seriously injured in road accidents.
· A 50% reduction in the number of children killed or seriously injured.
· A 10% reduction in the slight casualty rate.
An important strand of this strategy being to reduce road traffic incidents that are connected to work. The discussion document identifies that: "Many vehicles are driven for work purposes, for example lorries, vans, taxis, coaches, buses, emergency service and utility vehicles, company cars, construction and agricultural machinery, motorcycles, mopeds and bicycles. And many people work on or by the road, for example maintenance workers, refuse collectors, postal workers, vehicle breakdown employees, the police and so on. All these workers are exposed to risks from traffic".
One of the main findings of the Task Group was the need for employers to manage at-work road risk from within the framework that they should already have in place for managing all other occupational health and safety risks. It being held that safer driving for work purposes should result in fewer fatalities and injury, lower costs to employers and wider advantages to society as driving standards improve.
In this series of four articles we shall examine how work-related road risk can be included within an organisation's general risk assessment procedure, at control measures, including defensive and advanced driving training and checks on vehicle roadworthiness, that can be introduced following assessment of work-related road risks and at how the issue can best be incorporated within an organisation's health and safety management system. For the rest of this article, we shall consider the reasons why organisations need to urgently deal with work-related road risks.
A survey undertaken in four police force areas indicates that 30% of all serious or fatal road incidents investigated involved at least one person at-work.
The RAC estimate that there are 2,993,000 company fleet cars in Britain across 719,920 companies. According to National Travel Survey, 16% of car miles driven are at-work. Company cars average 10,580 at-work miles per year per car and self-employed business cars 7,250 at-work miles per year. Approximately 50% of the annual mileage of company cars and self-employed owned cars is at-work. Additionally, Road Accidents Great Britain estimate that commercial vehicles, such as LGV, HGV, buses and coaches, account for 17.3% of the total annual mileage of all motor vehicles. Therefore, taken together, vehicles at-work account for 30% of all miles driven on British roads.
Coroners coding of the deceased in fatal traffic accidents reveals that, on average, 123 people per year die in traffic accidents while at work, 4% of the total of traffic fatalities. These can be classified as follows:
· 40% in heavy goods and smaller commercial vehicles.
· 13% on foot.
· 10% in cars.
· 7% on motorcycles.
· 6% involving passenger-carrying vehicles such as taxis.
· The remaining 24% comprising farm, police, maintenance, recovery and other unspecified vehicles.
However, it is much more difficult to establish whether other vehicles involved in fatal incidents are at-work. What can be established is that 716 fatalities per year, 23% of all traffic fatalities, involve one or more commercial vehicle at-work, for example: heavy goods and smaller commercial vehicles, buses, coaches, taxis and other vehicles used solely for work purposes. As this 23% relates purely to commercial vehicles, it is a significant understatement of the at-work total as cars are only represented in the statistics if their occupant died at-work.
Finally, data provided by fleet risk management specialists indicates an average 0.65 claim rate per vehicle per year across a mix of all vehicle types. However, for delivery fleets, the claim rate per vehicle can rise to 1.2 per year. These figures are themselves an understatement as claims that fall below the excess of the policy will not be reported. Even so, risk management companies claim to be able to achieve a 70% reduction in claims through driver assessment, training, monitoring and changes to company culture. Data held by fleet vehicle insurance companies suggests that there are approximately 12.000 serious incidents involving fleet cars at-work and 3,000 serious incidents involving commercial vehicles every year.
Given the major involvement of at-work vehicles and personnel in road accidents, work-related road risks need to be given high priority in an organisation's risk assessment and risk management systems. Particularly as, according to The Police Foundation's Fleetcraft publication, traffic collisions in general account for:
· Almost half of all accidental deaths in Britain.
· Nearly a quarter of all adult deaths under 30, whether accidental or not.
· The largest single cause of death and injury for young adults.
Yet, according to UNISON's publication Safer driving at work, "because road safety is enforced by the police, few employers see it as being a health and safety issue. Their main concern is that the vehicle is taxed, insured, maintained, and the driver has an appropriate licence. It is because of that attitude that the death and injury rate is so high. Driving at work is more dangerous than working in construction, mining or agriculture".
In the remaining articles we shall examine how a positive approach to work-related road risks can be adopted by both employers and employees in order that the present appalling level of human tragedy and suffering can be effectively reduced.
Having looked at the scale of the problem in the previous article, we need now to outline how work-related road-risk can be dealt with from within the perspective of an organisation's general risk assessment procedure.
Although organisations adopt variants, the five step approach outlined by the Health and Safety Executive's publication Five Steps to Risk Assessment (INDG163(rev1)) is fairly common to all systems and is therefore adopted in this article. To recap, the five steps are:
1 Identify the hazards.
2 Identify who might be harmed.
3 Evaluate the risks, assess the present controls and suggest additional controls where necessary.
4 Record the findings.
5 Review the assessment where there is a significant change or reason to believe it may no longer be valid.
In fact, the Government appointed Work-Related Road Safety Task Group makes a similar point in its Discussion Document (DDE16) when it states that, for employers: "The first step is to assess the risks to their employees from the activities carried out at work, by identifying hazards and who might be harmed, and then evaluating the risks and assessing whether existing precautions are adequate".
In the next article we shall consider, where more needs to be done, the principles of prevention that can be applied in relation to Regulations 4 and 5 of the Management of Health and Safety at Work Regulations 1999 (MHSWR). For the remainder of this article we shall concentrate on the risk assessment itself.
According to the UNISON publication Safer Driving at Work, "risk assessments must include risks from driving, if they exist. Risk assessments should look at all the hazards which might be faced by workers on the road. It should also ensure that these hazards are removed or reduced as far as is practical".
Let us therefore examine how work-related road-risk could be incorporated into the five step approach outlined above.
"Hazards" are defined as being "something with the potential to cause harm", this might include:
· The employee who is driving. Their level of competence and state of physical and psychological well-being etc. According to UNISON, fatigue is a factor in over 15% of road traffic accidents. "This is related to the amount of time a person is driving, the lack of breaks and the time of day. Most motoring organisations, therefore, recommend drivers taking a 5 to 30 minute break every 2 hours - ideally this being a break away from the vehicle.
· The time of the day. Night driving being the most hazardous, particularly where an employee is called out for an emergency and drives just after being woken up. Similarly, driving after a long shift at work is hazardous as is driving after a first night-shift.
· The vehicle being used, whether it be a company vehicle or a private vehicle used for company business. Its state of road-worthiness and suitability etc. The Police Federation publication Fleetcraft, for example, suggests that "many drivers will make a selection based on 0-60mph times, top speed, alloy wheels and boot spoilers". However, selection needs to be well researched and aimed at identifying the primary safety features, such as: ABS brakes, traction control, electronic stability control, high level brake lights etc. Next, the secondary safety features need to be considered. These include: airbags, seatbelt pretensioners, side impact beams, head restraints and crumple zones. The primary features relate to the prevention of an accident, whereas the secondary features provide protection should an accident occur. Therefore, a direct relationship exists between them and the requirements under Regulation 5 of the MHSWR to make arrangements for protective and preventive measures.
· The road. Whether it is known to be a black-spot or whether it is subject to road works etc.
· People working on or near the road and pedestrians. Highway and motorway workers, hedge and tree trimmers should be considered along with whether the route is located near to busy pedestrian areas etc.
· Other drivers. Road rage, tiredness and their general lack of competence etc.
Careful consideration should therefore be given to the routes being travelled and the foreseeable hazards that may be faced by employees whilst driving. Reactive monitoring, such as checking insurance claims, incident and accident records and vehicle repair records, may provide useful hazard identification information. However, this should be fleshed out with information gather through proactive monitoring such as staff questionnaires, surveys and discussions. Finally, motor manufacturers subject their vehicles to standard crash tests under the New Car Assessment Programme, this results in every new vehicle being awarded a rating from 1 to 5, the higher the rating the better the protection provided to occupants in a collision. Such data needs to be obtained and utilised.
Employers need to consider employees and others, these might include: company drivers, other drivers, passengers in either the vehicle being driven or other cars and other people near or on the road. Again, reactive monitoring of accident and incident records and of insurance claims may prove helpful.
Detailed consideration of control measures will be discussed in the next article, therefore this section focuses upon the evaluation of risk. Such evaluation can adopt the form of qualitative, semi-quantitative and quantitative methodologies.
This form of evaluation relies purely upon the subjective assessment of the assessor involved. Therefore, it is important that the assessor is competent to make such a judgement. Discussions with members of staff who are regularly exposed to work-related road-risk being essential.
This form of evaluation provides scoring schemes, often for likelihood and severity, and guide-words in order to assist and support the assessor in reaching a judgement. However, ultimately, the judgement is still primarily a subjective one.
Quantitative
This form of evaluation is supposedly objective as it is based upon historical data and removes the subjective element from the assessor's role. However, an organisation would need significant data relating to past accidents and incidents involving work-related road-risk in order to operate such an evaluation system. The approach has also been criticised for merely moving back the subjective component to the system design and data selection and gathering stages. In many ways the approach attempts to gain objectivity by becoming reactive as it evaluates risk in reaction to past events, whereas the subjective elements in the other two approaches adds a proactive, anticipatory element.
Strictly, the law only requires the significant findings to be recorded where 5 or more are employed. However, smaller organisations will find the recording of findings valuable when identifying trends, measuring improvements and defending civil and criminal actions. Organisations can develop their own formats for the purpose, although the following basic approach may prove useful as a starting point:
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Strictly the law requires risk assessments to be reviewed either when there is a significant change, the use of new vehicles or drivers for example or the introduction of new legislation or guidance on the subject of the assessment, or where there is reason to believe the assessment is no longer valid, following an accident or near miss for example. However, most organisations also set automatic review dates for assessments as part of their safety management programme.
Having looked at the approach that can be adopted to integrate work-related road-risk into the organisation's general risk assessment procedure, the next article will focus upon measures that can be introduced to reduce such risks to acceptable levels.
Having looked at the scale of the road-risk problem and how to carry out a road-risk assessment in previous articles, we need now to outline how work-related road-risk can be dealt with from within the legal framework provided under Regulations 4 and 5 of the Management of Health and Safety at Work Regulations 1999.
Advanced driver training is one of the important control measures that need to be considered, advanced drivers having up to 75% less accidents than other drivers. Unfortunately, at present, only 12% of drivers have received such training. However, training is a protective measure in the context of Regulation 4 as the driver is still exposed to road-risk and the training merely serves to protect them against it. Where possible, preventive measures should be adopted to prevent exposure to road-risk in order to combat risk at source as advocated by Regulation 4. Such preventive measures could include: restricting the number of employees using road vehicles on company business, restricting hours spent travelling on the roads and journey planning to avoid known dangerous routes etc.
A useful pneumonic that can be adopted when considering possible control measures is MEEP which stands for:
· Materials. The loads being carried and the hazards they create and how these can be eliminated or the risks reduced to an acceptable level.
· Equipment. The type of vehicle being used and its suitability for the load being carried and the distance being travelled etc. How more suitable vehicles can be provided. The inspection, testing and maintenance requirements of the vehicle and how they can be met. Procedures covering the safe use of mobile phones, mobile office equipment and navigational aids may also need to be developed and implemented.
· Environment. The roads being used, the built-up areas being passed through and the roadworks being undertaken on the route etc. Use of safer alternative routes, even if slightly longer, being seriously considered.
· People. The driver's attitude and self-awareness, level of training and physical and mental health needs to be evaluated and, where necessary, improved. Restrictions and prohibitions may need to be placed on drivers in certain circumstances. Links may also need to be made to requirements in the company's alcohol and drugs misuse policy, for example approximately 85,000 people are convicted of drink driving offences in Britain each year. Tachographs may need to be fitted to certain vehicles to monitor driving hours and procedures introduced to deal with driver fatigue. Training may also be required concerning how to deal with driving conflict ("road rage").
Road safety is considered a priory under the European Union's transport policy. Although it is recognised that it is a shared responsibility between public authorities, enterprises and the general public, it is also stressed that enterprises and employees in the transport sector need to take a leading role. Employers in the transport sector are therefore encourage to include the following in their preventive plan:
· The appointment of a company safety officer.
· Staff consultation and the development of an internal communication system providing a channel for staff to put forward comments and suggestions.
· Specific training for staff, especially drivers.
· The introduction of arrangements to ensure that account is taken of the road safety performance of individual personnel.
· The introduction of arrangements to ensure effective maintenance of lorries and equipment.
· The introduction of arrangements to ensure working practices are aligned with road traffic legislation and highway codes, including requirements relating to tachographs and driving times.
Employers need to promote positive attitudes in all drivers, whether using their own vehicles or company vehicles on company business. Although this can be partly achieved through training, it has to be reinforced by a positive corporate culture. All those sharing the road network should:
· Anticipate possible risk situations and be able to react appropriately.
· Be able to react appropriately in hazard situations or when accidents actually occur.
· Adopt a non aggressive, cautious style of driving and treat other road users with courtesy, respect and consideration, even when the other road users are at fault.
The European Agency for Safety and Health at Work suggests, in its Facts 18 publication, that a drivers' good practice checklist be adopted. This should stress that drivers:
· Follow their organisation's safety instructions.
· Use seat belts at all times. Drive within the speed limit and reduce speed where required by weather conditions.
· Do not continue driving if tired. Take regular breaks away from the vehicle. Do not use stimulants to overcome tiredness.
· Always comply with local traffic conditions and following requirements relating to driving time.
· Adjust their seating position to be as upright as possible and use the head restraint.
· Be familiar with the maintenance procedure for their vehicle and ensure that it is kept in good running order.
· Do not drive under the influence of alcohol or drugs, including medicines which may affect their driving.
· Be aware that smoking can lead to drowsiness when driving due to carbon dioxide displacing the oxygen in the vehicle and increasing carbon monoxide in the blood.
· Make sure any load is evenly distributed and properly secured and that no loose objects can fly about inside their vehicle, particularly when braking.
· Ensure vision is not obstructed by pendants or stickers etc on windows.
· Avoid parking vehicles where they may obstruct traffic or the visibility of other drivers or pedestrians and ensure measures to prevent the vehicle moving are applied.
· Eat regular, healthy meals.
It is far better, and in line with the approach advocated by Regulation 4, to adopt a coherent company-wide strategy for dealing with road-risk rather than introducing control measures on an ad-hoc basis when problems arise. According to the UNISON publication Safer Driving at Work, such a strategy should include the following as a minimum:
· Hours of work. Fatigue is known to be a factor in over 15% of all fatal road accidents. Motoring organisations recommend a 15 to 30 minute break away from the vehicle every 2 hours. Driving after long shifts or when sleep patterns are disturbed due to being called out at night should be avoided.
· Training. Advanced driver training and specific training for driving minibuses, four-wheel vehicles and for off-road driving should be considered.
· Carrying equipment. Consideration needs to be given to its packaging, securing and labelling, where appropriate. Manual handling operations need also to be taken into account.
· Carrying people. The suitability of vehicles and the insurance arrangements need to be considered, along with the possibility of violence or damage.
· Mobile phones. At least 16 people have been killed in Britain as a result of accidents when the driver was using a mobile phone. The Highway Code prohibits the use of a hand-held mobile phone when driving and warns that even hand-free system are likely to distract attention from the road. Procedures should be introduced to ensure drivers utilise voicemail functions when driving and that they stop and check messages regularly.
· Condition of vehicles. Employers need to introduce procedures to ensure all vehicles used for work purposes, irrespective of ownership, are suitable and properly maintained and inspected. The type of vehicle should also be suitable for the purpose for which it is used and fitted with safety features such as airbags, central locking systems and emergency equipment including fire extinguishers, reflective jackets, warning triangles and ice scrapers. As driving is a major contributor to back pain, the seat needs to be adjustable for comfort and legroom etc.
· Breakdown arrangements. Employers should ensure that drivers are covered by an efficient national breakdown service and that drivers are fully instructed and trained in the procedure to follow.
The most effective way of dealing with these issues is through their incorporation into a safe driving policy. In the final article we will consider how to deal with road-risk from within the framework of the company's safety management system of which such a policy forms an essential element.
Having looked at the scale of the problems associated with road-risk and outlined risk assessment and risk control approaches that can be utilised to deal with road-risk in earlier articles, this final article outlines how the issue can be dealt with from within the organisation's overall health and safety management system.
Regulation 5 of the Management of Health and Safety at Work Regulations 1999 requires employers to make and give effect to appropriate arrangements, having regard to the nature of activities and size of the undertaking, for the effective planning, organisation, control, monitoring and review of the preventive and protective measures. Where five or more employees are employed, the arrangements need to be recorded.
The Health and Safety Executive's publication Successful Health and Safety Management (HSG65) offers a means of complying with the requirements of regulation 5, although the terms used vary slightly. Basically, the HSG65 model adopts the following approach:
· Prepare a policy.
· Organise around the policy.
· Plan and implement the necessary measures.
· Measure performance through both active and reactive monitoring.
· Review performance and audit.
The rest of this article considers how road-risk can be integrated within the HSG65 approach.
According to HSG65, policies demonstrate the general intentions, approach and objectives of organisations and the criteria and principles upon which they base their action. Put simply, the control of road-risk policy should display the vision of the organisation towards the elimination or minimisation of road-risk. To be effective, this vision will need to consider organisational factors, job factors and personal factors related to road-risk.
Although the control of road-risk policy will be specifically focussed on this issue, it will also need to be integrated with the general health and safety policy and with other relevant specific policies - such as the control of alcohol and drug abuse policy, in Britain 85,000 people are annually convicted of drink-driving offences.
According to the publication Preventing at-work road traffic incidents, produced as a discussion document for the then DETR by the Work-Related Road Safety Task Group, the control of road-risk policy should:
· Stress the importance of the need for the policy for the organisation.
· Indicate how road-risk assessments are to be conducted.
· Outline the action to be taken when an incident occurs.
· Align the policy to the general policy and other relevant specific policies.
· Align the policy to road traffic legislation and the Highway Code, including requirements relating to tachographs and drivers' hours.
· Clearly identify the roles and responsibilities of directors, managers, supervisors, drivers and those working on or by the road to ensure the policy commitment is translated into practical action.
· Set objectives and introduce performance standards for the organisation and for individuals within the organisation.
· Stress the importance of senior managers and managers setting positive examples.
· Allocate necessary resources.
Whereas the policy sets the direction the organisation is taking with regard to the control of road-risk, it is necessary to organise around the policy in order to create a robust framework for management activity and to detail the responsibilities and relationships which are required to deliver improved performance. In order to be able to organise effectively it is necessary for a positive safety culture to be in place. Positive cultures being nurtured through effective methods of managerial control, effective co-operation and consultation between all members of staff, effective and transparent two-way communication systems being in place and through ensuring employees are competent to deal with the tasks and responsibilities entrusted to them.
Those given specific responsibilities relating to the control of road-risk need to be held accountable and this may be achieved through the use of existing systems. For example:
· Job descriptions containing reference to the control of road-risk roles and responsibilities.
· Performance review and appraisal systems measuring and rewarding performance in relation to the control of road-risk.
· Procedures identifying and acting upon failures by members of staff in relation to the control of road-risk which are integrated into normal disciplinary arrangements.
It is important when introducing the above measures, and allocating roles and responsibilities to members of staff, that consultation with staff and that agreement with staff is reached. Otherwise a negative "blame" culture will start to emerge.
According to HSG65 effective planning is concerned with prevention through identifying, eliminating and controlling hazards and risks. With regard to road-risk, the specific detail of each of these aspects has been covered in earlier articles. Although the discussion document suggests that the planning should specifically cover:
· Finding out if you have a problem by looking at insurance claims, sickness levels etc.
· Involving staff and gaining their commitment through involvement, information, consultation and instruction.
· Preventing incidents through: the avoidance of unnecessary road journeys; the planning and organisation of road journeys in terms of the length of the journey, the route taken and the time of the day etc; introduce regimes relating to driving and rest periods and drivers hours; introducing fatigue management systems and dealing with issues surrounding working on or by roads.
· Introducing drivers' licence checks and fitness to drive checks before employment and routinely during employment.
· Ensuring employees are given sufficient instruction, information and training to work safely.
· Provision of refresher training and driver improvement training.
· Dealing with competence issues surrounding working on or by roads.
· Ensuring vehicles are suitable, ergonomically sound and fitted with necessary safety features.
· Ensuring vehicles are properly maintained.
· Provision of safe systems of work for reversing and other hazardous manoeuvres.
· Provisions of systems for dealing with breakdowns and emergencies.
· Ensuring loads are safely secured and safe means of loading and unloading are in place.
· Ensuring safe manual handling of loads and the safe carriage and tipping of loads.
· Provision of safe systems governing the use of mobile phones.
· Provision of safe systems of work for working on or by roads.
More generally the approach can be summarised as:
· Set SMART (specific, measurable, agreed, realistic, suitable timescale) objectives.
· Devise precautions using the following 3 steps approach:
· Hazard identification.
· Risk assessment.
· Risk control.
· Set performance standards and priorities.
Once the above measures have been planned they will then need to be implemented.
Procedures need to be put into place to measure how well the systems and precautions that have been implemented succeed in meeting policy objectives and performance standards. This is best achieved by an integrated system of active and reactive monitoring. Active monitoring often involves inspections of people, places, documents and records against accepted standards, whereas reactive monitoring involves investigation of near misses and accidents etc. From both sets of data a fuller picture of trends with regard to the control of road-risk will begin to emerge.
As pointed out in HSG65, monitoring also reinforces management's commitment towards the control of road-risk and, in general, helps to nurture a positive safety culture.
The trends identified by active and reactive monitoring will be helpful in reviewing the organisation's performance in regard to the control of road-risk against the objectives set in the policy. Even when the policy objectives have been met, however, continuous improvement should then dictate that new, more challenging, objectives are then set. Organisations can also benchmark their performance against other organisations by comparing:
· Road-risk accident rates with other organisations in the same industry.
· Management practices and techniques for the control of road-risk with other organisations in any industry.
HSG65 defines "auditing" to mean "the structured process of collecting independent information on the efficiency, effectiveness and reliability of the total health and safety management system and drawing up plans for corrective action". Where auditing already applies to the whole health and safety management system then it needs to be extended to cover the new sub-system relating to the control of road-risk.
The aims of auditing being to:
· Establish that appropriate management arrangements are in place to deal effectively with road-risk.
· Establish that adequate risk control systems exist, are implemented and are consistent with the hazard profile of the organisation in relation to road-risk.
· Establish that appropriate precautions are in place with regard to the control of road-risk.