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DDE 16 - Summary of responses to the Discussion Document on Preventing at-work road traffic incidents


1. The Work-related Road Safety Task Group's Discussion Document on Preventing at-work road traffic incidents was published on 1 March. The Discussion Document was central to the Task Group's ambitions to seek views from as wide an audience as possible on measures to be taken to reduce at-work road traffic incidents. The consultation period ended on 25 May 2001.


2. One thousand copies of the Discussion Document were issued directly to organisations identified as having an interest in at-work road safety. These included employers' associations, federations and other representative bodies, road safety groups, trades unions, central Government departments, local authorities, a number of large firms and organisations devoted to raising standards of health and safety. A further 2000 copies were ordered from HSE Books. In addition, about 150 e-mail versions were sent to individuals who had requested copies. The Discussion Document was also available on HSE's website (about 2000 downloads of the document), with links to and from the DETR site. In all, about 5000 copies of the Document were distributed.

The results from consultation

3. A total of 256 responses were received A proforma was included at the end of the document to assist respondents with structuring their replies. Some 219 responses followed this format. A number of respondents chose not to answer all the questions; a few commented only on specific issues, some of which were not raised in the document, for example on road design. In the event, the Discussion Document attracted responses form a wide range of organisations:

Type of organisation

Number of respondents

As a percentage (%)
Company 70 27
Local Authority 39 12
Voluntary Body 19 7
Public organisation 25 10
Employer organisation 37 14
TU/employee organisation 12 5
H&S consultant/advisor 17 7
Private individual 30 12
Other/not known 7 3

Overall reaction

4. There was widespread support for the Task Group's work in raising the issue of seeking to improve road safety. The Discussion Document itself was warmly welcomed by most. Of those who responded to question 10 (186 respondents, 73% of the total), about how the Document represented the different policy issues involved in at-work road safety, the breakdown was:

Response Number As a percentage (%)
Very Well 59 32
Well 117 62
Not well 7 4
Poorly 3 2

Taking action to reduce the incidence of at-work road traffic incidents

5. While recognising that more knowledge was needed to improve understanding especially in relation to incident causation, Question 1 asked respondents whether action needed to be taken to reduce the number of at-work road traffic incidents and if so, what should be done.

6. Although some were highly guarded in their comments, no respondent said that no action should be taken even if it was only further research. Many said that, given the evidence, there was a prima facie case for action immediately. The majority felt that employers could indeed do more, for example by introducing policies and procedures or by greater prescription including more enforcement. However, a number of respondents were more sceptical or cautious. Some were not persuaded that HSC/E's role should be extended into the already highly regulated areas of Large Goods Vehicles and Public Carriage Vehicles. Others felt that it was wrong to single out the occupational driver for particular attention. The viewpoint was part fuelled by the available evidence. Many respondents felt that the statistics were insufficiently robust and so inhibited forceful action.

7. Some echoed the point made in the Discussion Document that it was important to get the balance right between the employer and the employee. Employers could no doubt take measures to manage road risk better and perhaps reduce pressures on drivers but measures should be proportionate to risk. Factors leading to road incidents were often beyond the control of the employer.

8. The effect of work pressures and meeting deadlines, leading to drivers exceeding speed limits or driving carelessly, emerged as a theme. A number of responses called for restrictions on driver hours, limits on miles driven per day, or the avoidance of long driving periods including more rest breaks.

9. There was a call for definitions of terminology in the final report to be clear, especially what 'at-work' meant.

Central proposition: applying health and safety management systems to at-work road risk

10. The central proposition of the Task Group was that employers should manage at-work road risk within the framework they should already have in place for managing all other occupational health and safety risks. Question 2 asked respondents whether they felt such systems could reduce at-work road traffic incidents. Of the 227 respondents who answered this question (89% of the total number), all bar 17 agreed that they could (92% in favour). However, it needs to be borne in mine that a fair number of those offering general support included caveats when making practical suggestions on what the systems might comprise.

11. Many respondents cited the risk management approach laid down in the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999 as the best way to proceed, beginning with effective risk assessments and becoming part of an employer's safe system of work.

12. Others, however, were concerned about the potential burden on (small) businesses in carrying out risk assessments. Others called for flexible approach, given the range of vehicles being driven and types of driver at the wheel.

Training and testing

13. Question 3 asked respondents whether they thought there should be specific training and/or testing for occupational drivers/riders. Of the 214 respondents who answered this question (84% of the total), 87% were in favour of some form of training of those driving while at work. There was a wide range of views as to what that training should comprise, its status and scope and when it should be undertaken. Some respondents were split, arguing for training but against testing.

14. Some favoured prescription as they felt that raising levels of driver competence was a key means of reducing road traffic. The majority, however, saw that the trigger should tie in with the employer's risk assessment and be based on the type and nature of the job and the needs of the individual. A blanket approach was generally regarded as neither efficient nor effective.

15. In the company car sector, some saw a need to differentiate between those who drove regularly as part of their job and occasional vehicle users. Some argued for training for drivers involved in specific, higher risk areas such as the emergency services

16. Those who advocated training saw it as essential to maintain training regimes: one-off sessions were not considered adequate Some provided suggestions as to the nature of the training, that it should be connected with familiarisation with the vehicle, to raise awareness of driving methods, handling skills and hazards on the road. Issues such as avoiding fatigue, road rage and other stressors were considered important.

17. Some were concerned not just about driving standards but about health, fitness and ability to drive issues. For example there were calls for regular health monitoring. Several respondents urged that driver credentials be checked much more thoroughly at the pre-employment stage.

18. Those against the idea of additional training and/or testing argued that the driving test itself signalled a satisfactory degree of competence. If employers wished to provide more, that was up to them but there should be no form of compulsion. Training for many drivers was unnecessary; an untargeted approach would be costly.

Implementing change

19. Question 4 of the Discussion Document sought views from people on what they considered the best way to influence employers to take action: whether an HSE Approved Code of Practice was the preferred document to bring about change, guidance under the Highway Code Explained series was preferable, whether HSE generic guidance offered the best solution or whether respondents had other ideas.

20. Two hundred and thirteen respondents answered the question (82% of the total), broken down thus:

Type of document

Number of respondents

As a percentage (%)

HSE ACOP 94 44
Mix of ACOP/guide 17 8
Guide then ACOP 13 6
HSE guide only 56 26
Guide under Highway Code 10 5
Mix 11 5
None 8 4
Not clear 4 2

21. Respondents supporting an ACOP saw it as the only means to get employers to act by setting the yardstick against which performance could be monitored. Where the standards failed to be met, its legal status would be important as support for enforcement action. Others felt that this was too heavy a hand, in particular given the lack of understanding of the scale and nature of the problem. Many called for flexibility, seeking guidance or Approved Code aimed at particular sectors or size of firm; or a mix of guidance and Code within the same document; or guidance first, followed by ACOP; or ACOP but with a reasonable time to implement.

22. As might be expected, there was a split of opinion between employers and their representative groups and the trades unions and health and safety professionals. The majority of employers preferred guidance, if anything, while unions and specialists opted for an ACOP.

Content of the core document

23. The Discussion Document included an annex setting out a suggested content of the ACOP/guidance. Question 5 of the Discussion Document asked respondents whether the content was comprehensive and, if they thought not, to offer suggestions for addition or omissions. Of the 199 respondents who answered (78% of the total), just under two-thirds (130) were content while the other third proposed additional material. Much of this will be very useful when a publication on preventing at-work road traffic incidents is written.

24. Many suggestions were received, prominent among them:

Getting messages over to employers, particularly SMEs

25. In producing a strategy to implement measures arising from the Task Group's work, a key challenge will be to raise awareness of employers to take action, particularly those running small businesses. Question 6 of the Discussion Document sought ideas from respondents about how best to do this.

26. Many respondents felt that the insurance industry could play much more of a role in tying insurance premiums more closely to the success of a company in introducing and adhering to a successful road risk management approach; or discount premiums where employees undergo relevant training. Others felt it was more the role of Government in providing tax/VAT breaks, for example in relation to driver training; or that HSE should give grants and provide training.

27. Some saw the importance of arguing the cost benefit case strongly in order to convince business people to take note. It was important to get the message over that proper road risk management could result in savings. The publication of case studies in this area would help.

28. Sustained public awareness campaigns, using all types of media, were mentioned by a significant number of respondents as a key means of raising employers' awareness, supported by free educational material. Many mentioned that the publication of free, simple guidance was essential, explaining in clear terms the risk assessment process, and being made available on the Internet. Another avenue was through intermediaries such as trade federations and/or trades unions. Some suggested award schemes for effective road risk management or using supply chain pressure to try to ratchet up overall levels of performance with larger organisations giving a lead, sharing best practice.

29. Others preferred a more prescriptive approach - 'occupational drivers to carry special plates like taxis', 'naming and shaming poor performers', 'return to issuing licences every three years', 'fines and prison sentences', 'one stop shop to report bad driving'.


30. The extent to which, and the ability of the State to monitor and enforce any new arrangements to apply health and safety law to on-the-road work activities are key strands to securing improvements. Question 7 of the Document asked for respondents views on what the arrangements might comprise. One hundred and sixty eight responses were received that expressed a clear opinion on this issue (66% of the total).

31. There was general agreement that the initial investigation of a road traffic incident should remain the province of the Police who would call in HSE/LAs where it was suspected that a failure in management systems might have contributed to the incident. HSE/LAs would continue the investigation at the employer's premises.

32. Some suggested that the STATS 19 report form would need to be amended to ensure that the Police asked questions about whether the journey was work-related. There were training issues both for the Police and the health and safety enforcers.

33. Other views were expressed. Some felt that the Police themselves could do more, using powers under the 'aid and abet', 'use, cause and permit' provisions, noting that they had a key role to play in educating drivers and enforcing existing standards; or that the Traffic Commissioners and the Vehicle Inspectorate could play a prominent role. Some supported the extension of the O licensing regime to light goods vehicles, introducing tachographs, while others argued that the Commissioners should do more to take account of an operators' health and safety management system when considering licences.

34. Whatever new arrangements were devised, there would need to be clarity between the parties as to their roles and responsibilities. These would need to be widely advertised and be consistent in practice.

Reporting arrangements

35. Respondents were asked for views on whether employers should be obliged to report at-work road traffic incidents and if so what should be reported and to whom. Of the 207 respondents who gave an opinion (81% of the total), all but a tenth said that they should (although some expressed reservations).

36. The great majority of respondents called for an extension of the RIDDOR reporting requirements to cover at-work road traffic incidents and that reports should be made to the health and safety enforcing authorities. The justification for such an approach lay not just enabling investigation to take place but to send a message to employers that incidents on the road should be dealt with in the same manner as other health and safety failures. Importantly, RIDDOR reports would help to build a better picture of the causes of incidents and means to prevent them.

37. Significant opposition to reporting was expressed, principally by those representing small business. Opponents thought that the increased bureaucracy would be burdensome and that duplication should be avoided. And the enforcing authorities had reservations as hard pressed resources would need to be diverted to deal with what could be a huge caseload.

Further action

38. Finally question 9 asked respondents what additional measures they would like to see in support of efforts to encourage employers to manage at-work road safety. Many mentioned more research, commissioned usually by HSE or DTLR on issues such as incident causation, on personal factors and how employers' action could have helped to avoid incidents, including cost/benefit. Health issues needed to be examined more and include the positive benefits of alternative forms of travel

39. Many also mentioned promoting any new initiative in as extensive a public campaign as possible, drawing together all the key parties in a single endeavour, supported by an array of publications, in different media, targeted at specific audiences. Road safety competitions, roadshows and good driver schemes were seen as a means or raising awareness and encouraging support.

40. Many respondents expressed concern about the resources available to the enforcers to put effective measures in place and follow them up. Adequate Government funding was essential. There were call for a system to enable monitoring and evaluation of any changes arising from the Task Group's work.


41. Comments received on the Discussion Document have been extremely helpful in providing the Task Group with opinions and suggestions about the way forward. The Task Group will seek to ensure that they are reflected in the final report to Government and the Health and Safety Commission. However, it cannot guarantee to please all of the varying viewpoints expressed during the consultative period.

Updated 2009-05-28