Health and Safety Executive/Local Authorities Enforcement Liaison Committee (HELA)

To: Health and Safety Enforcing Authorities

For the attention of : Local Authority Health and Safety Enforcement Managers, Health and Safety Regulators and others

This circular gives advice to local authority enforcement officers

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Guidance on inclined moving walks in retail premises

1. Introduction

1.1 The intention of this document is to provide information with this type of transportation, some recent accidents which have occurred, and issues for consideration.

2. Scope, description and terminology

2.1 This document is intended to cover inclined moving walks in retail premises. It is not intended to cover similar equipment found in mass transit sites such as airports and railways although some of the advice may be relevant.

2.2 A moving walk can be described as a power driven installation for the conveyance of persons in which the user carrying surface remains parallel to its direction of motion and is uninterrupted (e.g. pallets, belt).

2.3 Moving walks are also referred to as travelators, auto-walks and passenger conveyors.

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3. Machine information

3.1 See drawing at Annex 1 which shows principal components and layout of a moving walk.

3.2 The inclination of moving walks should not exceed 12 degrees. Manufacturers of moving walks commonly produce moving walks with set inclinations e.g. 10 deg, 11 deg or 12 deg. Typical inclination found was 10 degrees.

3.3 For moving walks the nominal speed for inclinations greater than 6 degrees should not exceed 0.5 m/s and be fitted with an upper and lower transition curve. Typical speed found for moving walks used in conjunction with shopping trolleys was 0.5 m/s. Top and bottom transition curves for new moving walks seen were 6000 mm and 10000 mm respectively.

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4. Some legal considerations

4.1 An inclined moving walk is considered to be ‘machinery’ [1]. As from 1 January 1997 a responsible person, who is usually the manufacturer, must issue a declaration of conformity for completed products, and affix CE marking. Machinery and safety components must be safe. There is no legal requirement for declarations of conformity to accompany the machine concerned, but they have to be issued. In practice it would be reasonable to expect the owner of the machine to be provided with the declaration of conformity so that it can be made available at the user’s premises. In most cases certificates compliant to BS 5656-1 would have been issued by the manufacturer/installer following the testing and checks as specified.

4.2 Use of inclined moving walks primarily by members of the public in retail premises comes under the Health and Safety at Work etc Act 1974 (HSWA). Where equipment is primarily provided for use by persons not at work, specific regulations such as the Provision and Use of Work Equipment Regulations 1998 (PUWER) should provide a guide to satisfying legal duties under HSWA.

4.2.1 PUWER Reg 5 – Maintenance requires every employer to ensure that work equipment is maintained in an efficient state, in efficient working order and in good repair. Any maintenance logs should be kept up to date. This regulation builds on the HSWA which requires work equipment to be maintained so it is safe. Moving walks and shopping trolleys should be properly maintained.

4.2.2 PUWER Reg 6 Inspection – Inspections are required of moving walks to ensure health and safety conditions are maintained and any deterioration and detected and remedied in good time. Inspection does not normally include checks that form part of maintenance programme although some parts will be common. The risk assessment (see clause 4.5 below) should identify significant risks which could foreseeably result in a major injury or worse. It is recommended that moving walks are periodically inspected by a competent person. This practice is a continuity of recommendation contained in HS GN PM45.

4.2.3 PUWER Reg 10 Conformity with Community requirements – See amendment in Health and Safety (Miscellaneous Amendments) Regulations 2002 SI 2002/2174

4.3 The Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) do not apply to moving walks.

4.4 Persons having control of a workplace have a legal obligation [2]to ensure moving walks shall –

• function safely;
• be equipped with any necessary safety devices;
• be fitted with one or more emergency stop controls which are easily identifiable and readily accessible.

4.5 The Management of Health and Safety at Work Regulations 1999 (MHSWR) provide a framework for employers to follow in complying with relevant statutory provisions. Regulation 3 of MHSWR – Risk assessment requires all employers and self-employed people to assess the risks to workers and any others affected by their work or business. This is relevant for the safe operation of moving walks. Where conditions are unsatisfactory or likely to be unsatisfactory (e.g. new or planned activity) the employer’s assessment should be questioned.

4.6 The employer is responsible for carrying out a risk assessment for the safe operation of moving walks. In practice, some parts of the risk assessment might be generic but other assessments may need to be undertaken at locations for aspects are not covered by the generic assessment. Significant hazards should be recorded.

4.7 The risk assessment should include consideration of various hazards. The following hazards are not exhaustive.

4.7.1 Slip, trip and fall of persons – Eliminate or reduce the risk of contamination of the pallet treads (e.g. water, spillage from containers etc) which is likely to increase the risk of users slipping. This is particularly important if the moving walk(s) are sited partially outside or close to the entrance doors of retail premises. Further risk reduction can be achieved by the provision of automatic audible announcements to users warning users of their approach to the exit of the moving walk. Although there is some evidence that high ambient noise levels such as those found in some retail premises may mitigate the effect of such measures. Other measures which can be considered are provision of visual warnings when approaching entry exit points. Regular checks should be made to ensure articles like shopping baskets have not been left on or adjacent to the moving walk(s) which are tripping hazards

4.7.2 Environment – siting of the moving walk(s) adjacent to the entrances can increase the likelihood of contamination of the pallet treads which can adversely affect the slipperiness of the pallet treads.

4.7.3 Inadequate local lighting – to ensure levels of lighting are sufficient for users during normal use and in the event of power failure.

4.7.4 Inadequate design, location or identification of manual controls – to ensure that trained persons operate the run, direction and key controls.

4.7.5 Inadequate design, location or identification of control devices – in cases of emergency to ensure that the site position(s) of emergency stop controls are visible and accessible to persons using the moving walk and also persons in the vicinity of the moving walk. It is recognised that emergency stops can be subject to nuisance usage which can have the consequence of increasing risk which will need to be managed by the persons responsible for safe operation of the moving walks. It is unacceptable not to provide one or more emergency stops which are visible and readily accessible. See clause 4.14.7 below.

4.7.6 Lack or inadequacy of visual or audible warning means – adequate provision should be made of clear signage giving clear information and instructions to users which stand out from the formats used by the business concerned and product promotions. See BS5656-2 Annex C. Size and colours of lettering is an important consideration.

4.7.7 Inclined moving walks are difficult for some ambulant disabled persons. They can’t be used by persons in wheelchairs, those with assistance dogs etc. (Inclusive mobility guidance (DfT 2005) states the maximum gradient of a moving walk should be 5% (1 in 20 or 2.8 degrees). However, a limiting factor of this recommendation is likely to be the stability of particular wheelchair designs as well as the capability of wheelchair passengers to propel themselves up the ramp in the event of a power failure.) An essential feature of a moving walk is simultaneous installation of an alternative provision of vertical access (e.g. passenger lift) for those persons who wish to take such an alternative or who cannot use the moving walk. It is important this provision is very clearly and effectively signed at all pedestrian routes.

4.7.8 Human error, human behaviour – it is reasonably foreseeable to expect certain persons to make mistakes or behave irresponsibly whilst using a moving walk. It may be considered impracticable to supervise use of moving walks on a continuous basis but appropriate control measures should be in place. It is unacceptable to have no arrangements for supervision at all. For example, current anecdotal evidence has shown there is a greater risk of human error and accidents occurring following entry into service for the first time of a moving walk. During this initial phase of introduction into service there should be sufficient supervision of users by trained members of staff. At all times, it is for the employer to prescribe levels of supervision or monitoring according to the risk assessment undertaken but as a minimum particular employees should be identified and trained to monitor use of the moving walk and empowered to take appropriate action when necessary.

4.7.9 Unexpected start up or restoration of power supply after an interruption - important to ensure local procedures are in place to ensure no persons are on the moving walk during start up of the moving walk.

4.7.10 Failure of the power supply or operation of the emergency stop – important to ensure local procedures are in place to identify why the moving walk stopped and take appropriate action.

4.7.11 Fall of persons during access to or from the moving walk - important to ensure local procedures are in place to respond to such a situation. Consideration should be given to monitoring by CCTV security cameras.

4.7.12 Hazards linked to use positions – advice should be given to persons on the moving walk(s) to ‘maintain a safe distance between those persons in front of them’ to reduce the risk of collision in the event of a person having a problem removing the shopping trolley from the moving walk.

4.7.13 Failure of moving walk(s) and/or shopping trolleys to operate correctly – systems should be place to keep equipment properly maintained and in good working order. This is likely to include planned maintenance and regular inspections.

4.7.14 Unsecured/excessive loads – There should be adequate provision by the employer for loads being carried on manual handling devices such as trolleys and platforms to ensure they are capable of safely transporting, without risk to other passengers. Local procedures should be in place for the employer to provide an alternative to a moving walk where the load(s) are in excess of the manufacturer’s recommendations or where they pose an unacceptable risk to people.

4.8 BS EN 115 : 1995 Inc amendment A1: 1998 – ‘Safety rules for the construction and installation of escalators and passenger conveyors’ is the current harmonised standard that provides the manufacturer with a presumption of conformity to the relevant essential safety requirements of SOMSR.

4.9 A draft for public comment, draft prEN115 was issued in April 2005 by the British Standards Institution. The intention is this will supersede BS EN 115 : 1995 when published which could be towards the end of 2006.

4.10 It is important to note that the current BS EN 115 : 1995 treats use of moving walks for transportation of push chairs, luggage trolleys or baggage carts as an exceptional use and subject to special measures being agreed between the manufacturer of the moving walk, the means of transportation (e.g. the trolley manufacturer) and the owner (e.g. the retail premises employer).

4.11 The draft prEN115 includes at clause 4.9 ‘Particular hazards in combination with this type of machine’, ‘misuse by transporting other items than persons (e.g. shopping or luggage trolleys)’. Note the word ‘misuse’.

4.12 This draft standard has an Annex H (normative) ‘Requirements on escalators and moving walks intended to transport shopping and luggage trolleys’. As with the current BS EN 115 : 1995 the draft considers means of transportation (e.g. shopping trolleys, etc) an exceptional use and should be subject to special measures being agreed between the manufacturer of the moving walk, the manufacturer of the means of transportation and the owner.

4.13 Annex H is normative and therefore whilst not part of the essential safety requirements for the machine it is necessary if the moving walk is to be used with shopping trolleys.

4.14 It should be borne in mind the operator needs to fulfil the requirements of Annex H which are:-

4.14.1 The design of the shopping trolley shall fit to the moving walk to ensure safe handling (e.g. deflector devices, rollers, trolley locking devices);

4.14.2 Trolley width at least 0.4m less than the moving walk pallet width;

4.14.3 Inclination of combs max 19 deg combined with the stability calculation (toppling test) from the trolley manufacturer;

4.14.4 Horizontal pallets of minimum 400 mm in the upper landing for moving walks with an inclination of > 6 deg;

4.14.5 Speed of not more than 0.5 m/s for moving walks ≥ 6 deg;

4.14.6 Restricted area enlarged to 5.0 m independent of its width. (Ref [BS EN 115:1995 clause 5.2.1 - where moving walks transport only persons the width of the unrestricted area shall at least correspond to the distance between the handrail centerlines. The depth shall be at least 2,50 m measured from the end of the balustrade. It shall be permissible to reduce it to 2,00 m if the width of the unrestricted area is increased to at least double the distance between the handrail centre lines. Attention is drawn to the fact that this free area shall be considered as part of the whole traffic function and, thus, needs sometimes to be increased. Both the draft prEN115 and the CIBSE Guide D Section 10.4.5 recommends this unrestricted area is extended to 5.0m as a special measure when shopping trolleys are being transported];

4.14.7 Additional stop switches for emergency situations at exits with approximately 2.0 m distance before and after comb intersection line above handrail level. The stop switch before the comb intersection line shall be reachable from inside the moving walk and the stop switch after the comb intersection line shall be reachable from outside the moving walk so it is possible for non-users to help struggling persons in crowd by activating the stop switch for emergency situations.

4.15 It therefore follows before moving walks are supplied and installed that as part of the planning and design process for moving walks consideration needs to be given in the employer’s risk assessment to what special measures need to be put in place when shopping trolleys or other means of transportation are to be provided for use with the moving walk. Where consideration of special measures has not been included in the risk assessment this should be given retrospective action when reasonably practicable to do so.

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5. Some examples of accidents involving moving walks

5.1 An analysis of RIDDOR accident statistics showed 19 accidents occurred on moving walks between the years 2001 to 2005. 3 over 3 day, 15 major injuries and 1 fatal. Ref draft HSL Literature Survey.

5.2 Non RIDDOR accidents are likely to be more numerous based on the small number of locations considered. These included:-

5.2.1 A supermarket who pleaded guilty, for accidents where customers and members of staff fell over and slipped on a wet moving walk when descending on it from an open car park to the store below. Over 40 accidents had occurred over a two year period, not all were RIDDOR but those that were resulted in a fractured wrist and broken ankle. It was considered by the LA the main problem was not the slope of the moving walk but the lack of means to prevent water getting on to the moving walk (i.e. suitable matting etc). The fine imposed was £35,000 with costs (to be confirmed) approaching £60,000.

5.2.2 The LA concerned reported in a 3 month period since introduction of the moving walk(s) into service that 25 accidents had been recorded in the store accident book relating to moving walks. However, following that period only 3 accidents had been noted. The age range of persons injured was from 50 to 98 years of age. The LA had expressed concern over the lack of an accessible emergency stop switch in the event of a fall.

5.2.3 Another LA had raised concern regarding two ‘rubber guides’ fitted to a moving walk. It was understood the guides were there to guide the shopping trolleys away from the sides of the moving walk. The LA reported that a wide enough gap existed between the guide and side of the moving walk which allowed the trolley wheel to become trapped. There was also an issue with emergency stop accessibility. A recommendation was made that the supermarket should in the first instance write to the moving walk manufacturer about the trapping points with a view to the manufacturer, modifying the guides. Advice was also given on emergency stops by reference to BS EN 115:1995 clauses 14.2.2.3.1 and 15.1.2.2.

5.2.4 Another LA reported incidents that related to interaction between the customer and the operation of the moving walk resulting in injury. It seemed the elderly were more at risk than other age groups.

5.2.5 Another LA reported two members of the public had reported accidents on the moving walks. One accident involved a shopping trolley on a down going moving walk being placed sideways to the direction of movement. At the exit point the trolley did not lift causing a trolley behind to hit the person in front resulting in minor bruising. On investigation the emergency stop could not be accessed by persons on the moving walk. The other accident involved a person who fell on the moving walk and who alleges the moving walk was moving too fast and the angle of inclination was too steep.

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6. Contact

6.1 For further information please contact the HSE Construction Division Technology Unit, Grove House, Skerton Road, Manchester, M16 0RB Tel: 0161 952 8200.

6.2 Some issues for consideration

• Subject to the date of manufacture, do the moving walks have CE marking?
• Have special measures been agreed between the manufacturer of the moving walk, the manufacturer of the shopping trolley and the owner (ref BS EN 115 : 1995 clause 0.5.3?
• Is there evidence of adequate maintenance and suitable inspections for moving walks and shopping trolleys?
• Is the shopping trolley width at least 400 mm less than the moving walk pallet width?
• Does the shopping trolley locking system operate effectively with either a loaded or unloaded shopping trolley?
• Is there effective information to users by clear signage and/or audible announcements giving users simple do’s and don'ts?
• Are routes to passenger lifts clearly and effectively signed for all those prohibited from using the moving walk(s)?
• Where appropriate, are there simple precautions to prevent customers treading water onto the moving walk pallet treads?
• Does the location have suitable procedures in place in the event of a power supply failure or an emergency?
• Are there trained first-aiders available?
• Are the moving walks being periodically monitored and checked by identified and trained member(s) of staff?
• Does the store’s accident book show entries for any incidents and if so, what action has been undertaken to mitigate such incidents in the future?
• Are there effective stopping devices situated above handrail level which are visible and accessible for persons both on and off the moving walk?
• Are there suitable unrestricted areas at moving walk exits to accommodate persons with shopping trolleys or other means of transportation and their loads?
• Are all articles for sale in the retail premises a reasonable distance away from persons on the moving walk so as to be beyond their reach?

Notes:

1 Supply of Machinery (Safety) Regulations 1992 as amended (SOMSR)

2 Workplace (Health, Safety and Welfare) Regulations 1992 – Regulation 19

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Annex 1

Diagram showing principal components of a moving walk

Item	Component
1	Truss
2	Tracks
3	Drive motor
4	Gearbox
5	Service brake
6	Handrail drive wheels
7	Pallet chain sprockets
8	Pallets
9	Pallet chain
10	Handrail
11	Lower reversing station
12	Balustrade panels
13	Decks
14	Newel ends
15	Skirts
16	Access cover
17	Comb plates
18	Front plates
19	Controller

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Bibliography

Relevant legislation includes:

• Health and Safety at Work (etc) Act 1974 (HSWA);
• ‘Safe use of work equipment’ – Provision and Use of Work Equipment Regulations 1998 (PUWER) Approved Code of Practice and Guidance, L22, ISBN 0 7176 1626 6;
• ‘Management of health and safety at work’ – Management of Health and Safety at Work Regulations 1999 (MHSWR) – Approved Code of Practice and Guidance L21, ISBN 0 7176 2488 9;
• ‘Workplace health, safety and welfare’ - Workplace (Health, Safety and Welfare) Regulations 1992 – Approved Code of Practice and Guidance L24, ISBN 0 7176 0413 6.

Relevant Codes of Practice and Standards includes:

• BS EN 115: 1995 inc Amendment A1: 1998 – Safety rules for the construction and installation of escalators and passenger conveyors;
• pr BS EN 115 (draft for public comment April 2005) - Safety rules for the construction and installation of escalators and moving walks;
• BS 5656-1:1997 – Safety rules for the construction and installation of escalators and passenger conveyors – Specification and proformas for test and examination of new installations;
• BS 5656-2:2004 – Escalator and moving walks – Code of practice for the selection, installation and location of new escalators and moving walks;
• BS EN 1929-2:2004 – Basket trolleys – Requirements, tests and inspection of basket trolleys with or without a child carrying facility, intended to be used on passenger conveyors;
• CEN/TC 10 N 485 Item 12.2.4 – Amendment to EN 1929-2:2004 - Basket trolleys – Requirements, tests and inspection of basket trolleys with or without a child carrying facility, intended to be used on passenger conveyors – deletion of sub clause 4.3 of EN 1929-:2004;
• HSL – Assessment of pedestrian slip risk – the HSE approach [320KB];
• HSL Visit Report 6 th February 2006 – Roughness and slipperiness tests on a moving walk;
• HSL Visit Report 6 th February 2006 – Ergonomic risk surrounding moving walk installation;
• HSL draft Literature Survey on Moving Walks;
• HSE GN PM 34 – Safety in the use of escalators (currently out of print and agreed to be subject to industry revision);
• HSE GN PM 45 – Escalators: Periodic thorough examination (currently out of print and agreed to be subject to industry revision);
• HSE HS(G) 84 – Shopping Trolleys – Safe system of work guidance (Withdrawn following HSC Review of Regulations and Guidance);
• HSE HS(G) 156 – Slips and trips – Guidance for the food processing industry;
• CIBSE Guide D – Section on Escalators and moving Walks.

Health & Safety Executive publications are available from HSE Books, PO Box 1999, Sudbury, Suffolk, CO10 2WA. Tel: 01787 881165.

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