Posted By Trevor Hay
Unusually, I thought that it may be useful to add a few comments here. I do not intend to enter into a protracted discussion, but I tender the following comments in the hope of providing assistance.
I would request that any subsequent enquiries of HSE take the route outlined on the HSE web pages (i.e. via infoline, your trade association or local HSE inspector. My apologies for asking this - I would be swamped with queries if everyone came to me directly.)
I would suggest that the key document you will need to refer to is BSEN 1501-1:1998 Refuse
Collection Vehicles and their associated lifting devices - General
requirements and safety requirements.
Of particular note is the National foreword to this document. (Other EC states may not incorporate this foreword into their EN?)
It states that:
"The primary concern relates to the inclusion of subclauses 3.20 and 6.6
and the riding on refuse collection vehicles by operatives. Whilst it is
understood The (GB) industry considers that there are significant health
and safety risks associated with this practice.......For sound health and
safety reasons the (GB) industry deems the inclusion of steps into this
standard a retrograde move....(the standards in) HSE Guidance note PM52:
Safety in the use of Refuse Compaction Vehicles was prepared by the Health
and Safety Executive, along with industry representatives, and implemented
in 1985. This document was voluntarily adopted by UK manufacturers,
specifiers and operators from that date. The practice of operatives riding
on the outside of vehicles ceased in the UK over (20) years ago. The accident
statistics, though not comprehensive, indicate that deaths have reduced
significantly in the intervening period.. The industry considers that this
reduction is a direct result of the ban on the practice of riding on the
rear of vehicles......"
So, briefly, you will find our European colleagues using riding platforms manufactured with certain safeguards as indicated in the standard, but here in GB, we consider these safeguards are not capable of providing a sufficient degree of protection (and sometimes, they can add other risks).
Please also note the comment at the bottom of the national foreward in bold type "Compliance with a British Standard does not of itself confer immunity from legal obligations"
The Health and Safety Executive strongly supports this comment, as does the
trade body, the Environmental Services Association. Certainly among the
safety officers of the major British waste management companies I speak to,
there is a thorough understanding and support of the HSE stance on this
matter, and of the contents of the National Foreword to BSEN 1501-1.
One recent fatality would appear to have involved a worker riding on a vehicle using a wing mirror as a handhold and using the vehicle entry step as a 'footplate'. I await confirmation from the courts of the agreed facts of the matter.
Forward thinking, progressive manufacturers I have visited are now considering the design and location of wing mirrors to prevent this. Additionally, at least one manufacturer designs his vehicle door so that no step projects outside the cab.
I hope that this helps, colleagues?
Yours fraternally, and with regards,
Trevor Hay, HM Inspector of Health and Safety, Waste Management and Recycling Section. Cardiff