Recurring concern

Unsafe agricultural bale handling and transport

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First reported 31 Mar 2014•Latest report 17 Apr 2020

Definition

What this concern includes

Includes failures in safety guidance, planning, loading, securing, equipment positioning, conspicuity and operational controls specifically governing agricultural bale handling and transport, including stacking or unstacking bales, loading and strapping trailers, and transporting bale chutes or comparable attachments on public roads.

Not included

  • Excludes generic agricultural workplace-safety, vehicle-driving or trailer-maintenance deficiencies where bale handling or transport is not the material safety condition.
  • Excludes ordinary vehicle or road hazards unrelated to agricultural bales or bale-related equipment.
  • Excludes generic guidance inconsistency without a specific connection to safe agricultural bale handling or transport.
  • Excludes downstream collision, collapse or injury outcomes where no continuing deficiency in bale-handling or transport controls is asserted.
Reports
2

Distinct published reports

Individual concerns
5

A report can raise multiple concerns

Date range
2014–2020

First to latest report issue date

Stated actions
6

Described in published responses

Reports over time

Reports over time

Reports about this concern issued each year.

* 2026 is projected from reports observed to 7 Sep 2026.

Most frequent recipients

Most frequent recipients

Reports about this concern sent to each recipient.

AGCO Limited1
Department for Transport1
Health and Safety Executive1

Concerns and responses across reports

Only concerns grouped under this recurring concern are included. Select any concern, action or position to view the source wording.

  1. Lincolnshire

    AI-generated summary

    Ashley Mark Holden · Prevention of Future Deaths report

    This summary was generated using AI from the published report. Please read the original report for the complete account.

    Report summary

    On 10 November 2018, HGV driver Ashley Holden was struck by a falling straw bale while collecting bales from a farm and sustained a fatal head injury. The report identified inconsistent guidance and a lack of definitive guidance on stacking, unstacking, loading and strapping bales, creating a risk of unsafe practices and future deaths.

    Read the report on judiciary.uk

    Source evidence

    How this individual concern was interpreted

    PFD Monitor created a concise, searchable interpretation from the report wording shown below.

    PFD Monitor interpretation

    Inconsistent and uncoordinated guidance on bale safety

    Wider context from the report

    “3. The two pieces of guidance are not consistent in the approaches that they suggest and indeed the later guidance does not reference the earlier guidance. 4. There is no definitive guidance provided to the industry in relation to the stacking or unstacking of bales, or in relation to the loading and strapping of loaded trailers in a manner which takes account of the different sizes and composition of bales, and/or different trailer sizes and configurations. 5. The absence of specific guidance on this issue creates a risk of the development of unapproved and potentially unsafe individual practices, with the consequential risk of future deaths. ”

    Source location

    Ashley Mark Holden · Prevention of Future Deaths report
    Page 2 · concerns

    Open source report

    Source evidence

    How this individual concern was interpreted

    PFD Monitor created a concise, searchable interpretation from the report wording shown below.

    PFD Monitor interpretation

    Lack of definitive guidance on loading and strapping loaded trailers for differing bale and trailer configurations

    Wider context from the report

    “3. The two pieces of guidance are not consistent in the approaches that they suggest and indeed the later guidance does not reference the earlier guidance. 4. There is no definitive guidance provided to the industry in relation to the stacking or unstacking of bales, or in relation to the loading and strapping of loaded trailers in a manner which takes account of the different sizes and composition of bales, and/or different trailer sizes and configurations. 5. The absence of specific guidance on this issue creates a risk of the development of unapproved and potentially unsafe individual practices, with the consequential risk of future deaths. ”

    Source location

    Ashley Mark Holden · Prevention of Future Deaths report
    Page 2 · concerns

    Open source report

    Source evidence

    How this individual concern was interpreted

    PFD Monitor created a concise, searchable interpretation from the report wording shown below.

    PFD Monitor interpretation

    Lack of definitive guidance on stacking or unstacking bales

    Wider context from the report

    “3. The two pieces of guidance are not consistent in the approaches that they suggest and indeed the later guidance does not reference the earlier guidance. 4. There is no definitive guidance provided to the industry in relation to the stacking or unstacking of bales, or in relation to the loading and strapping of loaded trailers in a manner which takes account of the different sizes and composition of bales, and/or different trailer sizes and configurations. 5. The absence of specific guidance on this issue creates a risk of the development of unapproved and potentially unsafe individual practices, with the consequential risk of future deaths. ”

    Source location

    Ashley Mark Holden · Prevention of Future Deaths report
    Page 2 · concerns

    Open source report

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Amend the DfT Code of Practice, “Safety Loads on Vehicles”, to cross-reference relevant guidance effectively.

    Verbatim wording from the response

    “• To amend the DfT Code of Practice, ‘Safety Loads on Vehicles’ (2002) to ensure both are cross referenced effectively. Whilst HSE leaflet INDG125 already references the DfT guidance on page 10 titled Find out more - https://www.hse.gov.uk/pubns/indg125.pdf, we note that HSE intends to consider whether improvements can be made to INDG125 when it is next under periodic re-evaluation.”

    Source location

    2020-0096-Response-from-Department-for-Transport_Redacted
    Page 2 · response
    Published 18 May 2020

    Open published response

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Monitor incidents and modern farming practices and adapt bale-loading guidance accordingly.

    Verbatim wording from the response

    “The risk of fatal and serious injury when working with bales in agriculture is well known and guidance has been in place in various forms for decades. Recently, between 2014 and 2019, 6 people were killed by falling bales. We continue to monitor and adapt our guidance in light of”

    Source location

    2020-0096-Response-from-Health-Safety-England_Redacted-1
    Page 1 · response
    Published 18 May 2020

    Open published response

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Review INDG125, taking account of submitted comments and considering whether improvements can be made.

    Verbatim wording from the response

    “incidents and modern farming practices. For example, INDG125(rev3) was revised in 2012 to provide updated guidance to the industry on safe working practices, including the safe loading and unloading of bales. The DfT guidance Code of Practice: Safety of loads on vehicles is already referenced in INDG125 under the ‘Find out More’ section of the leaflet on page 10. We are grateful for your comments and we will take them into account at the next review.”

    Source location

    2020-0096-Response-from-Health-Safety-England_Redacted-1
    Page 2 · response
    Published 18 May 2020

    Open published response

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Work with relevant organisations, including DVSA and HSE where appropriate, to promote safe loading and unloading practices.

    Verbatim wording from the response

    “• DfT will work with other organisations including, where appropriate, the DVSA and HSE to promote safe working practices during loading and unloading operations. We note that HSE does and will continue to engage with the agricultural industry to promote safe practice over a variety of topics, including safe working with bales.”

    Source location

    2020-0096-Response-from-Department-for-Transport_Redacted
    Page 2 · response
    Published 18 May 2020

    Open published response

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Produce and publish updated on-road load-securing guidance for vehicle operators.

    Verbatim wording from the response

    “HSE recognise that unstable loads present a serious risk of harm during loading and unloading. In 2013 we worked with DVSA to introduce a new enforcement approach for vehicle loading, and produced updated on-road guidance on load securing for vehicle operators, which was published in 2015. We continue to work closely with DVSA and police forces, providing training on vehicle loading for frontline personnel alongside specialist technical support. We also provide loading and load securing advice through wider forums to the agricultural sector.”

    Source location

    2020-0096-Response-from-Health-Safety-England_Redacted-1
    Page 1 · response
    Published 18 May 2020

    Open published response

    Source evidence

    How this respondent action was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Provide vehicle-loading training and specialist technical support to frontline personnel, alongside load-securing advice through agricultural forums.

    Verbatim wording from the response

    “HSE recognise that unstable loads present a serious risk of harm during loading and unloading. In 2013 we worked with DVSA to introduce a new enforcement approach for vehicle loading, and produced updated on-road guidance on load securing for vehicle operators, which was published in 2015. We continue to work closely with DVSA and police forces, providing training on vehicle loading for frontline personnel alongside specialist technical support. We also provide loading and load securing advice through wider forums to the agricultural sector.”

    Source location

    2020-0096-Response-from-Health-Safety-England_Redacted-1
    Page 1 · response
    Published 18 May 2020

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    A comprehensive table covering every bale and trailer permutation is considered impractical because it would be overly complex and potentially confusing.

    Verbatim wording from the response

    “• That DVSA updates the ‘Load Securing - Vehicle Operators Guidance’ which was last reviewed with HSE in 2015. HSE has agreed in principle to assist DVSA in updating this guidance which was already proposed at the start of this year. Having considered the approaches that could be taken, we have identified that a generic approach to safe loading principles, rather than very specific information covering each size of bale and trailer, is considered to be most practical. A comprehensive table seeking to cover every permutation of trailer and bale would be overly complex and may confuse. However, the updated guidance will look at the key principles for the safe loading and transport of bales.”

    Source location

    2020-0096-Response-from-Department-for-Transport_Redacted
    Page 2 · response
    Published 18 May 2020

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    DVSA is assigned responsibility for updating the Load Securing—Vehicle Operators Guidance, with HSE assistance.

    Verbatim wording from the response

    “• That DVSA updates the ‘Load Securing - Vehicle Operators Guidance’ which was last reviewed with HSE in 2015. HSE has agreed in principle to assist DVSA in updating this guidance which was already proposed at the start of this year. Having considered the approaches that could be taken, we have identified that a generic approach to safe loading principles, rather than very specific information covering each size of bale and trailer, is considered to be most practical. A comprehensive table seeking to cover every permutation of trailer and bale would be overly complex and may confuse. However, the updated guidance will look at the key principles for the safe loading and transport of bales.”

    Source location

    2020-0096-Response-from-Department-for-Transport_Redacted
    Page 2 · response
    Published 18 May 2020

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Existing broad guidance and the legal framework are considered sufficient because risk assessment, planning and competent staff can safely manage varied bale-loading configurations.

    Verbatim wording from the response

    “The guidance contained in INDG125 is intentionally broad and sets out the principles of safe loading that meet the Act and LOLER. It has never been our intention to cover every possible configuration but the combination of suitable and sufficient assessment, planning and use of competent people allows for loads of many types to be loaded and transported safely within a robust legal framework.”

    Source location

    2020-0096-Response-from-Health-Safety-England_Redacted-1
    Page 2 · response
    Published 18 May 2020

    Open published response

    Source evidence

    How this respondent position was interpreted

    PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

    PFD Monitor interpretation

    Employers and those controlling loading operations are responsible for identifying risks, implementing effective controls and reviewing them.

    Verbatim wording from the response

    “The duty rests on employers and those in control of the loading operations to identify risks associated with the loading operation, implement effective controls to ensure the safety of persons who may be affected, and keep these controls under review.”

    Source location

    2020-0096-Response-from-Health-Safety-England_Redacted-1
    Page 2 · response
    Published 18 May 2020

    Open published response
  2. Shropshire, Telford and Wrekin

    AI-generated summary

    Valerie Anne HANCOX · Prevention of Future Deaths report

    This summary was generated using AI from the published report. Please read the original report for the complete account.

    Report summary

    Valerie Anne HANCOX died from injuries sustained in a collision on the A5 at Burlington, Shifnal, Shropshire, on 14 September 2012. The collision occurred when a tractor and baler obstructed the oncoming carriageway during darkness. Concerns included the bale chute being left lowered, unmarked, and painted matt grey, making it difficult for approaching road users to see.

    Read the report on judiciary.uk

    Source evidence

    How this individual concern was interpreted

    PFD Monitor created a concise, searchable interpretation from the report wording shown below.

    PFD Monitor interpretation

    Failure to clearly mark bale chutes for visibility on public highways

    Wider context from the report

    “(1) The bale chute, when on the public highway, should not be in its lowered position. However it appears to be standard farm practice to leave the bale chute down when moving from one field to another along or to cross a public highway. (2) The bale chute was just short of 2 metres in length and falls under the legislation that, when on roads, it should be clearly marked. If it were over 2 metres then it would have to be lit. (3) The bale chute had no markings and was painted matt grey. The manufacturers state in their handbook that the chute should be stored in the up position for travel on roads. This may explain why there is no marking but relies on the driver adhering to that instruction. (4) Given the potential for obstructing the highway, all the more so as the manufacturer's instructions appear to be not followed, bale chutes should be clearly marked so that anyone approaching side on, day or night, as the deceased’s husband was, should be able to see it. ”

    Source location

    Valerie Anne HANCOX · Prevention of Future Deaths report
    Page 2 · concerns

    Open source report

    Source evidence

    How this individual concern was interpreted

    PFD Monitor created a concise, searchable interpretation from the report wording shown below.

    PFD Monitor interpretation

    Failure to keep bale chutes in the raised position during public-road travel

    Wider context from the report

    “(1) The bale chute, when on the public highway, should not be in its lowered position. However it appears to be standard farm practice to leave the bale chute down when moving from one field to another along or to cross a public highway. (2) The bale chute was just short of 2 metres in length and falls under the legislation that, when on roads, it should be clearly marked. If it were over 2 metres then it would have to be lit. (3) The bale chute had no markings and was painted matt grey. The manufacturers state in their handbook that the chute should be stored in the up position for travel on roads. This may explain why there is no marking but relies on the driver adhering to that instruction. (4) Given the potential for obstructing the highway, all the more so as the manufacturer's instructions appear to be not followed, bale chutes should be clearly marked so that anyone approaching side on, day or night, as the deceased’s husband was, should be able to see it. ”

    Source location

    Valerie Anne HANCOX · Prevention of Future Deaths report
    Page 2 · concerns

    Open source report
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Data last updated 7 September 2026