PFD report

Christopher George Barnes · Prevention of Future Deaths report

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Issued 20 May 2019•Gloucestershire

Report record

Published report and response evidence

This page connects the concerns raised in this report with statements found in recipients’ published responses. A link shows a clear evidence connection; it does not assign responsibility.

View original report
Concerns
2

Raised in this report

Recipients
2

Named on the report

Responses found
2

Of 2 recipients

Stated actions
3

Described in responses

Source document

Full report text

This is the full text from the original published report.

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Concerns and recipient responses

Select any concern, action or position to view the source wording.

Report evidence summary

Concerns raised2

  1. Failure to ensure an appropriate level of safety and maintain sufficient control measures for working at height on vehicles or vehicle trailers
    Part of recurring concern: Unsafe work-at-height operations
  2. Lack of sufficient understanding of working-at-height hazards and risks on vehicles or vehicle trailers
    Part of recurring concern: Unsafe work-at-height operations
Responses linked to these concerns

Each statement is shown once, even when linked to more than one concern.

Actions described in response An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.2

  1. Action

    Raise the coroner’s concerns and explore wider dissemination of relevant vehicle-load safety guidance to operators at the next forum meeting.

    Stated by Traffic Commissioners for Great BritainStated plannedThe respondent said that this action was planned when they made their response on 29 July 2019.
  2. Action

    Continue drafting guidance on the safe use of tail-lifts with the Health and Safety Executive.

    Stated by Road Haulage Association LimitedStated in progressThe respondent said that this action was in progress when they made their response on 29 July 2019.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.5

  1. Position

    Responsibility for enforcing safe-working legislation lies with the Health and Safety Executive, not the traffic commissioners.

    Stated by Traffic Commissioners for Great BritainRedirects responsibilityThe respondent said that another organisation was responsible for deciding or taking action.

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to ensure an appropriate level of safety and maintain sufficient control measures for working at height on vehicles or vehicle trailers

Wider context from the report

“Whether consigness and consigners and their employees have sufficient understanding of the hazards and risks associated with working at height on a vehicle or vehicle trailer, and whether they ensure an appropriate level of safety and have in place sufficient control measures to satisfy their legal obligations. ”

Is this part of a recurring concern?

Yes — Unsafe work-at-height operations.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of sufficient understanding of working-at-height hazards and risks on vehicles or vehicle trailers

Wider context from the report

“Whether consigness and consigners and their employees have sufficient understanding of the hazards and risks associated with working at height on a vehicle or vehicle trailer, and whether they ensure an appropriate level of safety and have in place sufficient control measures to satisfy their legal obligations. ”

Is this part of a recurring concern?

Yes — Unsafe work-at-height operations.

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

Raise the coroner’s concerns and explore wider dissemination of relevant vehicle-load safety guidance to operators at the next forum meeting.

Verbatim wording from the response

“It is true that traffic commissioners seek to work with other agencies to ensure that shared concerns regarding the safe operation of vehicles are more widely communicated. Through contacts such as the Vehicle Safety Compliance Forum, chaired by DfT, we continue to liaise with HSE. The next meeting is on 5th June, I will ask my colleague, ████████ who represents traffic commissioners at that meeting and is commissioner for the traffic area in which your coronial district lies, to raise your concerns and to explore how that guidance might be drawn to the attention of operators more widely. I envisage that is also your purpose in seeking the involvement of The Road Haulage Association. If I have misunderstood the intent of your report, then I would be happy to discuss the issues in more detail with you.”

Source location

2019-0164-Response-Senior-Traffic-Commissioner-for-Great-Britain
Page 2 · response
Published 29 July 2019

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

Continue drafting guidance on the safe use of tail-lifts with the Health and Safety Executive.

Verbatim wording from the response

“The RHA is itself currently engaged with the HSE in drafting guidance with regard to the use of tail-lifts on behalf of the RHA, its members and other trade associations. This is however a costly and very time-consuming exercise (we are currently 3 years into this project) and further work is not something that we can do lightly or easily which may use a disproportionate amount of our members funds.”

Source location

2019-0164-Response-by-RHA
Page 1 · response
Published 29 July 2019

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

Responsibility for enforcing safe-working legislation lies with the Health and Safety Executive, not the traffic commissioners.

Verbatim wording from the response

“Your report at item 4 refers to circumstances where Mr Barnes was involved in the unloading of a vehicle. Mr Barnes climbed onto the palletised load and, whilst attempting to untangle the straps which were used to secure the load, he took a step back and fell from the load on the vehicle. This would appear unconnected with the specific terms of the operator’s licence. As you will be aware, the duties to establish safe systems of work are set out in The Management of Health and Safety at Work Regulations 1999 and The Work at Height Regulations 2005 and by reference to general duties under the Health and Safety at Work etc. Act 1974.”

Source location

2019-0164-Response-Senior-Traffic-Commissioner-for-Great-Britain
Page 1 · response
Published 29 July 2019

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

Traffic commissioners lack investigative powers and resources to undertake the responsive investigation.

Verbatim wording from the response

“Traffic commissioners are not provided with investigative powers or resources. However, a conviction for breaches of the above duties might be relevant to the consideration of an operator’s ability to hold an operator’s licence. I regret that I do not have formal powers in the way suggested in your Report as responsibility for enforcing that legislation lies with the Health and Safety Executive.”

Source location

2019-0164-Response-Senior-Traffic-Commissioner-for-Great-Britain
Page 1 · response
Published 29 July 2019

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

The incident appears unconnected with the specific operator’s licence requirements, which concern satisfactory arrangements to prevent vehicle overloading.

Verbatim wording from the response

“From your report I can infer that the operator in question holds a goods vehicle operator’s licence. The requirements for that licence include section 13C of The Goods Vehicle (Licensing of Operators) Act 1995. Section 13C(3) requires only that there be satisfactory arrangements for securing that vehicles used under the licence are not overloaded.”

Source location

2019-0164-Response-Senior-Traffic-Commissioner-for-Great-Britain
Page 1 · response
Published 29 July 2019

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

The Health and Safety Executive should lead or be involved in drafting relevant transport health and safety policies, advice or guidance.

Verbatim wording from the response

“Furthermore, we suggest that the most appropriate organisation to whom the Coroner could write with such a request is the Health and Safety Executive (HSE). The HSE have a team who we understand deal specifically with transport and large vehicle fleet operators and as such we believe that they would be interested in and, in order for it to be effective, should be involved with the drafting of any health and safety policies, advice or guidance going forward.”

Source location

2019-0164-Response-by-RHA
Page 1 · response
Published 29 July 2019

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

The trade association lacks a specific mandate to draft or distribute members’ health and safety obligation policies.

Verbatim wording from the response

“We at the RHA are a trade association who have strong links with the industry and do represent a significant proportion of the industry, however, as a trade association we do not have a specific mandate with which we can draft or distribute policy documents regarding a members Health and Safety at Work Act obligations.”

Source location

2019-0164-Response-by-RHA
Page 1 · response
Published 29 July 2019

Open published response

Other statements in published responses

These actions and other statements could not be clearly connected to one concern in this report.

Recipient-stated actions An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.1

  1. 1

    Continue liaising with the Health and Safety Executive on shared vehicle-safety concerns.

    Stated by Traffic Commissioners for Great BritainStated in progressThe respondent said that this action was in progress when they made their response on 29 July 2019.

Recipient positions A position is what a recipient says about a concern when they do not describe a specific action.1

  1. 1

    Leading the guidance project is constrained by its cost, lengthy timescale, disproportionate use of members’ funds and limited internal expertise.

    Stated by Road Haulage Association LimitedUnable to actThe respondent said that a constraint prevented them from taking the relevant action.

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

Continue liaising with the Health and Safety Executive on shared vehicle-safety concerns.

Verbatim wording from the response

“It is true that traffic commissioners seek to work with other agencies to ensure that shared concerns regarding the safe operation of vehicles are more widely communicated. Through contacts such as the Vehicle Safety Compliance Forum, chaired by DfT, we continue to liaise with HSE. The next meeting is on 5th June, I will ask my colleague, ████████ who represents traffic commissioners at that meeting and is commissioner for the traffic area in which your coronial district lies, to raise your concerns and to explore how that guidance might be drawn to the attention of operators more widely. I envisage that is also your purpose in seeking the involvement of The Road Haulage Association. If I have misunderstood the intent of your report, then I would be happy to discuss the issues in more detail with you.”

Source location

2019-0164-Response-Senior-Traffic-Commissioner-for-Great-Britain
Page 2 · response
Published 29 July 2019

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

Leading the guidance project is constrained by its cost, lengthy timescale, disproportionate use of members’ funds and limited internal expertise.

Verbatim wording from the response

“The RHA is itself currently engaged with the HSE in drafting guidance with regard to the use of tail-lifts on behalf of the RHA, its members and other trade associations. This is however a costly and very time-consuming exercise (we are currently 3 years into this project) and further work is not something that we can do lightly or easily which may use a disproportionate amount of our members funds.”

Source location

2019-0164-Response-by-RHA
Page 1 · response
Published 29 July 2019

Open published response
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Information checked against the published report and official responses · Data reviewed 7 Sep 2026 · About data quality and limitations

Official responses located
2/2

Data last updated 7 September 2026