PFD report

Terence Charles Scott DUNCAN · Prevention of Future Deaths report

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Issued 16 Nov 2023•Berkshire

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.

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Concerns
1

Raised in this report

Recipients
1

Named on the report

Responses found
1

Of 1 recipient

Stated actions
3

Described in responses

Recipients and published 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.

Concerns raised1

  1. Inadequate sideguard coverage on extended trailers
    Part of recurring concern: Inadequate physical separation between pedestrians and vehicular traffic
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

    Review sideguard requirements and propose amendments to require sideguards on extended trailers where possible.

    Stated by Department for TransportStated plannedThe respondent said that this action was planned when they made their response on 22 November 2023.
  2. Action

    Consider amending Construction and Use Regulations to keep required sideguards in place throughout a vehicle’s life.

    Stated by Department for TransportStated in progressThe respondent said that this action was in progress when they made their response on 22 November 2023.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.1

  1. Position

    Sideguards cannot be required on extendable trailers in all cases because fitting them is not possible in some circumstances.

    Stated by Department for TransportUnable to actThe respondent said that a constraint prevented them from taking the relevant 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

Inadequate sideguard coverage on extended trailers

Wider context from the report

“I was informed that the type of trailer involved in this inquest was an extendable trailer and therefore its construction was in compliance with the Regulations as long as the requirements were met when the trailer was in its shortest configuration. The sideguard on this trailer was only 50cm long whereas the distance between the wheels of the cab unit and trailer wheels was 3 metres when extended. The trailer was extended despite being not being loaded with a shipping container at the time. There was therefore a very significant gap between the end of the sideguards and front of the following wheels. I am concerned that there is no lesser risk posed to pedestrians or cyclists by an extendable trailer that posed by a fixed trailer of the same length which would have been required to have a more comprehensive sideguard device installed. ”

Is this part of a recurring concern?

Yes — Inadequate physical separation between pedestrians and vehicular traffic.

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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 sideguard requirements and propose amendments to require sideguards on extended trailers where possible.

Verbatim wording from the response

“In relation to sideguards, both UNECE Regulation 73 and C&U permit extendable trailers to be placed on the market and used respectively, without sideguards in the location of the increase in length when the trailer is extended. These provisions have been in place for many years, and I have asked officials to review the requirements, and to make proposals to amend the international regulation to require sideguards when the trailer is extended, where possible. This would increase the number of vehicles fitted with sideguards while continuing to recognise that this is not possible in all cases.”

Source location

Response from Department of Transport
Page 1 · response
Published 22 November 2023

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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

Consider amending Construction and Use Regulations to keep required sideguards in place throughout a vehicle’s life.

Verbatim wording from the response

“In addition, consideration is also being given to amending C&U to ensure that sideguards which are required for the purpose of the original vehicle approval remain in place throughout the life of the vehicle. I trust that these two actions will address your concerns on the absence of sideguards on extendable trailers. The Department will continue to monitor the”

Source location

Response from Department of Transport
Page 1 · response
Published 22 November 2023

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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

Sideguards cannot be required on extendable trailers in all cases because fitting them is not possible in some circumstances.

Verbatim wording from the response

“In relation to sideguards, both UNECE Regulation 73 and C&U permit extendable trailers to be placed on the market and used respectively, without sideguards in the location of the increase in length when the trailer is extended. These provisions have been in place for many years, and I have asked officials to review the requirements, and to make proposals to amend the international regulation to require sideguards when the trailer is extended, where possible. This would increase the number of vehicles fitted with sideguards while continuing to recognise that this is not possible in all cases.”

Source location

Response from Department of Transport
Page 1 · response
Published 22 November 2023

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 monitoring vehicle safety regulations to identify amendments that could improve road safety.

    Stated by Department for TransportStated in progressThe respondent said that this action was in progress when they made their response on 22 November 2023.

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 monitoring vehicle safety regulations to identify amendments that could improve road safety.

Verbatim wording from the response

“In addition, consideration is also being given to amending C&U to ensure that sideguards which are required for the purpose of the original vehicle approval remain in place throughout the life of the vehicle. I trust that these two actions will address your concerns on the absence of sideguards on extendable trailers. The Department will continue to monitor the”

Source location

Response from Department of Transport
Page 1 · response
Published 22 November 2023

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

Data last updated 7 September 2026