PFD report

Jennifer Lilian Davies · Prevention of Future Deaths report

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Issued 30 Aug 2022•Brighton and Hove

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
3

Raised in this report

Recipients
1

Named on the report

Responses found
1

Of 1 recipient

Stated actions
0

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 raised3

  1. Pedestrian exposure to delivery vans in hugely populated areas
  2. Exclusion of delivery van drivers from Working Time Regulations limiting working hours
    Part of recurring concern: Unreliable fatigue controls for prolonged safety-critical shifts
  3. Lack of a legal requirement for delivery van drivers to take a 30-minute break
Responses linked to these concerns

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

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.3

  1. Position

    Existing drivers’ hours, working-time and fatigue-management requirements are considered an appropriate response to risks involving light goods vehicle drivers.

    Stated by Department for TransportExisting arrangements considered sufficientThe respondent said that existing arrangements were sufficient, so no further action was needed.

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

Pedestrian exposure to delivery vans in hugely populated areas

Wider context from the report

“Delivery van drivers (of vehicles under 3.5 Tonnes) are not subject to the current Working Time Regulations. However, as in this case, a driver could be required to work up to 11 hours a day. Whilst employers can stipulate that their drivers should take a 30-minute break there is no legal requirement upon them to do so. With the growth in home parcel delivery this is putting lives at risk. Delivery van drivers, by the very nature of the work that they do, are being driven in hugely populated areas where pedestrians are particularly at risk. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

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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

Exclusion of delivery van drivers from Working Time Regulations limiting working hours

Wider context from the report

“Delivery van drivers (of vehicles under 3.5 Tonnes) are not subject to the current Working Time Regulations. However, as in this case, a driver could be required to work up to 11 hours a day. Whilst employers can stipulate that their drivers should take a 30-minute break there is no legal requirement upon them to do so. With the growth in home parcel delivery this is putting lives at risk. Delivery van drivers, by the very nature of the work that they do, are being driven in hugely populated areas where pedestrians are particularly at risk. ”

Is this part of a recurring concern?

Yes — Unreliable fatigue controls for prolonged safety-critical shifts.

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 a legal requirement for delivery van drivers to take a 30-minute break

Wider context from the report

“Delivery van drivers (of vehicles under 3.5 Tonnes) are not subject to the current Working Time Regulations. However, as in this case, a driver could be required to work up to 11 hours a day. Whilst employers can stipulate that their drivers should take a 30-minute break there is no legal requirement upon them to do so. With the growth in home parcel delivery this is putting lives at risk. Delivery van drivers, by the very nature of the work that they do, are being driven in hugely populated areas where pedestrians are particularly at risk. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

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 drivers’ hours, working-time and fatigue-management requirements are considered an appropriate response to risks involving light goods vehicle drivers.

Verbatim wording from the response

“Drivers of commercial goods vehicles weighing 3.5 tonnes or less fall in-scope of the GB domestic drivers’ hours rules (contained in the Transport Act 1968). According to these domestic rules, in any 24-hour period the maximum driving time is 10 hours and the maximum duty time is 11 hours. Duty includes all periods of work and standby but does not include rest or breaks. If someone is self-employed, duty time is only time spent driving the vehicle or its load. There are no specific break or rest requirements for goods vehicles under these rules.”

Source location

Response from Department for Transport
Page 1 · response
Published 22 March 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

The Department cannot provide a definitive interpretation of legislation because its meaning and scope are ultimately matters for the courts.

Verbatim wording from the response

“As I hope you will appreciate, I must point out that the Department is unable to give a definitive interpretation of the meaning and scope of any legislation as this is ultimately a matter for the courts to determine. We can, however, provide the Department's view.”

Source location

Response from Department for Transport
Page 2 · response
Published 22 March 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

DVSA is responsible for enforcing drivers’ hours rules, while employers and the Health and Safety Executive address workplace fatigue risks.

Verbatim wording from the response

“The current drivers’ hours and working time rules are vital in ensuring the safety of drivers and others on the road and it is important that those rules are adhered to by delivery companies. Any perceived breaches of the rules can be reported to Driver and Vehicle Standards Agency (DVSA), who are responsible for enforcement, via DVSA’s confidential hotline on 0300 123 9000 or by email to the DVSA intelligence team at intelligenceunit@dvsa.gov.uk. All calls/emails will be treated in confidence.”

Source location

Response from Department for Transport
Page 2 · response
Published 22 March 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