PFD report

Ashley Mark Holden · Prevention of Future Deaths report

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Issued 17 Apr 2020•Lincolnshire

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
2

Named on the report

Responses found
2

Of 2 recipients

Stated actions
7

Described in responses

Source document

Full report text

This is the full text from the original published report.

Open published report

Concerns and recipient responses

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

Report evidence summary

Concerns raised3

  1. Inconsistent and uncoordinated guidance on bale safety
    Part of recurring concern: Unsafe agricultural bale handling and transport
  2. Lack of definitive guidance on loading and strapping loaded trailers for differing bale and trailer configurations
    Part of recurring concern: Unsafe agricultural bale handling and transport
  3. Lack of definitive guidance on stacking or unstacking bales
    Part of recurring concern: Unsafe agricultural bale handling and transport
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.6

  1. Action

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

    Stated by Department for TransportStated plannedThe respondent said that this action was planned when they made their response on 18 May 2020.
  2. Action

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

    Stated by Department for TransportStated plannedThe respondent said that this action was planned when they made their response on 18 May 2020.
  3. Action

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

    Stated by Health and Safety ExecutiveStated plannedThe respondent said that this action was planned when they made their response on 18 May 2020.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.4

  1. Position

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

    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

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. ”

Is this part of a recurring concern?

Yes — Unsafe agricultural bale handling and transport.

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 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. ”

Is this part of a recurring concern?

Yes — Unsafe agricultural bale handling and transport.

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 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. ”

Is this part of a recurring concern?

Yes — Unsafe agricultural bale handling and transport.

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

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

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

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

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 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

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 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

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

    Introduce an enforcement approach for vehicle loading.

    Stated by Health and Safety ExecutiveStated completedThe respondent said that this action was complete when they made their response on 18 May 2020.

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

Introduce an enforcement approach for vehicle loading.

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
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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