If anyone thought developing standards and guidance was easy, believe me, it’s not. It might not even be worthwhile.
After months and months of research, evidence and fact-finding, mapping and looking at what was already available, it’s apparent that many of these documents I’ve researched are either ignored or not used. So the question is, why produce them?
I’ve got a couple of examples that seem to be ignored, yet no one has ever questioned them.
The first is “Raising The Bar Guidance”, a National Highways health and safety initiative to identify best practices, raise standards and improve supply chain engagement within construction and maintenance activities.
This guidance sits on the excellent Highways Safety Hub website.
It provides some excellent resources, including this guidance on current best practices and minimum health and safety requirements on construction and maintenance sites within National Highways.
One document, in particular, looks at minimum standards for Plant and Equipment and how to comply with the Supply Chain Leadership Council. Interestingly, it includes operators’ competence requirements for Truck Mixers, Volumetrics and Tippers, amongst other road-going vehicles.
It further explains the minimum and mandatory requirements and how they are applied ‘fully’. Things like a driver competency assessment, operating/using these vehicles per the manufacturer’s instructions and accepted competence cards/schemes – and that’s before we’ve gotten to the individual vehicle requirements.
Demonstrable training and experience in the vehicle’s operation, specific vehicle risks, and loading and unloading hazards are just some of the things that must be followed as a clear expectation in reducing risk in an activity and to people by the Supply Chain Safety Leadership.
So why is this ignored?
Secondly, we have another document from HS2 available on the government website and, again, sets out the requirements around drivers within the Principal Contractors Logistics ESSMP (Environment Sustainability and Safety Management Plan).
Mandatory requirements for progressive driver training and development appropriate for the construction activities.
Construction activities with a different set of hazards and risks that are vehicle specific.
As with Raising the Bar, there’s a requirement that drivers on the project are competent to drive their class of vehicle in the conditions expected.
Furthermore, as part of this ESSMP, it needs to be set out how they ensure drivers of these vehicles are competent for the conditions the vehicle is used.
Not a tick box generic driving assessment, an actual assessment of operational skills, knowledge and behaviours demonstrating competence. A competence assessment that exceeds the minimum requirements of legislation, British Standards and, more importantly, the operation and use laid out in the manufacturers operating instructions.
A competence assessment accredited by an industry awarding body, by CLOCS (Construction Logistics and Community Safety) and the DVSA (Driver and Vehicle Standards Agency) is strangely not adopted across these government-funded projects.
What’s the point of these official guidance documents? Are they meaningful or a necessity that only looks good?
“It’s only guidance; it’s not the law” is something I’ve heard hundreds of times over the past few weeks, but that’s missing the point and a slightly dangerous and arrogant view.
These documents I’ve featured are just two of many that not only does our sector ignore, but it also seems it’s a common theme across the board, but we need to do more if it really is that important to reduce and eliminate work-related road risk.