Liam Clark

Department for Transport 
Great Minster House 
33 Horseferry Road 
London 
SW1P 4DR 
Tel: 0300 330 3000 

Web Site: www.gov.uk/dft 

Our Ref: TO282472 
Your Ref: AAH/EAS152137 

18 May 2020 

Andrew A Haigh 
Senior Coroner 
Staffordshire (South) Coroner’s Jurisdiction 
Coroner’s Office, 1 Staffordshire Place 
Stafford 
ST16 2LP 

By email 

.gov.uk 

Dear Mr Haigh, 

Thank you for your Regulation 28 report dated 18 February, sent to the 
Department for Transport following the conclusion of your inquest into 
the death of Liam Anthony Clark. I am also grateful for a copy of the 
summary police report that you provided subsequently on 20 April. I am 
replying as Head of International Vehicle Standards division, which leads 
for the Department on vehicle construction standards. 

You found that the evidence considered during your inquest revealed 
two matters of concern. The first related to the absence of vehicle 
signage indicating the extent to which the boom of the crop sprayer 
protruded beyond the rear of the vehicle, and the second related to 
potential improvements in driver training.   

The summary police report gave the vehicle registration mark of the crop 
sprayer as W56STT.  Publicly available information held on the GOV.UK 
website confirmed this as a Bateman Model RB16 first registered in 
June 2000. The RB16 is a discontinued model and limited technical 
information is available.  It has been possible to identify the overall 
vehicle dimensions, but not the extent of any overhang or rearward 
projection, both of which may influence the extent of tail-swing, which 
has been implicated by the police in the outcome of this collision. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 It is worth noting in this context that overhang is a feature of nearly all 
vehicles and is essentially the distance between the rear axle and the 
rearmost point of the vehicle, excluding any load or appliance. The 
rearward projection is the distance by which a load or appliance extends 
beyond the rearmost point of the vehicle and in this case comprised part 
of the crop sprayer’s boom. 

Domestic regulations limit the extent of overhang and also require 
rearward projections exceeding 1m to be rendered clearly visible. The 
exact requirements are dependent on the extent of projection, with those 
exceeding 3.05m requiring marking and a person to accompany the 
vehicle, other than the driver, to provide added safety. These provisions 
are intended to increase awareness of other road users to a potential 
risk from a significant rearward projection.  It will of course always 
remain the responsibility of drivers of other vehicles to assess the extent 
of any potential hazard and determine appropriate action. 

In this case, it does appear that the deceased failed to appropriately 
assess the potential risk of the manoeuvring crop sprayer but the 
Department is not aware of significant evidence to suggest that a 
change in the requirements regarding improved identification of rearward 
projections would have prevented this collision. 

It does however, as you have indicated, raise potential issues around 
driver behaviour and training. It is worth noting that the Highway Code 
already sets out the standards of driving expected in a range of 
situations. For example, Rules 163 and 221 covers overtaking on the left 
and allowing extra space to allow large vehicles to turn respectively. 

We have engaged with colleagues from the Driver and Vehicle 
Standards Agency as they lead on driver training standards. They have 
noted the detail of your inquest and have agreed to review the advice in 
their official learning materials and consider the creation of a specific 
hazard perception clip covering tail-swing for the driver theory test 
covering all vehicle types.  

Furthermore, we will raise the marking of projections with the National 
Farmers' Union of England and Wales and the National Farmers Union 
of Scotland to remind them of the need to provide and maintain warning 
signs where these are required. 

 
 
 
 
 
 
 I hope you find this information helpful and are assured that the 
Department and its agencies are taking appropriate action to respond to 
your concerns. 

Head of International Vehicle Standards

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 

THIS RESPONSE IS BEING SENT TO: 

1.  The  Senior  Coroner  for  Staffordshire  South,  Andrew  A  Haigh  of  1 
Staffordshire  Place,  Stafford  ST16  2LP  in  response  to  a  ‘Regulation  28 
Report to Prevent Future Deaths’ following an inquest hearing into the death of 
Liam Anthony CLARK that concluded on 11 February 2020.  

1  HIGHWAYS ENGLAND 

I am Catherine Brookes, Regional Director for the East Midlands and West Midlands of 
Highways England Company Limited of The Cube, 199 Wharfside Street, Birmingham B1 
1RN. 

2  CORONER’S MATTERS OF CONCERN 

The MATTER OF CONCERN is as follows: –  

The A5 is a major trunk road used by all types of vehicles. There are numerous junctions. 
At the scene the speed limit is reduced to 50mph. Highways England is requested to look 
at the scene (the junction with Streetway Road) to see if any improvements are warranted 
– such as increased signage or road layout change. 

3  DETAILS OF ACTION TAKEN 

Existing conditions 

The  A5  Trunk  Road  at  the  scene  (the  junction  with  Streetway  Road)  is  a  single 
carriageway route 2 km in length running east to west. At the western end is a roundabout 
junction  with  the  A5127  (Wall)  and  where  the  A5  becomes  a  dual  carriageway.  To  the 
eastern  end  is  a  roundabout  junction  with  the  A38  (Weeford)  where  the  A5  again 
becomes a dual carriageway. 

Streetway  Road  runs  in  a  north-easterly  direction  from  a  roundabout  junction  on  the 
A5127  to  a  T-junction  with  the  A5.  The  A5127  and  Streetway  Road  are  local  authority 
roads and are the responsibility of Staffordshire County Council.  

The A5 between the two roundabouts is a wide  two way single carriageway approx. 10 
metres  wide.  The  alignment  is  straight  and  relatively  level  with  the  junction  with 
Streetway  Road  sitting  on  a  slight  crest.  The  A5  is  subject  to  the  national  speed  limit 
(60mph  for  single  carriageway)  and  is  not  restricted  to  50mph  as  provided  in  the 
Coroner’s report.  Street lighting is not present other than at the roundabouts at either 
end of the single carriageway section. The carriageway has one metre wide hard strips on 
both the nearside channels, and central hatching road markings to the centre of the road  
approx.  one  metre  wide.  Yellow  backed  junction  warning  signs  are  provided  in  both 
directions approx. 200 metres in advance of the junction. 

Streetway  Road  is  an  unclassified  rural  road  that  links  the  A5127  to  the  A5.  It  is  used 
locally as a rat run for cut-through driving to avoid the roundabouts at Wall. It varies in 
width from approx. 4.6 metres to 5.8 metres with a central warning line installed on part 
of the road. It joins the A5 at a slight angle and forms a Y shaped junction with a grassed 
splitter island. Traffic entering and leaving Streetway Road can pass on either side of the 
grassed splitter as they are marked as two way. Both junctions with the A5 are marked 
with transverse ‘Give Way’ markings, ‘Give Way’ triangle markings, ‘Give Way’ signs and 
an  advanced  ‘Give  Way’  sign.  Streetway  Road  is  also  subject  to  a  7.5  tonnes  weight 
restriction. 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Plan of Location 

2016 Road Safety Study 

In  2016  Highways  England  carried  out  a  road  safety  study  at  the  A5  Streetway  Road 
junction  following  a  reported  10  collisions  resulting  in  18  casualties  recorded  in  the 
proceeding 5-year period of available data (2010 -2014). 

Tables 1 and 2 below show the breakdown of collisions and casualties by severity over 
that period. 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Collision  Analysis  of  the  10  collisions  recorded,  showed  that  eight  of  the  collisions 
occurred within the vicinity of the Streetway Road junction and the remainder occurred 
on  the  eastbound  approach  to  the  Old  London  Road  junction.  Of  the  10  collisions 
recorded; 

•  The most common recorded contributory factor was a ‘Failure to look properly’, 
of which there had been four collisions at the Streetway Road junction. All four 
involved vehicles attempting to turn right out of the junction along the eastbound 
A5 towards the Weeford roundabout. 

•  Three were shunt type collisions by stationary or slow-moving traffic leaving the 
A5 for Streetway Road. Two of these occurred from traffic turning left (travelling 
westbound) and one occurred from traffic turning right (travelling eastbound). 

•  Two collisions occurred at the Old London Road junction; both as the result of 
traffic  turning  right  and  failing  to  look  whilst  turning  off  the  A5  and  into  the 
minor road. 

•  One collision involved a motorcycle to the east of the Streetway Road junction 

performing a U-turn, and could be discounted. 

The 2016 Road Safety Study recommended the following improvements:- 

•  Provision  of  warning  signs  to  Diagram  506.1  (Side  road  ahead)  of  the  Traffic 
Signs  Regulations  and  General  Directions  2016  with  yellow  backing  board  in 
advance  and  of  both  approaches  to  the  A5/Streetway  Road/Old  London  Road 
junction. 

•  The removal of significant vegetation on the eastbound approach to Streetway 

Road junction. 

The Safety Study concluded that this package of road safety measures could potentially 
address two of the 10 collisions within the study area generating a collision saving of 0.13 
collisions per annum. 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 In June 2017, as part of a carriageway renewal scheme, the measures  identified above 
were implemented. 

Highways England Post Fatal Collision Report 

Following  the  fatal  collision  on  the  10  September  2019,  the  Highways  England  Road 
Safety Team carried out a site visit. Their report concluded that there were no deficiencies 
within the highway layout at the collision location at the time of the site visit. 

Post Fatal Collision Safety Review following the Coroner’s report 

Following  the  receipt  of  the  coroner’s  report,  Highways  England  requested  a  further 
safety review of the junction to update the 2016 Road Safety Study. 

The further review focused on the proceeding 7½ year period of available data (January 
2011 to 30 June 2018).  

Tables 1 and 2 below show the breakdown of collisions and casualties by severity over the 
7½ year period of available data. The 12 month period from 2017 is highlighted to show 
the  period  when  the  carriageway  renewal  scheme  and  signing  improvements  were 
implemented (June 2017).  

Table 1: Collisions by Severity 

12 month 
period from 
2011 
2012 
2013 
2014 
2015 
2016 
2017 
2018 (1st 6 
months) 
Total 

Fatal 
0 
0 
0 
0 
0 
0 
0 
0 

0 

Table 2: Casualties by Severity 

12 month 
period from 
2011 
2012 
2013 
2014 
2015 
2016 
2017 
2018 (1st 6 
months) 
Total 

Fatal 
0 
0 
0 
0 
0 
0 
0 
0 

0 

Collisions 

Serious 
0 
0 
0 
0 
0 
0 
0 
0 

0 

Casualties 

Serious 
0 
0 
0 
0 
0 
0 
0 
0 

0 

Slight 
1 
2 
2 
2 
2 
0 
0 
1 

10 

Slight 
4 
3 
3 
5 
3 
0 
0 
1 

19 

Total 
1 
2 
2 
2 
2 
0 
0 
1 

10 

Total 
4 
3 
3 
5 
3 
0 
0 
1 

19 

The collision analysis identified that seven (70%) of the 10 collisions recorded occurred 
on a wet road surface, this is higher than the national average of 29%.  However,  six of 
these occurred before the carriageway renewal scheme in 2017.  This would suggest the 
scheme in 2017 had a positive impact on wet surface collisions. 

As with the 2016 Safety Study, the most common contributory factor recorded was ‘Failed 
to  look  properly’.  This  was  identified  in  five  (50%)  of  the  10  collisions.  Of  these,  four 
(80%) involved vehicles turning right out of Streetway Road, and one collision turning 
left out of the side road along with two recorded vehicle shunt type collisions. Again, the 

4 

 
 
 
 
 
 
 
 
 
 
 
 
 majority  of  these  collisions  occurred  before  the  carriageway  renewal  and  signing 
improvements were implemented in 2017. 

The evidence demonstrates a continued reduction in collisions at the location following 
the recent highway improvements in 2017, and there has only been one collision recorded 
(severity:  slight)  from  the  available  data  in  2018.  [Please  note  the  September  2019 
collision is currently outside of the available national verified collision statistics (STATS 
19 data) as provided by the police]. 

4  DETAILS OF FURTHER ACTION PROPOSED 

Due to the evidence demonstrating an improved collision history at the site, along with 
the post fatal collision report which did not identify any deficiencies within the highway 
layout,  Highways  England  have  not 
identified  any  further  appropriate  safety 
improvements at this time.  However, the junction will be routinely monitored in terms 
of collisions and the condition of the highways assets and should the number or severity 
of collisions change then the need for intervention will be reviewed, and action taken if 
deemed appropriate. 

5  EXPLANATION AS TO WHY NO ACTION IS PROPOSED 

Road Layout 

The most common cause of collisions (2011 to 2018 part data) involved vehicles turning 
right from Streetway Road of which there were four of the 10 collisions that occurred. 
There were also two side road shunt collisions. The common causation factor for these 
collisions as provided by the police was ‘Failed to Look’ or ‘Failed to judge other persons 
path/speed’. 

The visibility requirements for the junction as prescribed by the Design Manual for Roads 
& Bridges (DMRB) is between 160 metres and 215 metres at a point 2.4 metres back from 
the  ‘Give  Way’  line,  based  on  the  type  and  design  speed  of  the  road.    Overgrown 
vegetation was identified in the 2016 Safety Study and was addressed as part of the 2017 
carriageway renewal scheme.  Vegetation can be an issue due to its tendency to continue 
to grow and as a result it is routinely checked as part of Highways England’s vegetation 
management programme. 

Based  on  the  further  review  we  have  conducted  at  the  request  of  the  coroner,  I  can 
confirm that no further improvements are warranted such as increased signage or road 
layout change at the scene (the junction with Streetway Road).  

6  SAFETY OF ROAD USERS 

The  safety  of  our  road  users  is  an  imperative  for  our  business  in  what  we  set  out  to 
achieve, and a core value of our organisation in how we go about it. The action we have 
taken and our intention to continue to monitor the junction with Streetway Road in the 
future is to help to prevent future deaths at this location.    

7 

14 April 2020 

Signed:  

Catherine Brookes, Regional Director for East 
Midlands and West Midlands 

5