Prevention of Future Deaths reports · 2020

Ashley Holden

Regulation 28 report to prevent future deaths, reference 2020-0096, written 17 Apr 2020. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report17 Apr 2020
Reference2020-0096
DeceasedAshley Holden
CoronerPaul Smith
Coroner areaLincolnshire
CategoryOther related deaths · Accident at Work and Health and Safety related deaths
Sourcejudiciary.uk record · original PDF
Responses published2

The report

Text recovered by OCR from a scanned PDF. OCR is imperfect: check anything you rely on against the source PDF. Reproduced verbatim, including the scan's own layout.

HM CORONER
Lincolnshire

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS

THIS REPORT IS BEING SENT TO:
1. Department of Transport
2. Health and Safety Executive

| CORONER

| am Paul Duncan Smith, Area Coroner, for the Coroner area of Lincolnshire, 4 Lindum Road,
Lincoin, LN2 1NN

CORONER’S LEGAL POWERS

| make this report under paragraph 7, Schedule 5, of the Coroners and Justice Act 2009 and
regulations 28 and 29 of the Coroners (Investigations) Regulations 2013.

http://www. legislation.gov.uk/ukpga/2009/25/schedule/5/paragraph/7

http://www legislation.gov.uk/uksi/2013/1629/part/7/made

INVESTIGATION and INQUEST

On 19 November 2018 | commenced an investigation into the death of Ashley Mark Holden, aged
27. The investigation concluded at the end of the inquest on 11 December 2019. The conclusion of
the inquest was that Mr Holden died as a result of an accident, the medical cause of death being:

la. Head Injury

CIRCUMSTANCES OF THE DEATH

1. On 10 November 2018 Ashley Holden was employed as an HGV driver. He was instructed
by his employer to visit Staples Farm, Main Road, Stickney. Boston to collect a quantity of
straw bales.

2. Although his employment had not commenced until 7 November 2018 he had visited that
farm on previous occasions and had collected a similar load of bales without incident.

3. On 10 November, as previously, the trailer was loaded for him by farm operatives and the
bales were loaded in accordance with the normal pattern.

4. The trailer had an extendable bar fitted to the rear which lengthened the trailer bed by
approximately two feet. After the trailer had been fully loaded, Mr Holden noted that the
bales, as loaded, were overhanging the trailer bed. He requested that a number of bales be
removed from the rearmost section of the trailer as he wished to check that the bar was
fully extended.

5. The farm operative removed a total of 9 bales from the very rear of the trailer, following
which Mr Holden and the operative confirmed that the bar was fully extended. It was pulled
out by an additional couple of inches only.

6. As that occurred, two of the remaining bales, being unstable, fell from the trailer, one of
them striking Mr Holden and forcing his head onto the extended trailer bar where he
sustained fatal injury.

CORONER’S CONCERNS

During the course of the inquest the evidence revealed matters giving rise to concern. In my opinion
there is a risk that future deaths will occur unless action is taken. In the circumstances it is my
statutory duty to report to you.

The MATTERS OF CONCERN are as follows. — | received evidence that;

1. Fatalities from falling bales are an acknowledged risk within agriculture with a number of
fatalities annually.

2. There are two specific guidance documents available to the public which are relevant to
this issue;

e Department of Transport Code of Practice, “Safety Loads on Vehicles” (2002)
e Health and Safety Executive (HSE), “Safe Working With Bales in Agriculture”
(2012)

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.
6. The provision of definitive guidance would be welcomed by those working within
agriculture.
ACTION SHOULD BE TAKEN

In my opinion action should be taken to prevent future deaths and | believe you AND/OR your
organisation has the power to take such action.

YOUR RESPONSE

You are under a duty to respond to this report within 56 days of the date of this report, namely by
10 July 2020. |, the Area Coroner, may extend the period.

Your response must contain details of action taken or proposed to be taken, setting out the
timetable for action. Otherwise you must explain why no action is proposed.

COPIES and PUBLICATION

I have senta ~ of ~ _ to the Chief Coroner and to the following Interested Persons

Thorley Brothers Ltd
Health and Safety Executive
| am also under a duty to send the Chief Coroner a copy of your response.

The Chief Coroner may publish either or both in a complete or redacted or summary form. He may
send a copy of this report to any person who he believes may find it useful or of interest. You may
make representations to me, the Coroner, at the time of your response, about the release or the
publication of your response by the Chief Coroner.

Dated this 17th day of April 2020

avers, Ce

Paul D Smith
Area Coroner
Lincolnshire

Responses

2 responses published against this report on judiciary.uk. A response is a body's written reply to the coroner's concerns; publication is at the discretion of the Chief Coroner's office, so an absent response does not mean nobody replied.

Response from Department for Transport (PDF)
• 

Department 
for Transport 

Paul  Smith 
HM Area Coroner 
4 Lindum  Road 
Lincoln 
Lincolnshire 
LN2  1NN 

Dear Mr Smith, 

Baroness Vere of Norbiton
Minister for Roads, Buses and Places 

Great Minster House 
33  Horseferry Road 
London
SW1P4DR 

Tel : 0300 
E-Mail  : 

dft.gov.uk 

Web site: www.gov.uk/dft 

Our Ref: 
Your Ref: 

7 July 2020 

I am writing  in  response to the 'Regulation 28'  report issued on  17 April 2020.  I 
am  replying  as the Minister responsible for this issue. 

On behalf of the Department for Transport (DfT),  I would  like to take this 
opportunity to acknowledge the concerns you  have raised  regarding the tragic 
incident which resulted  in the death of Mr Ashley Mark Holden on  10 
November 2018. 

In  preparing this response my officials have consulted with the following: 

•  Driver and Vehicle Standards Agency (DVSA) 
•  Health & Safety Executive (HSE) 

Your report outlined a number of concerns relating to guidance for the safe 
loading and unloading of bales and the consistency of existing HSE and DfT 
guidance, which you considered to be insufficiently detailed to avoid the 
occurrence of unapproved and  potentially unsafe working practices. 

I understand you  have sent a similar letter and report to HSE. The report you 
have written offers clear scope for my department to take a lead in reviewing 
previous DVSA guidance, whilst working with  HSE to reach a consistent 
approach to future guidelines. 

There are two relevant and specific guidance documents available to the public, 
which you  have reviewed and  noted as being inconsistent in their approach. 
You have also highlighted that the most recently published guidance does not 
currently make proper reference to the earlier guidance. 

 We propose: 

•  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. 

•  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 mor~ -
https://www.hse.qov.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. 

•  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. 

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

BARONESS VERE OF NORBITON
Response from Health Safety England Redacted 1 (PDF)
Health and Safety 
Executive 

Engagement & Policy Division 

Agriculture,  Vulnerable workers, 
Waste & Recycling  Unit 
Hornbeam House 
Electra Way 
Crewe 
CW1  6GJ 

Tel : 020 -

§)hse.gov.uk 

http://www.hse.qov.uk/ 

Head of Unit 

HSE 

Paul Smith 
HM Area Coroner for Lincolnshire 
Lincoln Coroners' Court & Office 
4 Lindum  Road 
Lincoln 
Lincolnshire 
LN2  1NN 

3rd  July 2020 

Your Reference: 02848-2018 

Dear Mr Smith 

Inquest into the death of Ashley Mark Holden - Regul~tion 28 report. 

Thank  you  for  your  letter  dated  20  April  2020  to  Inspector . . . . . . and  the  associated 
operational  policy  in 
Regulation  28  report  dated  17  April  2020.  I  lead  a  team  th~ 
relation to the agriculture sector and this  includes safe use and stacking of bales in  farm  work. 

Vehicle  loading  and  load  securing  cross  over  two  areas  of  legislation:  road  traffic  which  is 
enforced by the  Driver & Vehicle  Standards Agency (DVSA)  and police forces,  and workplace 
safety  which  is  enforced  by  HSE  and  local  authorities.  As  such,  HSE  works  closely  with 
DVSA,  the  police,  Highways  England,  and  the  Office  of  the  Traffic  Commissioner  to  ensure 
that  guidance  is  available  to  vehicle  operators  and  drivers  to  help  them  comply  with  their 
duties on  the road  and in the workplace (e.g. farm or factory). 

I understand you  have sent a similar letter and report to the  Department for Transport (DfT). 

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  produce  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. 

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 

 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 then into account at the next review. 

The  overarching legal framework  in  place for workplace safety includes the  Health and  Safety 
at  Work  etc.  Act  1974  and  this  applies  to  work  with  bales.  The  Act,  and  Regulations  made 
under  the  Act,  require  employers  to  assess  the  risk from  work  operations,  including  loading 
activities,  and  provide  control  measures  to  reduce  these  risks,  so  far  as  is  reasonably 
practicable.  Of  relevance  to  loading  are  the  Lifting  Operations  and  Lifting  Equipment 
Regulations  1998  (LOLER)  which  set  out  what  duty holders  involved  in  any  lifting  operation 
must  do  to  comply  with  the  law.  Every  lifting  operation  is  different,  but  the  heart  of  LOLER 
requires all lifting work to be properly planned and organised. 

When  handling and loading bales,  control  measures would  normally include the following: 

•  Planning  the  configuration  of  the  load  and  the  loading  operation.  The  configuration  of 
the load will vary depending on  a number of factors including but not limited to the type 
of vehicle, the type of bale and the  nu.mber of bales. 

•  Using  a  competent  person  who  is  able  to  stack  bales  safely.  The  competent  person 
should  understand the  risks  when  loading  bales,  including  that  bales  shift  when  they 
get compressed and settle. 

•  Using  suitable  lifting  machinery to  load  bales.  The  machinery should be  operated  by a 

trained and competent person. 

•  Keeping pedestrians and all other people out of the way during loading. 

•  Not overloading the trailer. 

•  Not stacking bales beyond the edge of the trailer. 

•  Only allowing  securing  of the load to take place  after the  load has been  assessed by a 

competent person as being  stable. 

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. 

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. 

We  keep  guidance,  including  INDG125,  under periodic  re-evaluation.  When  INDG125  is  next 
reviewed we will consider whether improvements can  be made. 

Yours sincerely 

Acting Head of Health, Engagement,  Livestock and  Pesticides 
Agriculture Sector 

2

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