Prevention of Future Deaths reports · 2023

Christian Tuvi

Regulation 28 report to prevent future deaths, reference 2023-0239, written 10 Jul 2023. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report10 Jul 2023
Reference2023-0239
DeceasedChristian Tuvi
CoronerAndrew Harris
Coroner areaLondon Inner (South)
CategoryOther related deaths
Sourcejudiciary.uk record · original PDF
Responses published2

The report

Text extracted from the PDF text layer. Reproduced verbatim, including the scan's own layout.

REGULATION 28  

REPORT TO PREVENT FUTURE DEATHS 

1.  CORONER 

I am Andrew Harris, Senior Coroner, London Inner South 
jurisdiction 

2.  CORONER’S LEGAL POWERS 

I make these reports under paragraph 7, Schedule 5, Coroners and 
Justice Act 2009 and regulations 28 and 29 of the Coroners 
(Investigations) Regulations 2013. 

3.  INQUEST 

On 18th September 2019 the death of Mr Christian Kwame Tuvi 

, an escalator cleaner aged 44, in Waterloo Station was 

reported to the coroner by the British Transport Police.  
A forensic autopsy was conducted. An inquest was opened on 30th 
September 2019, and was suspended under CJA schedule 1(1). It was 
extended, due to the ongoing criminal investigation. On 1st March 
2022, BTP informed the coroner that there were to be no charges and 
that the matter was then referred to the Office for Road and Rail. The 
senior coroner resumed his investigation.  
The inquest did not engage Article 2 ECHR.  
On 16th June 2023, the jury returned a narrative Record of Inquest 
The medical cause of death was 1a blunt force (crash) trauma to the 
chest 1b Movement of the travellator while Mr Tuvi was in the gap. 

4.  CIRCUMSTANCES OF THE DEATH 

The jury concluded that there was an inadequate briefing to the 
cleaners, omitting the form of communication to be used, a failure to 
complete a site specific risk assessment, and a failure to give an audible 
warning that the travellator was about to be moved.  

The jury found that two other matters contributed to the death: failure 
of the person in charge to plug the inching pendant into the closest 
port to the gap being cleaned and an acceptance of variation and non-
compliance with the established method statement not being 
corrected. 

 
 
 
 
 
 
 
 5. 

THE CORONER’S MATTER OF CONCERN 

The ORR informed the coroner that in 2020 an improvement notice 
was served on Cleshar Cleaners, requiring them to provide a safe system 
of work for communicating the movement of the conveyor which does 
not rely solely on verbal communication.  

Cleshar has appealed the Improvement Notice and the Employment 
Tribunal have stayed the notice until 2024. Although the improvement 
notice is under appeal Cleshar has made some changes to improve their 
safe system of work. These included a padlock for the operative to place 
on the nearest isolator switch before entering the gap, pressing the stop 
button in, KONE discussing with Cleshar where the gap is to be left 
prior to handing over control of the machine and the risk assessment 
and method statement now identify the need for a middle person to 
relay messages.  

The improvements that Cleshar made have allowed them to resume the 
deep clean of Waterloo moving walkway. However, the TfL 
familiarisation training for working in a plant room no longer provides 
inching as part of the course. TfL expects their contractors to provide 
inching training for their operatives. Without the evidence of 
competence to inch the machine the isolation/inching function remains 
with KONE as a temporary solution. 

It is unclear why this cannot be a permanent solution. I heard from 
witnesses that it would be safer for engineers, who are present during 
deep cleans, to operate the movements of the travellator, but I was told 
that it would lead to a lack of clarity as to who was in charge. This  
seems not to be insoluble given different contractors with different 
employees is a norm on building sites working safely under HSE rules 
across the country. More likely there are undisclosed issues perhaps 
related to assumption of responsibility for risk or financial 
considerations which explain the resistance. 

The inquest heard that prior to the accident, cleaners would attend a 
TfL training course with a signed form which TfL observed was a 
certificate of competence to inch and operate the controls of the 
travellator. But the issuing manager and cleaners thought that the TfL 
course provided that training. The withdrawal of that training and the 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 inability to find another training facility, has led to the cleaners not 
being trained and so not permitted to operate the travellator. 

Cleshar Cleaners management have not in the past assessed their 
cleaners for competence to inch and there is no agreed standard of 
competence. Concerns were expressed in the inquest that most of the 
cleaners did not have English as their first language and that the risk 
assessment method statement was a huge technical document, with 
which the cleaners were not familiar and they all required training in 
the whole method of work, and not just the person in charge. 

MY CONCERN and reason for reporting this matter to the minister 
and not just the regulator and contractors, is that nearly four years have 
passed and there remains an impasse between the organizations as to 
whom should train whom, and the competence required to operate the 
travellator whilst it is being cleaned. It seems that TfL has the power to 
produce a resolution, but is leaving matters to others to resolve. It is 
hard not to conclude that there is corporate reluctance to assume risk 
for an important public service. The regulatory bodies and contractors 
in the supply chain have allowed this matter to remain unresolved for 
an unacceptable length of time and there may be a system failure in the 
allocation of responsibilities and powers in the process of contracting 
for cleaning escalators. 
________________________________________________________ 

This REPORT IS BEING SENT TO: 

6. 

1.  The Rt. Hon Mark Harper, The Secretary of State for Transport,  
Department of Transport, Zone 1/18 Great Minister House, 33 
Horseferry Road, London, SW1P 4DR 

2. 

, Chief Executive of Office for Road & Rail, 

25 Cabot Square, London, E14 4QZ  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 7.  

ACTION SHOULD BE TAKEN 

The public cannot be assured that the lessons have been learnt from this 
tragedy unless the redesigned improved system of work for cleaners is 
implemented with appropriate training and leadership in a permanent 
sustainable contracting system. These matters remain in dispute and 
may need political and regulatory enforcement. 

8. 

YOUR RESPONSE 

You are under a duty to respond to this report within 56 days of the 
date of this report, namely by September 4th, 2023.  I, the coroner, may 
extend the period.  
If you require any further information or assistance about the case, 
please contact the case officer, 

 and coroner paralegal, 

9. 

COPIES and PUBLICATION 

The report is copied to Transport for London (TfL), Cleshar Cleaning 
Services Ltd (Cleshar) and Kone Plc. as these organizations need to 
know of the report to the Department and Regulator seeking review of 
the contractual process or directions to resolve the impasse between 
them, to ensure that a permanent solution is found that secures the 
minimization of risks of deaths in cleaning moving walkways and 
escalators. It is also sent to the other interested persons:  

 representing family from Simpson Millar 

Solicitors.  

 representing 

 from Keoghs Solicitors.  

I have sent a copy of my report to the following interested persons:  

 for Transport for London.   

 for Cleshar of BCL Solicitors LLP.  
 for Kone Plc from Walker Morris Solicitors.  
 for Office of Road and Rail.  

I will also be sending a copy of my report to British Transport Police for 
information.  

 
 
 
 
 
 
 
 
 
 
 
 
 I am also under a duty to send the Chief Coroner a copy of your 
response. He 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. 

10. 

[DATE]                                       [SIGNED BY SENIOR CORONER] 

Monday 10th July, 2023  

A N G Harris

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)
Dr Andrew Harris  
HM Senior Coroner  
London Inner South HM Coroners Court  
1 Tennis Street  
Southwark London SE1 1YD 

From the Secretary of State 
The Rt Hon Mark Harper MP 

Great Minster House 
33 Horseferry Road 
London 
SW1P 4DR 

4 September 2023 

Dear Dr Harris, 

REGULATION  28  REPORT  TO  PREVENT  FUTURE  DEATHS:  MR 
CHRISTIAN KWAME TUVI, 

Thank you for your Report dated Monday 10 July 2023, following the inquest 
into the tragic death of Mr Tuvi at Waterloo Underground Station on 18 
September 2019. I note that you consider there is an unresolved matter 
relating to the provision of training and assessment of competence to operate 
travellators safely during cleaning, which you have raised with me and with 
the Chief Executive of the Office of Rail and Road, as you consider that this 
may need political and regulatory enforcement to address. 

I am responding to you in accordance with the Coroners (Investigations) 
Regulations 2013. 

As you will be aware, my Department has limited powers to intervene formally 
in transport safety matters, which are the responsibility of the Office of Rail 
and Road in its capacity as the independent Rail Safety Regulator.  
Furthermore, my Department does not have powers to intervene in London 
Underground Limited’s day-to-day operations or processes, for which it is 
separately accountable to the London Mayor as a subsidiary of TfL. 

Nonetheless, I asked my officials to investigate this matter and to report to 
me.  My officials have spoken to the Office of Rail and Road safety 
inspectors, who have been in regular contact with London Underground 
Limited throughout their investigation. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 I understand that London Underground Limited has now reached agreement 
with its contractors over where permanent responsibility should lie for 
operating its escalators during maintenance and cleaning and is in the 
process of agreeing safe systems of work before work resumes. The Office of 
Rail and Road has confirmed that it is satisfied that this will be a safe and 
effective solution to the specific concerns you raise in your Report.  I am 
assured that London Underground Limited intends to write to you very shortly 
with details of the arrangements it has agreed with its contractors to ensure 
that these concerns are fully resolved. 

Thank you once again for taking the time to raise this important matter with 
me, and I trust that my officials have been able to assist in ensuring a 
satisfactory and permanent resolution. 

I am copying this letter to 

 in the Office of Rail and Road. 

Yours sincerely, 

The Rt Hon Mark Harper MP 

SECRETARY OF STATE FOR TRANSPORT 

Copy: 

, Chief Executive Officer, Office of Rail and Road
Response from Transport for London (PDF)
12 September 2023 

Dr Andrew Harris 
HM Senior Coroner 
London Inner South HM Coroners Court 
1 Tennis Street 
Southwark 
London 
SE1 1YD 

Dear Dr Harris,  

Chief Operating Officer  

Transport for London 
Palestra  
1 97 Blackfriars Road 
London  
SE1  8NJ 

Death of Christian Tuvi at Waterloo station on 18 September 2019: 
Prevention of Future Deaths (PFD) report  

Following your inquest into the tragic death of Christian Tuvi, which took place 
between 5-16 June 2023, you issued a Prevention of Future Deaths (PFD) report 
addressed to the Secretary of State for Transport and the Office of Rail and Road 
(ORR). Your concerns related to the arrangements for training of inching 
activities on escalators and moving walks on the London Underground (LU) 
network, in particular clarity on responsibilities.  

I am aware that the Secretary of State for Transport has responded to you and 
noted that we would write to you with details of the arrangements we have put in 
place with our contractors to ensure that your concerns have been fully resolved. 
We have also been in regular discussions with the ORR about this issue and 
have given them assurance that we have addressed and resolved this issue. I 
have set out the steps we have taken below. 

You will remember that KONE plc (KONE) agreed at the inquest that training of 
their staff, or any suppliers who work for them, was their responsibility.  

In light of the report, we have discussed the training of inching activities with 
KONE. KONE has informed us that, having considered the relevant work 
arrangements, they have decided, in consultation with Cleshar Contract Services 
Ltd (Cleshar), to continue permanently with the current temporary working 
arrangements i.e. KONE engineers will undertake all inching activities on LU’s 
moving walks and escalators, which they are contracted to maintain and clean, 
so Cleshar operatives can clean the machines. KONE engineers are assessed 
and deemed competent against the National Vocational Qualification (NVQ) 
Level 3 for escalator maintenance which includes inching. KONE consider that 
this is a clear and safe way forward to ensure that they meet their responsibility 
for the cleaning of these assets. 

 
 
 
 
 
                                                           
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 We are currently working with KONE to ensure that their Safe Systems of Work, 
as well as Cleshar’s, have been updated to reflect these new arrangements. We 
want to ensure that, given the two parties are involved in an intrusive clean, the 
Safe Systems of Work are clear on who is always in control of the machine. We 
plan to complete this review with KONE by 29 September 2023.  

Thank you for your report and I hope that my response addresses the important 
concerns that it raises on escalator maintenance and training responsibilities.   

I am grateful for the opportunity to update you and have copied my response to 
the ORR. 

If you have any further questions, please do not hesitate to contact me.  

Yours sincerely 

Chief Operating Officer 
Transport for London 

cc:  

, HM Deputy Chief Inspector of Railways, Office of Rail and Road. 

, Commissioner for Transport, TfL. 

, Chief Safety Health & Environment Officer, TfL. 

, Principal Lawyer, TfL.

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