Prevention of Future Deaths reports · 2024

Tony Williams

Regulation 28 report to prevent future deaths, reference 2024-0385, written 18 Jul 2024. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report18 Jul 2024
Reference2024-0385
DeceasedTony Williams
CoronerJacqueline Devonish
Coroner areaCheshire
CategoryAccident at Work and Health and Safety related deaths
Sourcejudiciary.uk record · original PDF
Responses published1

The report

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

Regulation 28: REPORT TO PREVENT FUTURE DEATHS

NOTE: This form is to be used after an inquest.

REGULATION 28 REPORT TO PREVENT DEATHS

THIS REPORT IS BEING SENT TO: Health and Safety Executive

1

CORONER

I am Jacqueline DEVONISH, Senior Coroner for the coroner area of Cheshire

2

CORONER’S LEGAL POWERS

I 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.

3

INVESTIGATION and INQUEST

On 10 December 2020 I commenced an investigation into the death of Tony WILLIAMS
aged 45. The investigation concluded at the end of the inquest on 15 July 2024. The
conclusion of the inquest was that the death was a Misadventure.

4

CIRCUMSTANCES OF THE DEATH

On 2 December 2020, Tony Williams, an HGV driver for
hay to
at
experienced in the strapping and loading of Hesston bales. Three bales were loaded width
ways, the opposite direction to the rest of the bales, on the back end of the vehicle.

, was delivering bales of
in Cheshire. Thirty-three hay bales were loaded onto the 45ft HGV

in Suffolk by the farm director in the presence of Mr Williams, who was

On the journey from Suffolk, somewhere along the route an ANPR camera had caught an
image of hay overhanging the back of the vehicle. When arriving at
, with
the assistance of a banksman, Mr Williams reversed down
road with a known slope comparable to a wheelchair ramp. Mr Williams was witnessed by a
Farmhand unstrapping the load when the three width ways bales fell from the back. Two of
which fell on top of Mr Williams.

a public domain

The Farmhand who witnessed the unstrapping, removed the bales from Mr Williams with his
telehandler and administered CPR with guidance from the ambulance service operator.
When the ambulance arrived advanced life saving measures were administered to no avail.
He was pronounced dead at the scene at 11:01 hours.

5

CORONER’S CONCERNS

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

The MATTERS OF CONCERN are as follows:
The configurations for safely loading bales widthways, on a slope of 4.5 degrees and
utilising crisscross strapping were considered in evidence. HSE produced laser
measurements and images identifying the centre of gravity and risks associated with
unloading overhanging bales on a slope when the most rearward bales are loaded
widthways. HSE concluded that the accident would not have occurred if Mr Williams had not
unloaded with the overhang facing downhill.

Regulation 28 – After Inquest
Document Template Updated 30/07/2021

 It became apparent that there were no clear images in the guidance or support materials
produced by HSE to assist drivers who load and unload bales.

6

ACTION SHOULD BE TAKEN

In my opinion action should be taken to prevent future deaths and I believe you (and/or
your organisation) have the power to take such action.

7

YOUR RESPONSE

You are under a duty to respond to this report within 56 days of the date of this report,
namely by September 10, 2024. I, the 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

8

I have sent a copy of my report to the Chief Coroner and to the following Interested
Persons

I have also sent it to Mr William’s family, Liverpool University,
and

,

who may find it useful or of interest.

I am also under a duty to send a copy of your response to the Chief Coroner and all
interested persons who in my opinion should receive it.

I may also send a copy of your response to any person who I believe may find it useful or
of interest.

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.

9

Dated: 18/07/2024

Jacqueline DEVONISH
Senior Coroner for
Cheshire

Regulation 28 – After Inquest
Document Template Updated 30/07/2021

Responses

1 response 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 Hse (PDF)
Health and Safety 
Executive 

INVESTIGATION DIVISION 

Steve Parncutt 

INV UNIT 2 HEAD OF OPS - P 
Bootle - Redgrave Court 

Merton Road 
Bootle 
MER 
L20 7HS 

Tel: 

Line Manager 
Sarah Jardine 

HM Senior Coroner Jacqueline Devonish 
Cheshire Coroner's Service 
Museum Street 
Warrington 
WA1 1JX 

Reference  

Date 6th September 2024 

Dear HM Senior Coroner Devonish 

PREVENTION OF FUTURE DEATHS REPORT – TONY WILLIAMS 

Thank you for your email and attached Regulation 28 “Report to prevent future deaths” dated 18/07/2024.  
The report outlines matters of concern arising from the inquest into the death of Mr Tony Williams. Mr 
 in Cheshire on 2nd December 
Williams was killed while unloading bales from a trailer at 
2020.    I  am  the  Health  and  Safety  Executive’s  (HSE)  Head  of  Operations  covering  the  area  of  Great 
Britain (GB) in which the incident occurred. In providing this response I have consulted with the team that 
sets  HSE  operational  policy  in  relation  to  safe  work  with  bales,  and  the  team  responsible  for  HSE 
operational policy in relation to transport.  

You raise the following MATTERS OF CONCERN in your report: 

It became apparent that there were no clear images in the guidance or support materials produced by 
HSE to assist drivers who load and unload bales”. 

Background 
HSE recognise that unstable loads present a serious risk of harm.  Vehicle loading, unloading 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.  In this response, although I have made reference to some DVSA guidance, I will address the 
workplace  safety  aspect  as  other  agencies  are  better  placed  to  address  any  concerns  regarding  how 
material is transported by road. 

Your concerns for HSE to address 
Health and safety legislation is goal setting in its nature, rather than prescriptive. The Health and Safety 
at  Work etc. Act 1974 and Regulations made under it require employers to assess the risk from work 
operations, including working with bales, and provide control measures to reduce these risks, so far as is 
reasonably practicable.  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 To assist employers and provide a framework for compliance with the law, HSE produce guidance for 
industry to follow.  In relation to working with bales in agriculture, HSE produced publication INDG125(rev 
3)  “Safe  working  with  bales 
from  our  website  at: 
https://www.hse.gov.uk/pubns/indg125.pdf.   Whilst there is guidance on safe working with bales in other 
HSE publications, such as “Farmwise”  and “What a good farm looks like” (both available free from the 
HSE website), INDG125 is HSE’s primary guidance document for the safe loading and stacking of bales.   
In addressing your concerns, this reply will focus predominantly on INDG125.  

in  agriculture”  which 

is  available 

free 

Bales and the trailers on which they are transported, may be of a range of shapes and sizes.  INDG125 
must therefore contain sufficient information to be useful to duty holders such that they can plan for safe 
operation  of  activities,  but  also  be  broad  and  flexible  enough  to  reflect  the  variations.    The  guidance 
therefore sets out the principles that should be adopted rather than be prescriptive for specific situations. 

In relation to the safe stacking of bales, the principles are set out on pages 2, 3 and 4 of the guidance 
supported by Figures 1, 2 and 3.  In considering the concerns raised in your report we have concluded 
that there is sufficient information, by way of both images and supporting material, to allow duty holders 
to plan their stacking operations safely and that the current guidance is satisfactory.  

In relation to the safe loading and unloading of bales, the principles are set out throughout the guidance 
document  but  specifically  on  pages  6  and  7.  We  acknowledge  the  absence  of  images  in  this  section 
however, having considered the concerns raised in your report we have concluded that there is sufficient 
information that will allow duty holders to plan and carry out the loading and unloading of bales safely and 
that the current guidance is satisfactory.             

Guidance on the safe loading and unloading of vehicles is also provided in HSE publication HSG136, A 
Guide to Workplace Transport.  Although it does not specifically reference bales, the publication sets out 
employers’ responsibilities under health & safety legislation and provides guidance on key safety issues 
which also includes managing vehicle movements on sites, work at height, and coupling and uncoupling 
articulated vehicles.  It too takes a broad and flexible approach due to the complexity and variety of the 
many  different  transport  operations  in  GB  and  is  available  free  from  the  HSE  website  at 
https://www.hse.gov.uk/pubns/books/hsg136.htm. 

Other enforcing authorities and industry associations 
HSE  also  works  closely  with  other  enforcing  authorities  and  industry  associations  to  support  them  in 
producing their own industry-specific detailed guidance.  

This  includes  work  undertaken  with  the  DVSA  and  trade  associations  on  the  production  of  on-road 
guidance for drivers and operators.  In recognising that loads come in a variety of shapes and sizes, as 
do the vehicles transporting them, the DVSA guidance is also generally not prescriptive but sets out the 
general principles of load securing and advice to help vehicle operators and drivers comply with the law. 

The current version of this guidance can be found at https://www.gov.uk/government/publications/load-
securing-vehicle-operator-guidance/load-securing-vehicle-operator-guidance.  An updated version is due 
to be published in autumn 2024 which will contain advice that bales should be properly supported by the 
vehicle or trailer load bed. 

Further queries or comments on the DVSA guidance are best directed to the DVSA. 

In conclusion 
Having carefully considered the content of your report and your concern around a lack of information HSE 
provides we have concluded that the guidance currently available in relation to the safe stacking, loading 
and unloading of bales is sufficient and does not currently require further images or supporting material.  
HSE legislation is goal setting and not prescriptive.  As such HSE guidance documents adopt a broad 
and flexible approach that will allow duty holders to plan and safely undertake work activities for a wide 
range of situations.   

2  

 
 
 
 
  
 
 
 
 
 
 
 
 However we keep HSE guidance, including INDG125, under periodic review and we will keep your report 
on record for consideration when it is next reviewed.    

Yours sincerely, 

Head of Operations 

3

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