Paul Collingridge

Affinity Water Limited 
Tamblin Way 
Hatfield 
Hertfordshire AL10 9EZ 

4 April 2025 

Sonia Hayes 

Area Coroner for Essex 

Seax House 

Victoria Road South 

Chelmsford, CM1 1QH 

Dear Ms Hayes 

Inquest  into  the  death  of  Paul  Collingridge:  Report  under  Regulation  28  of  the  Coroners 
(Investigations) Regulations 2013 (Your Ref: 2025-0100) 

We  are  writing  in  relation  to  the  above  inquest  and  in  particular  the  above-mentioned 
report  of  20 February 2025 (the  “PFD  Report”)  that  Affinity  Water  Limited  (“Affinity”)  have 
received from yourself. We have duly considered the issues raised in the PFD Report and this 
letter serves as Affinity’s formal response to the same. 

In the first instance, Affinity extends its deepest sympathies to the family, fiancée and friends 
of Paul, and to anyone else who may be affected by his loss. 

Secondly, we thank you for forwarding us a copy of the PFD Report that was made following 
the  inquest  into  Paul’s  death.  Affinity  always  strives  for  high  standards  of  safety  and 
welcomes opportunities to improve the services it provides to the public. 

Affinity  has  a  shared  vision  that  “we  all  have  a  responsibility  to  make  sure  that  everyone 
goes home to friends and family safely everyday” and we are committed to achieving zero 
harm  by  promoting  a  culture  of  collaboration,  awareness  and  prevention.  In  helping 
achieve this vision, Affinity has in place robust health and safety measures and a good and 
collaborative  relationship  with  its  various  stakeholders  including  local  councils  and  its 
contractors. 

Matters of Concern 

You  have  asked  for  a  response  to  several  matters  of  concern  in  your  report  and  our 
responses to these concerns are set out below, including details of action taken or proposed 
to be taken and setting out a timetable for action, or alternatively explaining why no action 

 is  proposed.  We  have  not  provided  a  response  to  the  second  matter  of  concern  as  the 
Safety  at Street  Works Code  of  Practice  (the  “Code”)  is  published and  controlled  by  the 
Department of Transport (DfT) and therefore we do not believe that Affinity is required to 
respond to that point. 

(1)  Matter  of concern:  Where  Road  Works  Permits are required by utility  companies 
these are often urgent to carry out vital repairs. This can mean that roadworks are 
set up in hours of darkness and may cause difficulties calculating distances as set 
out in the Safety at Street Works Code of Practice. 

(2)  Matter  of  concern:  A  road  works  warning  sign  was  placed  at  the  junction  that 
joined the carriageway of a road that obscured visibility of traffic joining the main 
carriageway. Whilst this did not cause or contribute to this incident this was not in 
accordance with the Code of Practice. 

As recognised in the PFD Report, it is sometimes necessary for utility companies to carry out 
urgent works, meaning that roadworks are set up in the hours of darkness, which can cause 
difficulties in the calculation of distances set out in the Code. 

Public safety, as well as the safety of its personnel, is of paramount importance to Affinity. 
To ensure this, Affinity has in place robust processes for ensuring compliance with roadworks 
requirements, including ensuring all personnel are trained and qualified to carry out works 
under the New Roads and Street Works Act 1991 (“NRSWA”); that all operatives carrying out 
street works understand the requirements of the NRSWA and the Code; that all operatives 
are trained on and understand our common standards relating to safety when carrying out 
works in the public highway; and the production of site specific risk assessments and safe 
systems of work for all street works. 

Affinity use traffic management contractors to set up its roadworks. All of our contractors 
are  appointed  following  a  rigorous  procurement  process  that  assesses  the  contractor’s 
health and safety compliance, and all of our contracts contain requirements for adherence 
to  health  and  safety  standards  and  KPIs  regarding  the  conduct  of  street  works.  Affinity’s 
zero harm policies are also fed down to its contractors, including regular partnership forums 
to discuss health and safety matters.  There are also monthly and weekly reporting of street 
work  performance  to  ensure  compliance  with  health  and  safety  and  street  work  legal 
requirements. 

Following  Paul’s  death,  Affinity  reviewed  its  traffic  management  practices  including  the 
strengthening  of  our  planning  and  execution  of  emergency  works  and  have  already 
implemented stricter protocols with regard to oversight of our contractors.  Regular audits 
and assessments are carried out to monitor adherence and identify areas for continuous 
improvement.  This  has  resulted  in  a  significant  reduction  in  the  number  of  street  works 
requiring emergency permits. 

(3)  Matter of concern: The fatal incident that occurred on 6 December 2022 was not 
notified  on  the  retrospective  permit  application  for  roadworks  on  the  following 
day.  There  is  no  requirement  for  a  fatality  within  roadworks  be  notified  on 
application for an application for a permit. 

 
 
 
 
 
 
 Affinity has a good and proactive relationship with the local councils in its supply areas, and 
we regularly attend stakeholder groups to discuss any issues with health and safety when 
conducting street works. 

Affinity carried out a review of its permit application processes following Paul’s death and 
again following the inquest, and we have made a number of changes to our processes, 
including  additional 
resourcing  to  ensure  for  prompt  permit  applications,  better 
communications  with  councils  regarding  permitting  and  improving  our  training  and 
operational protocols to reinforce compliance with all permitting requirements, particularly 
for emergency or out-of-hours works. 

Affinity  will  also  work  collaboratively  with  DfT  and  councils  in  relation  to  any  proposed 
revisions to the Code and/or any new rules with regard to permit applications and the safe 
conduct of roadworks. 

Yours sincerely 

Director of Customer Delivery

Sonia Hayes 
Area Coroner 
Essex Coroner’s Service 
Seax House, Victoria Road South 
Chelmsford, Essex  
CM1 1QH 

From the Parliamentary  
Under Secretary of State  

Great Minster House  
33 Horseferry Road  
London  
SW1P 4DR 

Tel: 0300 330 3000  
E-Mail: 

Web site: www.gov.uk/dft 

Our Ref: 

      21 May 2025 

Dear Ms Hayes, 

Thank you for your letter of 21 February regarding your Regulation 28 Report 
about the tragic death of Paul Stephen Collingridge on 12 December 2022. 
May I begin by expressing my deep sadness about Paul Collingridge’s death 
and offering my condolences to his family and loved ones. I am also very 
sorry that there has been a delay in responding to your report. 

I would like to make clear that road safety is one of my Department’s highest 
priorities. Too many people are killed and seriously injured in road traffic 
collisions, and this government will work hard to prevent these tragedies. As 
part of this, it is vital that we ensure safety at street and road works for road 
users and workers. 

My Department is responsible for the Safety at Street Works and Road Works 
Code of Practice (“the Safety Code”) which is statutory guidance that must be 
adhered to at all street and road works sites in England, Scotland, Wales and 
Northern Ireland. The code of practice seeks to ensure street and road works 
sites in the highway are set up safely in the interest of those carrying out the 
works and road users, including pedestrians and those with disabilities. The 
Safety Code is issued under section 65 of the New Roads and Street Works 
Act 1991 and section 174 of the Highways Act 1980. Failure to comply with 
the code is evidence that an offence of failing to comply with safety measures 
under section 65 of the 1991 Act has been committed.   

I would like to address the matters of concern you raised in your report.  

You raised several concerns about how set distances can be measured 
accurately when a work site is set out with signing and guarding as required 
by the Safety Code. 

 
 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 You made references to the use of street furniture and road markings to 
determine distances and measuring distances accurately in the hours of 
darkness. The Safety Code details the sequence for setting out a street work 
site with reference to a table of distances. These distances are determined 
with reference to the street work site and do not depend on the presence of 
street furniture or road markings. The Safety Code makes it clear that it is the 
responsibility of those carrying out the works to ensure that the distances are 
measured accurately. This also includes during the hours of darkness. Failure 
to comply with the distances set out in the Safety Code is evidence that an 
offence for failing to comply with the Safety Code has been committed. If it 
appears to the highway authority that an undertaker has failed to comply with 
the Safety Code, they may take necessary steps and recover their 
reasonable costs from the undertaker. 

The Safety Code also states that bends in the road must be considered 
before setting up work sites. If a site is on or near a bend in the highway, then 
extra care must be taken to ensure safety. This includes providing additional 
advance signs, using reflective barriers and ensuring adequate visibility for 
both drivers and workers at all times of the day. 

You raised a further concern regarding a sign that was placed incorrectly at a 
junction which obscured visibility but was not a contributing factor to Mr 
Collingridge’s death. It appears that the placement of the sign was not in 
accordance with the Safety Code. However, it is for the local highway 
authority that granted the permit to decide on any enforcement action. It 
would have been for them to do this at the time of the incident. 

You raised a final concern that the fatality was not mentioned on the permit 
application for the works. For immediate works, permits can be submitted 
within two hours of arriving on site. If a fatality happens at the site, there is no 
requirement for it to be referred to on the permit application, as the permit is 
concerned with agreeing timings and durations of works. It is the Safety Code 
and the risk assessments that are carried out that take account of incidents to 
ensure sites are set up correctly.     

The Safety Code was last published in 2013 and is currently in the process of 
being updated, with a consultation due to take place in early summer. We are 
inviting comments on whether there are any parts of the Safety Code that can 
be improved to maximise safety, and we plan to publish an updated version 
by the end of 2025. I will ensure that we take into account your report when 
completing this work.  

I am sorry again for the lengthy delay in responding to your letter. This was 
due to handling errors within the Department. My officials will review this case 
and ensure necessary training is undertaken to avoid delays occurring in the 
future. 

 
 
 
 
 
 
 
 
 I am sending a copy of this letter to the recipients of your report. 

Yours sincerely, 

MINSTER FOR THE FUTURE OF ROADS

Subject: Response to Coroner’s Regulation 28 Report 

We are writing in response to the concerns raised in the Regulation 28 Report issued 
following the tragic incident that occurred on 6 December 2022. Firstly, we would like to 
express our deep condolences to the family of Mr. Paul Collingridge. The loss of life is 
deeply saddening, and our thoughts are with them. 

The role of Essex County Council in the regulation of street works is that it has to 
operate a statutory scheme made by the Department for Transport.  Certain 
organisations called ‘statutory undertakers’ have the right to work in the highway; 
although they need a permit applied for in advance – other than in an emergency where 
they are required to apply for a retrospective permit if the works are urgent – we can 
only issue permits to regulate hours of work and to co-ordinate timings, we do not have 
any ability to refuse permission for works done in accordance with the Safety at Street 
Works Code of Practice (the Code).  We can encourage good practice in some ways, 
but as statutory undertakers work with many different local authorities, local 
authorities are required to operate standard systems. Also, all local authorities and 
statutory undertakers are required to work with an online road works system for permits 
known as Street Manager, which is supplied by others.  Our response has to be viewed 
in this context. 

With regard to the points raised in the report, we wish to address the following: 

1.  Road Works Permits and Setup in Hours of Darkness.  All work is more 

difficult during the hours of darkness.  Undertakers and those working on their 
behalf are responsible for ensuring emergency works are set up safely and are 
required to have a trained and qualified person on site to ensure compliance 
with the Code.  ECC does not have the ability to inspect all emergency 
roadworks as that does not form part of the safety system. 

2.  Variations in Street Furniture and Road Markings: In general, road markings 
are maintained to standard lengths but everyone working in the highway – 
including statutory undertakers  - will appreciate that there will always be 
variations to take account of local features in the road such as junction 
locations and curvature in the road.  Road markings will also fade over time as a 
result of weather conditions, high traffic volumes, and other factors. At Essex 
County Council, we employ a robust inspection system according to our 
Maintenance Strategy, adopting a risk-based approach to identify and prioritise 
any required works. We also note that the Safety at Street Works Code of 
Practice provides guidance as to how to proceed in setting up appropriate traffic 
management. Regarding curved carriageways, the absence of specific guidance 
on distance calculation in the statutory Code of Practice is acknowledged. While 
this remains a broader area for review for the Department for Transport, Essex 
County Council is prepared to support any request from the Department of 
Transport to improve the Code to address such circumstances.  There is an 
overarching duty for statutory undertakers to have a safe system of work and the 
training they have will cover this. 

 3.  When applying for retrospective permission for street works there is no 

requirement for a statutory undertaker to notify the authority of any serious 
incidents that have occurred during the emergency period.  There is a 
national database run by the Department for Transport named Street Manager.  
This is the way that all local authorities communicate with all statutory 
undertakers.  That database does not have a data field to allow permit 
applicants to report incidents or unusual events. We will raise this with the 
Department for Transport.  However, the involvement of the police in any fatal 
road accident already provides a communications channel, meaning that in 
practice ECC is notified quickly of any fatalities and can quickly take any 
necessary action that it has the power to take.   

In closing, Essex County Council is fully committed to working with all parties involved 
in this matter to improve safety standards and prevent similar incidents in the future. 
Please do not hesitate to contact us if we can provide further assistance.

Subject: Inquest into the death of Paul Collingridge: Report under Regulation 28 of the Coroners 
(Investigations) Regulations 2013 

Dear Ms Hayes, 

HTML is not in a position to respond or comment in relation to recommendations 5 (1), (2) and (4) of the 
Regulation 28 Report.  

Insofar as recommendation 5 (3) is concerned, HTML can confirm that it undertook a full review of 
emergency works procedures which resulted in new design layouts for all traffic light schemes on all 
road speeds. These provide additional more detailed guidance and direction on the placement of signs 
and were rolled out across the business on 23rd January 2025.  

A specific toolbox talk addressing this issue and the above changes, was devised and rolled out across 
the business on 30th January 2025. 

In addition, an additional question has been added to the installation process flow which requires the 
relevant operative to answer and record whether sight lines to signage have been checked and assessed as 
appropriate. 

Yours faithfully, 

Managing Director 

Hatton Traffic Management Limited 
1 Horton Park, Seaton Burn, Newcastle upon Tyne, NE13 6BU