Prevention of Future Deaths reports · 2025

Leonardo Machado

Regulation 28 report to prevent future deaths, reference 2025-0611, written 5 Dec 2025. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report5 Dec 2025
Reference2025-0611
DeceasedLeonardo Machado
CoronerBrendan Allen
Coroner areaDorset
CategoryRoad (Highways 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 (1) 

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

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 

THIS REPORT IS BEING SENT TO: 

1)  Secretary of State for Work and Pensions 
2)  Secretary of State for Business and Trade 
3)  Secretary of State for Transport 
4)  Secretary of State for Education 
5)  Chief Executive of the Health and Safety Executive 

1  CORONER 

I am Brendan Joseph Allen, Area Coroner, for the Coroner Area of Dorset 

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  the  19th  April  2023,  an  investigation  was  commenced  into  the  death  of 

Leonardo Cardoso Machado, born on the 13th July 2005. 

The investigation concluded at the end of the Inquest on the 11th September 
2025. 

The Medical Cause of Death was: 

1a Traumatic Head and Neck Injuries 

1b  

1c  

2   

The conclusion of the Inquest as recorded by the jury empanelled to hear the 

Inquest  was  that  Leonardo  Cardoso  Machado  died  at  Lindsay  Road  near 

junction with St Aldhelm's Rd, Poole, Dorset on 16th April 2023. 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 On balance of probability the fact the Police attempted to effect a traffic stop 

at the County Gates Gyratory caused Leo to "make off" at high speed through 

the red traffic lights to continue to travel at speed along Lindsay Rd. 

The excessive speed of the motorbike driven by Leo was the causative factor 

in the collision causing Leo to lose control at the bend in the road and drive 

into the railings on Lindsay Rd.  

The cause of death was traumatic head and neck injuries caused by the road 

traffic collision.  

4  CIRCUMSTANCES OF THE DEATH 

Leo was 17 years of age at the time of his death. Leo “rented” an “Uber Eats” 

delivery licence, though he was too young to obtain such a licence himself. As 

a result of the rented licence, Leo was able to earn money as a food delivery 

driver. 

In the early hours of 16th April 2023 Leo was riding a 599cc Yamaha sports bike 

with an “Uber Eats” delivery box attached to the rear. He was not licenced to 

use such a motorcycle, which requires a full category A driving licence, with the 

licence holder being 21 years of age or older. Leo had been stationary on the 

motorcycle at a red light when approached by police. He made off at speed and 

subsequently  lost  control  of  the  motorcycle,  colliding  with  metal  railings and 

sustaining injuries that caused his death. 

5  CORONER’S CONCERNS 

The MATTERS OF CONCERN are as follows:   

1.  During the inquest evidence was heard that: 

i. 

There is significant national concern about the “rental” of food 

delivery licences to under 18s. In general terms, food delivery 

platforms  place  age  restrictions  on  those  who  can  obtain  a 

licence  to  deliver  food.  However,  there  appears  to  be  no 

oversight of the rental of these licences to those under the age 

limit. This places children in a vulnerable position: lone working, 

often at night, riding electric or motorised scooters, mopeds or 

2 

 
 
  
 
 
 
 motorcycles and delivering to individuals that are not known to 

the drivers.  

2.  I have concerns with regard to the following: 

i. 

There  appears  to  be  no  or  limited  oversight  of  the  practice  of 

“renting” a food delivery licence to children under 18 years of age, 

which I heard is a national issue; 

ii. 

As  a  consequence,  children  are  working  in  the  food  delivery 

economy, which involves lone working at night, with deliveries being 

made  to  the  home  addresses  of  private  individuals,  placing  the 

children in a vulnerable position;  

iii. 

That placing children in a lone working environment at night and on 

the roads on electric or motorised scooters, mopeds or motorcycles 

also  increases  the  risks  of  them  coming  to  harm  through  a  road 

traffic collision, leading to a risk of death. 

6  ACTION SHOULD BE TAKEN 

In my  opinion urgent  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, by 30th January 2026. 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. 

8  COPIES and PUBLICATION 

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

(1) 

father)  

(Leo’s mother) and 

 (Leo’s ste-

(2) 
(3) Chief Constable for Dorset Police 
(4) Independent Office for Police Conduct 
(5) Dorset Child Death Overview Panel 

 (Leo’s father) 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 At the request of the Home Office, the initial recipient of the original report to 
prevent future deaths dated 23rd September 2025, the following have also been 
sent a copy of the report: 

(1) 
(2) 
(3) 
(4) 
(5) 

 of the Department for Business and Trade 
 of the Department of Transport 

 of the Health and Safety Executive 

 of the Department for Education 

 of the Home Office 

I 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. 

9  Dated 

5th December 2025 

Signed

Brendan J Allen  

4

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 Gov Dept (PDF)
Health and Safety 
Executive 

Deputy Director for Technical 
Support and Engagement  

Health and Safety Executive  
Engagement and Policy Division 

Mr Brendan J Allen 

Area Coroner for the County of Dorset 

30 January 2026 

Dear Mr Allen 

Regulation 28 - Prevention of Future Deaths 

Thank you for your letter and Prevention of Future Deaths report of 5th December 2025, 
, and arising from the inquest into the 
addressed to HSE’s Chief Executive, 
unfortunate death of Mr Machado whilst using a ‘rented’ Uber Eats licence. 
 has 
asked  me  to  respond  to  you  in  my  capacity  as  HSE’s  Deputy  Director  for  Technical 
Support and Engagement 

This was essentially a road traffic accident, and you acknowledge that excessive speed 
was the causative factor in Mr Machado losing control of the motorcycle he was riding.  
However,  you  also  raise  concerns  around  the  rental  or  sharing  of  permits  for  these 
platforms, the employment of minors and lone working.  

In leading the response, the Health and Safety Executive (HSE) has sought the views 
of several other governmental organisations, and these are included in our response 
below  which  viewed  together  describe  a  comprehensive  framework  of  guidance  and 
legislation. However, that does not mean that we are complacent, and you will also note 
proposals to improve on the current situation. 

Riding and driving for work: 

In respect of the road traffic accident itself, HSE views that road traffic accidents are 
generally a matter for the Police to investigate and enforce, rather than HSE, using the 
most applicable legislation. This is set out in Health and Safety at Work etc Act 1974 - 
Section 3. 

The  Department  for  Transport  (DfT)  commented  that  the  safety  of  anyone  driving  or 
riding  on  our  roads  is  a  priority,  and  that  includes  those  who  drive  for  work.  The 
government expects that employers or engagers of anyone driving or riding for work to 
ensure that they are as safe as possible on our roads. DfT worked closely with the HSE 
to  update  the  joint  DfT/HSE  guidance  on  work  related  road  safety.  The  revised 
guidance, published in September 2021 and called Driving and riding safely for work, 
clearly sets out what commercial organisations and their workers, whether employees 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 or  self-employed,  must  do  to  manage  work-related  road  safety  by  reference  to  their 
obligations under law. 

DfT has also announced as part of the Road Safety Strategy that it will pilot a National 
Work-Related Road Safety Charter for businesses that require people to drive or ride 
for them. The aim of the Charter is to help employers to reduce work-related road risk 
and  improve  safety  for  all  road  users  by  promoting  good  practice,  and  to  improve 
compliance with current legislation and guidance. It will include the use of Heavy Goods 
Vehicles (HGV)s, Light Goods Vehicles (LGVs), cars, motorcycles, e-cycles and cycles. 
The pilot will run for two years and will be monitored and fully evaluated.  

The tragic death of Leonardo Cardoso Machado has raised several important concerns. 
DfT is committed to making our roads safer and we are ready to work with others to 
achieve this. Road safety is a shared responsibility, and DfT’s strategy reflects that. It 
considers action needed by government, local authorities, industry, emergency services 
and  communities  to  tackle  the  causes  of  collisions  and  save  lives.  By  investing  in 
infrastructure, education, and enforcement, DfT are taking decisive steps to make our 
roads safer for everyone. 

Sharing of permits 

The sharing of permits between licence owners and “substitutes” is a contractual issue 
and not an area HSE has any control over.  

The Department for Business and Trade (DBT) are the more appropriate governmental 
body, and they have addressed the practice of “renting” food delivery licences to under 
18’s and the concerns that this raises. 

Food delivery companies do often allow account holders to use other people to carry 
out  work  for  them  under  their  account.  This  practice  is  sometimes  referred  to  as 
substitution or sending  a  substitute.  The ability  for someone  who  is  self-employed  to 
subcontract  work  is  a  key  feature  of  self-employment  and  is  a  lawful  commercial 
arrangement.  It  is not something  that  is regulated  or licensed by government  in  food 
delivery, or many other sectors where this practice can be found.  

As the report notes, most food delivery firms require that all riders and their substitutes 
are at least 18 years old. The government has been working closely with food delivery 
firms  so  that  they  increase  the  use  of  facial  verification  checks  and  fraud  detection 
technology to ensure only registered account holders and their registered substitutes 
can work off their platforms. 

Employment of Minors: 

HSE has some high-level guidance on the employment of young people under the age 
of 18: Young people at work: Overview - HSE. The Department for Education state that 
the restrictions on child employment in the Children and Young Person’s Act 1933 apply 
to children who are of compulsory school age. Therefore, these restrictions would not 
apply  in  the  case  of  Leonardo  Cardoso  Machado  who,  as  a  17-year-old,  would  be 
classed as a ‘young worker’.  

 
 
 
 However, we note from the response from Uber Eats UK Limited to the coroner on 18 
November  2025,  that  their  terms  and  conditions  include  requirements  that  persons 
under the age of 18 are prohibited from having a delivery licence or to act as a substitute.  

Lone Working: 

It is well known and established that lone working can present a risk to workers, and 
this should form part of an employer’s risk assessment. This includes the requirement 
to  assess  risks  and  should  consider  ways  in  which  the  work  can  be  organised  to 
minimise the potential for harm.  Relevant training, supervision, monitoring and support 
should  be  provided  for  lone  workers.  HSE  specifically  considers  lone  workers  in 
providing  guidance  and  this covers both  the  employers of  lone  workers and  the  lone 
workers themselves; Lone working - HSE. 

However, HSE acknowledges that there are practical limits to what can be done in the 
driver  delivery  sector  because work  like  this  inevitably involves working  alone, to 
deadlines, often at night and with the attendant road risks.  

Lastly,  a  great  deal  of  work  is  going  on between  government  and  the  food  delivery 
industry to tighten control and reduce abuse of legitimate systems such as substitution, 
for example  this initiative Delivery firms to bolster rider security  checks  to  stop  illegal 
working - GOV.UK.   

The new Employment  Rights  Act 2025 is  also  aimed  to  address  weakness  of current 
system - Employment Rights Act 2025: overview factsheet  

I  trust  that  this  response  from  HSE,  along  with  the  contributions  from  the  other 
governmental  departments,  gives  you  confidence  and  reassurance  that  the  issues 
raised in his report are actively being addressed.  

Yours sincerely,

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