The most dangerous ladder in a transport business is not in the warehouse. It is the one welded to the back of the tanker, the catwalk along the tipper, the step up to the flatbed - used daily, in all weathers, by people whose job description says “driver”, not “working at height”. Falls from vehicles are one of the biggest single sources of serious injury in the haulage industry, and the law that governs them is the same law that governs scaffolding: the Work at Height Regulations 2005. HSE’s guidance on the regulations is short enough to read over coffee, and it applies on top of a trailer exactly as it applies on a roof.
The regulations’ purpose is to prevent death and injury from falls, and they bind employers and anyone who controls work at height - HSE’s own examples include facilities managers and building owners who contract others to work at height, which maps directly onto the sites and customers whose premises drivers work on. Three core duties follow. Work at height must be properly planned. It must be appropriately supervised and carried out by competent people. And the right type of equipment must be used. Before any of that, the risks must be assessed - the guidance is explicit that assessment comes first. There is a proportionality clause: low-risk, straightforward tasks need less planning effort. But proportionality cuts both ways: climbing onto a wet curtain-sider roof to free a snagged curtain is not the low-risk end of anything.
Employees carry duties too - to take reasonable care of themselves and others - which is why the safe system has to be usable in the rain at 5am, not just compliant on paper. A system drivers cannot follow in real conditions gets followed by nobody, and the legal position of the employer who designed it for the file is poor.
The honest starting point is a walk through the operation counting how often people leave the ground. Access to cabs and catwalks: three points of contact is the discipline, and worn steps, missing grab handles and diesel-slick boots are the enemies. Trailer beds during loading and sheeting: open edges, uneven loads, and the driver working backwards with a strap or a corner of tarpaulin. Tanker top access for loading and sampling: the highest routine exposure in the industry, which is why modern tanker fleets fit collapsible handrails and fall-protection gantries at loading racks. Curtain and roof work: freeing snagged curtains, clearing roofs, checking sheeted loads. Vehicle maintenance: fitters on top of units, tail-lift work, and the classic improvised climb on a wheel or a bumper to reach something just out of range.
Each of those is work at height, each is assessable, and for most of them a control already exists that keeps feet off the furniture: ground-operated sheeting, loading-rack gantries, extending poles for load checks, proper access equipment for maintenance.
The planning duty is where most fleets have the largest gap, because driver work at height happens dispersed and unsupervised. A risk assessment that lives in the office cannot plan a specific climb at a specific quarry - so the planning has to be built into the rules drivers carry: which tasks are done from the ground only, which need the equipment on the vehicle, which are refused and escalated. Competence is the second gap: drivers are trained to drive, and the work-at-height part of their job often rides on assumption. Short, practical training on access, three points of contact, equipment checks and the refusal route is cheap against a single fracture claim.
Equipment is the simplest gap to close and the most commonly open: access steps and handholds inspected on the walkround and repaired when flagged, catwalks and working platforms with edge protection where people work at trailer height, fall protection at any fixed location where staff regularly work at height, and a ban - actually enforced - on improvised climbing. The regulations’ equipment duty is not satisfied by the ladder being there; it is satisfied by the ladder being the right equipment, in the right condition, used the right way.
Because so much driver work at height happens on third-party premises, the shared-duty question from the regulations matters as much here as anywhere: sites that control the activity owe duties too, and a quarry, farm or distribution centre whose layout forces drivers onto trailers is part of the risk, not a bystander. Fleets that ask their regular destinations what access provision exists - and put the answers in the driver’s job information - find the answers improve, because sites respond to being asked formally. The Work at Height Regulations have been on the books since 2005, and falls from vehicles still fill the industry’s injury statistics. The gap is not knowledge; it is treating the top of the trailer as a workplace that deserves the same planning as the ground beneath it.