The compliance conversation in transport usually faces outward: the road, the roadside check, the O-licence. But some of the most serious vehicle incidents in the industry happen inside the fence - the shunter who did not see the forklift, the driver crushed coupling up, the agency driver reversing across a dark yard. HSE is blunt about it: every year there are accidents involving transport in the workplace, some fatal. People are knocked down, run over, or crushed against fixed parts by vehicles including HGVs, lift trucks and trailers. People also fall from vehicles - getting on or off, working at height, or during loading and unloading.
Your yard, dock, and loading bay are workplace transport, and health and safety law applies to them as much as the road traffic acts apply outside the gate.
HSE’s starting point is that your risk assessment must consider all workplace transport activities, including loading and unloading. Their method is disarmingly practical:
That last point cuts both ways for our industry: your own drivers are the vulnerable visitors on customer sites, and visiting drivers are the vulnerable strangers in your yard. The driver who does not know where pedestrians walk, which way the one-way system runs, or where to stand during loading is at risk precisely because nobody told him - and if your site is the one he is hurt on, that is your risk assessment under examination.
HSE’s site measures read like a description of the yard every operator wishes they had:
The theme is separation - physical, not painted-on optimism. A pedestrian walkway that crosses the artic reversing line three times is not separation; it is a schedule of future incidents.
The vehicle side extends the maintenance duty into specifics: vehicles suitable for their purpose, maintained in good repair with particular attention to braking, steering, tyres, lights, mirrors and safety systems. Two design points deserve emphasis. First, remove the need for people to climb on vehicles where possible - gauges and controls accessible from ground level - and where climbing is unavoidable, provide well-constructed ladders, non-slip walkways and guard rails. Falls from vehicles are a named killer in this guidance, and every sheeting operation on a flatbed is within it. Second, reversing aids such as CCTV where appropriate - and, for relevant plant, rollover protective structures with seat belts used where fitted.
HSE expects lift truck operators to be trained and reassessed at regular intervals - every 3 to 5 years, or when new risks arise - and drivers of other vehicles trained to a similar standard, with all drivers supervised, including those visiting the site. Note the visiting-driver clause again: the agency driver on his first visit is inside your safe-driver duty, not outside it.
The guidance’s case examples are not exotic. A forklift operator killed in a poorly lit yard with no designated traffic lanes when a reversing truck tipped the forklift over - avoidable with lighting, marked lanes, working reversing alarms and a worn seat belt. A maintenance engineer killed by a reversing dumper after taking a shortcut across the vehicle route, on a site where banksmen had been stood down because the job was nearly finished - avoidable with trained banksmen when needed, barriers keeping pedestrians and vehicles apart, and warning signs. Both read like a Tuesday in the wrong depot.
The law behind all this is not vague: the Workplace (Health, Safety and Welfare) Regulations 1992 - regulation 17 on traffic routes - the Provision and Use of Work Equipment Regulations 1998 (PUWER), and the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) where lifting equipment is involved. For transport operators, workplace transport safety is the compliance area where the O-licence world and the HSE world overlap completely - a fatal yard incident brings both, and the maintenance records, risk assessments and training files will be read by investigators from each.