Many employers think that a drivers fitness to carry out their job and to drive safely is the drivers responsibility and is therefore often not considered as part of occupational health and safety management.
This section emphasises why employers should mange F2D and gives an overview of occupational health and safety management requirement, with the ultimate aim of reducing accidents and saving lives.
Ensuring your drivers are fit to drive applies to all occupational drivers (sales staff, managers driving to meetings etc.) and not just professional large goods vehicle (LGV) and passenger carrying vehicle (PCV) drivers.
Collisions cause immeasurable pain, grief and suffering to casualties, their relatives and friends.
Financial costs include adverse publicity, lost economic output, damage to vehicles, insurance claims, potential legal costs etc but there are also more hidden costs to our economy from use of fire, police, ambulance and NHS resources.
Two main groups of law which apply to work related road safety are the Road Traffic Act and the At Work Act and associated legation.
Employers have a duty to assess risks in the workplace. This duty also applies to driving activities. Where an employee is involved in a motoring incident there can be serious consequences for the employee and the employer. The police will investigate under the Road Traffic Act and The Health & Safety Executive (HSE) may investigate in order to determine whether the employer’s actions or lack of actions contributed to the incident and prosectutions can follow.
Employers should make sure that every driver has a valid driving licence for the vehicle they are driving. They should check the driving licence(s) of their driver(s) annually (or more often) and keep a record of the check.
Licence endorsement codes and penalty points will be shown. Many are linked to F2D factors e.g.
- DR20 Driving or attempting to drive while unfit through drink
- DR80 Driving or attempting to drive when unfit through drugs
- LC30 Driving after making a false declaration about fitness when applying for a licence
- MS70 Driving with uncorrected defective eyesight
It is important for employers to review their overall work-related road safety performance. It allows them to assess how well F2D risk management is working and to identify any gaps or required improvements.
There are various options for reviewing F2D risk management for example:
The review process can gather information through:
- Review of accidents and incidents/ill-health data
- Review of claims data with insurers
- Managers regularly discussing F2D with their drivers, for example, during periodic staff appraisals and team meetings. Any feedback from drivers about health issues should be noted and addressed as necessary. Any information you record on staff health is classed as sensitive data. You must make sure that it is stored confidentially. You can find out more about these in the Data Protection Act 2018.
Employers should also consider the F2D experience of others in similar industries or organisations – could the same mistakes be avoided?
Some other options which may assist employers with the review process are listed below:
Evaluate Employer Activities:
Monitor and evaluate employer policies and practices to ensure that they are working effectively. Advice on evaluation is available in “How to Evaluate Managing Occupational Road Risk: A guide for employers.”
Benchmark Employer Performance:
The free Fleet Safety Benchmarking Tool at www.fleetsafetybenchmarking.net can be used to compare employer organisation against others. Once completed, it automatically provides a personalised report with feedback on the results. Benchmarking is an effective way of improving work-related road safety, identifying good practices and generating cost saving opportunities. It also supports compliance with legal requirements and standards such as ISO39001.
Take action on lessons learned:
Companies should then look at the occupational road risk management system to see whether it should be changed in light of the review process. Revisit plans, policy documents and risk assessments to see if they need updating. Develop a simple action plan with targets for further improvement.
A key component of any risk management system is a comprehensive accident and incident reporting and investigation policy and procedure that is designed to:
- Ensure work-related road accidents, incidents and near misses are reported and recorded.
- Identify their immediate and underlying causes
- Enable lessons to be learned and shared throughout the organisation
- Implement measures to reduce the likelihood of similar accidents or incidents occurring again
F2D factors such as personal health, stress, fatigue etc. can be identified as immediate and underlying causes.
The ROSPA guide gives simple advice on developing and implementing approaches to incident and accident reporting and investigation to enable organisations to learn appropriate lessons from their experiences.
Note: Telematics can be very helpful in accident and incident investigations because the data provides an accurate and objective picture of what happened. This often means that investigations are quicker, easier and less expensive to conduct, and the conclusions are more accurate and reliable. It can also help to ensure that accidents and incidents are recorded, with less reliance on staff and witness reports.
The technology, which includes "black boxes" fitted to cars, has also been rolled out via mobile apps, helps to monitor real driving behaviour. For individual drivers, telematics can help them to reduce their risk of being in an accident or committing a motoring offence, reduce their fuel costs and make their driving less stressful and more enjoyable.
It is crucial that lessons are learned from the results of monitoring and investigations, and fed back into the company occupational road risk policy, procedures and risk assessments. Key points should also be communicated to managers and staff.
The HSE's driving at work guidance states that…
Health and safety law applies to work activities on the road in the same way as it does to all work activities and you need to manage the risks to drivers as part of employer health and safety arrangements
Essentially this means, that in order to minimise risk and ensure legal compliance, employers must actively manage occupational road risk as part of their overall health and safety management system. This includes considering the health status of your drivers.
Any company policy covering driving for work should include statements on key health areas such as:
- Alcohol and drugs (including prescribed, illegal or over the counter)
- Medical Fitness to drive and reporting and support within the organisation
- Actions to be taken if an employee is unfit, or considered unfit to drive
It's worth noting that creating a policy shouldn't be considered a paper exercise. Creating a policy in conjunction with employees, middle and senior managers that clearly explains responsibilities and shows commitment from senior management, is one of the first steps that you can take to improve standards. The policy creates your framework for future actions and the direction that the organisation will take to tackle safety and health while driving. However, to be effective, these policies should be linked to other policies across the organisation for example your organisations attendance policy go together with an educational program that involves everybody in the workplace.
To access free resources and an example of a road safety policy, sign up to SCORSA free.
Employers are required to carry out risk assessments for work activities and should include taking specific factors when assessing driving for work, for example consider organisation's working practices, journey requirements, the types of vehicles used and required and the fitness of the driver to perform necessary tasks.
Link to DFt for example of risk assessment process. DFt
- Driving large vehicles in high risk pedestrian areas can be stressful. Planning journeys and deliveries to avoid peak times could help to minimise risk and reduce any pressure or stress drivers may feel.
- Driving at certain times (e.g. between 2am and 6am) can increase risk of driver fatigue. Schedules should therefore seek to reduce night driving.
- Manoeuvring vehicles in certain high risk locations can be difficult and stressful. (E.g. narrow lanes, locations with restricted access/parked cars or other obstructions). Using the correct type and size of vehicles with incorporated essential safety features e.g. CCTV, reversing alarms/sensors can help to minimise risk and reduce potential driver stress.
- Poor vehicle ergonomics could cause, or exacerbate health problems (e.g. back pain/ musculoskeletal disorders). Assessing the design of vehicles and equipment at the procurement stage would help to minimise risk.
Specific F2D factors must also be considered in the risk assessment process for individual drivers and groups of drivers. For example:
- Pregnancy: At some point during a pregnancy, changes to work patterns (including driving duties) are likely. The HSE website has useful information on what you must consider if you employ new or expectant mothers.
- Age: With age, general fitness, eyesight, hearing and reaction times deteriorate, but not at a uniform or predictable rate; each person is different. Employers could consider these elements as part of the risk assessment process.
- Stress: Employers need to ensure that work tasks do not put undue pressure on drivers. Poor work organisation and uncertain roles; poor work-life balance etc may contribute to a buildup of stress.
Managers may inadvertently cause impacts that affect driving standards and abilities for example
- Target driven performance - setting high targets might inadvertently lead to employees feeling compelled to drive long hours making them more fatigued and/or stressed and more likely to take risks and be involved in a collision.
- Lack of support for health issues - If a company does not have clear policies and practice around supporting staff with health issues, employees are less likely to come forward when issues arise, sometimes keeping health issues that affect their ability to drive, hidden until it's too late.
The above list of examples is not exhaustive and employers must consider how their own particular set of circumstances will affect a driver's fitness and ability to drive.
Specific risk assessment tools are also available e.g. SCORSA/ROSPA Driver profiler risk assessment tool can help (log in free to access tool). SCORSA
This software aims to risk assess an individual's attitude to driving by measuring driver history along with eight human characteristics, including factors such as alertness and stress. A report is sent to each individual highlighting problem areas and giving tips and advice so drivers can see where and how to improve.
Remember to include all drivers (e.g. standby and agency drivers and drivers who may use their own vehicle) when developing policy, procedures and risk assessments.
The following sections highlight other important elements which employers must consider as part of any health and safety risk management system.
Good communication and provision of information, instruction and training (IIT) is crucial to the success of any occupational health and safety management system.
Provision of IIT should cover everything from providing basic F2D information to drivers e.g. how to report any health concerns, to more formal F2D training for line managers/supervisors e.g. how to recognise signs of possible alcohol or substance abuse, investigating the causes of accidents, medical rules for drivers (and requirements to notify the DVLA)
It is also crucial to communicate company policy, procedures, risk assessments and associated F2D information to staff on a regular basis.
Consider posters, memos, newsletters, talks and presentations all as a means of providing IIT.
Issue a driver’s handbook to all drivers which sets out clearly employer organisation's expectations, rules and procedures (all the 'musts and must nots'). Everyone must be aware of what is expected of them.
Company policy, procedures and risk assessments will only be effective if they are implemented in practice. It is therefore essential to regularly monitor and check that F2D is being managed effectively. (It will give you confidence that you are doing enough to keep on top of health and safety and maybe show how to do things better in the future).
There are various options for monitoring F2D risk management for example
The monitoring process can gather information through:
- Scrutiny and recording of relevant documentation; e.g. ensure that any health surveillance ‘medical fitness to drive’ forms have been completed for all drivers. Ensure ‘eye sight check’ forms have been completed for all drivers.
- Interviews with staff including drivers; (they may have concerns, problems or ideas for improvements)
- Direct observation of conditions and of peoples’ behaviour; e.g. train managers to recognise signs of possible alcohol or substance abuse.