FLEET SAFETY
FIT FOR PURPOSE
38


Survival of the fittest  


Ensuring a vehicle is “fit for purpose” is a major duty-of-care issue for company bosses, says the Health and Safety Executive. To find out what fleet decision-makers need to consider, Ashley Martin spoke to a range of experts


Roger Bibbings
“Defining the term ‘fit for purpose’ is proving to be a vexing issue”
The Health and Safety Executive says that it is the responsibility of company bosses to ensure that the vehicles staff drive on business are “fit for the purpose for which they are used”.

The warning is contained in the HSE’s “Driving at Work: Managing Work-related Road Safety Advice” – guidelines that have become the fleet chief’s Bible since their publication last September as they seek to reduce occupational road risk and meet their duty of care obligations.

In addition, the Provision and Use of Work Equipment Regulations stipulate that “work equipment should be so constructed or adapted so as to be suitable for the purpose in any respect which it is reasonably foreseeable will affect the health or safety of any person”. This interpretation applies to vehicle use and, in particular, vehicle ergonomics. But, defining the term “fit for purpose” is proving to be a vexing issue that has raised a number of questions among fleet operators anxious to ensure they are abiding by the law and the latest HSE advice.

Roger Bibbings, occupational safety adviser at the Royal Society for the Prevention of Accidents, says the HSE had set a series of objectives for fleets to follow in relation to all vehicles driven on company business no matter who owned them. But, he says, the legal interpretation of “fit for purpose” remains unclear.

“Employers need to ask themselves if a vehicle is right for the job and the person”

It is, according to independent total vehicle risk management solution’s company Risk Answers, vital that employers provide employees with the correct tools to undertake their job – the tool in this case being the vehicle. However, as the fleet decision-maker bids to leverage fleet cost savings by restricting vehicle choice it is crucial that ensuring that a vehicle being “fit for purpose” is not overlooked. As Jeremy Hay, Chief Executive of Risk Answers, says: “While considerable cost savings can be achieved through solus or dual badge deals, consideration should also be given as to whether the vehicles on the choice list accommodate the ergonomic needs of each driver, as well as all job functions. A low-mileage ‘perk’ driver will have different needs to a high-mileage job-need driver or a service engineer (see panel 1).

“When considering vehicle wholelife costs or monthly lease rentals, employers may overlook vehicle ergonomics and the job function of the driver. Company car drivers come in all shapes and sizes and a vehicle that suits one person may be totally unsuitable for another.”

When compiling a vehicle choice list, employers must consider:

  • The driver’s body size
  • The driver’s job function/type of work
  • The driver’s annual mileage
  • The ergonomics of the vehicle

Paul Jobson, general manager, training for IAM Fleet, says: “Choosing a car, be it for private or business use, can prove to be highly complex due to the vast selection of manufacturers and vehicle types available on the market. From the fleet manager’s perspective, this complexity increases through the need to provide employees with company vehicles that are ‘fit for purpose’. In addition, a balance is also required between the requirement for human resources colleagues to offer cars that attract and help to retain the best staff, yet at the same time ensure that the same vehicle is appropriate to an individual’s job role.”

How to determine that vehicles are “fit for purpose” for different types of driver

High-mileage drivers

  • The vehicle should be of an appropriate size for the length of journey and number of hours spent driving. A small vehicle may cause discomfort and induce fatigue in a high-mileage driver
  • If the employee routinely carries passengers, the vehicle should be of a suitable size to convey them in comfort
  • All parts of the seat should provide adequate support. The seat depth should be appropriate for leg length and adjust for height, rake and reach to ensure that: feet can operate pedals without stretching, all controls are within easy reach, all display instruments can be seen, the driver has good all-round vision
  • The seat material should not cause discomfort and the seats should be comfortable, firm and supportive with independent height and tilt adjustment and, ideally, lumbar support
  • The steering wheel should adjust for rake and reach;
  • Sports seats are becoming increasingly popular but are often narrow and may not suit all drivers
  • Employers should consider if their employees carry heavy loads. The loads must be properly restrained to prevent them from dislodging and injuring the driver and/or any passengers in the event or a crash, or if the vehicle is subjected to emergency braking, heavy loads will affect the dynamics and handling of the vehicle and the tyre pressures must be adjusted accordingly.

Service engineers

  • An estate car with a low rear sill or van may be more appropriate for a service engineer, ideally with self-levelling rear suspension to compensate for heavy or uneven loads
  • If tools or equipment are carried in the boot, employers should also consider training the employee in manual-handling techniques, to prevent injury when loading/removing items from the boot
  • The vehicle must be used in compliance with its specification – passenger numbers, load weights and load distribution
  • The vehicle should have a luggage safety net and/or load carrier, to restrain loads and prevent them from entering the cabin area in the event of a crash
  • Drivers should familiarise themselves with all adjustments in their vehicle before setting off by first putting the seat into the “initial set-up position”, where adjustable: steering wheel fully up, fully forward; seat height at lowest point possible; cushion tilted so that the front edge is in the lowest position; backrest approximately 30 degrees reclined from vertical; slacken off the lumbar support; seat adjusted fully rearwards
  • Whatever type of driver, the head restraint should be adjusted correctly – the base of the head restraint should be level with the base of the skull where it meets the top of the neck. The restraint should be about an inch away from the back of the head. This position offers optimum restraint in the event of an accident and helps to prevent whiplash-related injuries

All drivers Whatever type of driver or vehicle, it is important that regular breaks are taken to stretch legs and reduce the risk of lower back pain. Drivers should plan their journeys ahead and build in a 15-minute break every two hours. Taking a short walk will get the circulation flowing in the back.

Source: Risk Answers

 

Meanwhile, in an increasingly user-chooser world where many staff are able to select vehicles from a wide choice list or employees take a cash alternative to fund their vehicle, Mr Bibbings says companies must ensure the characteristics of the vehicle are matched to the ability of the driver. “Vehicle familiarisation should be carried out before drivers are given the keys,” he says. “Companies that use their fleet policies as a staff recruitment and retention mechanism must assess whether it is appropriate for an employee in their mid-20s to drive a Porsche – is that the right vehicle for the job and the right vehicle for the person. “Before the employee receives the Porsche, some assessment of the employee’s attitude and competency should be made.”

Mr Bibbings says such an issue is unlikely to surface in HSE enforcement, but that following an accident the police may raise questions from a business point of view rather than a legal point of view. He says: “Employers need to ask themselves if a vehicle is right for the job and the person and if the company is investing in the right safety features. The company also needs to ask if the person is right for the vehicle given the job they are being employed to perform. “Employers must then make sure vehicles are maintained and, for example, that lights are not defective and tyres are not bald. It is a question of what is reasonable in law from a business case point of view. Fleets need to come up with some answers.”

It is a view shared by Steve Johnson, Marketing Director of Drive & Survive, who says: “For fleets that incentivise staff through a variety of schemes including car choice, ensuring a vehicle is ‘fit for purpose’ is a major issue. Often they have car parks full of Audi TTs, Porsche Boxsters and Subaru Imprezas – powerful performance cars driven by 25 and 26-year-olds.

“But we can make those drivers safer by implementing a risk management programme and would advise that certain vehicle features should be mandatory, such as ABS with EBD, high-level brake lights and a heated windscreen – a feature that is frequently overlooked, but a vital aid in winter weather. It is the grown-up approach to ask for independent advice on whether such features are required and how they function and then instruct drivers on their use.”


Jeremy Hay
“Company car drivers who clock up more than 25,000 miles a year were six times more likely to be on sick eave due to low back trouble”
Mr Bibbings says: “Businesses may decide that all vehicles driven on company business must meet, for example, Euro NCAP five-star crash test standards and tyres fitted must be range-topping and not cheap alternatives. Company bosses, particularly where staff drive their own cars on business, should also undertake spot checks to determine tyre tread depths and inspect vehicle maintenance books to ensure services are being undertaken in accordance with manufacturer recommendations.” James Sutherland, Managing Director of Peak Performance, adds: “The task itself will dictate the basic type of vehicle and will determine its size, engine capacity, number of seats, equipment to be carried and the environment that the vehicle is to be operated within – such as off-road, urban deliveries or motorway driving.

“But the task requirement must be balanced by the cost of the provision of the vehicle, as well as the final specification that is identified as being required to suit its use and operation – it may not be in the best interests of the company from a financial viewpoint to supply top-of-the-range, fuel-inefficient gas-guzzlers for field sales staff driving high mileage on UK motorways.” Specification may ultimately be decided by ensuring that the vehicle is “fit for purpose”, for example, the fitting of an audible reversing alarm for vehicles that are required to reverse frequently in work situations; ensuring a vehicle has a low rear sill if the driver needs to carry loads; similarly that vehicles are equipped with a luggage safety net and/or load carrier to restrain loads and prevent them “crashing through” the rear seat in the event of an impact.

Mr Jobson says no two vehicles are the same and all drivers should go through an “induction” programme prior to taking the wheel of their latest company car. The Management of Health and Safety at Work Regulations 1999 stipulate that employers should provide staff with “adequate health and safety training” in relation to “their exposure to new or increased risks, introduction to new work equipment or changes in work equipment”, which would also include the introduction of new technology such as driving a vehicle fitted with ABS brakes for the first time.

Mr Jobson says: “Employees attend familiarisation programmes in connection with the introduction of new computer equipment or a new phone system in offices and exactly the same familiarisation process should relate to company cars. If staff take delivery of a completely different vehicle to the one they were driving before an element of on-road driver training may also be required to make them feel comfortable.”

Last year, the Chartered Society of Physiotherapy published a leaflet, sponsored by the Association of Car Fleet Operators – Drivers: Steer Clear of Pain – that not only promoted stretches for drivers to help them avoid discomfort and fatigue, but also highlighted that company car drivers at the wheel for more than four hours a day or who clock up more than 25,000 miles a year were six times more likely to be on sick leave due to low back trouble (Roadsafe: winter 2003/04).

Risk Answers’ Jeremy Hay says: “Poor posture leads to degeneration and wear and tear of the spine, leaving it vulnerable and susceptible to injury. That in turn leads to back pain, which can cause fatigue.” A vehicle’s ergonomics – seat adjustment, steering wheel adjustment, head restraint adjustment and pedals being inline and not offset – are vital in ensuring any car, van or lorry is “fit for purpose” says Mr Johnson.

He adds: “Fatigue can be caused through having the wrong seating position. Posture in the car and behind the steering wheel is important to prevent aches and pains and fatigue. Frequently, long-term complaints can be traced back to poor posture particularly with high-mileage drivers. The body – ankles, hips and shoulder – should be all in one line. “All these issues are considered by the HSE to be part of an employer’s duty of care. We believe employers are obliged to make sure a vehicle is right for the person and right for the job and that it is as comfortable as it possibly can be. “We have had a few clients who have asked us to test cars to make sure they are ‘fit for purpose’, taking into account the driver’s age, job requirement, environment they are driving in – on motorways or hilly terrain – and the need to carry passengers/loads and the impact of roof racks on fuel consumption, and so on. We are being asked more and more about the safety aspects of ergonomics and to draw up inspection sheets.”

In driver-training observation is a key issue – “see and be seen” is a frequently repeated mantra – but if a driver can’t see out of the vehicle that is a major ergonomic issue. Similarly if limited seat and steering wheel adjustment mean pedals and controls cannot be reached properly the vehicle will not be “fit for purpose”.

“If limited seat and steering wheel adjustment mean pedals and controls cannot be reached properly, the vehicle will not be ‘fit for purpose’”

Mr Jobson says: “Fleet managers should allow employees to choose from a number of manufacturers to ensure the vehicle selected accommodates the needs of each individual driver by providing a good ‘fit’ that is ergonomically correct. They should also ensure that drivers have input into the selection process by encouraging and arranging test drives before a vehicle is selected.” Mr Sutherland adds: “The needs of the driver are important in determining ‘fit for purpose’ and these will include facts such as access to the rear of the vehicle, goods to be carried, suitability of seating particularly for long journeys, all-round visibility, mobile communications and even satellite navigation to help in route finding.

“Managing the vehicle should also include a risk assessment of the final vehicle specification and this should take place with an experienced operator in demanding job situations to prove the specification produces a ‘fit for purpose’ vehicle. “Additionally, the driver must be assessed as competent to carry out the required task, which may involve more than simple licence checking and may include specific driver training.”

In the world of vehicles being “ fit for purpose”, there is no such thing as a one-stop shop – every employee is unique and their requirements will be different.

20 issues to consider to render a vehicle “fit for purpose”

  1. Visibility by vehicle colour – lighter colours are more visible in dawn, dusk and poor weather conditions
  2. Sufficient all-round visibility through screens – parking and manoeuvring is the highest frequency crash statistic
  3. Door mirror size and adjustment – some vehicles fit small mirrors, which can reduce the drivers’ rear view
  4. ABS – antilock braking systems allow steering when full braking pressure is applied and avoid wheel lock and skidding
  5. Driver and passenger airbags – for the protection of driver and passenger in an impact
  6. Air conditioning – to provide better airflow in the vehicle and combat drowsiness
  7. High visibility rear light – for better identification of vehicles when brakes are applied
  8. Reversing light/s – to aid parking and manoeuvring and warn others of the intended manoeuvre
  9. Fog lights – to provide better vehicle identification in poor visibility
  10. Mobile telephone hands-free kit (if required) – to comply with current legislation and stop the temptation to hold the device when driving
  11. Seat adjustment – to meet the requirements of a full range of driver body types
  12. Head restraint adjustment – to protect drivers and front passengers from whiplash injury in a rear impact
  13. Load restraint (if required) – to restrict the potential of projectiles from load after impact
  14. Locking seatbelt – to restrict the travel of the driver in a frontal impact
  15. Power to load ratio – sufficient power for the vehicle to be operated safely when fully loaded
  16. Safety kit – containing standard safety equipment for use in breakdown or emergency situations
  17. Towing equipment – must subscribe to legislation
  18. Crash pack – safety and procedural advice and guidance if a crash occurs
  19. Vehicle safety check sheet – pre-use safety check advice and guidance with a defect reporting element
  20. Satellite navigation – if it makes the task of business driving less complicated in helping with route finding

NB: This checklist is not exhaustive and can be supplemented with other considerations specific to the individual company requirements, but the process above should provide the company with guidance to achieve a “fit for purpose” specification, which has taken into account the task, driver and vehicle and management requirements and complies with latest HSE guidance.

Source: Peak Performance

 

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