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