Home > Member services > Health and safety > Health and safety news > Withdrawal of HSE transporting paper guidance INDG 396

The Health and Safety Executive (HSE) has announced the withdrawal of paper industry guidance INDG 396 “Transporting paper safely: Guidance for hauliers and others who transport paper and paper products” after discussions with Department for Transport (DfT).  The guidance booklet included advice in relation to securing tall paper reels, bales and palletised products on curtain-sided lorries. The industry is now advised to refer to section 16 of the DfT code of practice for guidance.

 

Amicus GPM has opposed the withdrawal of this guidance until it can be replaced by a suitable alternative. Unfortunately the current position appears to be that guidance on handling waste paper bales has also been removed, since the interim advice from HSE considers only paper reels. Meanwhile, most curtain sided vehicles used in the UK to transport paper do not meet the DfT guidelines for securing loads on the roads.

 

Separately HSE has now said that “the advice about clamping of reels applies equally to clamping of bales … If heavy items are merely resting under gravity on the clamped load beneath there is a high risk of them falling off. The full load should be securely clamped and there is materials handling equipment on the market that duty-holders can utilise to ensure secure clamping of complete loads.”

 

Amicus GPM will now be targeting HSE and Local Authority Inspectors to ensure they enforce the interim guidance they have issued. HSE has said that:

 

“HSE and Local Authorities are the enforcing authorities for vehicle loading and unloading activities at most premises and their Inspectors would be expected to enforce Regulation 3 of the Management of Health and Safety at Work Regulations 1999 which requires the duty holder to make a suitable and sufficient assessment of the risks in relation to the loading and unloading activity. Inspectors will also enforce Section 2(1) of the Health and Safety at Work etc Act 1974 which places a duty on employers, among other things, to provide and maintain safe systems of work covering the loading and unloading activities.”

 

“The nature and severity of the risks in each case, and consequently the safe system of work for loading and unloading will depend on a number of factors (the nature of the particular load, the nature of the vehicles, the condition of the load etc) and Inspectors will need to take these into account in making their judgements about whether there is legal compliance”.

 

This whole process has been highly unsatisfactory. Initially Amicus GPM opposed the withdrawal of this guidance on the basis it was not being replaced by any effective, alternative guidance, thus leaving people in the industry unclear about what they should do. Although the DfT guidance has existed for some time, there is no evidence of it ever being enforced. In addition it only refers to the public highway and not loading/unloading operations.

 

 

 

 

Chapels should approach their employers to clarify the standards that operate in their company for the loading and unloading of curtain sided vehicles.

 

In doing so they should:

 

-          Seek compliance with the new HSE recommendations, by employers and hauliers

 

-          Question local Health and Safety Inspectors about implementation of the new HSE recommendations

 

-          Ensure that Inspectors meet the advice to inspectors from the HSE