Compliance summary: loading and unloading

KEY POINTS TO REMAIN SAFE

HSE’s guidance on loading and unloading lists various key points to remain safe, which are listed below.

Loading and unloading areas should be:

• clear of other traffic, pedestrians and people not involved in loading or unloading;
• level – to maintain stability, trailers should be parked on firm level ground with brakes/stabilisers applied.

Loads should be:

• spread as evenly as possible, during both loading and unloading;
• secured or arranged so that they do not slide around;
• suitably packaged.

In addition:

• it may be possible to install a harness system in some workplaces to protect people working at height;
• vehicles must never be overloaded, as overloaded vehicles can become unstable, difficult to steer or be less able to brake.

CHECK YOUR LOAD

If you are responsible for loading vehicles, you should make sure that they are loaded so the load remains in a safe condition during loading, transit and unloading. Checks must be made before unloading to make sure loads have not shifted during transit and are not likely to move or fall when restraints are removed. If the drivers do not load the vehicle, ideally they should be given the opportunity to observe the competent person loading the vehicle or as a minimum, be given information about how the load has been secured and/or given the chance to check the load prior to departure.

PLAN AHEAD

HSE and DfT recommend that where more than one company is involved, they should exchange information about their loads in advance and agree on a loading/unloading plan so that everyone knows what they are responsible for. Areas for consideration include how the load is to be unloaded and what happens if the load shifts in transit. Information about the load should be clearly communicated to the driver, considering possible driver handovers and language barriers. A loading docket that travels with the load may help to communicate information to the haulier and the delivery site. This can be as simple as a sketch showing the position of the load and the load securing system. The driver should be made aware of what is expected of them at the delivery site, including things like whether they should report to security on arrival or stay in their cab during unloading or if they are expected to help unloading.

STREET LOADING

When loading and unloading on a street, it must be a continuous activity and the vehicle must be moved as soon as the process is complete. Loading includes the movement of goods to and from premises, checks on the goods delivered and paperwork. Enforcement staff will not consider stopping for a chat, shopping or having a cup of tea as part of the loading and unloading process! Always check nearby signs for details of additional restrictions on loading, as these may vary in towns or even times of the year.

Loading and unloading on a street by commercial vehicles is permitted in designated loading bays – normally for a maximum of 20 minutes (up to 40 minutes in some London boroughs). Always check the hours that the loading bay operates on nearby signs for confirmation. Vehicles should not be parked with one or more wheels on the footway to load and unload unless the loading and unloading could not otherwise have been satisfactorily performed and the vehicle was not left unattended at any time while parked.

Most streets, in town centres particularly, will have short yellow lines at right angles to the kerb, which indicate a loading ban. If there is just the single “pip”, this means loading and unloading is sometimes allowed (look out for the sign showing the restricted times which vary from street to street). Where there are two “pips” next to each other, this means loading/unloading is not permitted at any time.

PAVEMENT PARKING BAN

Following Scotland’s pavement parking ban, of which, enforcement has been delayed until 2023 owing to the effects of COVID-19, Section 55 of the Transport (Scotland) Act 2019 includes an exemption for the delivery or collection of goods. The legislation states a vehicle will be exempt from the pavement parking ban in Scotland if “the motor vehicle is being used in the course of business for the purpose of delivering or collecting goods or for loading or unloading the vehicle; that action cannot reasonably be carried out without the vehicle being parked on a pavement or double parked; and the vehicle is not parked for a continuous period of more than 20 minutes; and, in addition, no part of the vehicle is within 1.5 metres of the pavement edge which is furthest away from the centre of the carriageway”. The Department for Transport closed a consultation in October 2020 for England and Wales, as to whether they should follow Scotland’s lead on this subject, but the summary of responses are still to be published at the time of writing.

CHECK THE LOADING AREA FLOOR

HSE’s guidance also recommends that when loading/unloading, to always check the floor or deck of the loading area, or the surface to make sure it is safe. Look out for debris, broken boarding, potholes etc. The Manual Handling Operations Regulations 1992 require employers to avoid, assess and reduce the risk of injury from manual handling.

PROTECT YOUR WORKERS

Employers must protect their workers from the risk of injury from poor manual handling in the workplace. When loading/unloading, some risks can be avoided by mechanising the risk using pallet lifters or sack trolleys for example. If it is not reasonably practicable to provide mechanical help, consider:

• how far the load is lifted, lowered or carried;
• the frequency of the task;
• the weight of the load;
• the nature of the load (for example hot, sharp or slippery);
• cramped work areas;
• poor floor surfaces;
• poor lighting, extremes of temperature;
• workers’ strength, fitness and underlying medical conditions (for example a history of back problems)

Training can be important in raising awareness and reducing risk, but it won’t ensure safe manual handling on its own. Employers should first design the manual handling operations to be as safe as reasonably practicable, then monitor and review procedures to make sure workers understand and apply them. Training should be relevant to the type of work carried out.

*For any further advice on loading and unloading, contact Logistics UK’s Member Advice Centre on 0370 605 0000.