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Letter sent to Tom Beegan, CEO of Health and Safety Authority

The Dublin Cycling Campaign (DCC) has been concerned for some time about the generally low safety standards applied by both road-works undertakers (town & city councils, Bord Gais, ESB, telecoms operators, etc.) and their contractors operating in the Greater Dublin area and the high degree of risk of injury and death these works present to cyclists if not properly controlled. These road works generally involve cross- or longitudinal cuts being made in the normal road pavements (‘openings’) and arise from deliberate work activity and not wear-and tear. These are construction sites, in effect mobile sites in the terminology of the HSA, but uniquely present in very public places – our roads and streets. DCC takes the view that an exemplary standard of risk control has to apply at these sites due to the hazards presented to the public and the number of third parties affected.

Cyclists would seem to be quite simply forgotten when principals and their contractors implement their invariably inadequate risk controls at these sites. I need hardly remind you that cyclists are a totally unprotected category of traffic – the rider is not surrounded by a steel cage (car body), has no active restraint system (seat-belts) and no passive restraint system (air bags) and with no suspension system on bikes. Couple this with the fact that a bike is a meta-stable machine and you can see that risk control at road works is complex but necessary.

Many DCC members travel and ride extensively in the EU, the Antipodes and North America and they are conscious of the much higher standards applying to road works control observed in these jurisdictions when compared to Ireland. For this reason, DCC seeks a meeting with officials from the HSA to set out its concerns and in the hope that your Authority can see its way to improving safety standards among the various road works contractors, in particular.

In DCC’s view, the worst culprits in all of this are the local authorities and their divisions such as waterworks and pavements/roads along with telecoms operators and their contractors (such as Gerry McCloskey, Sierra, etc). ESB and Bord Gais tend to be better principals in terms of openings’ safety management. Some local authorities have published road works control codes of practice (see for instance http://www.dublincity.ie/Images/roadworks_control2005_tcm35-19614.pdf) but it is clear that implementation and enforcement are largely missing. [Anecdotally, a senior City official has said privately that Dublin City is unable to enforce the code of practice against recalcitrant contractors.]

I list below some of the particular hazards that DCC wishes to see action taken by the Inspectorate.

Steel plates used to provide temporary closure to road openings to be rebated into road surface and not left proud with macadam ramps that can send riders off course or into a skid. Surface of plates must not be slick but treated with a suitable non-skid thermoplastic coat
Steel plates are being left in position for far longer than a ‘temporary period’ as recognised in the road works control code.
End to use of delayed-set macadam temporary fill in openings tamped in by a whack from the back of a shovel and deliberately left mounded for traffic to compact
Many reinstated road openings are to a low standard with inadequate fill and compaction having been performed leading to collapse of the surface in a short time. Road openings to be properly backfilled, compacted mechanically and road surface to be reinstated to suitable standard far sooner than seems to be the case.
Safety barriers around road openings to be sand-bagged at all times to prevent toppling by traffic and winds
Hazard warning notices to be standardised by size, positioning, wording, pictograms, etc. All notices to be kept out of carriageway (particularly in gutter region) to avoid cyclists striking them. All notices placed on road surface to be sandbagged at all times.
Longer sequences of warning cones deployed to ‘feather’ in/out approach sectors to road works
Segregated lane set out for use by cyclists and pedestrians and marked accordingly
Notices placed at site providing names and contact details for principals behind projects and their contractors – end to anonymity and end to provision of only 9am – 5 pm emergency contact telephone numbers. The safety officer contacts to be provided for both principal and contractor.

DCC is also concerned at the risks presented to cyclists by the presence of HGVs on city and town streets, in particular, in relation to drivers’ work practices (just-in-time deliveries, work scheduling leading to speeding, tiredness leading to poor driving standards, overloading of trucks and load shedding, etc.). Collision with HGVs has killed 10 cyclists within Dublin City since 2000. DCC notes the very unfavourable outcome from UK road transport authorities (combined operations by HM Customs, HSE, Department of Transport and transport police) check-points mounted on UK roads in 2004 where 26.3% of Irish owned HGVs failed vehicle standards inspection, loading or tachograph infractions. [See report by Tim O'Brien in The Irish Times, 21 April 2005] This indicates to DCC that too many Irish HGV operators/drivers may be putting other road users at risk. And cyclists are the most vulnerable of all traffic. It all arises from work activity and enforcement falls within the remit of the HSA and not just An Garda. DCC is aware that An Garda is concerned about HGV safety and in its strategic review has stated under issue #4: ‘ Enforce road transport and haulage legislation effectively and consistently using available technologies’. [www.garda.ie]

DCC would like data on the number of on-road checkpoints operated by the HSA in 2005-06 targeting HGV safety issues in relation to work activity. In the case of detection of infractions how many improvement or prohibition notices were issued and were any cases taken to courts? If any in the latter category, what were the outcomes?

DCC wishes to meet with representatives from your agency to discuss these two serious safety issues and to explore ways in which the Inspectorate might better tackle the issues. I look forward to hearing from you.

Yours sincerely,
Dr. Mike McKillen