Decision for Carey London Ltd (OF2000356)
Source: gov.uk (2025-04-11)

Written confirmation of the decision of the Traffic Commissioner for the East of England for Carey London Ltd and Mircea Contra, driver

IN THE EASTERN TRAFFIC AREA

CAREY LONDON LTD – OF2000356

AND DRIVER: MIRCEA-OCTAVIAN CONTRA

CONFIRMATION OF THE TRAFFIC COMMISSIONER’S DECISION

Background

Carey London Ltd holds a Restricted Goods Vehicle Operator’s Licence authorising 6 vehicles and 6 trailers. The Directors are Martin John Carey, Enda Cosgrove, Eamonn Carty, and Neil Skelton.

There is one Operating Centre at Moor Mill Lane, Colney Street, St. Albans AL2 3UB. Preventative Maintenance Inspections are said to be carried out by CPA Commercials Ltd and SCANIA (South Mimms) at 6-weekly intervals for vehicles and 12-weekly for trailers

The operator was the subject of an immediate prohibition notice, issued due to inoperative direction indicators on both off- and near-sides of YE08 EEY on 28 March 2024. The driver was Mircea Contra.

Hearing

The Public Inquiry was listed for today, 12 February 2025, in Tribunal Room 1 of the Office of the Traffic Commissioner in Cambridge. The operator was present in the form of Directors, Enda Cosgrove and Eamonn Carty, represented by Carolyn Evans of CE Transport Law. Mr Contra was present and represented by Sasha Jagroo of Counsel.

Issues

The public inquiry was called at the request of the operators and following notice that I was considering grounds to intervene in respect of this licence and specifically by reference to the following sections of the Goods Vehicle (Licensing of Operators) Act:

• 26(1)(b) – conditions on licence to notify changes – conviction, ability of Directors.

• 26(1)(c)(ii) – conviction of the driver.

• 26(1)(c)(iii) – prohibition (28 March 2024).

• 26(1)(e) – statements relating to safe operation and to abide by conditions on the licence.

• 26(1)(f) – undertakings (vehicles to be fit and serviceable, to employ an effective written driver defect reporting system, to ensure completed maintenance records, to comply with the laws on drivers’ hours and tachograph regulations).

• 26(1)(h) – material change in fitness to hold the licence and or the availability of finance.

• 28 – Disqualification.

Mr Contra was also called to a conjoined Driver Conduct Hearing to consider whether he should be permitted to continue to rely on his vocational driving entitlement.

The operator was directed to lodge evidence in support by 29 January 2025, including financial, maintenance and other compliance documentation. The operator was unable to produce authenticated bank statements.

Summary of Evidence

On 21 October 2024, a vehicle being operated by this operator collided with a bridge on the A205 Upper Richmond Road in London, just outside East Putney Tube Station. The collision resulted in the load, an 8-tonne excavator, being knocked off the trailer bed of the vehicle and onto the adjacent footpath. No one was injured.

The operator informed my office on 28 October 2024. A copy of an investigation report was submitted approximately 3 weeks later. In summary, I was told that the vehicle was being driven by Mircea-Octavian Contra. He was said to have immediately called his manager. A member of the public contacted the police, with police and the fire brigade later attending and the road was closed. There was said to be no significant damage to the bridge, a small flange and some guttering underneath the bridge was damaged but structurally the bridge was intact.

Mr Contra had apparently completed his walk-around check at approximately 6.00-6.30am on 21 October 2024. He attended Springfield Hospital (SW17) at approximately 8am to collect an 8-tonne excavator which was to be conveyed to Crayford. However, the plant was not ready for collection. Whilst on site, he received a telephone call asking him to take some road plates to Twickenham. I heard in evidence that route planning was left to the driver.

Mr Contra drove the excavator onto the load bed and then secured it with the arm of the excavator facing the headboard. There were four chains available (in a box on the load bed), but these were not used to secure the excavator. The risk assessment at that time did not address this and consequently control measures such as written instructions were not present (but note the confusion arising from training). He then apparently measured the height of the load using a tape measure (not a measuring stick) before moving to another area of the site where the road plates were collected and loaded and secured with ratchet straps. The height of the load was measured to be 15’4”. The arm of the excavator was not re-stowed after the excavator was moved to allow the loading of the plates.

Approximately 20 minutes after leaving Springfield Hospital, Mr Contra arrived in Putney. The vehicle passed under a first bridge without difficulty, but he then struck the second bridge. The operator stated that Mr Contra had seen the bridge height of 15’ but proceeded to attempt to pass under the bridge, at speed. The bridge was struck at 12.01pm. As soon as the excavator boom struck the bridge, it toppled from the vehicle, breaking the straps and came to rest on the pavement underneath the bridge.

The operator attributed the incident to the driver’s failure to adequately measure the height of the load and/or restrain it but also acknowledged a failure to have sufficient systems and processes in place to prevent the incident. The operator referred to work to implement better systems and processes, as follows:

• revisited the driver induction

• issued driver handbook and highway code

• set out expectations in relation to bridge strikes for each driver and delivered training on 30 October 2024

• Carried out a driver assessment in relation to competency (15 November 2024)

• provided a height measuring stick for every driver

• added height measurement to the walk around check

The operator planned to:

• issue further guidance on load security to be delivered (16 November 2024)

• conduct gate checks at site to ensure height measurement in cab

• carry out a reconstruction and use this to devise a training programme

• train on serious incident provision

• update risk assessments to include additional measures in place post bridge strike

• implement a policy and procedure to apply in event of major incident.

Driver Contra received additional training on 16 November 2024.

The driver, Mr Contra, has a full LGV vocational entitlement. He was issued with a warning when he applied for his renewal in March 2018. Mr Contra began his employment on 31 July 2023. Prior to that, he had been a vocational driver for eight years. From the outset of his employment, he held ALLMI and lorry loader qualifications. He received a site induction from the yard manager, Ronan Fayne, at the commencement of his employment, which covered the basic safety elements and requirements of the role. Mr Fayne has apparently attended Operator Licence Awareness Training, as has Mr Cosgrove. Mr Contra had attended FORS training and on 5 October 2024 he received training in respect of load restraint on plant and machinery. I heard that this training had caused confusion in the mind of the driver, and it informed his decision to use ratchet straps on the day, when he had previously used chains to secure similar loads.

My office was informed of a pending prosecution but not the outcome. Mr Contra was convicted on 19 November 2024 of an offence of driving without due care and attention. On entering that plea, a further charge was withdrawn. He received a fine and other costs totalling £433 fine (plus costs and surcharge) and his driver’s licence was endorsed with 5 penalty points.

Representations (and accompanying bundle) dated 29 January 2025 signed by Mr Cosgrove, confirmed the incident on 21 October 2024, with notification on 28 October 2024. It was stated that Mr Contra was “brought back to the operating centre by another driver” and did not attend work on the following day, but returned on the Wednesday, when he was interviewed by the operator. I was referred to the transcript. There appeared to be no issue as to the highlights identified by those representing the operator:

• He attended Springfield Tooting to collect an 8-tonne machine.

• Whilst at Springfield, he received a telephone call from ‘Robert’ to ask him to collect some road plates which had to go to a different site.

• It was difficult to load the machine on because of the wet weather.

• He attended a different area of the site and had to move the machine in order to make room for the road plates.

• He measured the height of the load using a measuring tape (but did not really remember)

• He believed the height was 15’4” or 15’6” (but see below).

• He did not use chains to secure the load as he believed (following recent training) that this might cause damage.

• There were five ratchet straps covering the excavator, three for the bucket and two for the road plates.

• He had to adjust the arm or the boom of the machine to load on the road plates and did not re-adjust it after loading the plates.

• He used a normal app to plan the route.

• He had attended a training course in loading trailers two weeks prior.

A further interview took place on 12 November 2024, summarised as follows:

• instructions for the job were via a collection book, but he could not be sure it was on the screen in the main office at the Operating Centre.

• the excavator was loaded with the boom facing towards the cab (the bucket). The forklift driver then loaded the road plates which were strapped down by Mr Contra.

• Although he confirmed he measured the height at 15’4” or 15’6”, he was not able to explain why he then attempted to pass under a bridge at 15’4”.

• He indicated that he had taken a machine to the same place on the previous weekend, but it was positioned the other way around.

• On the previous occasion, he had taken a 13-tonne machine, under the bridge with no issue.

• The driver was familiar with the route and did not require the use of a satnav.

• There should not have been an issue with the load if it was loaded correctly.

• The bucket should face forward. The excavator was moved to allow for the road plates and then never returned to the original position.

Mr Carty (Operations & SHEQ Director) assisted the police with the criminal investigation. I was referred to the assessment supplied via Police Sergeant Burlison. The operator put its case on the basis that the collision was entirely down to the actions of Mr Contra. I was told that the collision could have been avoided if Driver Contra had correctly measured his vehicle, updated his height marker to reflect the actual height of the vehicle, if he had planned his route and he had loaded the excavator so that the arm faced towards the rear. However, the operator accepted responsibility to the extent that the operator should have had measures in place to check the quality of the training being provided to drivers and ensure that the height of the load is measured and recorded in each case. The operator maintained that the principal cause of the incident was complacency on behalf of the driver, who had travelled under that bridge previously with larger machines. It accepted that it could have been prevented by a better quality of training and checks in the business to ensure that measurements were accurately taken and recorded. The drivers had received training on load security from an external third-party supplier just weeks before the incident (on the 5 October 2024), but Mr Carty could not be confident that the quality of the training was good. The training was revisited and a different provider delivered further training on 16 November 2024 following driver assessments the previous day.

Following the bridge strike, all drivers were required to record the height of the load (by way of an image of the height indicator in the cab) on a WhatsApp group and this was checked periodically by Ronan Fayne (Yard Manager) or Eamonn Carty. Reminders were placed around the site and drivers attended re-training. Since then, the improvements have been refined to include an amendment to the delivery notes to include a height check, but not routes. The operator has also adopted the digital platform Chime in order to improve the quality of the driver walk around check. Presently the driver will receive a ‘prompt screen’ which has been tailored to remind drivers to record the height of the load. The actual defect check includes a ‘tick box’ for the height and a space to include the measured height.

The operator has implemented the following remedial steps which it has adopted as part of a 12-month training plan. It has revisited the driver induction, with a refresher induction delivered on 30 October 2024 and the issue of a driver handbook and the Highway Code. It has communicated the operator’s expectation in relation to Bridge Strike avoidance to each driver at that session. It carried out driver assessments on 15 November 2024 and has now provided a height measurement device (but see above) to every driver as the height measurement forms part of the walk around check and is subject to undocumented gate-checks. Further Guidance was delivered on load security through a training session on 16 November 2024. I was told that the operator had carried out a reconstruction on 16 January 2025, as a learning opportunity. I was invited to view the presentation, but drivers were also all asked to comment on the cause of the incident as part of the discussion. Options are being considered for training on Serious Incident Investigation.

The risk assessment was updated, as required under the Management of Health and Safety at Work Regulations. The operator indicated that the previous version dated from the preceding January, but it clearly did not cover the risks evident from this incident or provide sufficient control measures. The operator has now implemented new policies and procedures to apply in the event of a major incident but has yet to take on board the control measures identified as long ago as 2020. I was naturally interested in what was in place to prevent infrastructure strikes in the first place. It was said that drivers generally attend the Operating Centre at around 6 am. They clock-in at the office and are met by the Yard Manager to discuss the deliveries allocated for that day. The vehicles are often pre-loaded, in order to reach sites by 8 am. Drivers may be required to go via a supplier but usually go straight to the site. They will move between two and three items of plant per day before finishing work between 4-4.30pm. The drivers work Monday to Friday with very occasional Saturdays.

The Senior Traffic Commissioner gave general guidance to operators on 25 September 2020, reminding them of their obligations and that it is incumbent upon any operator to ensure that vehicles are operated without unacceptable risks to road safety. Those risks include the need to prevent infrastructure strikes, which bring with them potentially serious consequences as well as avoidable costs in terms of checking and repair, and delays to rail services and other road users. That noted that the risks were not a new issue for the commercial vehicle industries and that regulatory action is a real possibility for those who fail to take appropriate control measures. Operators are expected to:

• assess the risks and ensure that routes are planned in advance, so far as is reasonably practicable

• ensure that drivers, transport managers and planners are properly trained to enable them to assess the risks

• ensure that drivers are provided with adequate information including about the vehicles which they are driving.

In providing information that allows anyone planning or altering a route, operators should consider how to:

• ensure that drivers have access to height conversion charts

• ensure that sites have height measurement gauges

• ensure that each vehicle and trailer in the fleet has an established running height on its technical record

• ensure that running heights are available to anyone planning a route including drivers who encounter unexpected or unmapped obstructions, such as temporary works.

The operator accepted that the Driver failed to adequately restrain the load using the chains, stow the boom arm of the excavator and load the body of the excavator against the headboard. There was a failure to record the height of the load using the height indicator in the cab and “appreciate” that the height measured was higher than the height of the bridge Issues. The operator admitted in early communications that it had failed to adequately to incorporate a requirement to measure and record the height of the load as part of training; to issue a height measuring tool for vehicles and to audit the drivers to ensure that a check of the height was made and recorded, with the height indicator in the cab. Despite the Senior Traffic Commissioner’s guidance, which has now been reissued, it failed to ensure all drivers had an image of the tie down procedure for each item of plant and reference to the detailed guidance and instructions for post- incident.

The driving licence checks all date to 28 January 2025. Drivers Mircea-Octavian Contra and Adrian Baja have driving and Working Time infringements recorded on the print outs supplied. The infringements are being counter-signed but without any further action or instruction recorded and certainly no evidence of disciplinary processes being engage. The Directors were unable to tell me how much time is actually being spent on driver walk rounds and whether this is being recorded. Shea Transport Ltd are producing infringement reports but these are not followed up on by Ronan Fayne Yard Manager. To Mr Fayne’s credit, he conducted a reconstruction of the incident and used that as an opportunity to further training on the reporting of defects.

My dip sampling of the maintenance documentation disclosed the following:

PN73 EHF

• 31 December 2024 – Preventative Maintenance Inspection with roller brake test on 17 December 2024 but 42% and 16% and 19 December 2024: 47%, 25%, 18% but imbalances of up to 45% and neither test within 7 days of the inspection. It also records defective spray suppression, windscreen, driver’s mat and legal plates (again).

• 7 November 2024 – Preventative Maintenance Inspection with roller brake test but 33% 15%, 10% and under-laden. It also records defective wheel arch (again), offside second wing (again) and nearside wing and legal plates (again). No rectification recorded.

• 30 September 2024 – Preventative Maintenance Inspection with roller brake test but 30%, 16%, 9% and an imbalance of 28%. It also records defective wheel arch, offside second wing and legal plates (again).

• 15 August 2024 – Preventative Maintenance Inspection with roller brake test but 30%, and 6% and imbalances of up to 33%. It also records no legal plate.

• 4 July 2024 – Preventative Maintenance Inspection with roller brake test but 31% and, 6. It also records defective offside inner tyre, cooling system, cracked wing (tiny), and no legal plate.

KX66 OPK

• 11 January 2025 – Preventative Maintenance Inspection with roller brake test: 47%, 50%, 16% but the record produced by CPA fails to record the measured weight of the vehicle and after brake discs and pads reported. It also records defective nearside headlamp and side lights. The tyre readings are inconsistent.

• 29 December 2024 – Preventative Maintenance Inspection but no discernible brake test.

• 29 November 2024 – Preventative Maintenance Inspection with roller brake test, 40%, 50%, 17% but the record produced by CPA fails to record the measured weight of the vehicle.

• 14 November 2024 - Preventative Maintenance Inspection with HTC roller brake test recording the tested weight at 24880 kg. It also records defective indicator lamp etc.

• 14 October 2024 – Preventative Maintenance Inspection but no discernible brake test. It also records a defective mirror, NOX sensor and CAT replaced.

• 8 September 2024 – Preventative Maintenance Inspection but no discernible brake test. It also records a defective wiper blade.

The keys are kept by the operators but generally the same driver is allocated to the vehicle. I refer to PN73 EHF driven by Driver Baja and KX66 OPK, driven by Driver Basile, where driver detectable defects are identified at Preventative Maintenance Inspection but without accompanying driver defect reports. I saw an example of the new driver defect reporting app, which will now require drivers to submit photographs of defects. However, that still requires Preventative Maintenance Inspection records to be cross-referenced and addressed with drivers. At present, too much is being left to Mr Fayne, without the Directors taking responsibility for compliance with the operator licence requirements. There is clearly an awareness of health and safety in the business, but in regard to the transport operation, the risk assessment process and control measures have been shown to be lacking.

Determination

Based on the evidence, summarised above, I was satisfied that I should record adverse findings under the following sections: 26(1)(b) – conditions on licence to notify changes – conviction and in the ability of Directors, 26(1)(c)(ii) – conviction of the driver, 26(1)(c)(iii) – prohibition arising from a driver failure, 26(1)(e) – statements relating to safe operation and to abide by conditions on the licence, 26(1)(f) – undertakings (vehicles to be fit and serviceable, to employ an effective written driver defect reporting system, to ensure completed maintenance records, to comply with the laws on drivers’ hours and tachograph regulations).

The operation involves vehicles from 1 tonne up to 30 tonne excavators, 1 tonne to 9 tonne dumper trucks, rollers etc. I was told that the business had grown considerably during the last 13 years, with additional Directors appointed on 27 November 2014 (Enda Cosgrove, Finance Director), 17July 2018 (Eamonn Carty), and 28 February 2022 (Neil Skelton, Commercial Director). There are approximately 20 employees, with over 700 operatives, and turnover of £80 million in the last financial year.

The police investigation established the driver’s standard of driving, but the operator was responsible for the management of risks arising from its activities. As the Upper Tribunal remarked as long ago as 2013/022 David James Roots t/a Orange Coach Travel: TCs are not required to wait and then react after some serious event has occurred because they can, when the evidence justifies it, take action to prevent the serious event from occurring in the first place. The operator correctly accepted its responsibility for the context in which the incident occurred. It had already looked at measures in the business to ensure that drivers (and yard staff) are adequately trained. I disagreed that management measures are now sufficient, and I took that into account when addressing the case for Mr Contra:

Driver Conduct

The relevant legislation is set out in Sections 110-122 of The Road Traffic Act 1988. The legislation draws a clear distinction between Large Goods Vehicle (LGV) licence holders and applicants and Passenger Carrying Vehicle (PCV) licence holders and applicants.

Section 112 of the 1988 Act provides that the Secretary of State shall not grant to an applicant a LGV driver’s licence or a PCV driver’s licence unless he is satisfied, having regard to his conduct, that he is a fit person to hold the licence applied for. It is section 121(1) which defines conduct:

• in relation to an applicant for or the holder of a LGV driver’s licence or the holder of a UK licence for the Community, his conduct as a driver of a motor vehicle; and

• in relation to an applicant for or the holder of a PCV driver’s licence or the holder of a PCV Community licence, his conduct both as a driver of a motor vehicle and in any other respect relevant to his holding a PCV driver’s licence or (as the case may be) his authorisation by virtue of section 99A(1) of this Act to drive in Great Britain a PCV of any class.

Counsel ascribed the failings to a genuine error, during a period where personal circumstances had led to this lapse of attention. As the Administrative Court, on the application of Meredith and Others EWHC 2975 (Admin) 18, explained whilst the personal circumstances of the driver are, at the preliminary stage of consideration of fitness, irrelevant to the question whether his conduct as a driver has been such as to make him unfit, save to the extent that those circumstances concern his conduct as a driver. Personal circumstances which go to mitigate the conduct itself (such as illness, or emergency, or momentary lapse of attention, or carelessness) will be relevant, while personal circumstances which would, in the ordinary sentencing exercise by a criminal court go to mitigation of penalty (such as loss of work, or other hardship, or the dependence of others upon the licence-holder) would not.

The Administrative Court did not go on to consider the applicability of the principle of deterrence, which was considered by the Court of Session in Thomas Muir (Haulage) Limited v The Secretary of State for the Environment, Transport and the Regions [1999] SC 86, but regulatory action undoubtedly contributes to achieving of the purpose of the legislation. As the Senior Traffic Commissioner’s Statutory Document No. 6 on Vocational Driver Conduct advises, the starting point for intervention after a bridge strike is a suspension for 6 months. The starting point for driver’s hours offences is much less.

A professional driver is not expected to allow lapses of attention as they are in charge of vehicles which are by their very nature and size, dangerous. The decision to drive in that state presents an unacceptable risk and the decision making is not indicative of a professional driver. In addition to the incident described above, I noted recent and recurrent WTD infringements recorded against Mr Contra. He confirmed that Mr Fayne identified these to him, but there is no record of any other action. In evidence he admitted that his infringement rate was far better when he worked for another operator, where he was forced to address any infringements. The commitment to this driver by the operator and its readiness to accept overall responsibility was notable in regard to this decision and in respect of the operator’s licence. The Directors indicated that he would continue to be employed in a more minor role during any suspension. Taking all the circumstances into account, I determined that the vocational entitlement should be suspended for a period of two months, commencing today.

Operator

I was told that the operator had responded promptly and appropriately to the incident by conducting an internal investigation and then reacting to this by making changes and improvements to training, policies and procedures across the business. The changes were described as comprehensive and specifically designed to address the root causes of the incident. The operator pointed to the limited damage to infrastructure, lack of injury to pedestrians or road users, accepted the possibility of interruption to train traffic and pointed to co-operation with the investigation, which I accept. I also took account of the annual test pass rate. It was suggested that there is regular roller brake testing but see above.

In seeking to persuade me that the absence of injury and the resulting damage was minor, representations risked confusing this hearing with a health and safety sentencing exercise. Whilst I have departed from the starting points advocated by the Senior Traffic Commissioner, for the reasons identified above, that does not detract from the fact that this incident could so easily have killed another road users or members of the public. This is intended to be a preventative regime. The operator is subject to statutory duties, which include a requirement to maintain a suitable and sufficient risk assessment and to implement control measures to reduce those risks to a level so far as it reasonably practicable. It can be hard to trust an operator to manage its risks if it has failed to make a proper assessment, particularly where guidance has been in circulation for years.

If the driver had received training and the operator had planned a route to avoid or given instructions which took account of the bridge height sign more seriously instead of assuming it would fit as usual. The driver was not allowed sufficient time after the first bridge to avoid the second, having seen the height of 15’. He should have adjusted his speed. Training delivered through the operator had confused the driver as to the correct method of securing the load, although he had previously stowed the arm of the excavator correctly. In this case, the ready acknowledgement of the failings led me to believe that the operator is some way towards a position where it is capable of future compliance. However, there is further action required, and the operator offered me the following undertakings:

• To employ laden roller brake testing of vehicles and any trailers at every Preventative Maintenance Inspection (or 7 days before) as per DVSA guidance.

• To employ an effective driver disciplinary process which address all areas of non-compliance, from 14 days following the Public Inquiry.

• Within 14 days to produce and adopt Key Performance Indicators for each of the operator licence requirements so that the Board of Directors now takes responsibility for compliance with the same, starting from the operational meeting on 27 February 2025.

To identify an independent body (i.e. not an existing consultant to carry out an audit of all licence compliance systems. The audit will assess the operator against the standards published under the DVSA earned recognition scheme: www.gov.uk/government/publications/dvsa-earned-recognition-vehicle-operator-standards A copy of the report together with the operator’s detailed proposals for implementing the report’s recommendations is to be submitted to the Office of the Traffic Commissioner in Cambridge within 6 months of the date of the Public Inquiry. The audit will assess the systems for complying with maintenance and/or drivers hours requirements, and the effectiveness with which those systems are implemented. The audit should cover at least the applicable elements detailed in the guidance on Operator Compliance Audits available at: www.gov.uk/government/publications/operator-compliance-audits

• To supply admissible financial evidence (copies having already been lodged) which is endorsed on every page by a representative of the supplier, to show an average which meets the required sum, within 14 days of the Public Inquiry.

As a spur to action and as a warning that there can be no recurrence, I determined that deterrent action was required. Moving the plant from site to site is a small but important part of the business, as it enables the operator to access the right plant at the correct time to prevent delays on site. There are between eight and nine operational sites. I was told that suspension, even for a short time, would build in significant delays across the construction sites. The carriage of plant was said to be specialist work (that depends to some degree on the size), and outsourcing would require a significant amount of planning. It was suggested that significant curtailment “would begin to affect their ability to meet demand”. The operator has authority for six vehicles with four in possession. I was told that there are three vehicles on the road every day, which are moving the items of plant between sites.

In this case the failings have tarnished the fitness of this operator. The licence is curtailed by half to 3 vehicles with effect from 23:45 tonight with YE08 EEY to be removed from the licence and disc returned to the Office of the Traffic Commissioner in Cambridge within 7 days.

Whilst safety management is often miscategorised as an antidote to common-sense, all operators need to appreciate that risk assessment is not simply a matter of waiting for a danger to materialise, to then take action after the event. The outcome of this incident could have been truly catastrophic. Effective control measures should prevent an incident from occurring, protecting others from injury, drivers from the lasting impact, the reputation of the business and its liabilities. Compliance should make good business sense to any reputable operator.

R Turfitt

Traffic Commissioner

12 February 2025