Provision of evidence-based assessment of litter-picking risks
Zilch UK made this Freedom of Information request to Highways Agency
This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.
Dear Highways Agency,
Increasingly governments and organisations are adopting an evidence-based approach to decision making and policy and this request is for you to provide us with your evidence-based assessment of the risks associated with roadside litter picking.
On the one hand we are told that are motorways are the safest roads in Europe, on the other we are told that in order for litter picking to be carried out along the sides of these highways it's necessary to deploy costly and obstructive lane closures.
If this is the case, tackling existing and ongoing litter is likely to be prohibitively expensive and enormously time consuming; so much so as to make the task impossible.
Undeniably roadsides of any kind are unpleasant places but this doesn't necessarily mean that they are prohibitively dangerous. There may well be more danger meandering along a pavement in a busy and congested town than there is associated with walking down the hard shoulder of a motorway.
We would therefore like to know what evidence-based risk assessment the Highways Agency has carried out to determine the true risk to personnel of this activity.
In particular we would like to know what assessments have been made of undertaking litter-picking activities:
- on highways with different roadside configurations such as hard shoulders, crash barriers etc
- in different weather conditions comparing for example dry clear conditions with working in the rain
- using a variety of operational practices such as lane closure, barrier vehicles or unprotected
- at various times of day and under a variety of different lighting conditions
- alongside a variety of traffic flows; slow moving when approaching roundabouts etc
- around different road configurations such as sliproads and roundabouts
We would also like to know whether any comparison of the risk to workers and motorists of the different operational approaches has been undertaken. Comparing at the one extreme the activity of coning off and deviating traffic along a considerable length of motorway with that of merely having a litter-picking person walk along the side of that motorway with nothing more than a high-viz vest as protection.
Wherever risk assessments have been carried out we would appreciate being provided with the conclusions of that work and the references to any contributing studies.
Yours faithfully,
Zilch UK
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Dear Sir/Madam
I am writing in response to your request for information concerning risk
assessment of roadside litter picking below.
I can confirm that risk assessments for different sites and road types are
undertaken as required by the Management of Health & Safety at Work
Regulations 1999, but not by Highways England. The duty to undertake risk
assessments falls to the employers of the staff carrying out this
activity. As you may be aware we engage a number of supply chain partners
to carry out this work on our behalf.
The legislation places a clear duty on employers to apply the following
preventative principles when considering appropriate protective measures:
Avoiding risks
Evaluating risks which cannot be avoided
Combating risks at source
Adapting the work to the individual
Adapting to technical progress
Replacing the dangerous by the non-dangerous or less dangerous
Developing an overall prevention policy
Giving collective protection measures priority over those that protect the
individual
Giving appropriate instructions to employees
Our supply chain partners will take account of these legal requirements
when preparing their risk assessments. I am unable to comment further on
any other factors which may be taken into account.
I attach two examples of risk assessments and a related procedure for
litter picking for your information. Please note that some personal
information has been removed in reliance on the exception in regulation 13
of the EIRs.
If you are unhappy with the way we have handled your request you may ask
for an internal review. Our internal review process is available at
[1]https://www.gov.uk/government/organisati...
If you require a print copy, please phone the Information Line on 0300 123
5000 or email [2][Highways England request email] You should contact me if you
wish to complain.
If you are not content with the outcome of the internal review, you have
the right to apply directly to the Information Commissioner for a
decision. The Information Commissioner can be contacted at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
If you have any further queries about this matter, please contact me.
Please remember to quote reference number 17912246 in any future
communications.
Yours faithfully
FOI Advice Team
Highways England
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