Sledges & the Law

HSE meeting with the Sledge owners - Updated 01Mar08

Note: This article may still be subject to an update in the near future, so please watch this space!

As a result of a fatality involving a Sledge in 2007 and the subsequent HSE investigation, in February 2008 a meeting took place at the White Lion at Alcester (Warwickshire) between three representatives of HSE and a large group of Sledge owners, operators and interested parties. The HSE not only wished to quash a number of ill-informed rumors and speculation circulating at the time but also to clarify the issue of current legislation which applies to Sledges and to appraise the operators of the need to perform a Risk Assessment prior to each Pulling event.

The HSE representatives present at the meeting were: -

Andy Gay - Principal Inspector, Field Operation Directorate North West
Liz Evans - Investigating Officer North West
Geoff Frackelton - Principal Specialist Inspector, Mechanical Engineering North West

The Tractor Pulling contingent included members of the: -

BTPA - British Tractor Pullers Association
PPA - Power Pullers Association
Independent Pullers - including Landford, Peak Vale Pulling, Malpas Tractor Pullers, the 'Total Overload' Team, South West Tractor Pullers, etc.

The meeting had originally been called by the HSE to discuss Pulling Safety with the 'Independent Pullers' however was later expanded to encompass all Pulling in the UK to ensure everyone was in possession of the full facts and to ensure all Risk Assessments would be performed using exactly the same criteria in all cases.

What rules currently govern the use of a Sledge?

The following is based on the presentations made by Liz Evans and Geoff Frackelton of the HSE. Presently the Sledge is covered by the the Provision and use of Work Equipment Regulations 1998 (PUWER98) and at certain times the Heal and Safety at Work Act. If the Sledge has been 'hired' as part of an event then the Pulling Track and the Sledge form part of a 'Workplace' and is therefore governed by the Health & Safety at Work Act!

Under the terms of the current HSE legislation the Sledge should be "fit for purpose".

PUWER98

Sledges are subject to the Provision and use of Work Equipment Regulations 1998 (PUWER98) and must: -

Be inspected at regular intervals to detect deterioration (separate to pre event inspections by officials) and all inspection results should be recorded and kept.
Inspection varies from a simple visual inspection to a detailed inspection with dismantling and or testing.
As a minimum, inspect safety related parts e.g. brakes, limit switches, warning devices etc.
Inspections should be carried out by people who have the necessary qualifications, experience and skills, for example a qualified BAGMA engineer.
Inspection frequency based on how quickly the Sledge is likely to deteriorate and give rise to risk.
Inspection results should be recorded and kept until the next inspection.
All Sledges should be maintained in an efficient state, in efficient working order and in good repair.
Maintenance should include 3 elements:
- Planned preventative
- Condition based
- Breakdown

Health & Safety Executive

From the purely HSE standpoint Sledge Owner must consider the following: -

Event safety
Employee and volunteer health and safety
Spectator safety
Emergency planning
Competitor and vehicle safety
Training

Health & Safety responsibilities - Sledges

Operator's responsibility - to ensure equipment is safe
Operator's responsibility - to be able to prove health and safety standards have been considered
Operator's responsibility - to do all that is reasonably practicable to ensure the safety of all involved i.e. themselves, employees, volunteers and others
Operator's responsibility - to undertake risk assessment and implement the findings

Summary

Need a risk assessment
PUWER for inspection and maintenance
Think safety at all times

We must always bear in mind that ultimately it is the event organisers' responsibility to ensure the event is safely organised!

Whilst the Sledge is regarded as an Agricultural Trailed Appliance, Tractor Pulling is actually a Motor Sport and therefore is subject to Health and Safety at Motor Sport Events. The definitive publication is available from the HSE web site, priced at £10.00.

Both HSE PowerPoint presentations are available to download in either PPT or PDF format along with a number of other resources which are either directly or indirectly related to the sport of Tractor Pulling.

Additional Information & Resources (HSE & BAGMA)

'Tractor Pulling Sledge Owners Meeting - 9 February 2008' - MS PowerPoint Presentation by Liz Evans, Investigating Officer, HSE.
'Pulling Sled Safety - 9 February 2008' - MS PowerPoint Presentation by Geoff Frackelton, Principal Specialist Inspector, HSE.
'PUWER98 - Inspections'. (BAGMA)
'Simple Guide to Provision and use of Work Equipment Regulations 1998' (PUWER98). (HSE)
'PUWER 98: How the Regulations apply to agriculture and forestry'. (HSE)
'A step by step guide to using tractors safely'. (HSE)
'Operator seat restraints for mobile work equipment in agriculture and forestry'. (HSE)
'BAGMA Vehicle Health Check' (BAGMA)
'BAGMA Trailed Appliance Health Check'. (BAGMA) To be used as a 'template' for creating a check list for the Sledge.
'Five steps to risk assessment'. (HSE)
Event Plan Template -Event Safety Management Plan. (Ribble Valley Borough Council)
Health and safety at motor sport events - A guide for employers and organisers. Authored by ACU, British Motorcycle Sport, MSA, Motor Sports Association United Kingdom for HSE. (HSE). This publication can be ordered from the HSE web site, priced £10.00

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