Being struck by a moving vehicle is one of the main ways people are killed on construction sites, and the person killed is often not the driver. The person hit by a reversing lorry is usually walking to the welfare, or to their car, or past the gate on the way to school. Regulation 27 of the Construction (Design and Management) Regulations 2015 exists for that person, and it applies to a two-week extension as much as to a hospital. What changes with the size of the site is how much paper the answer takes, not whether there is one.
What the regulation says
Regulation 27 requires every construction site to be organised, so far as is reasonably practicable, so that pedestrians and vehicles can move without risk. Traffic routes have to be suitable for the people and vehicles using them, sufficient in number, in suitable positions and of sufficient size. Vehicles and pedestrians are separated or, where that is not reasonably practicable, other means of protecting pedestrians and effective warning are provided; a loading bay has a way out for people on foot; where it is unsafe for pedestrians to use a vehicle gate there is a clearly marked pedestrian door nearby, kept clear; and routes are signed where safety needs it.
Regulation 28 deals with the vehicles: steps to prevent unintended movement, a warning to anyone at risk, given by the driver or by the person directing the driver where the driver cannot see, safe loading and unloading, and nobody riding on a vehicle except in a safe place.
On a project with more than one contractor the principal contractor owns these arrangements under regulation 13; with a single contractor, regulation 15 puts them on that contractor. Regulation 16(1) puts Part 4, which includes regulations 27 and 28, on every contractor for matters within their control. HSE's guidance is HSG144, The safe use of vehicles on construction sites, and where the site meets the street, HSG151, Protecting the public.
What "organised" means on a small site
The regulation never says "traffic management plan", but a site cannot show it is organised without one. On a small site the plan is two or three pages and a drawing, and the drawing is the part that matters: the gate, the route in, where a vehicle turns or drives through so that it leaves forwards, where it is unloaded, where the people walk, and where the two cross.
Reversing. HSG144's order is to design reversing out first and control what is left. A one-way route, a turning head, or an unloading bay laid out so that the lorry arrives forwards removes the manoeuvre altogether. Where one remains, the site names it and who marshals it, and says what the vehicle must carry before it is allowed to reverse. That is the person directing the driver in regulation 28(2)(b).
Deliveries. An unbooked delivery is the one that reverses across the pavement at half past three. A booking sheet with a window, a holding area off the highway and a known offloading method turns a surprise into a planned movement. The driver rarely receives the full site induction; a one-page notice at the gate, with the speed limit the site has set written on it, is how the rules reach them.
Separation. A marked walkway with a barrier, a pedestrian gate that is not the vehicle gate, and a crossing point where the two routes must meet. On a tight site the answer is often time rather than space: vehicles move in a window when nobody else does.
The public
Where the boundary is a school railing or a shop front, the plan has a second audience. Regulation 18(2) requires the perimeter to be identified by signs and/or fenced off where necessary, in accordance with the level of risk; HSG151 adds the arrangements — sensitive times when the gate stays shut, no offloading onto the pavement, a marshal holding the footway when a vehicle crosses it, and a number a neighbour can ring. The weekly inspection then walks the routes against the drawing and records where the two have drifted.
What a template does not do
A template gives the site the headings, the questions and the legal driver printed on the sheet. It does not know where your gate is, and it does not know what speed your route can take. The competent person running the site draws the drawing, sets the limit and appoints the marshal, and no document makes anyone compliant. Why we will never call a document "compliant".
Documents for this work
- The traffic management bundle — all six documents
- Site Traffic Management Plan — the regulation 27 plan, with the drawing
- Delivery Management Plan and Booking Sheet
- Banksman and Vehicle Marshal Appointment and Briefing
- Site Speed and Vehicle Rules Notice
- Public Interface Plan — Schools, Shops and Occupied Buildings
- Reversing and Restricted Visibility Control Sheet
- Site inspection records — the weekly inspections that check against these plans