LOADING AND UNLOADING

VEHICLES

SAFETY RULE #4

“Vehicles are loaded and unloaded

safely”

Implementation Guidance

1 15-Jan-2019
4 – LOADING AND UNLOADING VEHICLES

Vehicles are loaded and unloaded safely

• Two levels of protection are used to prevent drive-

away during loading or unloading
Management
• The design of docks, ramps, levellers, and the
selection of vehicles, meets all standard
requirements
• Falls from the top of vehicles and rail cars are
prevented through engineering controls

• I always ensure two levels of protection are working,

Supervisors including backup methods if needed
• I always ensure that the correct vehicle and
equipment is used for the activity

• I always check that two levels of protection are in

Employees place to prevent drive-away

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CONTENTS
4 – LOADING AND UNLOADING VEHICLES .............................................................................................. 2
CONTENTS ............................................................................................................................................... 3
BACKGROUND ......................................................................................................................................... 4
MANAGEMENT REQUIREMENTS ............................................................................................................ 5
4.1 Two levels of protection are used to prevent drive-away during loading or unloading ........... 5
4.2 The design of docks, ramps, levellers, and the selection of vehicles, meets all standard
requirements ........................................................................................................................... 10
4.3 Falls from the top of vehicles and rail cars are prevented through engineering controls ...... 16
SUPERVISORS REQUIREMENTS ......................................................................................................... 19
4.4 I always ensure two levels of protection are working, including backup methods if needed 19
4.5 I always ensure that the correct vehicle and equipment is used for the activity .................... 20
EMPLOYEES REQUIREMENT .................................................................................................................. 21
4.6 I always check that two levels of protection are in place to prevent drive-away ................... 21

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BACKGROUND
RULE Vehicles are loaded and unloaded safely.
INTENT To prevent drive-aways, falls from trailers, falls from open docks, or other
falls and collisions.
HISTORY
Several Zones have had a number of recordable accidents and serious near-misses involving
loading and unloading, including fatalities.

Fatal accident – 2010

Serious Near-Miss / High Potential Incident 2016

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MANAGEMENT REQUIREMENTS
4.1 Two levels of protection are used to prevent
drive-away during loading or unloading
Safety Rules Audit
An external auditor will look for:
• Evidence that two methods are in use during loading/unloading.
• Evidence of training for employees and truck drivers.
• Methods being used during site visits.
• Vehicle restraint systems.
• Traffic lights to indicate when it is safe (green) or not safe (red) to move a vehicle.
• Inspect a sample of loading or unloading activities.
• Dock plate creep markings.
• Evidence of monitoring, daily inspections and maintenance checks.
Scoring Guide (3.4.1)
1 - No - Nothing has been done or no reliable methods are in place.
3 - Implementation is at an early stage or there is a substantive lapse. Only one method is regularly
used or there has been a failure in the second method without additional controls.
5 - Partially implemented. The site has identified the two methods for each loading / unloading
location but not fully implemented and trained methods to prevent creep not effective.
8 - Substantially implemented. All locations have two methods to prevent ‘Drive-away’ with
instructions for the driver and employee. There are effective methods to prevent creep.
10 - Yes - Substantially implemented and effective. Two permanent methods to prevent a ‘Drive-
away’ at all loading / unloading locations, with evidence of training for drivers and employees.
Expectation
Two Levels of Protection
Two methods will be employed to prevent the vehicle from driving away during
loading/unloading. Methods can include:
• wheel chocks;
• removing and securing the key of the driver of the vehicle;
• installing a locking device to the vehicle;
• Uncoupling a trailer so it cannot be driven away;
• for docks, a recognized vehicle restraint system.
This list and the examples below are each one type of method. A combination of two is
required. The methods may be short term while funding is requested for a permanent
solution, or for the installation of an automatic system. If one method fails then the
loading/unloading activity is halted until the failure is corrected, or another short-term level
of protection is selected and implemented before loading/unloading is resumed.

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Examples

Wheel chocks. Locking device.

Removing and securing the driver key. Interlocked ‘Powerchock’ system.

‘Salvo’ loading dock safety systems. Interlocked dock-lock system.

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Permanent automatic and semi-automatic vehicle restraint systems
It is important to make sure that vehicles do not move when they are parked, and during
loading, unloading and other operations, so that people who might be working on or around
the vehicle are protected from unexpected movement.
For loading docks, systems that physically restrain the vehicle and prevent it from moving
during loading and unloading, are to be installed and used on site. These systems must
include signals, such as traffic lights, to indicate when it is safe (green) or not safe (red) to
move a vehicle. Traffic lights should be used in conjunction with indicator lights inside the
dock at each loading bay to inform workers that the external traffic lights are set to red and
that it is safe to open the loading bay doors.
Vehicles should have suitable and effective brakes, both for general service and for parking.
Drivers sometimes use the emergency brakes as parking brakes when they uncouple the
tractive and semi-trailer units, because they have to disconnect the air-lines anyway. This
should never be allowed to happen. Air brakes should never be applied solely by
disconnecting the air-line hose. The emergency brakes should not be relied on to secure a
semi-trailer.
Although the actual brakes on this sort of system are the same for both the parking and
emergency brakes, the control mechanism is very different, and emergency brakes should
never be relied on to secure a semi-trailer.
Reconnecting the hose will free the brakes immediately, leaving the vehicle free to move
with the driver away from the cab. These accidents are called ‘vehicle runaways’ and can
mostly be prevented.
Making sure that both the tractive unit and semi-trailer parking brake controls are used is
the most effective way of making vehicle runaways less likely.
People in control of workplaces where trailers are parked need to make sure that drivers are
aware that both tractive unit and semi-trailer parking brakes should be used when parking.
Trailer parking brakes are there because they need to be, and must be used every time a
vehicle and trailer are parked. You should consider signs, instruction and any other
measures to make sure this happens.
Examples

The truck drives away whilst the fork The truck starts to creep away from the
lift truck is loading or unloading dock

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A fully automatic system that locks the A semi-automatic system that locks the
wheel. wheel.

External and internal traffic lights to Control panel indicating when it is safe
signal safe vehicle movement. to load or unload.

A Salvo system that prevents Dock doors are interlocked with the
reconnection of the air brake hose thus Salvo system.
immobilising the trailer.

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Systems to prevent movement (creep) when docked
Vehicles can move (or creep) away from the edge of the loading bay as loading equipment
jolts the vehicle or compresses its suspension when moving between the bay platform and
the vehicle. This can widen the gap between the bay and the vehicle and cause the dock
plate/leveller, which provides a platform between them, to suddenly slip. The vehicle
loader, machinery or goods can fall from the vehicle, posing a danger to the loader and
anyone working in the vicinity. This can occur even if the trailer has its park brake applied,
due to the vehicle rocking on its suspension.
Dock creep can also occur if the trailer landing leg area of the yard is uneven or is
deteriorating, causing the trailer foot to rock forward when loads are transferred into/out of
the back of the trailer.
This problem can also be exacerbated when:
• there is a difference between the height of the vehicle and the height of the dock;
• differences in positioning and thickness between the buffers on the dock and those
on the vehicle/trailer mean that the gap between the vehicle/trailer and dock vary;
• the vehicle/trailer is backed too close to the loading bay causing buffers to compress
and the vehicle/trailer to be temporarily wedged in position. The ‘bouncing’ motion
caused by the loading/unloading operation can then lead to a sudden drop in height;
• freight containers are backed onto a dock and inadvertently sit on top of buffers
(due to the significant height difference on a skeletal trailer). The container can then
break away during loading/unloading, resulting in a sudden drop.
Vehicle creep is prevented by implementing a vehicle restraint system as described in the
previous section. In the absence of a vehicle restraint system, a reliable wheel chock
procedure should be used as a minimum. The use of a system to prevent creep will usually
also count as one of the methods to prevent unexpected drive away.
The dock plate that forms a bridge between the vehicle bed and the loading bay provides an
overlap that should be able to allow for a certain amount of vehicle creep, without the plate
falling and causing a risk of injury. The larger the overlap, the more vehicle movement can
be incorporated.
A simple marking system should be used to show the minimum amount of plate that must
be within the vehicle and/or dock to allow for the maximum expected movement. This is
commonly marked at around 150mm depth (6 inches).
The inspection of dock plates prior to use should be documented and include a check of
creep prevention measures, and that marking systems are legible and properly aligned.
Evidence of such checks is required for full implementation.
Examples
Dock plate creep marking

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4.2 The design of docks, ramps, levellers, and the
selection of vehicles, meets all standard
requirements
Safety Rules Audit
An external auditor will look for:
• Evidence that dock doors are closed when not in use.
• Evidence of physical protection of open edges.
• Warning signs are in place.
• Inspect a sample of loading or unloading activities.
• Compliance with the Truck / Vehicle Compatibility Matrix.
• Inspect a sample of loading or unloading activities.
• Evidence that pallet trucks are only used in docked trailers.
• Evidence that fork lift trucks do not enter soft sided trailers.
• Administrative controls, and an approved action plan for reducing the risks
• Instructions for the use of loading ramps on site.
• Inspect a sample of loading or unloading activities using a mobile loading ramp.
• Evidence that Jacks are in use if required.
Scoring Guide (3.4.2)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. There is a clear plan with progress implementing adequate controls to
prevent falls from the rear of vehicles.
8 - Substantially implemented. All permanent solutions have been implemented to control
significant risks. Changes meet standard design requirements.
10 - Yes - Substantially implemented and effective. All permanent solutions have been implemented.
All docks, ramps, levellers and vehicles meet standard requirements.
Expectation
Protection for open docks to prevent edge drive off
For loading docks, it is important that there is a physical system to prevent a forklift from
driving over the open edge when a truck or trailer is not present. When a physical vehicle
restraint system is used (as described in previous examples) it is usual for the system to be
interlocked with either the door, or the dock leveller. The door, or the leveller, then act as a
physical barrier that protects the edge, and can only be opened after a truck/trailer is
docked in place.
If the site does not have an automatic system, then alternative controls must be
implemented. This could include a manual door, gate or barrier in combination with good
procedural control. The door or barrier must remain closed when the dock is not in use.
In addition to drive-off protection, if the presence of open docks cannot be avoided, signs
and ground markings should be in place to warn employees of the fall hazard. Generally,
employees should not work within 2 metres (6 feet) of an unprotected dock edge.

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Examples

Interlocked door system. The dock leveller acts as a barrier.

A warning sign

Correct vehicle selection for all loading/unloading activities.

There are many types of lifting trucks used to load and unload many types of vehicles. The
Compatibility Matrix clearly identifies which trucks can be driven into/onto which vehicle
when loading or unloading.
Truck / Vehicle Compatibility Matrix
Fork Lift

Ride-on
Stacker

Stacker

Mobile
Walkie
Reach

Ramp
Pallet
Truck

Truck

Truck

Container Y Y Y Y Y Y
IF DOCKED

Refrigerated Y Y Y Y Y X
IF DOCKED

Curtain-sided X X X Y Y X
IF DOCKED

Rigid Box Y Y Y Y Y X
IF DOCKED

Flat Bed Y X X X X X
FROM
GROUND

Tail Lift X X X X Y X
Mobile Ramp Y Y X X N N/A

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No pallet trucks in trailers unless docked.
Pallet trucks can only be used to unload trailers that are docked in a semi or automatic
restraint system (see Management Requirements examples).
Pallet trucks placed in the back of the trailer must be avoided. Falls from the back of trailers
are a common accident in the logistics industry.
Examples

Fork lift trucks are not permitted in soft-sided trailers.

Generally, Fork lift trucks are not permitted in soft (curtain) sided trailers. Pallet trucks and
Electric pallet trucks (such as a ‘walk-behind’ or a walkie-stacker) can be used to unload soft
sided trailers, but only through the rear door when the trailer is docked in a semi or
automatic restraint system.
The intention is to avoid the risk of the forklift placing a wheel off the side of the deck, with
a potential tip-over. Even with the side closed, this type of trailer may not offer any more
protection than an open deck. In some cases, the trailer deck may not be designed to carry
the dynamic load of a forklift, so has the additional risk of giving-way under a forklift wheel,
with a potential tip-over.
If soft sided trailers cannot be avoided, the first option should be to consider if loading from
the side at ground level is possible. If not, some trailer designs have side support bars and
toe-boards that would prevent the forklift driving off the side of the trailer, as shown in the
examples below. If this is not possible, administrative controls could include limiting the
type of forklift, implementing a specific loading procedure, and inspecting the trailer for
damage prior to loading and unloading.
The risk may not be as great as that of drive-away or creep, but a proper understanding of
the risks depends on the total system, including the specific design and maintenance of the
trailer, and the type and weight of the forklift. If this is a common practice that is not easily
eliminated, then a review and risk assessment approved by the zone ORM lead should be
completed. For the practice to continue, there must be at least administrative controls
implemented that reduce the risk, with an agreed action plan to implement a more
permanent solution. The actions and implementation time-frames must be appropriate, as
agreed with the zone ORM lead. Agreed actions that are delayed or deferred may reduce
the scoring on subsequent audits.

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Examples

Fork lift truck driving inside a soft sided Access from both the side and the rear
trailer. of the trailer.

Fork lift truck loading a soft sided Fork lift truck unloading a soft sided
trailer. trailer.

Soft sided trailer with support bar and ‘toe’ boards.

Loading ramps are used for containers only.

Containers are typically loaded and unloaded by reversing the vehicle against a raised
concrete loading bay of a similar height, allowing counter-balanced fork lift trucks to
transfer cargo on and off the container. Inherently there is a height differential between the
container and loading bay, as well as a horizontal gap; a levelling device is therefore used as
a loading ramp to allow access and bridge the gap. Nonetheless, there are many situations
where it is impractical or even impossible to install a loading bay at all, let alone one that is
appropriate to the variety of vehicles and heights common to a busy loading/unloading
operation. In these situations, a container loading ramp is an ideal solution. The container
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ramp delivers fast and efficient loading/unloading of trailers via fork lift truck without the
need for a permanent raised structure.
Businesses without fixed loading bay facilities often move goods manually to the back doors
of the vehicle, to be removed by fork lift truck at ground level – a highly hazardous and ill-
advised solution.
The container ramp typically incorporates a tow bar or hitch allowing it to be swiftly and
easily re-positioned as required by a single fork lift truck. The mobile design of loading
ramps makes them ideal for sites where space is a premium, or sites with rapidly changing
operations/requirements.
The container ramp is raised above the vehicle bed height by a hydraulic pump (manual or
electrical). The ramp is then positioned against the vehicle (or vice-versa), and hydraulic
pressure released which lowers the ramp to the vehicle. As the vehicle and ramp will change
height during the (un)loading process, the ramp will ‘float’ with the vehicle ensuring smooth
and safe operation. Safety chains are used on both sides of the ramp to prevent the ramp
from separating from the vehicle during use. Wheel chocks are fitted to both the wheels of
the vehicle and the container ramp. A Trailer Safety Support must be used to provide
additional support under the fifth wheel of a parked trailer with no cab in situ. This prevents
the trailer from tipping when unbalanced during (un)loading.
Examples

Unloading without a ramp. A mobile loading ramp

A mobile loading ramp. Wheel chocks to prevent creep.

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Uncoupled trailers require a fixed Jack at the front during loading.
When a trailer is uncoupled from the tractor unit and the landing legs lowered, the trailer
can be prone to tipping forward from the landing legs if too much weight is placed towards
the front of the trailer. This can be caused by a heavy load or the use of heavy equipment,
such as a fork lift truck, within the trailer. It is also possible for the landing legs to collapse,
especially if rocking or ‘creep’ occur as discussed previously.
One approach to control this hazard is to ensure the tractor unit remains coupled to the
trailer whilst the vehicle is being loaded, thus avoiding the potential ‘see saw’ effect about
the landing legs. However, in certain circumstances this may increase the drive-away risk.
Alternatively, trailer props can be used to stabilise the trailer. A robust safe system of work
covering the use of trailer props is important, as workers who put them in place and remove
them may be exposed to hazards from moving vehicles on site as well as the mechanical
handling and safe positioning issues.
Some locations may have regulations that require the use of such equipment. Where it is
not mandated, risk assessments should be used to identify the correct controls for this type
of hazard, taking into account the specific design of local trucks and trailers, and the
loading/unloading methods and equipment.
Examples

Trailer tipping during loading A trailer safety Jack

A trailer safety Jack in use. A trailer safety jack in use.

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4.3 Falls from the top of vehicles and rail cars are
prevented through engineering controls
Safety Rules Audit
An external auditor will look for:
• Engineering controls to prevent falls from the top of vehicles.
Scoring Guide (3.4.3)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. There is a clear plan with progress implementing adequate controls to
prevent falls from the top of vehicles.
8 - Substantially implemented. All permanent solutions have been implemented to control
significant risks.
10 - Yes - Substantially implemented and effective. All permanent solutions have been implemented
to prevent falls from the top of vehicles, for any person on site.
Expectation
Avoid work at height if possible, do as much as you can from the ground, for example by
using gauges and controls that are accessible from the ground.
If work at height cannot be avoided, collective control measures should always take priority
over personal control measures. Collective measures protect everyone who is at risk (i.e.
more than one person at any one time), for example gantries or platforms fitted with guard
rails, and they usually require no action by the user to work effectively. They should also
have a safe way for people to get on and off them. Stairs are preferable to ladders on site-
based platforms
Personal control measures rely upon personal protective equipment (PPE) and only protect
the individual, for example a personal fall-protection system. They usually require the user
to do something for them to work effectively, such as putting on a safety harness correctly
and connecting it via an energy-absorbing lanyard onto a suitable anchor point.
Where vehicles have their own access system and working platform, such as on tankers and
tipper trucks, these may be used in preference to site-based systems. However, the working
platform should be suitable for the work being carried out and the edge protection to the
working platform should be suitable and sufficient. Edge protection would typically include
a rigid upper and intermediate guard rail which incorporates a self-closing gate. Some
vehicle-based systems, such as those found on many tankers, only have one side rail, so
permanent site facilities may offer increased protection.
Most site-based platforms are simple drive-through or drive-past structures. They should be
designed so that drivers are able to pull up closely alongside the platform to prevent falls
between the vehicle and the edge of the platform. Most platforms are a fixed height and
width, so cannot be adapted to accommodate vehicles of different sizes.
Gantries can be used where many different-sized vehicles are expected and normally consist
of a platform with an overhead beam that extends over the vehicle. A personal fall-
protection system is attached to the beam. They provide greater flexibility in terms of
vehicle size, but rely on the user being trained, and monitoring to make sure they are used
properly.

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Examples

The driver has accessed the top of the The truck starts to creep away from the
tanker without using the safety rail. dock.

The driver climbs on top of the product Fixed installation.

to apply the tarpaulin cover.

Fixed installation. Fixed installation.

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 Vehicle mounted installation. Portable installation.

Vehicle mounted installation.

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SUPERVISORS REQUIREMENTS
4.4 I always ensure two levels of protection are
working, including backup methods if needed
Safety Rules Audit
An external auditor will:
• Check documented procedures.
• Check documentation of training and communications.
• Look for physical evidence of the two levels of protection in use.
• Interview supervisors through a conversation to understand how they would respond
to one of the levels of protection failing.
• Observe behaviour.
Scoring Guide (3.4.4)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all the verification steps align, and substantial improvement is
required.
8 - Substantially implemented. Evidence from all the verification steps is aligned, and only minor
improvements are recommended.
10 - Yes - Substantially implemented and effective. Evidence from all the verification steps is aligned
and consistently maintained. No further improvements identified.
Expectation
It is the responsibility of the supervisor to ensure that the two levels of protection to
prevent drive-away are being used by employees and drivers, and working effectively. If one
of the methods fails, then a temporary or interim method must be implemented and
communicated to all affected people, until the usual methods can be restored.
For example, if one of the methods relies on an automatic docking system or interlocked
door, and the system fails or needs to be bypassed or overridden, then addition manual
controls must be added. If drivers are used to relying on an automatic system and they are
not aware that the system has failed, this can easily lead to false assumptions about the
level of protection with potentially severe consequences.

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4.5 I always ensure that the correct vehicle and
equipment is used for the activity
Safety Rules Audit
An external auditor will:
• Check documented procedures.
• Check documentation of training and communications.
• Look for physical evidence of the availability of different vehicles and equipment.
• Interview supervisors through a conversation to understand how vehicle and
equipment selection is made.
• Observe behaviour.
Scoring Guide (3.4.5)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all the verification steps align, and substantial improvement is
required.
8 - Substantially implemented. Evidence from all the verification steps is aligned, and only minor
improvements are recommended.
10 - Yes - Substantially implemented and effective. Evidence from all the verification steps is aligned
and consistently maintained. No further improvements identified.
Expectation
As explained in the vehicle selection section of the Safety Rule, some vehicles or equipment
are not to be used to load or unload certain types of trucks and trailers. Supervisors need to
be aware of how the vehicles selections are made and what the incompatible combinations
are.
For some sites, incompatible combinations may not physically be present, especially if the
trucks and forklifts are all a consistent compatible design. For other sites where there is
more variability, and different vehicles and equipment are available for selection, then
supervisors must be able to demonstrate how incompatible combinations are controlled
and managed on a day by day basis.

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EMPLOYEES REQUIREMENT
4.6 I always check that two levels of protection are in
place to prevent drive-away
Safety Rules Audit
An external auditor will:
• Check documented procedures.
• Check documentation of training and communications.
• Look for physical evidence of the different levels of protection available.
• Interview employees through a conversation to understand their current awareness
and practices.
• Observe behaviour.
Scoring Guide (3.4.6)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all the verification steps align, and substantial improvement is
required.
8 - Substantially implemented. Evidence from all the verification steps is aligned, and only minor
improvements are recommended.
10 - Yes - Substantially implemented and effective. Evidence from all the verification steps is aligned
and consistently maintained. No further improvements identified.
Expectation
It should be made clear to employees that they are expected to stop work and seek
assistance if they believe it is unsafe to proceed.
The person that operates a vehicle to load or unload a truck or trailer, needs to have
confidence that it will not move or drive away during loading/unloading. This is especially
critical when they are driving a vehicle into the truck or trailer from a dock.
They are expected to take some responsibility for their own safety and check that the
methods of protection are working, so that the truck/trailer will not move until after they
signal that the loading/unloading is completed.

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