Camden CLOCS up another first

Camden is the first London borough to become a CLOCS (Construction Logistics and Community Safety) champion. In this article we examine why Camden decided to join 400 industry members of CLOCS and how it is implementing the CLOCS safety standard on the ground. Given the clear benefits of CLOCS,  the question for politicians in other London boroughs (only Camden and the City of London are CLOCS champions) is why have they not joined CLOCS?

Work related road risk

Gone are the days when you could see a construction worker climbing a poorly secured ladder with bag of cement under each arm. Health and safety at the work place is much more tightly controlled in recent decades and high accident rates such as those during the construction of the Channel Tunnel (502 accidents in 1989-1990 giving a rate of 4% of the workforce) have faced Parliamentary scrutiny.

The focus on work related road risk (WRRR), however, is a new development and became a priority issue in London after a series of fatal cyclist collisions in 2012. Responding to the public outcry Transport for London commissioned a report called Construction Logistics and Cyclists Safety which noted the high proportion of cyclists deaths (around 50%) resulting from collisions with lorries and identified a series of measures that could help reduce that death toll.

CLOCS

CLOCS – now entitled the Construction Logistics and Community Safety standard in recognition of its role in reducing both pedestrian and cyclists collisions (around 20% of pedestrian fatalities involve a lorry) – was formed as an industry–led body to help implement the recommendations of the CLOCS report. While the construction industry signed up in numbers (around 400 thus far) boroughs have been slower on the uptake.

Camden’s says its decision to join CLOCS was founded on its transport policy which prioritises sustainable forms of transport and seeks to minimise risk to road users. The Council’s Cabinet Member for Transport, Phil Jones explains: 

“In Camden we take a proactive role in improving the safety of large vehicles travelling through our borough and London… We have also used the opportunity to introduce changes to our procurement practices to include stringent road safety requirements, as well as via our planning process to ensure safer vehicle operation on construction projects in the borough. This means we are the first borough to monitor and spot check compliance for safety equipment on large vehicles as well as driver training and accreditation.”

Having accepted the importance of WRRR in 2014 and incorporated it into its planning procedures and procurement policies, the step to becoming a CLOCS champion for Camden was a logical one. Using a nationally recognised, and industry-led, standard improved clarity for developers and helped ensure consistent standards between the council’s own procurement and that in the private sector.

Working with contractors

Camden’s contractors are now required to meet work related road risk terms linked to CLOCS and which include Fleet Operator Recognition Scheme (FORS) (link) silver level accreditation (grade) as a component. As a CLOCS champion, Camden has stipulated that construction developments in the borough also have to adhere to the CLOCS standard. Compliance for both contractors and construction sites is monitored and enforcement action taken if necessary. Camden’s own fleet is gold FORS accredited.

Camden uses Section 106 agreements to enforce CLOCS standards on development sites in the borough. All developers are asked to complete a Construction Management Plan which aheres to CLOCS standards and Camden’s own minimum requirements for building construction. The Construction Transport Management Plan is accessible on the Council’s Planning Obligations (section 106) web page.  The specific arrangements are agreed with council officers before developments can proceed on site. In effect, the application of the CLOCS standard is part of the planning process.

The advantage to developers of following the CLOCS standard and procedures is that they are in line with industry-led standards (something many of them highlight on their vehicles and websites) that have council support and, importantly, that they are likely to have fewer impacts on the local community and therefore generate fewer complaints from residents. Both cyclists and pedestrians will have noticed, for example that the use of banksmen at developments in Camden and the City of London have reduced the occasions when conflicts arise at the entrances to worksites. The standards also specify the safety features fitted to lorries, vehicle routing arrangements, loading arrangements and access. The outcome, as far as Camden residents are concerned, is that they face less danger, less mud and rubble on the roads and less disruption as a result of  CLOCS standards.

CLOCS standards align with TfL’s Construction Logistics Plan as well as FORS standards so a company that meets requirements once knows it is in good stead for the other regulations.

Ensuring standards are implemented

Camden’s CLOCS procedures don’t end with an agreement on completion of a construction management plan and a section 106 agreement. The agreement has legal implications and Camden Council takes steps to check that the measures agreed are in place. This is now being carried out, on a trial basis, by representatives of the well-established Considerate Constructors Scheme (CCS) which has joined the CLOCS secretariat.  Sites get visits from officers to check that CLOCS standards are maintained.

Where the developer or contractor is already a CLOCS member the monitoring and compliance process is simplified as they are usually familiar with the requirements but Camden has found that compliance can vary. Most larger sites that are aware of CLOCS will ensure that all contractors are FORS graded and in some cases they will carry out their own compliance checks. During the trial period CCS will be talking to developers and providing them with reports on compliance with suggestions on how it can be improved.

Camden has not had need to step up enforcement beyond negotiation on procedures but there is the option of seeking a legal injunction to ensure that Section 106 conditions are met.  

Camden’s tips for boroughs on implementing work related road risk terms and CLOCS.

1 Define business case: Implementing WRRR should be defined as a normal health and safety issue that should be considered along with any other workplace or construction site issue

2. Prioritise corporate compliance: Aim to lead by example and as a minimum, achieve the same standards as your WRRR terms. Engage your Transport Manager early on to set a timetable for achieving FORS accreditation.

3 Balance scope with ability to monitor and enforce: Non-compliance rates across Camden suggest that simply including WRRR terms in contracts is not enough; compliance needs to be monitored

4 Prioritise by risk: If there is not the resource or appetite to implement across all contracts and vehicle sizes initially, then scope should be prioritised by risk.

5 Use available tools and existing processes: WRRR terms can be easily implemented using available templates, such as standard contract terms and WRRR non-compliance letters and monitoring resources, available via TfL’s WRRR toolkit and the Implementing Road Safety Using the CLOCS Process guide.

For further information, see www.clocs.org.uk,  www.camden.gov.uk/WRRR  and www.camden.gov.uk/CLOCS  

What you can do:

Ask your local councillor (unless you live in Camden or City) why your borough hasn’t become a CLOCS champion yet. This article is intended as a quick summary that a councillor can read and share with officers and other councillors. There is plenty of more detailed information on the www.clocs.org.uk and either TfL or LCC will be pleased to answer questions. 

Download this article as a PDF 

(This article first appeared in the Spring 2017 issue of London Cyclist magazine.)