When you think about winter driving risks, chances are that images of icy roads, snow-covered motorways and freezing temperatures come to mind. While it is true that adverse weather certainly increases the danger, some of the most significant driving-for-work risks during the final quarter of the year have little to do with snow and everything to do with workload, fatigue, darkness and commercial pressure.
For many businesses, this is one of the busiest periods of the year. Retailers, logistics companies, service providers and sales teams often face increased demand in the run-up to Christmas. Deliveries need to be made, customers expect rapid responses and employees may find themselves spending longer behind the wheel. Unless these risks are carefully managed, the festive rush can create serious health and safety consequences.
What does the law say?
Many employers still view road safety as primarily a road traffic matter. However, the Health and Safety Executive (HSE) is clear that driving for work is one of the most dangerous activities many employees undertake as part of their job. Health and safety law applies to work-related driving in just the same way it does to any other work activity.
Under the Health and Safety at Work etc. Act 1974, employers have a duty to protect the health, safety and welfare of employees so far as is reasonably practicable. The Management of Health and Safety at Work Regulations 1999 require employers to assess the risks arising from work activities and implement appropriate control measures. These duties extend to employees who drive for work, whether they use company vehicles or their own vehicles for business purposes.
The HSE recommends that employers consider three key areas when managing occupational road risk, especially in winter:
- The journey
- The driver
- The vehicle
Motor vehicles used for work come under the Provision and Use of Work Equipment Regulations 1998 (PUWER), as long as they are not privately owned cars used purely for private commuting (though company or non-private vehicles used for work are covered).
Key Points on PUWER and motor vehicles to bear in mind are:
- PUWER applies to non-private motor vehicles used as work equipment (such as commercial vans, lorries, site/dumper trucks and company cars), as well as any equipment mounted on them.
- While PUWER sets duties for maintenance, suitability and training, road traffic legislation takes precedence when the motor vehicle is being operated on public roads. However, PUWER still applies to the vehicle’s general suitability, maintenance and safe operation in workplaces or off-road sites.
- Under PUWER and related health and safety law, employers must ensure that work-supplied vehicles are:
- Suitable for the intended task.
- Maintained in an efficient state, efficient working order and good repair.
- Inspected where safety depends on installation or maintenance conditions.
- Operated only by people who have received adequate information, instruction and training.
Work-related driving is also governed by the Management of Health and Safety at Work Regulations 1999 (see above), which make risk assessments mandatory, alongside standard road traffic laws enforced by police and agencies like the DVSA
The hidden danger of Christmas delivery pressures
The weeks leading up to Christmas can create intense commercial pressure. Delivery deadlines become tighter, customer expectations increase and employees may feel under pressure to complete more journeys in less time. Unrealistic schedules can encourage unsafe behaviours such as:
- Speeding or rushing between appointments
- Skipping rest breaks
- Driving for longer periods without sufficient recovery time
- Taking risks in poor weather or low-light conditions
- Continuing journeys despite fatigue
Even where managers do not explicitly encourage these behaviours, overly ambitious schedules can create unintended pressure that influences driver decisions.
Therefore, employers should review workloads, journey schedules and performance expectations during busy seasonal periods. Building realistic travel times into plans is often one of the most effective ways of reducing risk.
Driving in twilight and darkness
While winter weather receives significant attention, reduced daylight hours present a major hazard in their own right. Many employees start and finish their journeys in twilight or darkness during Q4.
Twilight can be particularly hazardous because the changing light creates an awkward transition between daytime and darkness. Drivers’ eyes need time to adjust, while low sun, glare, long shadows and reduced contrast can make pedestrians, cyclists, road markings and unlit vehicles harder to distinguish from the background. Some road users may also delay switching on their lights because conditions do not yet appear fully dark. Drivers should therefore reduce their speed where necessary, increase the distance from the vehicle ahead, use dipped headlights appropriately and take extra care at junctions, crossings and on rural roads.
Reduced visibility can make hazards more difficult to spot, including:
- Pedestrians
- Cyclists
- Motorcyclists
- Animals on rural roads
- Vehicles without adequate lighting
- Standing water and potholes
Darkness can also affect depth perception, reaction times and concentration, particularly on unfamiliar routes.
Employers should consider whether journeys can be scheduled to make the best use of daylight hours where possible. Driver training can also help employees identify seasonal hazards and adapt their driving style accordingly.
Vehicle lighting becomes particularly important at this time of year. Faulty headlights, indicators and brake lights that may appear to be a minor issue during summer can become a significant safety risk during winter.
Fatigue can be as dangerous as bad weather
Fatigue represents one of the most significant but often overlooked driving-for-work risks. Long working hours, increased workloads, seasonal stress and disrupted routines can all contribute to driver tiredness. For some employees, the combination of long shifts and lengthy journeys creates a perfect storm for fatigue-related incidents.
Tired drivers may experience:
- Reduced concentration
- Slower reaction times
- Poor judgement
- Difficulty processing information
- Microsleeps
Importantly, fatigue does not only affect professional drivers. Employees travelling to customer sites, carrying out field-based work or attending meetings can all be vulnerable.
Businesses should therefore ensure that workloads and journey schedules allow sufficient time for regular breaks and rest periods. Managers should also be trained to recognise signs of fatigue and encourage employees to report concerns without fear of criticism or losing performance incentives.
Vehicle checks are more important in winter
Mechanical issues can become far more significant during winter conditions. Drivers should be encouraged to carry out routine vehicle checks before travelling, paying particular attention to:
- Tyres and tread depth
- Lights and indicators
- Windscreen wipers
- Washer fluid levels
- Battery condition
- Brakes
- Demisting and heating systems
Organisations that operate vehicle fleets should ensure maintenance schedules remain up to date and that defects are reported promptly. Where employees use their own vehicles for work, employers should not assume responsibility ends with confirming that the vehicle has an MOT. Appropriate checks should be in place to verify that vehicles are roadworthy, insured for business use and suitable for the journeys being undertaken.
Effective journey planning reduces risk
Good journey planning is one of the simplest and most effective controls available to employers. Before any significant journey, employees should consider:
- Route selection
- Expected traffic conditions
- Roadworks and diversions
- Weather forecasts
- Fuel or charging requirements
- Break locations
- Alternative travel arrangements where appropriate
Winter weather can change rapidly, particularly in rural areas. Employees should have clear procedures for delaying, re-routing or postponing journeys where conditions become unsafe. No employee should feel pressured to continue a journey if doing so would put them or others at risk.
