Allan Stevenson

Dear Mr Parsley Regulation 28 Report to Prevent Future Deaths following the inquest touching upon the death of Mr Allan Stevenson
1. I am writing to you on behalf of Anglian Water (Anglian) in response to you Regulation 28 Report dated 6 April 2026 (the PFD Report), following the inquest into the death of Mr Allan Stevenson (the Inquest). I wish to express our deepest sympathy and sincere condolences to the family and friends of Mr Stevenson.
2. By way of background, Anglian is a water and recycling company which operates throughout England and Wales. We supply essential water and water recycling services to around 7 million people, covering 14 counties across the East of England and Hartlepool. Our group employs around 6,000 people and work alongside 3,000 alliance partners and contractors. We are constantly striving to be the best company we can be, which reflects a company that makes a real and meaningful impact for our customers, communities, colleagues and environments.
3. The health, safety, and wellbeing of our employees, contractors, and all those affected by our operations is Anglian’s highest priority. We are fully committed to creating and maintaining a safe working environment, and our approach to health and safety is embedded at every level of the organisation. We foster a culture of continuous improvement and encourage open reporting of hazards, near misses, and safety concerns.
4. As an Interested Party (IP) to the Inquest, Anglian was requested to provide witness statements addressing both the status of the permit application for the relevant works and further details regarding the operation of Anglian’s ‘defect line’. In response, Anglian submitted two statements to the Coroner, in May 2024 and December 2025. Registered Office: Anglian Water Services Ltd. Lancaster House, Lancaster Way, Ermine Business Park, Huntingdon, Cambridgeshire, PE29 6XU. Registered in England No. 02366656. An AWG Company.

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5. To the best of our knowledge, the witness statements submitted by Anglian were not included in the final Inquest bundle, nor were they read into evidence by the Coroner. In view of this, we consider it helpful to reiterate the position set out in those statements, with the aim of addressing any concerns relating to Anglian as highlighted in the PFD Report. ‘Defects Line’
6. Anglian operates a system for the notification and rectification of site defects identified during works, primarily managed through the Street Manager online reporting platform in collaboration with Suffolk County Council (SCC).
7. As digital logging into Street Manager can occasionally result in a “time lag”, there is also a dedicated telephone line available for the immediate reporting of defects. This line is used for multiple purposes, with one of the menu options specifically relating to defect reporting. If a call to this dedicated line is not answered directly, an automated answering system records the message. Two administrators are responsible for checking for new messages every 15 to 20 minutes and ensuring prompt action is taken.
8. At the time of the incident in October 2022, notifications received via the dedicated phone line were managed as follows:
• the administrator would manually compile the details of each notification into an email, which was then circulated to a location-specific distribution list;
• this distribution list comprised Area Managers, Field Performance Managers, and, where applicable, Traffic Management companies; and
• the relevant individuals on the distribution list would then assume responsibility for addressing and rectifying the reported defect.
9. Whilst Anglian operates both a system for the notification of defects and a dedicated phone line to ensure reporting, when SCC identifies a defect during inspection, the risk level of the non- compliance determines the communication protocol: a) For low-risk non-compliances, such as those identified at the relevant site on 24 October 2022, SCC records the defect on Street Manager and issues a notification to Anglian’s Street Works Compliance Team. There is no expectation for SCC to make a direct telephone call to Anglian Water in these circumstances. The Compliance Team monitors these notifications every 15 – 20 minutes both via automated prompts and through manual checks. b) For high-risk non-compliances, SCC notifies Anglian Water through both Street Manager and a direct telephone call to the general number for the Street Works Compliance Team, which is provided in the permit application and is known to SCC.
10. The distinction between ‘low-risk’ and ‘high-risk’ non-compliance can be subjective and may vary between different authorities. For example, ‘low-risk’ non-compliance may include issues such as Registered Office: Anglian Water Services Ltd. Lancaster House, Lancaster Way, Ermine Business Park, Huntingdon, Cambridgeshire, PE29 6XU. Registered in England No. 02366656. An AWG Company.

[Page 3] fallen down signs, or incorrect traffic management arrangements. In contrast, ‘high-risk’ non- compliance may involve more serious matters, such as missing safety zones or exposed excavations in the carriageway. While the classification of these defects may differ between authorities, the critical consideration is the manner and urgency with which they are addressed, according to their categorisation.
11. On 24 October 2022, SCC identified two low risk non-compliance areas relating to signage and traffic management at the site. These were communicated to Anglian via Street Manager only, in accordance with established assignment and reporting procedures.
12. Following additional internal investigation, we were able to confirm in the witness evidence that no phone call was made or expected, as the issues were not classified as high risk. Our Compliance Team received and acted upon the notifications as required, in accordance with Anglian’s established assignment and reporting procedures and SCCs assessment of the risk profile.
13. In light of this, we would like to respectfully confirm that there was no failure in the operation of the defect line on the day in question. The process functioned as intended for the risk level identified, and Anglian responded to the notification in line with established procedures.
14. We trust this clarification addresses the concern raised and confirms that the defect line was not at any stage unresponsive or the cause of any delay. Post-Inquest
15. As outlined above, Anglian is committed to maintaining the highest standards of health and safety across all its operations. As a responsible business, we recognise the importance of regularly reviewing and enhancing our processes and procedures to ensure they remain robust, effective, and in line with industry best practice.
16. Since the Inquest, we have taken the opportunity to reflect on our systems and identify further measures to strengthen our approach, with a view to continually improving the safety and efficiency of our operations.
17. Since early 2023, Anglian has tested and implemented the SKEWB Permit Manager System, which interfaces directly with the Street Manager platform and automatically imports incoming defect data into its database. Within the SKEWB system, Automated Working Groups are mapped to specific business cohorts, enabling the system to relay any identified failures or defects to the appropriate teams. While this represents a significant improvement over previous processes, the effectiveness of the system remains contingent upon the timely upload of defect information by the inspector to the Street Manager system. Consequently, the overall success of the system continues to depend on the SCC inspector’s ability to upload defects promptly to the Street Manager platform.
18. In order to ensure a rapid response to urgent issues and to prevent delays that could compromise safety, Anglian continues to accept direct telephone notifications from the Highway Authority. If a telephone notification is received before the corresponding digital permit update is available in Street Registered Office: Anglian Water Services Ltd. Lancaster House, Lancaster Way, Ermine Business Park, Huntingdon, Cambridgeshire, PE29 6XU. Registered in England No. 02366656. An AWG Company.

[Page 4] Manager, the administrative team manually enters the relevant information into the SKEWB system to initiate the necessary notifications and actions.
19. When the formal Street Manager notification is subsequently received, the system may, on occasion, issue a duplicate notification. While this duplication is unintentional, it is considered to be a safe and precautionary measure designed to ensure that no necessary actions are missed, thereby reducing the risk of further incidents.
20. We remain committed to ongoing learning and improvement, and we are grateful for the opportunity to address the matters raised in your report.
21. If you require any further information or clarification, please do not hesitate to contact me.

Dear HM Senior Coroner Parsley, Inquest touching upon the death of Allan Stevenson We are instructed on behalf of Core Highways (Southeast) Limited, formerly MLP Traffic Limited (‘‘CHSEL’’) and write on its behalf in response to your report dated 6 April 2026. CHSEL extends its condolences to Mr Stevenson’s family and friends. Prevention of Future Deaths (‘‘PFD’’) report We note the matters of concern set out in your PFD report and deal with these in turn below, which we were surprised to see directed at our client. At the conclusion of the Inquest, following submissions from Interested Persons, three recipients of the report were named, which did not include CHSEL. Prior to making a report you were respectfully invited to set out any concerns in respect of CHSEL which you chose not to do. As indicated during submissions at the Inquest, policies, controls, and procedures in place at the time of the Inquest were, and have been for some time, materially different from those in place in 2022. CHSEL Following any serious incident involving CHSEL, the business takes the opportunity to reflect and learn lessons, and where appropriate, implement improvements. Clyde & Co Claims LLP is a limited liability partnership registered in England and Wales under number OC344148 and is authorised and regulated by the Solicitors Regulation Authority. A list of members is available for inspection at its registered office The St Botolph Building, 138 Houndsditch, London EC3A 7AR. Clyde & Co Claims LLP uses the word 'partner' to refer to a member of the LLP, or an employee or consultant with equivalent standing and qualifications.

[Page 2] Since October 2022, the business has undergone a name change from MLP Traffic Management to CHSEL. This occurred in 2024 as part of a wider group restructuring to rebrand smaller regional businesses as Core Highways companies. A central Group Head of Safety, Health, Environment and Quality (SHEQ) was appointed to review and implement standardised policies across the group with a focus on continual improvement in health and safety. The business is also now part of the National Highways Stakeholder Advisory Forum and the Traffic Management Contractors Association, supporting health and safety innovation and sector-wide best practice. CHSEL notes the content of the evidence heard during the Inquest. This included confirmation that the Operative who installed the traffic management (“TM”) plan had implemented arrangements that differed from the agreed plan. The Operative was unable to provide any evidence that such changes had been authorised in accordance with the accepted process and CHSEL also found no evidence of authorisation having been given. Furthermore, the Inquest heard that none of the documentation that would accompany an agreed change had been produced. The TM as implemented was inspected by a Network Inspector. The Inspector did not consider that the TM plan required significant change or that it ought to have been closed (which was an option available to him). The Forensic Collision Investigator concluded that the LGV driver had sufficient opportunity to observe Mr Stevenson prior to the collision. The Investigator’s view was that, once both Mr Stevenson and the LGV were on the roundabout, the primary contributing factor was the inherent blind spots associated with the LGV’s design, rather than the TM layout. Response to concerns raised
1. Complex schemes being ‘flipped’ on site; Previous position: The Inquest heard evidence that trained Planners designed TM plans based upon customer instructions and in accordance with the Red Book. Plans were checked by senior team members before being issued to customers in advance of the requested works for approval. Qualified Operatives then installed the temporary TM works in accordance with the TM plan.

[Page 3] The TM plan in question was sent to the customer 12 days prior to the works commencing and no issues were noted or changes requested. Evidence was also heard that changes to the TM plan required appropriate authorisation from suitably qualified personnel (Planners). Accordingly, any requests by Operatives to amend the plan, whether arising from customer requests or initiated by the Operatives themselves, were required to be referred to Planners. The Planners assessed the request and determined if a job could be continued or needed to be cancelled. Authorised changes would prompt the creation of further documents for ‘job packs’ where required. This included revised risk assessments and a new TM plan which would be issued to the Operative to implement. If the requested changes were not practical, the job would not proceed. Whilst it is disputed whether the Operative who amended the TM plan received the required authorisation, evidence indicated that he was aware of a ‘review system’ or ‘process’ being in place at the time. Updated position: CHSEL now requires written customer confirmation that TM plans meet requirements before work commences which significantly reduces the potential for changes to be required on the day. In the absence of such confirmation, the job will not proceed. Any requested changes prompt the plan to be reviewed and if necessary redrawn. Customer approval of the revised TM plan is required before the job can proceed. This requirement cannot apply to emergency response work where different considerations apply. Material revisions to TM arrangements and schematics are now recorded in a Central Issues Register and monitored internally. Revisions are reviewed by the Group Head of Technical Standards, allowing updates to existing processes where necessary. Further, CHSEL has formalised its established processes around changes to TM on site, clarifying permissible on-site changes and the appropriate level of documented approval required for changes to plans. It also reinforces that, if in any doubt, staff should contact their supervisor. A failure to follow the process as set out in the policy document will result in disciplinary action. This policy has been communicated to operational staff and is available to Operatives via a QR code present within all company vehicles.

[Page 4] Additionally, TM sites are now subject to random audits by supervisors to ensure compliance with plans and safe implementation. Whilst audits are random, they are generally completed based on the risk profile of the set up. A formal target is in place for site audits to ensure compliance with policies.
2. Escalation where an operative identifies a safety concern; Previous position: Processes dealing with requested changes (regardless of who made the request) are set out above. Those responsible for planning and implementing the TM held relevant qualifications to undertake their roles. In relation to the material works, the changes suggested by the ‘‘relatively junior TM operative’’ were considered by the trained and qualified Operative during the Inquest. The Operative did not feel the suggested changes would have been practical. Updated position: As in 2022, suitably qualified and trained personnel plan, design, and implement temporary TM works. As part of the commitment to continual improvement, CHSEL’s WorkSafe (refusal to work) policy has been reviewed and updated. This confirms the circumstances in which work should not be completed if there are safety concerns and details what actions Operatives should take. It makes clear that staff are not expected to work when:
• They are not competent to perform tasks;
• The correct equipment is not available;
• There is no safe system of work;
• The site conditions have changed impacting the planned method of work; or
• The correct PPE is not available. In summary, the policy requires staff to cease work if they feel their safety or that of others may be at risk and to contact a supervisor to allow the work and method to be reassessed. Additionally, CHSEL has introduced nine TM life-saving rules that form part of employees’ inductions and are reinforced through briefings as well as visible posters. The rules include:

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• Ensure we are both qualified and competent to complete tasks;
• Stop work if anything changes and seek guidance; and
• Report all safety concerns to our supervisor/manager. These sit alongside the overarching golden rule of ‘‘Stop, think, check – we never put ourselves in harm’s way … a two second pause could prevent a lifetime of regret.’’
3. Special signage and cyclist-specific considerations; Previous position: All TM plans were designed in accordance with customer requirements and the Red Book. As such special consideration for cyclists within TM plans was already incorporated into CHSEL’s design process in 2022. The Inquest heard evidence that the specific TM plan, as designed in line with the customer’s request, included instructions for cycle lanes to be closed and ‘special’, or bespoke signs to be used on site. These were set out on the plan as equipment required to be taken to site. This requirement was also detailed in the ‘front sheet’ or cover letter, of the ‘job pack’ provided to the Operative. They were not collected. The signs would have been created at the depot where the Operative would collect all other required equipment. This process would have taken a short period of time. However, after the TM had been altered by the Operative on site the special signs would have been redundant. Had the Planner been notified new special signs could have been considered. Updated position: Planners share TM plans to Operatives directly via an application on their digital tablets in advance of the job. On every job, the ‘job pack’ now includes a separate ‘equipment list’ detailing all the required signage needed to implement the approved plan. This lists the equipment required which was available previously on the plan itself. When plans require special signage, the Planners will share this request with the relevant local depot in advance of the job. The local depot considers if the signs are in stock or if they need to be ordered in advance of the works. If they are, they will be ordered.

[Page 6] Further, CHSEL has implemented the Design Guide for ‘Cycle Safety in TTM Design’ which sets out the specific considerations regarding cyclists for Planners when designing TM plans. This guide is easily accessible to all Planners when drafting TM plans.
4. Signage availability, spare equipment loaded onto vehicles; Previous position: The Inquest heard that a Local Authority Network Inspectors’ role is to ensure that TM plans, as physically set out, comply with the Red Book. They do not receive or review the TM plans themselves. If the Network Inspector feels the TM arrangements on the ground do not comply with the Red Book they can raise their concern with the permitholder for the relevant works. CHSEL does not consider it safe or appropriate to require operatives or Network Inspectors to utilise ‘spare signage’ to re-design TM schemes on site. It would be impossible to select the correct signs in advance as any issue with the TM is unclear until operatives are at site. This presents practical difficulties in terms of vehicle weight limits which may necessitate further operatives and vehicles increasing the footprint of the TM set up itself. As noted above, both the Planner and TM Operative hold relevant qualifications. We respectfully submit it would be unsafe for Network Inspectors, who may not hold such qualifications, to request that signs are moved, added or changed, as this would amount to redesigning a TM plan which they may not be trained to do. This would likely necessitate a wholesale retraining of Network Inspectors nationwide. Updated position: As mentioned above, TM plans are approved in advance by customers to ensure they fit the requirements and equipment lists are prepared and shared in advance of jobs. As per the WorkSafe (refusal to work), change management policies and life-saving rules Operatives should not work unless it is safe to do so, as such, it is not anticipated that a situation should arise where the TM plan is amended, changed or redesigned with ‘spare signage’. Further, the powers of Network Inspectors are set by Central Government and outside of CHSEL’s control.
5. Communication with customers, permit holders and, where relevant, network inspectors; Any system around Network Inspectors’ access to information is a matter for Central Government.

[Page 7] CHSEL will continue to share best practice and look to improve health and safety practice across the sector.
6. Operation of Anglian Water’s ‘Defect Line’ CHSEL has no involvement in the operation or use of Anglian Water’s ‘Defect Line’ and is therefore unable to comment on its functionality or use at the material time. However, CHSEL does and will continue to respond to any defects reported to it in a proportionate and timely manner. Conclusion The safety of CHSEL staff and the public remains its highest priority. The business remains committed to ongoing learning and continual improvement to raise health and safety standards across the business and the wider industry. We hope this letter helps to alleviate any concerns and demonstrates that significant changes were already in force prior to the Inquest. Such changes have been embedded through training, accessible documentation and are subject to ongoing audit and review to allow for ongoing improvements where opportunities for these are identified. Thank you for taking the time to consider this response.

Dear Coroner Parsley, Investigation into the death of Allan Stevenson Suffolk County Council (“SCC”) writes in response to your Regulation 28 Report dated 06 April 2026. SCC acknowledges it is a recipient organisation of the Report, however, wishes to clarify its statutory and operational remit in relation to the specific issues raised. Concerns raised:
1. Concern 1: ‘I am concerned that what was agreed by witnesses to be a complex temporary road traffic plan, can be ‘flipped’ on the ground on the day it is installed without any identifiable process being in place to ensure the scheme is subsequently safe. The court heard that some schemes (such as a single carriage way scheme controlled by only two sets of traffic lights) were straight forward to flip if required, but that no additional or enhanced review system was in place when a complex scheme needed to be flipped at short notice’. Concern 1 appears to relate to the installation of temporary traffic management and the processes followed by Core Highways Group Ltd and Anglian Water where arrangements were altered on the day of installation. These matters principally concern the internal operational arrangements of the Statutory Undertaker and its specialist traffic management contractor, rather than matters within SCC’s direct control. SCC is therefore not able to speak for those organisations but sets out below its own role and the relevant statutory framework. For the purposes of this response, the terms “street authority” and “highway authority” are used interchangeably, reflecting the terminology used within the New Roads and Street Works Act 1991 (“NRSWA”) and the Traffic Management Act 2004. As outlined in the Witness Statement of dated 15 January 2026, Suffolk County Council’s role is to:

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1. Coordinate works on the network, primarily through its Permit Scheme; and
2. Undertake compliance checks, where appropriate, against the Safety at Street Works and Road Works Code of Practice (“the Red Book”) through network inspections once works are in place. Statutory framework and undertaker responsibility Under Section 48 of NRSWA, “street works” include not only the placement and maintenance of apparatus but also works required for or incidental to those activities, which includes the provision and management of temporary traffic management necessary to undertake the works safely. The Act identifies the undertaker (in this case, Anglian Water) as the party authorised to carry out those works. Responsibility for the planning, design, implementation, and ongoing operation of temporary traffic management therefore rests with the Statutory Undertaker and any specialist contractor it appoints. This is reinforced by Section 65 NRSWA, which places a duty on undertakers to ensure that works are adequately guarded, lit, and signed, and that appropriate traffic signs are provided for the safe guidance of road users. Temporary traffic management is inherently dynamic. The Red Book permits adjustments to be made on site to reflect prevailing conditions (for example, site constraints, parked vehicles, or other operational factors), with responsibility for ensuring that those arrangements remain safe and compliant resting with the undertaker at all times. Role of the highway authority The role of the highway authority is distinct from that of the undertaker. Suffolk County Council is responsible for coordinating works and managing the network, but it is not responsible for the detailed design or approval of traffic management layouts, nor does it provide a safety “sign-off” of those arrangements. Highway authorities must take care not to become involved in the design or specification of traffic management measures. The design and delivery of compliant traffic management therefore remain the responsibility of the undertaker and its appointed, competent contractors. Permit scheme Suffolk County Council operates a Permit Scheme under the Traffic Management Act 2004 and the Traffic Management Permit Scheme (England) Regulations 2007. The purpose of the Permit Scheme is to enable the highway authority to:
• Coordinate works across the network, and
• Manage the impact of those works, particularly in relation to congestion and disruption. The Scheme does not provide for the approval of detailed traffic management design.

[Page 3] OFFICIAL-SENSITIVE PERSONAL Undertakers are required to submit information about their works, including duration and general method. The authority may apply conditions where appropriate, and undertakers may submit variations where there are material changes affecting duration, traffic management type (for example, signals or road closure), or network impact. However, on-site operational adjustments, including changes to the positioning or orientation of traffic management (such as the “flipping” of a layout), would not necessarily require a formal permit variation where:
• the nature of the works remains the same; and
• the impact on the network and road users, particularly in terms of congestion, is not materially altered. Such operational decisions sit within the undertaker’s responsibility for delivering the works safely. Inspections The Code of Practice for Street Works Inspections provides statutory guidance on how highway authorities may undertake inspections. These inspections are typically risk-based and sample- based, and authorities are not required to inspect every site. undertook a Category A (live site) sample inspection. Network Inspectors are responsible for selecting sites as part of this inspection regime. During an inspection, the Network Inspector assesses the traffic management arrangements as implemented on site at the time of inspection, measuring compliance against the Red Book. Where non-compliance is identified, defects may be raised against the undertaker. Inspections represent a snapshot in time. Site conditions may change after an inspection due to ongoing activity or operational adjustments. Application to this concern The concern raised suggests that the absence of a process to notify the highway authority of changes to a complex scheme (including the “flipping” of the layout) compromised the safety assessment. However:
• Responsibility for ensuring that traffic management remains safe and compliant at all times rests with the Statutory Undertaker.
• The inspection regime is designed to assess what is physically present on site, rather than to verify compliance against an original or proposed plan.
• Whilst advance notification (of a layout change) may assist contextual understanding, the Network Inspector’s task remains to assess the arrangements actually in place set against the requirements of the Red Book. As set out in the evidence of , incorrect signage was observed on site during the inspection and was raised with the undertaker in accordance with established procedures.

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2. Concern 2: ‘I am concerned that there is no apparent safety escalation process, when as in this case a relatively junior Traffic Management Operative identifies a safety issue with a scheme once it has begun operations’. Concern 2 principally relates to the internal escalation arrangements of Anglian Water and Core Highways Group Ltd. SCC has reinforced its procedures for identifying relevant issues to those responsible for the temporary traffic management.
3. Concern 3: ‘I am concerned that the correct ‘special signage’ that would have undoubtedly made this scheme safer, was not even considered in this case (as a direct result of the flipping of the original plan). I am further concerned that Network Inspectors have no power to declare a special sign (or the lack of a special sign) as a defect, as these signs fall outside the mandatory signage shown in the Red Book. As such, even if a Network Inspector identified what they believed to be a dangerous temporary traffic management scheme, any danger being caused by the lack of special signage (or caused by special signage on site that is incorrect), there is no mechanism available for a Network Inspector to issue a defect notice to raise their concern’. This concern appears to arise from the present scope of the statutory inspection framework and the guidance currently available to highway authorities and inspectors. As highlighted in the concern, ‘special signage’ is not considered mandatory signage as per the Red Book and other advisory material and is therefore not something which a Network Inspector could raise a defect for in the same way as mandatory signage. However, SCC recognises the importance of ensuring that wider safety concerns can still be escalated promptly to the undertaker where identified.
4. Concern 4: ‘I am concerned of that the only recourse for a Network Inspector to get temporary traffic management signage replaced, is an apparently protracted procedural route involving multiple individuals remote from the site, with the Network Inspector having limited or no contact with the Traffic Management Operatives at the site itself. I am further concerned that there is no requirement for spare signage to be carried on vehicles used for setting up the schemes, for obvious or frequently occurring errors identified on temporary road traffic schemes (such as in this case the road narrow signs being the wrong way around)’. Concern 4 primarily concerns the operational arrangements and equipment practices of Core Highways Group Ltd and Anglian Water, rather than matters determined by SCC.

[Page 5] OFFICIAL-SENSITIVE PERSONAL Local Authorities are required to report any identified defects to the statutory undertaker as the holder of the street works licence. As covered in the evidence, verbally reported the defect to the traffic management operative on site following completion of his inspection on 24 October 2022. He also reported the defect to Anglian Water via the English national online system (Street Manager) and via telephone, as the Code of Practice of Inspections requests. The Network Inspector can take the steps available to him/ her within the limits of the statutory inspection role.
5. Concern 5: ‘I am concerned that there is no apparent system in place to inform Network Inspectors that a traffic scheme has been laid out, contrary to the original plan that was in place (as in this case when a plan has been flipped). As a result of the Network Inspector having no access to, or sight of the original plan, he was unaware that the original plan had been flipped, unaware of the suspension of the cycle lanes approaching the roundabout and unaware that the special signage deemed necessary in the original plan, was completely absent in the flipped scheme that was put in place. As such the Network Inspector’s ability to check the safety of the flipped scheme was seriously compromised’. As set out under Concern 1 above, highway authorities have powers to investigate and monitor street works activity, including through the use of network inspections where appropriate. These inspections can be undertaken on a random sample basis and are focused on assessing compliance with relevant safety requirements. The role of the Network Inspector is to assess whether the traffic management arrangements as implemented on site at the time of inspection comply with the requirements of the Red Book. Inspections are not intended to verify detailed design intent or confirm whether a scheme has been implemented in accordance with a previously submitted plan. Statutory Undertakers may appoint specialist traffic management contractors to design and implement appropriate measures. Responsibility for ensuring that traffic management is safe, compliant, and responsive to changing circumstances rests with the statutory undertaker and its appointed contractors. Temporary traffic management is inherently dynamic, and the Red Book allows for adjustments to be made on site to reflect conditions such as parked vehicles, site constraints, or nearby activity. The statutory framework draws a clear distinction between the undertaker’s responsibility to design and implement safe traffic management, and the highway authority’s role in coordination and inspection. SCC must therefore avoid stepping into the undertaker’s operational function. The duty to design and deliver compliant traffic management remains with the organisation undertaking the works, supported by appropriately qualified and competent personnel. Non-compliance was identified by during his inspection and raised with both the on- site operative and Anglian Water in accordance with the established inspection and enforcement process. The absence of advance notice of the change did not prevent the identification of this defect or appropriate action being taken.

[Page 6] OFFICIAL-SENSITIVE PERSONAL It should also be noted that, under the present framework, the presence or absence of non- prescribed or advisory signage is not necessarily in itself, a matter that can give rise to a defect under the Red Book where such signage is not a mandatory requirement. In addition, the presence of advisory cycle lanes at this location does not create a statutory restriction, as these are not supported by a Traffic Regulation Order. Their temporary obstruction or absence during works is therefore not subject to a formal suspension process. While permit applications submitted via the DfT’s Street Manager system require undertakers to describe their works and associated traffic management, there is currently no specific mandatory field to explicitly identify impacts on cycle routes (advisory or not), in contrast to provisions such as footway closures. Any such impacts are typically conveyed through supporting information, drawings, or permit conditions. A Network Inspector, in their role, is to assess compliance based on the arrangements in place on site at the time of inspection.
6. Concern 6: ‘I am concerned that the ‘defect line’ operated by Anglian Water was not answered or responded to on the day of this incident, adding unnecessary delay to the changes required to the scheme signage. It is acknowledged that the signage defect identified on the 24 October 2022 would not have affected the tragic outcome of this case, however that may not be the case in future incidents’. Concern 6 relates primarily to the responsiveness of Anglian Water’s own defect reporting arrangements. SCC cannot comment on the internal operation of those systems. Conclusion SCC has carefully considered the Coroner’s concerns. For the reasons set out above, and following specific review, it does not consider that the statutory role of the highway authority should extend to approving or redesigning temporary traffic management laid out by undertakers. Responsibility for the safe design, implementation and operation of such arrangements rests with the undertakers and their appointed contractors. However, SCC has reviewed its own procedures and has taken active steps to reinforce the inspection and escalation processes applicable to Network Inspectors. In particular, SCC has delivered a toolbox talk to Network Inspectors to reaffirm the correct application of established inspection and escalation processes and will continue to do so as appropriate. SCC has also provided, and will continue to provide, refresher learning to both Network Inspectors and Network Coordinators. In addition, SCC has been in contact with the Department for Transport with a view to discussion as to the findings of the inquest and the extent to which any aspect of national guidance or the wider regulatory framework may merit further consideration. Whilst SCC can contribute its views and respond to any such consultation or discussion, responsibility for

[Page 7] OFFICIAL-SENSITIVE PERSONAL changes to national guidance or the regulatory framework rests with the relevant national bodies.