Low Level Letter Boxes - CWU campaign

[TrueBlueTerrier]

No. 891 /09
Ref C32
Date: 12 October 2009

To: All Branches

Dear Colleagues

Low Level Letter Boxes - CWU campaign to call for the European Standard EN 13724 to be enshrined into UK Building Regulations:

Further to LTB Numbers 880/09, 160/07, 559/06 and 164/05 a letter has been sent to the Rt Hon John Denham MP, Secretary of State for Communities and Local Government, in order to refresh efforts to get the Government to enshrine the European Standard EN13724 into Building Regulations, making it compulsory and outlawing low level letter boxes in any new housing development, refurbishment and replacement front doors.

The CWU has run three major campaigns on the issue (1957/1958, 2001/2002 and 2004/2006) and we continually raise the matter at various appropriate junctures. In 2005 Deputy Prime Minister John Prescott was confident that stakeholders would comply with the standard on a voluntary basis. This clearly has not been the case and the CWU has at local and national level had to tackle developers and local authorities who ignore the standard.

The CWU has had to work and campaign hard to bring the EU standard EN13724 to the attention of stakeholders despite having received good support from various organisations including the NHBC (National House builders Council), Double Glazing Federation, Local Authorities, local politicians, Development Agencies and MPs etc. However, the idea of a 'voluntary' basis only approach to EU standard EN13724 is not working!

A meeting is planned with the HSE as the government confirmed to the CWU in 2005 that the HSE would examine the problem via their planned Inspection programme and would begin an awareness raising process with those who design, build, install and buy doors in bulk to influence change and minimise injury risks to Postal Delivery Staff in respect of new and replacement letter boxes. This aspect clearly needs revisiting. However, HSE resources may be an issue.

The HSE did give the matter some attention in 2005 and assisted us to ensure that Low Level Letter Boxes are fully considered when Royal Mail Managers complete Delivery Round 'Walk Logs' and 'Walk Risk Assessments'.

[TrueBlueTerrier]

LTB 892/09 - Level Letter Boxes - Petition to Prime Minister calling for the European Standard EN 13724 to be enshrined into UK Building Regulations:
To view this download, please click here

No. 892/09
Ref C32
Date: 12 October 2009

All Branches
All Regional H&S Forums
All CWU Safety Representatives

Dear Colleagues

Level Letter Boxes - Petition to Prime Minister calling for the European Standard EN 13724 to be enshrined into UK Building Regulations:

As you will know from previous LTBs and the Union's ongoing campaign, there is no legal requirement in the UK to follow the specifications set out in current European Standard (EN 13724) covering Private Letter Boxes and Letter Plates which for ergonomic and safety reasons specifies the height, positioning and design of "letter boxes" in order that the safe delivery of Mail can be made without the risk of injury. The standard sets down that the centreline of the Letter Box aperture should be at a height between 700 mm (2 ft 3.5 inches) and 1700 mm (5 ft 7 inches). The EU Standard was issued in 2002 but the UK government hasn't enshrined the standard in to UK building regulations, claiming that the standard would be followed on a voluntary basis. The experience of the CWU is that this certainly hasn't been the case and we come across many instances where the EU standard is IGNORED. Postmen and Women need the support of the Government to protect their backs and their Health & Safety.

A CWU member has launched a petition on the Prime Minister's No Ten e-Petition site, using the CWU campaign material. We are therefore urging Branches and Branch Representatives to maximise support and signatures on the Petition which closes on 18 November 2009.
The Petition reads:-

We the undersigned petition the Prime Minister to follow the European Standard (EN 13724) regarding letterbox height.

Deadline to sign up by: 18 November 2009 - Signatures to date: 514

Link to the Petition: http://petitions.number10.gov.uk/Letterbox/" onclick="window.open(this.href);return false;

Yours Sincerely

Dave Joyce
National, Health, Safety & Environment Officer

[TrueBlueTerrier]

The Rt Hon John Denham MP
Secretary of State for Communities and Local Government
Communities and Local Government
Eland House
Bressenden Place
London 
SW1E 5DU
 
 
Dear John,
 
Low Level Letter Boxes - CWU campaign to call for the European Standard EN 13724 to be enshrined into UK Building Regulations:

The CWU Low Level Letter Box campaign received great support from a large number of MPs when I initially launched the last campaign in 2005.
 
David Hamilton MP for Midlothian put down Early Day Motion (EDM) 381 in the House of Commons on 21 June 2005 on Low Level Letter Boxes which attracted around 100 MPs signatures.
 
In light of recent experiences I am writing to refresh efforts to get the Government to enact the European Building Standard EN13724 into Regulations which would outlaw low level letter boxes.
 
In 2005 Deputy Prime Minister John Prescott was confident that stakeholders would comply with the standard on a voluntary basis. John was naive to believe that and the CWU has had to face many battles with developers and local authorities who ignore the standard.

The CWU has run three major campaigns on the issue (1957/1958, 2001/2 and 2004/2006) and we continually raise the matter at various appropriate junctures.

In the Irish Republic, the Government banned low level letterboxes in all new homes, under amended building regulations, introduced by the Irish Environment Minister in 2001. Their action followed years of complaints of back injuries by Irish postal staff. A number of compensation claims were made and an intensified campaign for change was waged by the CWU's sister union the Communication Workers' Union of Ireland. Finally a landmark Irish High Court case resulted in a Dublin postman being awarded a record IR £43,500 damages against the Irish Government (owners of the Irish Post Office) for back injuries.

The Irish letter box regulations were then introduced which outlawed the mouse-trap type letter boxes at the base of doors, favoured by many Irish home owners and builders and perceived by them as being "trendy". The Irish Government finally accepted the warnings that they can be positively dangerous for postal staff, forcing them to stoop to ground level - and risk serious back strain - to make their deliveries. The Irish Regulations took effect from January 2001 but only applied to new houses and it's unlikely that existing home owners will spend hundreds of pounds redesigning their front doors and the new regulations did not legally compel them to do so. However, it was overall a positive move in the right direction. The CWU last made a request to the UK Government in 2001 to follow suit. The CWU have long lobbied for similar measures to be adopted in the UK and again did so following the Irish legislative changes.

The whole issue of back strain caused by having to stoop while carrying a heavy pouch of mail is an extremely important issue. There are thousands of back strains and injuries suffered by Royal Mail Postmen and Women each year and delivering to low level letter boxes at the base of a house front door, forces Postal Staff to stoop to ground level, whilst carrying a satchel of mail weighing up to 16Kg and thereby risks serious back strain. 

Approximately 10% of all major back injuries take place while handling, lifting or carrying. Manual Handling injuries along with Slips, Trips and Falls remain key safety issues for Royal Mail staff and this is one change which could potentially contribute to a reduction in injury risks. The Royal Mail Safe System Of Work advises that the Pouch of Mail should be removed when delivering to low level letter boxes in order to maintain a safe delivery and better lift. However, this in itself may introduce complications and difficulties of additional lowering and re-lifting of pouches. Clearly it would be far better that low level letter boxes did not exist. Information, instruction and training for delivery members is important as is following the walk design risk assessment process and safe system of work, wherever possible minimising the carrying of weight on the shoulder.

The Universal Service Obligation (USO) commits Royal Mail by law to deliver to each of 27,000,000 UK addresses and the Mail will be delivered to a Letter Box or via a Door Letter Plate. There are a few exceptions where modern blocks of flats have numbered Foyer Mail Boxes.

The main problems with letter boxes for Postal Workers are:

1. Finger tips cut or chopped off by sharp, sprung flaps.

2. Dog bites when letters are pushed through the plate and a Dog attacks on the inside.

3. Low Level letter boxes causing back strain injuries as staff stoop to deliver letters with a 16k Pouch of Mail on the shoulder.

In 2002 an updated European Standard was introduced (EN 13724). However, because the EU Standards are not enshrined in UK Law and the standards are not compulsory in the UK, the CWU campaign is to call for the European Standard EN 13724 to be enshrined into UK Building Regulations, following the Irish Republic's example.

Although the Union received good support from various organisations including the NHBC (National House builders Council), Double Glazing Federation, Local Authorities, local politicians, Development Agencies and MPs etc, the idea of a 'voluntary' basis only approach to EU standard EN13724 is not working.

The CWU has had to work and campaign hard to bring the EU standard EN13724 to the attention of stakeholders. The CWU intensified the last campaign locally by approaching Local Government, Authorities, development agencies and builders directly or organisations involved with house building, renovation and granting building permission and door manufacturers and suppliers etc. The response was very positive but we can not reach everyone and not everyone is interested in what they see as voluntary standards which they can freely ignore. 
 
The Union obviously is not demanding that householders and businesses change their doors overnight but we hope that the government would see the merit in minimising the risk or injury to our delivery staff members in respect of all new and replacement Letter Boxes so making a contribution to a reduction in injury risks. The CWU has the support of Royal Mail, the HSE plus the NHBC, GGF and “Secured By Design” organisations.

The positioning of Letter Boxes is not covered by the current UK buildings regulations. The current European Standard EN 13724 entitled "Postal Services - "Apertures of Private Letter Boxes and Letter Plates - Requirements and Test Methods", specifies the height, positioning and design of "letter boxes" or “letter plates” in order that the safe delivery of Mail can be made without the risk of injury. EN 13724  states that for "ergonomic and safety reasons the centreline of the Letter Box aperture should be at a height between 700 mm (2 ft 3.5 inches) and 1700 mm (5 ft 7 inches). However, in the absence of this being enshrined in buildings regulations it is not compulsory or retrospective.

As far back as 1958 the Council of Industrial Design and British Standards Institute issued a British Standard specifying letter box/letter plate aperture size, maximum flap spring tension and a recommended height position for the letter plate in the door of between 2 ft 6 inches and 4 ft 9 inches from the ground with an ideal height being 3 ft 6 inches (waist high). The standard was introduced after the Union took the matter up with the Postmaster General who subsequently raised the matter with the Council of Industrial Design and British Standards Institute.
 
The absence of it being a legal requirement to meet the EU standard means that UK Postal Workers are more at risk of back injury and ill health than their counterparts in Ireland for example where there is such a legal requirement and where ground level letter boxes have been banned in new properties since January 2001.
 
Whilst government ministers have in the past fully supporting adherence to EN13724, sadly the absence of its inclusion in building regulations makes it a waste of time and dialogue with the industry has not been universally successful. 
 
Alan Johnson Secretary of State for Work and Pensions (our former CWU General Secretary and former Postman) was supportive in the past, sharing the view of the HSE that this was one of a combination of factors that increased the risk of back injury. He stated that HSE would examine the problem via their planned Inspection programme and would begin an awareness raising process with those who design, build, install and buy doors in bulk to influence change and minimise injury risks to Postal Delivery Staff in respect of new and replacement letter boxes. The HSE did give the matter some attention and assisted us to ensure that Low Level Letter Boxes are fully considered when Managers complete Delivery Round 'Walk Logs' and 'Walk Risk Assessments'. However, sadly the HSE is short of resources and any awareness raising process has to date been 'limited' and not a priority. 
 
Postal Workers suffer Back Injuries, trapped fingers and dog bites. In light of recent experiences I am writing to refresh efforts to get the Government to enact the European Building Standard EN13724 into Regulations which would outlaw low level letter boxes and seek your support.
 
  
Yours Sincerely
 

 
Dave Joyce
National Health, Safety & Environment Officer

[piranha]

Every front door that has been replaced on my walk in recent years has now got a low letterbox. It's funny how we ignore some EU regulations and bend over backwards to accomodate others.

[Exrep]

Havnt these LLLBs been outlawed in N/Ireland for at least two years .

Every new build now installs LLLBS in the uk its a joke , but these days i think its an anti key theft deterent as one of the new crazes is with burgulars stickinh there hands through middle place L/BS to steal your cars keys.

Its about time The uk followed suit and these be banned and included in new building regs.

E-Petition signed......

[brothermagrew]

Finally a landmark Irish High Court case resulted in a Dublin postman being awarded a record IR £43,500 damages against the Irish Government (owners of the Irish Post Office) for back injuries.

Case in question http://www.bailii.org/ie/cases/IEHC/1998/110.html" onclick="window.open(this.href);return false;