Letter to the Editor: I take exception to the Environmental Agency (EA) response within the Review’s article Backlash to harbour pier plans for week ending August 11 2023 regarding the fencing that has been erected on the North and South sides of Lydney Harbour.
Separating the public from ongoing work as required by the management of Health and Safety at Work Regulations 1999 under the Health and Safety at Work etc Act 1974, is understandable.
But I suggest that the Environmental Agency (EA) Risk Assessment (RA) that identified the piers as a safety risk outside of this work and the EA stance that they cannot guarantee that the piers fencing may become permanent in the long term I believe is flawed.
The EA RA should has identified hazards that could cause harm (fall into the harbour) and the likely risk that someone (including third party – eg the public) could be harmed and therefore, the Place Manager for Gloucestershire statement by Mark Quine that says “….is not about fatalities, it’s about the risk” is misleading.
The EA RA therefore requires to be proportionally managed with suitable mitigation measures in place for when the ongoing work is complete.
This approach uses best practice and is proportional to the hazard – without such an approach we would have barriers on every roadside pavement preventing car/pedestrian impact, there would be no house/flat balconies and so on.
What doesn’t come across in the article is a derived risk that has been created by the siting of the fencing.
It is acknowledged that due care by boat skippers is needed during harbour transit and the likely area that an incident may occur is behind the fencing towards the river.
In the event of such an incident, how is a member of the public now able to deploy a lifebuoy to the crew?
Therefore, I urge the EA to reassess their stance on the permanent use of fencing that will result in an alternative practicable and safe arrangement that minimises the potential for someone falling into the harbour and allows the public safe access around the harbour piers.
Colin Popplewell, Lydney