26 October 2022
Our Ref: C32/22
To: All Branches
CWU Low Level Letter Box Campaign:
This is an update for Postal Branches on the continuing work and campaigning being undertaken by the Health, Safety & Environment Department on this important subject, further to LTBs 040/22, 98/19 and 142/2019.
The Communication Workers Union, on behalf of postmen and women, has campaigned for the introduction of new legislation to stop low-level letter boxes being installed in new-build houses for many years.
In addition to our campaigning in the House of Commons to get the UK Government to amend Building Regulations and Standards, we have now made representations to the devolved administrations, taking the matter up with the Scottish Government, the Welsh Assembly and Northern Ireland Assembly.
In January 2019, following meetings and briefings in Westminster, Chelmsford MP Vicky Ford introduced a Private Members’ Bill in the UK Parliament, in support of the CWU campaign.
The Bill, namely the ‘Low-Level Letter Boxes (Prohibition) Bill was heard before a full House of Commons on Wednesday 16 January 2019. The Bill was supported by all political parties and was unanimously accepted by the Government and MPs. Mrs. Ford subsequently withdrew the Bill, on the basis of an undertaking given by Government that they accepted the Bill’s intention and that it would be referred to the Building Regulations Advisory Committee who would include low-level letter boxes within a formal review of Building Regulations.
Since then however, progress has been painstakingly slow and of course the interruptions of ‘Brexit’ and the ‘Covid-19 Pandemic’ have indeed slowed that progress further. The Health, Safety and Environment Department has however continued to press for action from government ministers and current minister Paul Scully MP, Minister of State at the Department for Levelling Up, Housing and Communities and Minister for London who recently responded in a letter dated 14 October 2022 as follows:
14 October 2022
Please accept my apologies for the delay in this response.
There is clear continued interest in guidance and regulation for low level letterboxes, given it creates a risk of injury to many where letter boxes are too low.
Since last writing on 14 September 2021, we have made progress in our research work. We have conducted survey work and laboratory testing looking at reach ranges for everyday activities, including the specific activity of posting and picking up letters at different level options. This research will soon complete. This relates to postal workers but also residents of all abilities collecting their mail. Research is needed to develop robust data and evidence will enable this department to support future policy decisions for possible improvements, simplification, and changes to statutory guidance and so that people can have confidence in regulatory standards. This research is an integral step towards updating the clarity of statutory guidance supporting the Building Regulations.
You will appreciate how statutory guidance supports the Building Regulations and references the Door and Hardware Federation’s technical specification TS 008:2012. This in turn refers to the British and European standard relating to letter boxes: BS EN 134724: 2013 Postal services. Apertures of private letter boxes and letter plates. These independent standards are presently referred to by Approved Document Q: Security – Dwellings. Guidance for letter plates is to be positioned in a range of 700mm up to 1700mm and the TS008:2012 drawings for a door recommend a letter box height of 1100mm. Our commitment is in taking the steps to evidence and make statutory guidance for doors clearer.
You will be pleased to know that our ergonomic study of using low level letter boxes will soon complete. The research work will inform our review of statutory guidance supporting Part M and help in turn to inform guidance for any future review of Approved Document Q. Doors with letter boxes feature in both these guidance documents and we continue working to make guidance clearer based on data and research.
I trust this information is helpful and I thank you for writing on this important matter.
Paul Scully MP, Minister of State at the Department for Levelling Up, Housing and Communities and Minister for London
Nearly four years have gone by since MP Vicky Ford’s Bill was passed in the House of Commons. The Minister’s assurance that the Government’s sponsored research work and ergonomic study of low level letter boxes will soon be completed and that this will inform the Government’s review of statutory guidance to the Building Regulations is welcome.
Around 750,000 homes have been built across the UK in the last 4 years and with no ‘mandatory’ regulation controlling letter box height in place, many have been built with low level letter boxes which cause so many problems for Royal Mail delivery workers.
The CWU Health, Safety and Environment Department has had to challenge and fight each of these developments, brought to our attention on a piecemeal basis, with representations to the local authorities, lobbying counsellors and local MPs, challenging developers and builders etc., hoping they’ll accept our case and change their plans. We have won a number of these battles to our great credit but it’s hard going at times and hard to keep pace with these home building developments which are sprouting up everywhere across the UK.
We’ve made it clear to the Minister again, that in the view of the CWU, the case is well made for regulating letter box heights and for the banning of low level letter boxes. Past research resulted in European Standard (EN13724) which sets a minimum height of 70cm for letter boxes (2 feet 3½ inches). There’s really no case for or good reason for further delays. The current European Standard covering private letter boxes sets out and specifies for ergonomic and safety reasons the height, positioning and design of letter boxes in order that the safe delivery of mail can be made by postal workers and others without the risk of injury.
EN 13724 ‘Postal Services – Apertures Of Private Letter Boxes And Letter Plates’ specifies the requirements and the test methods of the apertures for the delivery of letter post items when fitted in accordance with the manufacturer’s instructions. It takes into account security, impregnability, safety, ergonomics and performance for the recipient, and safety, ergonomics and efficiency for postal delivery personnel. It allows the daily delivery in good condition of a great majority of post items.
The Union has been assured that; “Postal workers’ safety in the review of building regulations is included as part of Government’s commitment in bringing about the biggest improvement in building and fire safety for a generation.” The assurance is of course welcomed – but the big question remains – when will we see the needed legislative changes?
At least we are making progress, all be it slowly. We will continue our campaigning and keep the pressure on Government at every opportunity. Branches will continue to be updated.
Dave Joyce National Health, Safety & Environment Officer