Employment agencies throughout the UK supply drivers for haulage companies. This workforce is a valuable resource: a phone call away and very low maintenance. They will turn up at short notice with no idea of what the next job entails.

These drivers fit their agency work round other interests and it follows that they work when they can, so may be tempted to drive when an employed driver - through injury, sickness or fatigue - would not.

This is a serious health and safety concern, as is stress and lack of training, which are endemic in the agency driver workforce. It should be a worry for the agencies themselves, but it should also be a concern for any business that is interested in the safety standards of its supply chain and of those taking to the road in its name.

Hour after hour

Drivers can work three 15-hour shifts with a nine-hour break after each and, after the break following the third shift, start a 13-hour shift. (Under EU rules, the minimum daily rest is 11 hours but on three days of the week this can be reduced to nine hours. Since April 2007 there has been no obligation under the rules to compensate for the "lost" rest hours.)

So, over a period of 85 hours or more, drivers may have had little sleep. During each of the three nine-hour breaks they will drive home, attend to the usual matters such as washing, eating and resting, then drive to the next job. In this period and under current regulations, they could have driven their trucks for up to 38 hours and engaged in "other work", such as loading and unloading, for 15 hours and 30 minutes.

What's more, they could have driven through the most dangerous period of the early morning, a three or four-hour period when the driver is least alert, prone to nodding off or hallucinating, and has a dangerously slow reaction time.

The only caveat is that if a driver is tired then they should not work until rested. There's no objective measure of tiredness and it's open to the driver's interpretation. What's more, an agency driver is in no position to turn down work if they feel tired, because they could lose pay and further work if they are seen as awkward or inflexible.

This applies equally to sick or injured drivers. Those who should really be signed off will work because they can't afford to miss the job and don't appreciate their agency's obligations in this area. Sickness, injury or fatigue, the consequences are the same: unacceptably low levels of driving skill.

Many directly employed drivers insist on having an 11-hour break with a maximum working day of 13 hours, an option rarely open to agency drivers. Even covering two of those four possible work periods can leave many drivers, directly employed or agency contracted, too tired to operate safely. Many admit to "micro-sleeps" while on the move.

Going unequipped

With many different tractor units and trailers each with its own on-board systems, gears and switches regulated by up to 50 fuses of different ratings, agency drivers may have to ignore any failure en route simply because they won't have received the training they need to rectify the fault. The Vehicle and Operator Services Agency (VOSA) or traffic officers would stop a truck with unserviceable lights, but many travel on unchecked.

What's worse, many unserviceable vehicles roll out of depots at the start of their journeys because the drivers are under pressure to get on their way. Trailers may be pre-loaded, and our agency driver, assured that all is in order, doesn't have the knowledge to check. On tanker work, for example, will the driver be briefed on the venting sequences, procedures for accessing valves or securing hatches, tank cleaning procedures, and proper eye and hand protection? The answer's often a resounding "no" because it's convenient for each party, agency and client to assume the other will deal with it.

Agency drivers also face extra stressors. Drivers will suffer stress when they have only a vague notion of where they are going with a fully loaded LGV. There are myriad opportunities for getting into serious trouble: low bridges, narrow roads, sharp bends on country roads, weight restrictions, traffic diversions, and often having to turn the vehicle round in very restricted places when they have taken a wrong turn.

In this respect, agency drivers are seriously disadvantaged, as they won't have gone through the sort of route or job-familiarisation exercises provided for new, directly employed drivers. Added to that, they will have target times for deliveries and will often be given a job change while en route or be chased by the transport office for a progress report, and they will have to take compulsory breaks even though they are running late. A stressed driver will be inclined to take risks, to engage in manoeuvres they wouldn't otherwise even contemplate.

Ask for more

There are too many incidents involving LGVs and they are often dramatic in scale, effect and consequence. Digital tachographs retain driver activity data for 28 days, and the police can download information, including speeding offences, and prosecute.

When a case gets to court, learned counsel for the prosecution will delve into all aspects of a driver's record, including driving hours, training and the haulier's operating criteria. Any deviation from the strict rules laid down by Brussels and by UK law is grist to the mill for those interested in a conviction.

One fertile area of enquiry will be what the driver did during their nine-hour breaks, and in the harsh light of a courtroom, there is no escaping into generalities.

Ultimately it's down to the drivers to take a sensible approach to their work, but anyone contracting them via an agency can take the steps listed in the box above to help ensure the drivers working in their name are safe on the roads.

Where they receive proper support and aren't penalised when they rightly address health and safety concerns, agency drivers can do their jobs more efficiently and, more importantly, safely.