LTB 058/23 – CWU Low Level Letterbox Campaign: (CWU Response to the Government Public Consultation on ‘The Levelling-up and Regeneration Bill – Reforms to National Planning Policy’ – ‘Letterbox Heights’)
No. 058/2023
9 March 2023
Our Ref: C32/23
To: All Branches
Dear Colleagues,
CWU Low Level Letterbox Campaign: (CWU Response to the Government Public Consultation on ‘The Levelling-up and Regeneration Bill – Reforms to National Planning Policy’ – ‘Letterbox Heights’):
The Department for Levelling Up, Housing and Communities has conducted a public consultation seeking views on proposals to develop new and revise current national house building planning policy. This consultation seeks views on the government’s proposed approach to updating to the National Planning Policy Framework.
The government’s stated position is a commitment to ‘levelling up’ across the country, building more homes to increase home ownership, empowering communities to make better places, restoring local pride and regenerating towns and cities.
Also the ‘Levelling-up and Regeneration Bill’ is currently before the Houses of Parliament and is intended to put the foundations in place for delivering the government’s plan which includes an infrastructure which mandates new developments to meets clear design standards amongst other things.
Local Planning Authorities will have a statutory duty to follow the National Planning Policy Framework which guides local decision makers on the government’s national policy within the new planning system as soon as possible.
The intention is to allow government to swiftly deliver the government’s commitments to building 300,000 homes a year by the mid-2020s with enough of the right homes in the right places, incentivising local authorities to adopt plans in order to realise the housing supply benefits as soon as possible.
As the Public Consultation is dealing with a review and revision of the planning and building regulations, a response to the Consultation has been made by the CWU Health, Safety and Environment Department concentrating on our long established policy of enshrining a ‘minimum’ height for letterboxes and ‘banning all low level letter boxes’.
Secondly, we have been in dialogue with Baroness Angela Smith of Basildon, Leader of the opposition for Labour in the House of Lords and Baroness Susan Hayman of Ullock, who has tabled an amendment, number 476 to the Bill which would include a minimum letterbox height in law. The government are being pressed to accept the amendment prior to the debate in the House of Lords.
We have also been in contact with Vicky Ford MP (Con. Chelmsford) to flag up amendment number 476 in the House of Lords, requesting that Vicky Ford asks for government support for the opposition amendment and for the government to accept amendment 476.
Below is a copy of the CWU response to the above Consultation, centring on an amendment to the Bill, legislating to introduce a new legal minimum letterbox height.
The response also makes reference to the House of Lords, Amendment number 476 to the Bill which would insert a new Clause in respect of a legal “minimum letterbox height” of 70cm from the ground. The CWU is urging the government to support it.
Finally, we have additionally approached the devolved administrations of Scotland, Wales and Northern Ireland on the matter of legislating on the introduction of a minimum letterbox height, in line with CWU policy.
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Communication Workers Union
Dave Joyce National Health & Safety Officer
150 The Broadway, Wimbledon, London SW19 1RX
Tel: 020 8971 7365/7308 E-Mail: djoyce@cwu.org
28 February 2023
H.M. Government
Planning Policy Consultation Team
Planning Directorate
Planning Policy Division Department for Levelling Up
Housing and Communities Floor 3
Fry Building
2 Marsham Street
London SW1P 4DF
Dear Sir/Madam,
Re: Department For Levelling Up, Housing & Communities – Open Public Consultation on The Levelling-up and Regeneration Bill: Reforms to National Planning Policy: – CWU Response – “Letterbox Heights” (CWU Low Level Letterbox Campaign)
This is the response of the Communication Workers Union to the Department for Levelling Up, Housing and Communities (DLUHC) consultation on the ‘Levelling-Up and Regeneration Bill.’
Royal Mail provides the UK’s Universal Postal Service, delivering 8 Billion Letters at ‘one price all destinations’ and 1.5 Billion Parcels a year to the UK’s 31,000,000 addresses, plus all election letters and during the pandemic Royal Mail workers additionally collected and delivered up to 1,000,000 Covid-19 Test Kits a day at peak and handled up to a 40%
increase in Parcels at peak – across the country during ‘lockdown’. Delivering economic and social benefits to the communities, companies, businesses and organisations served as a key objective for the Royal Mail Group which is also one of the UK’s largest contributors to the UK economy.
The Communications Workers Union has been campaigning to outlaw low level letterboxes for many years due to the occupational health and safety risk posed to Postmen and Women by letterboxes positioned at the foot of dwelling front doors. (see attached CWU campaign flyer/leaflet).
The CWU has been striving for the European Standard (EN13724) to be added to U.K building regulations – this requires letterboxes being at a height safely accessible to postal workers, significantly reducing possible injuries such as, dog bites, fingers being trapped or back strain caused when bending excessively and repeatedly to reach ground level letter boxes. (See attached copy of European Regulation: EN 13724 for Post Boxes).
This issue was first raised by the Union as far back as 1958 when the British Standards Agency deemed it appropriate that letter boxes be at a proper height. Unfortunately it was not enshrined into UK building standards Law.
In 2002 the European Standard EN 13724 was introduced and this states that for “ergonomic and safety reasons” the centreline of the letter box aperture should be at a height between 700 mm/70 cm (2 ft. 3.5 inches) 1700mm/170 cm (5ft 7inches). Unfortunately, once again, it was not enshrined into UK building standards Law.
In January 2019, Vicky Ford Conservative MP for Chelmsford, Essex introduced a Private Members’ Bill in the UK Parliament, in support of the CWU campaign, namely the ‘Low-Level Letter Boxes (Prohibition) Bill. This was unusually 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.
The Housing minister at the time Kit Malthouse MP gave Vicky Ford MP an assurance that the change would be made to introduce a letterbox minimum height and her bill was withdrawn. (See attached BBC News Report).
Additionally, the government’s Building Regulations Advisory Committee (BRAC), the statutory body that provides expert advice to the Secretary of State on building regulations, standards for design, construction, including health, safety, welfare and convenience of people etc. indicated their support and announced that it will be reviewing low level letter boxes on new build properties. (See attached BBC News Report).
Sadly, four years have passed since MP Vicky Ford’s Bill was passed in the House of Commons with no material progress despite continual lobbying of Ministers and continual promises from ministers.
With around 200,000 houses a year being built, and no regulation on letter box height in place, the problem of low level letterboxes continued to be exacerbated. Indeed the CWU, has to continually make representations, piecemeal, to a huge number of developers, house builders and local authorities across the UK, asking them to cease the installation of low level letter box design front doors to new homes. Some are understanding and supportive and some just ignore our plea.
So – over half a century later and several high profile campaigns later the problem still exists.
The CWU has campaigned relentlessly for the UK Government to implement the specifications set out in current European Standard (EN 13724) covering private letter boxes, outlawing low level letter boxes by enshrining the EU standard into UK Law.
The Union would stress that it does not expect householders or businesses to change any existing front doors – rather we have asked that government will see merit in minimalizing the risk of injury to CWU members by passing legislation to cover the manufacture of all new and replacement doors – fitted to new houses and developments as well as replacement and refurbishments etc.
Low level letter boxes have been outlawed in many European countries. For example the Republic of Ireland banned all low level letterboxes as far back as 2001.
CWU members in Royal Mail deliver to each of the 31,000,000 UK addresses daily, and the CWU feel the time has come to standardise letter box height and safe design well above ground level.
The problems with low level letterboxes is that back injuries to postmen and women occur each year in Royal Mail 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 mail items and this can cause back strain. Low Level Letter boxes also present an increased risk of dog bites when the mail is pushed through the aperture at ground level.
Royal Mail postal workers had 18,000 back-related injuries and absence spells in 2021/2022, sustaining back problems connected wholly or in part because of the act of bending and stooping to deliver mail into low level letterboxes. Fingers are also more easily trapped and injured in low level letterboxes, as well as significantly increasing the risk of being bitten by dogs. 2,000 – 3,000 dog attacks on postmen and women occur across the UK annually and 1000 postman and women have had a finger injured or bitten off in the last 5 years through the letterbox.
The Union has the full support of Royal Mail Group as well as many influential bodies and organisations during its campaign including the HSE, National House-Building Council, the Glass and Glazing Federation (GGF), Local Authorities Coordinators of Regulatory Services.
The ‘Levelling-up and Regeneration Bill: Reforms to National Planning Policy’ offers an opportunity to finally deal with this long outstanding matter and the CWU suggests that the Part 12: Miscellaneous section of the bill should include a new clause, after Clause 214, that The National Planning Policy Framework stipulates that in regards to Letterbox heights, the centreline of the letter box aperture should be at a height between 700 mm/70 cm (2 ft. 3.5 inches) 1700mm/170 cm (5ft 7inches), in line with European Standard (EN 13724).
This would benefit the health and wellbeing of CWU Members including over 90,000 Royal Mail Postmen and Postwomen across the UK as well as to a lesser extent politicians and electoral candidates delivering leaflets and any other organisation including charities, schools, clubs, companies and organisations leafleting.
The CWU notes that in the House of Lords, Amendment 476 to the Bill would insert a new Clause in respect of “minimum letterbox height” of 70cm from the ground. The CWU would urge the government to support it.
Yours sincerely
From Dave Joyce CWU National Health, Safety & Environment Officer
Member TUC Union Health and Safety Specialists Committee
Email djoyce@cwu.org | Direct line 020 8971 7365
Communication Workers Union, The communications union
Headquarters 150 The Broadway | Wimbledon | SW19 1RX
T 020 8971 7200 | F 02089717300 | www.cwu.org | @CWUNews
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Levelling-up and Regeneration Bill: Reforms to National Planning Policy
Amendment 476 [HL]
After Clause 214, insert the following new Clause—
“Letterbox height: England
In this section “local authority” means—
- a district council in England;
- a county council in England for an area for which there is no district council;
- a London borough council;
the Common Council of the City of London.
A local authority within subsection (1)(a) or (b) may, by order, direct that
dwellings may not include a letterbox which is less than 70cm from the ground.”
Member’s explanatory statement
This would allow local authorities in England to direct that dwellings may not
include a letterbox which is less than 70cm from the ground.
Yours sincerely
Dave Joyce
National Health, Safety & Environment Officer