Extreme Heat in Bus Cabs: If No One Owns the Risk, Who Is Protecting Drivers and Passengers?

Only a short time ago, I published my concerns following the Health and Safety Executive’s response to my MP, Michael Payne, regarding extreme heat in bus cabs.

That response has stayed with me.

The HSE confirmed that heat is a workplace hazard and that employers have a legal duty to assess risk. But it also confirmed something deeply concerning: the Workplace (Health, Safety and Welfare) Regulations 1992 do not apply to vehicles, and HSE currently has no plans to revise its guidance specifically for transport workers operating in vehicle cabs.

That means bus drivers are working in a serious regulatory grey area.

We are responsible for public safety. We carry passengers, schoolchildren, elderly people, disabled passengers and vulnerable road users every day. We drive large vehicles through busy towns and cities. Yet when those cabs reach extreme temperatures, there appears to be no specific national standard, no clear temperature limit, and no dedicated regulatory ownership.

That cannot be right.

This Is Not Just About Being Hot

Some people may hear this issue and think it is simply about comfort.

It is not.

Extreme heat affects the human body. It affects concentration. It affects judgement. It increases fatigue. It can cause dizziness, dehydration, headaches, nausea and heat exhaustion.

Now place that worker behind the wheel of a public service vehicle.

That driver is not sitting in an office where they can step away, open a window properly, move to a cooler room or take an unscheduled break. A bus driver may be trapped for hours behind a large glass windscreen, in traffic, in direct sunlight, in a vehicle where the air-conditioning has failed or the blowers are pushing warm air around the cab.

That is not simply unpleasant.

It is a safety risk.

The Incident That Brought This Home Again

Recently, I was made aware of a driver being questioned after taking a bus out of service because of failed cab cooling during hot weather.

That vehicle had reportedly been checked in a garage environment and considered fine. But a bus sitting under cover in a depot is not the same as a bus running for hours in full sun with passengers onboard, heat building inside the cab and the driver expected to remain alert and safe.

This is exactly the kind of disconnect drivers face.

On paper, the system says there is a process.

In practice, the driver is the one sitting in the heat, feeling unwell, trying to make a judgement about whether it remains safe to continue driving.

And if that driver stops, they risk being challenged.

That culture is dangerous.

Section 44 Exists for a Reason

Under Section 44 of the Employment Rights Act 1996, workers have the right to remove themselves from situations where they reasonably believe there is serious and imminent danger.

Extreme heat can absolutely fall into that category.

But rights on paper are only meaningful if workers feel able to use them.

If a driver believes they may lose pay, face questioning, be treated as awkward, or be accused of refusing work, then many will carry on even when they know they are becoming unsafe.

That is not a safe system.

No driver should be forced to choose between protecting public safety and protecting their wages.

I Have Now Sent Freedom of Information Requests

Following the HSE response, I have now submitted a coordinated series of Freedom of Information requests through WhatDoTheyKnow.

These requests have been sent to:

• Health and Safety Executive
• Department for Transport
• Driver and Vehicle Standards Agency
• UK Health Security Agency
• Office of the Traffic Commissioner
• Met Office
• ACAS
• Department for Work and Pensions / HSE joint policy work

The aim is simple.

I want to know who, if anyone, has considered the risk.

I have asked for internal discussions, correspondence, modelling, policy work, enforcement guidance, risk assessments and climate adaptation planning relating to:

• extreme heat affecting bus drivers;
• failed cab air-conditioning;
• vehicle cab temperatures;
• heat stress and driver impairment;
• Section 44 rights;
• public safety risks;
• and whether any regulator considers excessive cab heat to be a transport safety issue.

Why These FOIs Matter

This is not about paperwork for the sake of paperwork.

The responses may reveal one of two things.

Either public bodies have discussed this issue and failed to act.

Or they have not seriously discussed it at all.

Both outcomes matter.

If regulators, government departments and public health bodies have considered heat risks to transport workers but have not produced meaningful guidance, then that raises serious questions.

If they have not considered it, despite increasingly frequent heatwaves and known effects of heat stress on human performance, that raises even bigger questions.

Either way, bus drivers and passengers deserve answers.

Climate Change Makes This Urgent

This issue is not going away.

Summers are getting hotter. Heatwaves are becoming more frequent. Extreme weather is arriving earlier in the year. Yet much of the UK bus fleet was not designed for repeated periods of intense heat.

Older vehicles are still in daily service. Air-conditioning systems fail. Repairs often do not last. A vehicle may be signed off as acceptable in a depot but become unbearable once it is out on the road for several hours.

The industry cannot keep treating this as a seasonal inconvenience.

It is now a predictable and recurring risk.

If a risk is predictable, it should be planned for.

The Public Has a Stake in This Too

Passengers need to understand that when a driver raises concerns about heat, they are not being difficult.

They are protecting everyone.

A driver who is dizzy, dehydrated, exhausted or suffering heat stress is not in the safest possible condition to be driving a bus.

Public transport safety depends on the condition of the person behind the wheel.

If we care about passenger safety, we must care about driver safety.

What Needs to Change

At the very least, we need:

• national guidance on safe cab temperatures for transport workers;
• clear employer duties during heatwaves;
• properly functioning cab cooling systems;
• proper access to water, toilets and welfare facilities;
• recognition that heat stress can impair driving;
• clear guidance on Section 44 rights during extreme heat;
• and a regulator willing to take ownership of the issue.

At present, responsibility appears fragmented.

HSE says vehicles are outside workplace temperature regulations.

Transport bodies focus on vehicle operation and roadworthiness.

Public health bodies issue heat warnings for the public.

Employers are left to manage risk locally.

Drivers are left sitting in the cab.

That is the gap.

Waiting for a Serious Incident Is Not a Safety Strategy

The bus industry has a habit of addressing safety concerns after something has gone badly wrong.

That cannot be allowed to happen here.

We should not need a driver to collapse at the wheel before regulators decide cab heat matters.

We should not need passengers injured before anyone agrees that heat stress affects public safety.

We should not need repeated summer incidents before government departments accept this issue requires national guidance.

The warning signs are already here.

Drivers are already speaking up.

The question is whether anyone in authority is listening.

I Will Publish the Responses

As the FOI responses come back, I intend to review and publish the key findings.

If it turns out that no one has responsibility for this issue, then that needs to be exposed.

If it turns out concerns have been raised internally but not acted upon, that also needs to be exposed.

Bus drivers deserve safe working conditions.

Passengers deserve safe journeys.

And the public deserves to know whether the regulatory system is keeping pace with the reality of climate change.

No one should have to risk heatstroke to keep a timetable running.

Lee Odams
Bus Driver – 19 Years Service
Nottinghamshire

Blog: https://leeodams.blogspot.com

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