| Name/Organisation | ROAD DANGER REDUCTION FORUM |
| Email address | rdavis4499@aol.com |
|
Rule
/ page no |
Suggested change | Reason |
| 4 Introduction | Insert "drivers' and motorcyclists'" before "liability". | To prevent insurance companies attempting to reduce drivers' liability in collisions with vulnerable road users by blaming the victims. |
| 4 Introduction | Add a cycling organisation and other road user groups as co-authors of the code. | The driving standards agency is not obviously expert on safe cycling techniques, and may not be fully appraised of the needs of other road user groups such as horse riders |
| 2 / 5 | Delete "keep close to the side of the road". | Pedestrians are least visible close to the edge of the road, and most at risk if not seen. |
| 3 / 5 | Replace "use" with "consider using". | Drivers have a responsibility to avoid hitting unlit obstructions in the road. Fallen trees and loose animals are unlit and have to be avoided. Pedestrians may choose to increase their visibility, but can not be reasonably expected to always be wearing hi-viz, fluorescent or iridescent clothing. |
| 11 / 7 | Replace second sentence with 'Buses and/or cycles may be allowed to go both ways in otherwise one-way streets.'" | Cycle contraflows are allowed without marked lanes. Buses can be exempted from no entry signs. |
| 25 / 11 | Put Puffins in a rule on their own. | Most new signalled crossings are Puffins. |
| Describe pedestrian+cycle (toucan) and pedestrian+horse-riders (pegasus) crossings in a consistent way. | So that pedestrians and cyclists can identify them and use them correctly. | |
| 30 / 12 | Replace the comma with a semicolon or full stop. | Grammar. |
| 47 / 15 | As 3 / 5 | Drivers must be able to avoid unlit horses. Horse riders may choose to increase their visibility, but should not be expected to. |
| 50 / 16 | Delete new clause. | The clause reflects the idea that drivers may be going too fast to stop in the distance they can see to be clear, and that it is the rider's duty to keep out of the way. This suggests that it is acceptable to drive this way when it is not. Failing to drive in such a manner that you cannot stop within visible distance is a central problem of road safety |
| Preamble / 17 | Speed limits, drink-driving laws, and others do not apply to cyclists. Also many of the later rules are written for motor vehicles and make no sense when applied to cycles. I suggest use of an asterisk in the rules for all road users to indicate the ones that do not apply to cyclists. It is important to stress that while cyclists have responsibilities, failing to fulfil them does not have the potentially lethal consequences for the well being of others that failing to fulfil motorist's responsibilities does. | |
| 56 / 17 | Change the helmet clause to "Consider wearing a cycle helmet. Remember that cycle helmets are not designed to give protection in collisions with motor vehicles, and can be dangerous if too loose." Also move it further down the cycling section. | It is misleading to make the first cycling recommendation something that has never been shown to reduce real-life cycle casualties. It must be made clear to insurers that they cannot claim contributory negligence on the grounds of not wearing a cycle helmet. We are concerned that emphasis on what is at best a marginal aid to safety is given excessive importance. |
| 56 / 17 | Change the recommendations for light-coloured, reflective, and fluorescent clothing to "Consider wearing" | Drivers need to be able to avoid unlit, matt obstructions and t see pedestrians wearing normal clothing. Cyclists may choose to increase their visibility, but should not be expected to. There is little evidence to suggest that high visibility clothing aids the safety of cyclists. More important, this is another example of removing responsibility from motorists to watch out for other road users, resulting in careless driving in general and excessive speed in particular. |
| 56 / 17 (picture) | Both or neither of the cyclists should be helmeted. | There is no evidence that helmets do not aid visibility, as the caption suggests. Most cyclists are unlikely to be wearing helmets at present. There is also no or little evidence that they reduce cyclists' injury (including head injury) rates. |
| 58 / 18 | Rewrite as: "You may use cycle facilities such as cycle tracks, cycle lanes, Advanced Stop Lines, and Toucan crossings if you feel they will help your journey. You are not obliged to use them." | Cycle facilities frequently do not reduce danger for cyclists or make cycling more easy. |
| 60 / 18 | Replace last sentence with: Warn following traffic when leaving the lane. Ride slowly and carefully when using a cycle lane to overtake other traffic. | The "possible" wording would imply staying in a lane on the left even when about to turn right, and dodging in and out between cars parked in the cycle lane. Read 'Cyclecraft' by John Franklin for best advice for cyclists. |
| 63 / 19 | Delete the new clause about single file etc. | This is bad advice and will increase danger in all sorts of ways. It also reflects the idea that drivers may be going too fast to stop in the distance they can see to be clear, and that it is the rider's duty to keep out of the way. This suggests that it is OK to drive this way. It isn't. When riding round left-hand bends, it is safest to ride further out, so that you can see and be seen from further away. It is rarely safe to overtake one cyclist and not safe to overtake two riding side by side. Singling-up and keeping to the side on narrow roads just increases the chance that a driver will try to overtake when there isn't sufficient width, and makes you less visible. |
| 63 / 19 | Replace the new text at the end with "or speaking to them." | Bells are useful for communicating with pedestrians, as is the clicking of brake or gear levers, but the voice is just as good. |
| 63 / 19 | Add a new clause "have the skills needed to ride safely on the road. If in doubt, take some national standard cycle training." | It is important that there is no return to old-style cycle proficiency activity, and that the correct updated training is referred to. National Standard cycle training is very effective in improving cyclists' confidence and safety. |
| 68 / 19 | Reword after "advanced stop line": "...where you can wait ahead of other traffic until the light changes" | Original wording illogical. |
| 74 / 20 | Delete the text about riding round the edge of roundabouts. | This technique increases danger and should not be recommended. |
| 79 / 21 | Replace with: "Level crossings and tram tracks. These can be slippery. Always cross as near to a right angle as possible, and never at less than 30 degrees." | 'Cyclists Dismount' at level crossings is usually an attempt to avoid liability for a layout that is dangerous to cyclists. The layouts need to be changed and the responsible authority should remain liable for crashes in the meantime. |
| 120 / 34 | Add after first sentence: "At night, do not rely on other road users having lights or reflectors." | Remind drivers that their duty of care extends to all road users. |
| 137 / 39 | Change second sentence to "Buses and/or cycles may be exempted, with or without contra-flow lanes." | No entry except buses, and contra-flow cycling without a lane, are both permissible. See traffic advisory leaflet 06/98. |
| 146 /42 | Add to last clause "... who need to ride well out from parked cars to avoid danger from opening doors." | Inform drivers of the reason why cyclists cannot safely allow them to overtake when there appears to be room. |
| 147 / 42 | Replace last sentence with: "You should not overtake moving motor vehicles in these areas, and should allow extra distance when overtaking cyclists." | I presume you did not mean to recommend never overtaking cyclists in these areas. But drivers take longer to pass cyclists because they're going slower, and often misjudge it. |
| 148 / 42 | Add: "Ensure that you can always stop within the distance you can see to be clear." | Emphasise this fundamental rule of safe driving. |
| 157 / 45 | New clause: "Not overtake motorcycles or cycles if the road ahead is too narrow for two cars to pass in opposite directions." | Deter drivers from delaying cyclists in narrow roads. |
| 157 / 45 | Change last clause. "Give cyclists and motorcyclists plenty of room when overtaking: at least a metre of clear space at speeds up to 30mph; more at higher speeds or in high-sided vehicles. When passing horses, slow right down and give at least 3m clearance. | The biggest deterrent to cycling is overtaking too close. Drivers need clear guidance on what is and is not acceptable. The horse clause should probably be a new bullet point. |
| 164 / 47 | Add clause: "Watch out for cyclists on a cyclepath crossing a road into which you are turning. They may not see you approaching from behind them, and cannot stop as quickly as pedestrians." | Attempt to reduce the danger of cyclepaths at junctions. |
| 180 / 53 | Add: "Do not overtake other vehicles, including cycles, on roundabouts, unless they are in a clearly marked separate lane." | What happened to the prohibition on overtaking on roundabouts? |
| 192 / 56 | Add ", cyclists, and horse-riders" after "pedestrians". | The advice applies to all crossings, including Toucan and Pegasus. |
| 206 / 59 | Delete "attempt to". | Implies cycling isinherently hazardous, rather than a practical way to use the roads. |
| 207 / 59 | Add "... or change course to cross rails or ridges at a bigger angle." | Rails and ridges are dangerous to cross at shallow angles. |
| After 207 / 59 | New rule: Cycle facilities. Be aware of cyclists using off-carriageway cycle tracks and cycle paths, who may enter the carriageway from unexpected directions, especially at junctions. Cyclists are not required to use cycle facilities. | Off-road cyclists are in more danger than on-road at junctions. This rule is to try to reduce this danger and to prevent driver aggression against cyclists choosing not to use cycle facilities. |
| 224 / 63 | Add to first bullet point: "Do not assume that roads have been gritted." | Emphasises the point that ice must be expected at any time if it's cold enough. |
| 226 / 64 | Add: Allow extra space when overtaking cyclists in windy conditions, especially if you are driving a high-side vehicle. | Changes in wind force while being overtaken can push cyclists sideways. |
| 233 / 66 | No change | Specific mention of cyclists when opening car doors is a useful addition. |
| 237 / 67 | Add after "wheelchair users": "or cyclists entering the carriageway from a cyclepath." | Additional dropped kerb type that should not be obstructed |
| 258 / 71 | Delete "or if you are delaying traffic behind you", and following sentence. | ALL vehicles should move left when they can. But if you are passing slower vehicles you should not be forced to slow your journey so that others behind you can go faster. |
| Signs / 87 | Add sign 956, unsegregated pedestrian/cycle shared use. | A common sign indicating to cyclists that they can legally use a footway or path. |
| Annex 1 / 98 | Delete "strongly" | Bells are useful to alert pedestrians, but voice works just as well. |
| Annex 3 / 100 | Insurance section. Add 'motor' before 'vehicle', throughout. | Pedal cycles are vehicles, but cyclists do not require insurance. |
| Annex 3 / 101 | Vehicle excise duty section. Add 'motor' before 'vehicle', throughout. | Pedal cycles are vehicles, but no excise duty is payable. |
| Annex 3 / 101 | SORN section Add 'motor' before the first two 'vehicle' in the text. | As last. |