The Road Danger Reduction Forum makes the following submission as part of its commitment to make safe travel an integral part of a sustainable transport system. It hopes that initiatives to reduce danger on the road will arise from the present consultation process. While we welcome the chance to comment on national policy, and many of the comments made in the document, we are sceptical that the necessary change in thinking is occurring in the Department of Transport and elsewhere in the dominant levels of the road safety professions. However, we will continue to press for the cultural change which we believe is necessary among professionals and all members of society.
Below we:-
Comments of particular importance are made in block type.
A. The Road Danger Reduction Forum (RDRF):
The RDRF is a network of road safety professionals (road safety officers, traffic engineers, transport planners, public health doctors and others) who wish to develop a new approach to road safety, based on danger reduction at source. Since its inception in November 1993 some 40 local authorities have signed the RDRF's Road Danger Reduction Charter. In 1996 the House of Commons Transport Committee published a report on 'Risk Reduction for Vulnerable Road Users' where the organisation whose submission obtained the largest number of favourable comments was the RDRF 1. The approach of the RDRF, often referred to as the 'New Agenda', the "road danger reduction approach", or the "movement for real road safety", are now expressed by other organisations such as Transport 2000, RoadPeace, the Environmental Transport Association, and those bodies concerned with the rights and well being of people travelling outside cars, particularly cyclists and pedestrians. In October 1996 the Chairman of Edinburgh City Council's Transport Committee stated that the RDRF's 'Is It Safe: A guide to road danger reduction' "should be compulsory reading for everybody concerned with road transport" 2.
A principal measure of the RDRF's impact is that the consultation document now refers, albeit unsatisfactorily, to some of the concerns we have raised over the last three years. In particular there is reference to the issue of 'who kills whom' - for too long absent from official road safety discussion. The question of danger is also raised for the first time. This brings us to consideration of the consultation document as a whole.
The consultation document shows a welcome recognition of some of the important issues, and as such represents a step forward for the Department of Transport (DoT). Nevertheless, a number of issues have been inadequately considered. It is essential that they are properly approached if we are to avoid a confused and self-contradictory policy regarding danger on the road. We would briefly summarise the areas where the DoT's approach is inadequate as follows (numbers in brackets refer to paragraphs in the consultation document):-
· Transport policy. What we know as 'road safety' has traditionally been largely associated with policies and attitudes which are centred on meeting the wishes of users and operators of motor transport, with the needs of others subsumed to this. This has not only been inequitable but also unlikely to provide proper safety for these other road users, or indeed, often to road users of all kinds. The issue of safety on the road is obviously dominated by the kind of traffic mix and associated issues - such as amount of travel, permissible speeds etc. - which is facilitated or determined by transport policy. While this is at last recognised to some extent (7,35), this recognition does not go far enough. For example, in 35. it is stated that "policies should be directed at reducing the demand for travel, where this is practicable, and at encouraging the use of modes other than the car".. Yet, while the Government has correctly set a target for increasing the modal share of cycling, such targets will be unobtainable and/or inadequate to the task if car use continues to be encouraged. While there is the unqualified promotion of "mobility"(6.), which is normally thought of as car usage, there will continue to be an unsustainable transport policy. We regard the association of road safety policy with sustainable transport policy such as is made by the Institution of Civil Engineers 3 as particularly welcome.
The RDRF believes that successful safety policies must occur within an objective of sustainable transport policies, and can indeed assist and promote such policies. Targets promoted outside such an overall objective will have little meaning or beneficial effect.
· Danger. We believe that road users are often concerned not so much with any retrospectively calculated statistics pertaining to casualties, or even casualty rates, but the danger which is presented to them. Danger is all too real and should not be presented in inverted commas (36.). While there are difficulties in specifying easy numerical assessment of danger, it is often accurately assessed by road users and is a concern which affects their behaviour and quality of life. We are also particularly concerned at the continuing confusion between danger and casualty numbers. Part of the reason for the success of the RDRF is the awareness among wide sectors of the population that the road environment may become more dangerous while reported casualties decline. This may happen because of the migration of vulnerable road users (cyclists, pedestrians and motorcyclists) and vulnerable people in these groups (particularly elderly and child pedestrians) from the road environment and also more cautious behaviour by them. It does not mean that the road environment has become less dangerous.
The RDRF agrees that "Road safety is about making the roads safer.." , although roads themselves are inanimate objects and danger arises from the behaviour of (basically motorised vehicle) road users. The road environment should be safer for all. It is of great importance that danger is seen as different from casualties or casualty rates, and that care should be taken to use the English language properly.
· Responsibility. Danger arises predominantly from the actions of those in charge of motorised vehicles, although those in a position to affect their behaviour, such as highway authorities and vehicle engineers, have a responsibility as well. We believe it is vital that this responsibility is fully recognised. Unfortunately, the tradition of the official road safety establishment has often obscured this. The danger road users present to other road users has been confused with danger presented to them. A decline in some statistics has generated complacency among motorists.
The RDRF welcomes the comment that for vulnerable road users, "An improvement in their safety lies in the actions of others". It is common practice in industrial safety management to firmly prioritise control of danger at source: this practice should continue into road safety thinking and clearly specify control of motorist behaviour as the basis for all road safety policy and practice.
· Morality. The issue of endangering the lives of others is above all a moral one, rather than statistical or technical one. Failing to differentiate between endangering others and being endangered has diminished this point, as has reliance on inadequately presented statistics.
The RDRF believes that it is essential to create a cultural shift in values which make behaviours likely to endanger others socially unacceptable. This will require a commitment to high levels of law enforcement and appropriate sentencing policy which at present does not exist.
· Setting the record straight. In order to promote high professional standards it is essential to properly account for changes that have occurred as safety has declined in the road environment. Without this there can not be proper confidence in the activities of practitioners. While there will always be uncertainties in interpreting data, it is vital to correct some of the received wisdoms of practitioners if a proper understanding of the likely effects of interventions is to be made. In particular, there has been a failure to properly accept the effect of adaptive or compensatory behaviour by road users to road safety and other interventions. As this has now been accepted throughout much of the scientific community, including Government employees4, it should now be formally acknowledged at the highest level. Explanations for reductions in fatalities, such as changes in quality of medical care for casualties should be properly acknowledged. So too should increased caution to excessive danger presented to them by vulnerable road users. Where motorist behaviour improves, such as with declining speeds in more congested conditions, this too should be acknowledged.
The RDRF does not believe that a reduction in those reported as killed and seriously injured in 'Road Traffic Accidents' can be seen as an unequivocal success. Where this has occurred because of a migration of pedestrians and cyclists from the road environment it is quite wrong to see such effects as "…a tremendous road safety achievement" (2.) The destructive effect of the use of so-called "safer" cars and devices such as car seat belts5, in terms of increasing danger to other road users, should be fully acknowledged. Reference must also be made to under-reporting of casualties: in particular declines in levels of reporting which can explain some of the apparent, but not actual, decline in serious injuries.6
C. Targets beyond the year 2000
We are uncertain that the introduction of the one-third reduction had the beneficial effects which are ascribed to it; we must repeat our point that targets must be set to contribute to objectives related to creating a sustainable transport system. Our comments on the possible targets set forward are as follows:-
· A target based on all casualties, or all those killed and seriously injured.(19 -24) Aggregating casualties in this manner fails to recognise the decline or increase of modes of transport which should be supported as part of a sustainable transport policy. We are strongly opposed to the use of such targets. 21. Points out that "A KSI target could…lead to an emphasis on secondary safety measures………(which) is unlikely to be detrimental to vulnerable road users". We would argue, on the contrary, that an emphasis on protecting car occupants from the consequences of bad driving is quite likely to be detrimental to vulnerable road users. With regard to severity of casualty, the same problem arising from failing to disaggregate by mode of travel arises. Obviously a serious injury will be of more importance in terms of suffering and waste of resources than a slight one. However, this does not mean that slight injuries should be disregarded. They - in the case of car occupants - indicate the results of crashes which may, in other circumstances where more vulnerable road users are concerned, be significant. In this context we would point out that slight injuries have increased by approximately 50% since the early 1950's. There is also a substantial literature on reporting and classification of injuries which suggests that under-reporting levels may have increased from studies performed in the 1970s, and that significant proportions of severe injuries have been misreported as slight injuries6,7 .
· Targets based on casualty severities (25 -27). For the reasons given above, we are opposed to such a target. If attention continues to be drawn to the different types of severity, we would argue that a fourth category should be included, namely non-injury involving motor vehicle crashes. While there are significant problems with finding appropriate data - as there are with all data in the area of road safety - we believe use of insurance claims to be a meaningful indicator of the number of motor vehicle crashes. We therefore suggest that insurance claim figures going back to 1980 should be used as one of the indicators of road danger, and that negotiations are entered into with the insurance industry to refine such figures further to give more precise indicators of crashes and road danger.
· Targets for reductions in casualties per kilometre travelled. This is a much better measure of road safety than the previous measures referred to. It would be even better to measure rates per journey. We need a target of this type particularly for pedestrians and cyclists. We are quite sure that data on crash involvement can be obtained by more work on under-reporting. In addition, it is vital that far superior traffic indices on pedestrian and cycle travel is gathered. Local authorities are already doing this to check on modal shift targets. A variety of data gathering processes can and should be used to obtain superior traffic indices. We are sure that problems referred to such as the difficulty of differentiating between children playing on bicycles and people cycling for travel purposes (29.) can be overcome. We are also convinced that this data need not be "..difficult and expensive to collect.."(29.). Funding should be made available via the TPP process for such work to be pursued as a matter of urgency.
· Targets per head of the population. We are opposed to the use of such targets. Such targets are misleading to the point of significantly opposing the task of reducing danger on the road.
· Targets for different modes. It has already been indicated that we believe targets per journey for different modes are desirable. We welcome the commitment to supporting the benign modes as expressed in 35. However, we would point out that traditionally what has been known as "road safety" has been about "influencing modes of transport". The benign modes have been discouraged and motor traffic generating programmes such as motorway construction have been pursued partly on the basis that such roads are "safer". We believe it is now time for road safety policy to be associated with good transport policies instead. We therefore support casualty rate targets for different modes. We would, however, emphasis that such targets are not as good as danger reduction targets: we would also point out that in the past the DoT has supported measures that have little or no evidence to suggest that they will result in casualty rate reduction, such as the use of bicycle crash helmets. Future polices must be based on the priority of unambiguous commitment to reduce danger at source.
· Targets for danger reduction. We strongly welcome the interest in danger reduction, albeit imperfectly stated, as expressed in 37,38 and 39. This shows a significant step forward by the DoT., and we hope it leads to equally significant policy proposals. Targets to reduce motor traffic volume and increase compliance with existing and/or lower speed limits would be welcome and easy to measure. They would meet the objective of reducing danger at source.
· Other targets for danger reduction. Useful indicators would be
(a) Motor insurance claims, as discussed above.
(b) The proportion of children allowed to go to school independently.
(c) Qualitative assessment of the experience of use of benign modes. There are a variety of projects which measure the numbers of 'near-misses' and other indicators which can and should be introduced as a matter of urgency.
(d) It is quite possible to measure a variety of criminally negligent driving behaviours, such as driving with inadequate eyesight, falling asleep at he wheel, giving inadequate headways, driving without being able to stop within visible distance, failing to defer to pedestrians when appropriate, overtaking cyclists when giving inadequate room, etc., etc. Many of these behaviours can be measured and severe reduction targets can and should be set. It could also be possible to count up successful prosecutions relating to such behaviours and establish conviction rate indices.
There are a number of avenues which can be pursued to reduce danger at source. All of them, however, are likely to fail unless they are implemented as part of an overall danger reduction programme. We refer to some of them below:-
* ROAD ENGINEERING
There is a substantial literature on reducing road danger by traffic calming and other methods of restraining the capacity of motorists to endanger other road users. There is now significant scope for integrating such approaches with on-board vehicle technology.
* VEHICLE ENGINEERING
We believe significant benefits can be achieved from the appropriate use of 'smart' technology on motor vehicles to create a safer road environment for all road users. In the first instance this would include the installation of automatic on-board speed governors on all motor vehicles (excepting emergency vehicles) to be activated by electronic roadside beacons or transponders. 'Black box' type devices to monitor motorist behaviour ca n be an invaluable crash investigation aid. Ultimately devices designed to prevent motor vehicles from colliding with vulnerable road users can and should be investigated with a view to installation at an early date. We regard it as a matter for considerable concern that such technologies have not been pursued in the interest of vulnerable road users to a significant extent, and that this may in fact increase problems for the vulnerable road users.
· LAW ENFORCEMENT
We are concerned at the lowering of already inadequate levels of police resources devoted to enforcing road traffic law. It is vital that motorists are made aware that there is a real prospect of being apprehended for committing visible offences. While there is no need for harsh punishment for the vast majority of offences, it is however necessary that there is a perceived likelihood of loss of licence resulting from the breaking of road traffic law. The awareness of such a likelihood would have a significant deterrent effect on bad driving behaviour.
At present the potential for deterring criminally negligent behaviour is not being realised, partly because of the low level of traffic law policing, but also because of the low levels of sentencing, even within the constraints of existing law. We would like to see penalties increased, in particular for serious offences such as failing to stop after an accident.
While it is important to increase both the likelihood of being caught, and of losing the right to drive, for illegal driving, it must be realised that the extent of such behaviour is so widespread and ingrained that fundamental change is unlikely in the near future. In order to deal with this state of affairs - while at the same time progressing to a more civilised pattern of behaviour - it is necessary to consider a radical change in road traffic law.
This change involves special protection for the right of vulnerable road users to move about in safety. We would seriously consider that where pedestrians or cyclists are involved in collisions with motorists, these incidents should be treated as offences of strict liability in that the motorist would be required to prove their innocence. This may appear to be unfair and against the spirit of the law (although drink-driving and speeding are offences of strict liability). However, given the wide scale of illegal motorist behaviour, resulting in nearly 5 million insurance claims alone annually, we consider that it is legitimate to assume that motorists have a tendency to engage in behaviour likely to result in collisions. Indeed, it is conventional wisdom, as seen in the engineering of the highway environment (crash barriers, anti-skid treatments, long sight lines etc.) and vehicle engineering (seat belts, roll bars, crumple zones, air bags, anti-burst door locks etc.), that the collision of motor vehicles with other objects or human beings is an expected fact of life.
· EDUCATION
While traditional road safety education has minimal impact on reducing danger on the road, we believe that useful changes may be effected. In particular, motorists should be educated of their responsibilities towards vulnerable road users. Motorists can be usefully informed that the non-motorised have a longer history in the road environment and have as much, if not more, right to be there as they have. We do not believe this point is being made sufficiently strongly by Government.
The non-motorised should be educated not just of their responsibilities, but much more stress should be made at all levels of road safety education of their rights. As a useful start to such a process, the Department of Transport could reverse the incorrect tendency to praise the 'road safety record' of Britain's motorists. Apart from being factually wrong this inevitably breeds complacency and exacerbates the situation.
In addition, compulsory re-testing of motorists as a condition of holding a driving licence as advocated by the Institution of Civil Engineers3 should be considered.
NOTES.
1. House of Commons Transport Committee: 'Risk Reduction for Vulnerable Road Users.' Paper 373. Session 1995-96. HMSO.
2. Councillor David Begg at Road Safety and the Road Danger Reduction Charter Seminar, 22nd October 1996.
4. Institution of Civil Engineers: A Vision for Road safety beyond 2000, 1996
5. See 'Behavioral adaptation to changes in the road transport system', OECD Scientific Experts Group, OECD 1990. Participants included G. Grayson of the TRL and representatives of similar organisations from 15 OECD countries. To take just one quote: "Controversy surrounding the discussion of behavioural adaptation has generally centred on the interpretation of what causes it and how complete it is, not on whether it occurs."(our emphasis). This process has a number of manifestations, such as accident migration, and is accepted by engineering practitioners (see Institution of Civil Engineers, op. cit.)
6. See 'Is It Safe: A guide to road danger reduction' (RDRF, current edition).
7. See in particular Transport Research Laboratory Report No. 173. (Also see note 7).
8. See the review of the literature in Plowden,W. & Hillman,M, Speed Control and Transport Policy, Policy Studies Institute, 1996.
Road Danger Reduction Forum November 1996