Correspondence from Mountain Rescue England
and Wales to the Department for Transport, 15 March 2005
PROPOSED AMENDMENT
TO THE
ROAD VEHICLE
LIGHTING REGULATIONS
1989 AND REGULATION
37 OF THE
ROAD VEHICLES
(CONSTRUCTION AND
USE) REGULATIONS
1986
Thank you for the consultation document issued
on the 13 January 2003.
As a general comment, it is highly desirable
to for both Breakdown Vehicles and Pedal Cycles to be allowed
the facility as stated in the consultation papers, to be more
conspicuous.
The Consultation Document however does bring
me to another point.
Currently Mountain Rescue in the UK represented
by the Mountain Rescue Council for England and Wales, The Mountain
Rescue Committee of Scotland, and the Northern Ireland Coordinating
Committee, does not have a specific paragraph in either the RVLR
or C&UR.
I raise this now, as I am the Executive Officer
responsible in England and Wales for Transport matters. Last year
I was the correspondent with the Driving Standards Agency on the
training of Blue Light Drivers and the dissemination of the "Expectation
Document" of Driver Competencies.
Mountain Rescue Teams and Cave Rescue teams,
the 5th and 6th Emergency Services, have for many years used Blue
Lights and Sound Warning Devices on their vehicles under the provision
of paragraph (a) in both sets of regulations.
(a) vehicles used for fire brigade, ambulance
or police purposes
Whilst in the vast majority of Police areas
it is recognised that Mountain and Cave Rescue services provide
a 999 life saving and rescue service, there have been cases where
this has been brought into question by individual Police Officers
who interpret the regulations differently.
Over the last three years I have received a
number of enquiries from teams relating to advice given by both
Constabularies and by individual Police Officers.
I have recently provided information to a team,
when they were requested by a Police Force to take up the fitting
of blue lights and sound warning devices with the Mountain Rescue
Council, as there is no specific paragraph in the regulations
covering Non—RAF Mountain Rescue Teams.
Essentially there is confusion. On a number
of occasions what has been quoted, is that only the RAF Mountain
Rescue Service are included in the regulations. Therefore Non—RAF
teams, cannot have blue lights and sirens. In each of these cases
I have been able to provide accurate and timely information and
so far no prosecution has taken place.
Whist recognising the specific work the RAF
Mountain Rescue Teams undertake at aircraft incidents, other emergencies
and the assistance they provide to the local mountain rescue teams,
it must be recognised that their primary role is for aircraft
incidents and that the 5 Teams located at Saint Athan, Stafford,
Leeming, Leuchars and Kinloss are hours distant from many of the
local Mountain Rescue Teams area of operation.
Mountain and Cave Rescue Teams, take ambulance
level aid on to the Mountains and into Caves and disused Mines,
and take Police services in the provision of trained members who
supply coroner's evidence.
I am quite surprised that in 2003 the 5th and
6th—999 Emergency Services do not have their own paragraph
in both sets of regulations. Especially with so many other organisations,
who are listed where it may be argued that they are not, or are
marginal lifesaving services.
To take the words direct from the consultative
document:
"principally connected with life saving
or rescue"
Mountain and Cave Rescue take Ambulance level
aid to these specialist areas and are now are being called to
ever increasing semi urban and countryside areas, where their
specialised skills are recognised as paramount in dealing with
a wide range of incidents including rescue from river gorges,
quarries, disused mines and railway tunnels.
These are all "Life and Limb Emergencies",
where the three core emergency services are neither equipped or
trained to deal with such incidents and their staff wanting to
assist those in danger, can place themselves in extreme hazard.
If we add to this the implications of Health
and Safety Legislation, where the "core emergency services"
have to Risk Assess situations where they have no training or
equipment, this could lead to possible prosecution.
Example.
In just one area of the UK, it has been reported
in the last 2 years, that one ambulance personnel and one fire-fighter
have been seriously injured attempting to deal with mountain rescue
situations.
Add to this the situation (in the same area)
where a Fire Control, contacted Police Control to ask if they
had radio or mobile phone contact with Fire and Ambulance personnel
who had deployed on to the mountain and now been out of contact
for 1½ hours. Police Control had no knowledge of this incident
and immediately called Mountain Rescue. The missing fire and Ambulance
personnel were found some 45 minutes later by mountain rescue,
some near exhaustion, having climbed the highest mountain in Southern
Britain, attempting to carry a person with no signs of life, on
a spine board.
Whilst this had a major element of "lack
of coordination" of the incident from the outset, it has
resulted in a complete review of procedures in that area. What
made the press was, that Mountain Rescue had to rescue "Fire
and Ambulance Personnel" from the mountain.
The majority of Mountain and Cave Rescue Vehicles
in the UK are already fitted with Blue Lights and Audible Warning
Instruments (two tone horns and sirens), as provided by the Regulations,
as they have been constructed or adapted as an "Ambulance"
and are registered as such.
However we still have individual Police interpretations
as stated above.
In addition there are a number of Mountain and
Cave Rescue Vehicles, around 20 in the UK that are not "Ambulances"
eg personnel carriers and control vehicles, and a change in the
Regulations would permit these essential vehicles to use Blue
Lights and Audible Warning Instruments.
This is a small number of additional vehicles,
as the majority as at present, will be registered Ambulances.
The increased impact on the public for these
additional vehicles will be minimal.
A Search and Rescue service now exists in some
English Counties, and these bodies are represented by the Association
of Lowland Search and Rescue, (ALSAR). Currently there are seven
teams who provide a search and rescue service. Again they are:
"principally connected with life saving
or rescue"
I have consulted with ALSAR and they agree that
as a lifesaving service they should be included in the regulations.
Some of the ALSAR team vehicles are Ambulances and the current
impact of inclusion in the regulations would be 6 additional vehicles.
UKSAR
The United Kingdom Search and Rescue Committee
(UKSAR), is a committee of the Department for Transport and one
of its Key Role's is to coordinate Inland Search and Rescue.
The Mountain Rescue Council, the Cave Rescue
Council and the Association of Lowland Search and Rescue, are
members of the Operators Group of UKSAR. This is in recognition
that they provide key services of search and rescue, to the communities
and population of the UK.
In order to include and establish the correct
"recognised bodies" for the use of blue lights and sound
warning devices, I would request the following addition to both
the Road Vehicle Lighting Regulations and the Construction and
Use Regulations, (as specified above).
"Vehicles used for mountain rescue cave
rescue and search and rescue by bodies listed by the United Kingdom
Search and Rescue Committee".
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