Memorandum from Department for Transport,
Trade Union Side (RS 79)
This is a submission on behalf of the recognised
Trade Unions within the Department for Transport.
In the pre-amble to the terms of reference to
the inquiry the select committee state:
The Transport Committee recognises that considerable
progress has been made in reducing the scale of deaths and injuries
on the roads of Great Britain since the publication of Tomorrow's
Roads—safer for everyone in March 2000.
There is ample evidence to show that the number
of serious road accidents has not decreased as claimed.
SERIOUS ACCIDENTS
Police forces send DfT details of road accidents
via a return called STATS19.
Yet DfT—or at least DfT statisticians—are
aware of the short comings of the STATS19 returns.
Two reports: Road Safety Research Report
No. 69 Under-reporting of Road Casualties—Phase 1 and
Road Accident Casualties: a comparison of STATS19 data with
Hospital Episode Statistics; have been commissioned by the
department to investigate these short comings.
Road Safety Research Report No 69 states
in its introduction:
There is some concern that the trends in the
serious road traffic injuries as recorded in STATS19 may not be
an altogether accurate reflection of the true situation. Indeed,
there is general recognition and acceptance that the STATS19 record
is an underestimation of the actual number of road traffic accident
casualties.
Later on the same report states:
The authors conclude from the limited data available
that the serious group of casualties could be up to twice as large
as indicated by the STATS19 serious category.
The Road Accident Casualties report concludes:
The data reported to and by the police which
underpin the public record are not perfect. It is well known that
under-reporting is significant, although fatalities are reported
according to the STATS19 requirement. Studies have shown that
there are about as twice as many casualties in road accidents
as there are reported to and by the police, and under-reporting
for some types of vulnerable road users is very much higher.
These are startling conclusions. If the degree
of under reporting is as great as that suggested then the Government's
apparent success in reducing serious accidents and possibly deaths
on the roads largely evaporates away. Therefore a premise on which
the inquiry is conducted is incorrect.
THE "TREND"
DEFENCE
Now it could be argued that over time the difference
between STATS19 serous injury figures and the "real"
serious accident figure has been constant. Thus you would still
see a substantial reduction in accidents since 1997 if this constant
were added to the STATS19 figure ie it is the trend that is important
not the actual figures.
We reject that argument for the following reasons:
It implies that the absolute figures for the
numbers of serious injuries is immaterial; but if the "real"
serious accident figure is up to twice as large as that indicated
by STATS19 that surely says something about the success or otherwise
of the practical/theory test and other DfT policies ie the absolute
figures must have an impact on how DfT operates;
Allowing "it's the trend that's important"
argument means that Government targets can be ignored ie don't
look at the performance against the stated target, look at the
trend;
The argument implies that over time the degree
of under reporting/recording has been the same. There is evidence
within Road Safety Research Report No 69 that this may
not be the case. At page 38 of that report it states: "the
number of serious casualties in STATS19 could be under-reported
and/or be under-recorded by as much as a half, and it is possible
that this has risen over recent years";
It allows the continuation of a system (STATS19)
that clearly is not accurate in its present form;
It allows DfT to evade a serious public debate
on the accuracy of accident statistics.
In our view the department, as a matter of urgency,
should overhaul its accident reporting system to more accurately
capture what is actually happening on the roads. If it does not
then the "real" serious accident rate will continue
to differ from that of the "official" rate. Thus policies
that appear, in terms of the official data, to be working well
may not be so effective in the real world—and surely the
real world is one that the department should be concerned with.
QUESTIONS POSED
BY THE
SELECT COMMITTEE
To what extent have targets for casualty reduction
been a useful tool for focusing professional activity?
The Unions (who include the PCS union which represents
driving examiners) are somewhat sceptical that targets for casualty
reduction have focused activity in DfT up to now. Our view is
that road and vehicle engineering measures have been the major
cause of reductions in fatalities but that approach is beginning
to show diminishing returns.
We take it as a truism that good drivers are
safer drivers. Given that the real check of the driving standard
is the practical driving test we would expect that if targets
did drive DfT and its professional activity then there would have
been a significant impact on the driving test itself. Yet the
driving test has not changed much since 1997.
As far as we can see there is no linkage between
DfT targets and Driving Examiner (DE) work. For example there
is no reference in the DE's annual reporting system to road safety
or casualty reduction.
On the contrary, there is a sense that efforts
within DSA are being directed at making the test easier to pass
with more lax assessment of, for example, manoeuvring faults such
as reversing errors.
What further measures need to be adopted to reduce
deaths and injuries arising from drinking and driving?
There is clear evidence from the USA that graduated
licensing reduces fatalities and accidents. We believe that graduated
licensing would effect novice driver's attitude to drinking. In
Nova Scotia, for example, sufficient violations incurred during
the two-year intermediate stage start the clock over. The threat
of such a penalty can provide strong motivation for safe, sober,
driving. Therefore we believe that it should be introduced in
the UK. In addition the Unions call for a lower blood alcohol
limit for young drivers as part of the graduated licensing process.
Whilst the Unions wish to see graduated licensing
introduced for young and new drivers it can also be used as an
alternative to banning and other orders. In certain circumstances
we believe magistrates and other legal officials may welcome putting
a driver found guilty of drinking offences on graduated licensing
rather than banning them; for example where a driving ban would
lead to loss of livelihood. In that way graduated licensing could
become a form of driver ASBO.
A generation of drivers has grown up without
the benefit of continuous anti drink-driving campaigns which were
a feature of the 1970's. We think that a new continuous anti drink/drug-driving
campaign would influence drivers attitude to road safety as it
has in New Zealand Influencing drivers throughout their careers
is likely to be more effective if there is an integrated approach
where the Department's road safety policies are informed by accurate
accident data collection and analysis. The conclusions of this
analysis should then drive the testing and assessment carried
out by DSA.
How do approaches in reductions in risk on the
roads compare to those adopted in other modes of transport?
DfT has Rail, Marine and Aviation Accident Investigation
Branches, there is still no equivalent Road Accident Investigation
Branch. In the United States there is such a body. We believe
that such an organisation is necessary in the UK to identify/analyse
accident trends and to make recommendations to reduce deaths and
injury. We further believe that the U.S. practice of such bodies
publicising "most wanted" safety improvements could
effectively challenge the Department by a statutory requirement
to respond and justify inaction publicly in the face of such recommendations.
What further policies, not already widely used,
might be considered for adoption and what evidence there is for
their success?
Graduated Licensing has been proven in other
countries to work. We cannot see that UK is not sufficiently different
that such a licensing process could not work here.
The driving test does not have a motorway element,
nor does it test overtaking, nor manoeuvres such right turns across
the path of fast moving traffic. We believe that the driving test
must have these elements. Of course to incorporate such new features
into test will require the use of dual control cars.
We also believe that it is now necessary to nationalise
the ADI (Approved Driving Instructor) industry to allow sufficient
control over the delivery of a consistent standard of driving
tuition to new drivers.
If this is considered too bold a move then there
must be better regulation, training and help to raise ADI standards.
What should be the priorities for government in
considering further targets for casualty reduction beyond 2010?
Improving road safety should be the key target
for the relevant DfT Agencies rather than "meaningless"
(in the context of road safety) customer service targets. DfT
Agencies should operate as a coherent whole rather than operating
at cross purposes as they currently do. DfT must focus on the
drivers rather than predominantly on engineering solutions and
it should develop a long term media and enforcement strategy for
influencing new drivers.
February 2008
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