DVS is based on the amount of direct vision the driver has from the cab. The aim is to encourage the operation of vehicles with increased levels of direct vision to protect vulnerable road users such as cyclists and pedestrians. Logistics UK’s view is that whilst we and our members take road safety extremely seriously, we do not believe that vehicle standards should be set at a local level. At a minimum, it should be for central government and in reality, the manufacturers are designing vehicles for the whole of Europe and beyond. We will see through new European vehicle design standards, the amount of direct vision in new HGVs increasing over the next few years. But London does have a specific challenge with HGV and cyclist safety which is not shared by other cities and therefore, the Mayor of London decided in his last election campaign to commit to introducing DVS.
THE SAFE SYSTEM
If your vehicle doesn’t meet the minimum one-star rating, you will need to comply with the requirements of the Safe System. Fitting the Safe System does not change your DVS rating, it just gives you an alternative route to compliance to obtain an HGV safety permit. There is a guidance document on the Safe System that can be downloaded from the Transport for London (TfL) website which contains all the details.
The Safe System is a series of vehicle safety measures which aim to improve the overall safety of an HGV. The Safe System requires:
- Class 5 and 6 mirrors and side under-run protection all of which are standard on new vehicles and have been a requirement to enter London for the Safer Lorries Scheme for the last five years
- Warning signage or sticker to warn vulnerable road users of the hazards around the vehicle
- A sensor system that alerts the driver to the presence of a vulnerable road user fitted to the nearside of the vehicle
- An audible vehicle manoeuvring warning to warn vulnerable road users when a vehicle is turning left
- A fully operational camera monitoring system fitted to the nearside of the vehicle
PERMIT APPLICATION PROCESS
For vehicles rated one star or above, the process is very straightforward. Just apply via the TfL online application system. For zero-star rated vehicles fitted with the Safe System, you will need to submit photographic evidence of the equipment fitted. The permits will be electronic only, so there is no requirement to display anything in the vehicle and there is no cost for the permit. We are aware that a couple of bogus websites have appeared for permit applications. Only use the TfL website to apply for your permits.
Zero-star vehicles with an approved Safe System and one and two star rated vehicles will be granted a permit until 2024. Anything three star or above will be granted a ten-year permit. Larger fleets can submit a multi vehicle application and don’t have to supply evidence for all their vehicles – there is a sliding scale depending on the number of vehicles you operate.
For multi-vehicle applications, the operator submits a list of vehicles they need permits for. The TfL system will then check the star rating. A permit will be automatically generated for one- to five-star rated vehicles. TfL will advise which zero-star rated vehicles they need photographic evidence for. Once the evidence for the sample vehicles has been approved, permits will be granted for the remaining zero-star rated vehicles
OBTAINING STAR RATINGS
If the vehicle does not have a star rating, you will need to check with the manufacturer (there is a list of who to contact for each one of the TfL website). If you know the vehicle is zero star and you have fitted the Safe System, you can now self-certify the zero-star rating, but you can only do that via the single vehicle application route. To self-certify the vehicle as zero-star rated, you must upload a written statement as part of your application. The statement must include the following:
- Your name
- Number plate (vehicle registration mark)
- Vehicle make and/or model
- Statement that you are providing self-certification of the vehicle's zero-star rating
Once you receive confirmation that TfL’s records have been updated, you can make a zero-star HGV Safety Permit application for the vehicle. Those without a rating need to check with the manufacturer.
SAFE SYSTEM EVIDENCE
If you have fitted the Safe System, you will need to supply two photos – one of the front and one of the rear of the vehicle. For rigids, the photos must show the VRM, class V and VI mirrors, side under-run protection and warning signage. Whereas artics only need photos of the front and rear of the tractor unit and must show VRM, class V and VI mirrors. If the trailer is attached, the warning signage must also be visible, so it is recommended to only photograph the unaccompanied tractor unit.
GRACE PERIOD
Following calls from Logistics UK to further delay the start of enforcement of the London Direct Vision Standard (DVS), to allow fleet operators more time to prepare amid the challenges logistics faces from tighter COVID-19 restrictions, TfL is developing an ‘allow list’ of vehicles whose owners/operators have begun the HGV Safety Permit application process and/or have vehicles booked in to have the Safe System components installed. Vehicles registered on this list will be given a grace period of 90 days to continue to operate in the capital without holding a permit as of 1 March 2021.
To apply for the grace period, you will need to submit evidence from the fitter/garage on branded documentation with details of the appointment for the installation of Safe System equipment to their vehicles, plus their Vehicle Registration Number, to DVSGracePeriod@TfL.gov.uk before 1 March 2021. TfL will review the request and send written confirmation of the outcome. Once the Safe System equipment has been fitted, you must follow the DVS Permit Application process. Operators informing TfL of a delay after 1 March will not be eligible for the grace period.
ENFORCEMENT
Enforcement will be via ANPR camera detection. Vehicles over 12 tonnes will be checked against TfL’s permit database. Those without a permit will be issued a PCN of £550 – regardless of their star rating. However, the ANPR system can only check if the vehicle has a permit, so this will be backed up by on-street enforcement to check if vehicles have the correct equipment fitted, that it is switched on and functional. TfL does not have the powers to stop vehicles, so they will be piggy backing on enforcement checks by DVSA and the Police.
THE FUTURE
From 2024, the scheme will be tightened up and all vehicles rated zero, one and two stars will be banned, unless it can be demonstrated that they are fitted with the ‘Progressive Safe System’ – the details of which are yet to be determined. But TfL has committed to consulting on the Progressive Safe System in 2022, confirming any new requirements in 2023, a year before the scheme is tightened.
More details on the DVS permit application process can be found on the TfL website here.
LEZ TIGHTENING AND ULEZ EXPANSION
As well as the start of enforcement for DVS, 1 March is also the date that the London-wide Low Emission Zone (LEZ) standard is tightened up for HGVs. Goods vehicles over 3.5 tonnes will be required to meet Euro VI emission standards or pay a daily charge. Vehicles which are below Euro VI but meet the Euro IV and V standard for Particulate Matter will need to pay a daily charge of £100 and those which are Euro III or below will have to pay £300. To find out if your vehicle is affected by the LEZ changes, TfL has an online compliance checker: https://tfl.gov.uk/modes/driving/heavy-vehicle-checker/. More details about the LEZ changes can be found here: https://tfl.gov.uk/modes/driving/low-emission-zone/changes-to-the-lez?intcmp=52426
On 25 October, the central London Ultra Low Emission Zone (ULEZ) will be expanded out to, but not including, the North and South Circulars roads. This will require all vehicles to meet the Euro VI/6 standard, including cars and vans. HGVs won’t be specially affected, as by then, they will have already complied with the tightened-up London-wide LEZ. More details about ULEZ expansion can be found here: https://tfl.gov.uk/modes/driving/ultra-low-emission-zone/ulez-expansion?intcmp=53057
