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Logistics UK’s full letter re: Direct Vision Standard – resolution of issues

As part of the policy team's ongoing work to press key messages to government on Direct Vision Standard (DVS), Logistics UK alongside the Road Haulage Association and AICES, sent a joint letter on 26 October to senior officials in TfL and London Councils which addressed key points including lack of accreditation of required kit, lack of real-world testing and also unrealistic implementation timescales. This is the letter in full.

By email to:
Will Norman - Walking and Cycling Commissioner
Alex Williams – Transport for London
Christina Calderato – Transport for London
Stephen Boon – London Councils

26 October 2023

Direct Vision Standard – resolution of issues

To all addressees

We, the signatories, have engaged with TfL on the introduction and development of the Direct Vision Standard (DVS) since its introduction and, throughout this year, have had a number of meetings with officials and yourselves to discuss our concerns relating to Phase 2 of DVS. We welcome the offer of a joint initiative, to run until April next year, to help prepare the market readiness report that the TEC of London Councils will consider in June 2024 and will contribute to this.

Our respective members are required to take Board level decisions now on procurement for vehicle purchases next year and, as a result, there are deep worries about several issues we have raised with you that cannot wait until the second quarter of next year. We need some urgent action on these points to reassure our members that their concerns are being fairly addressed.

As stated, we need to get this right. The UK economy is in a fragile state, with all business indicators pointing to flat or declining demand for goods and services for the foreseeable future. According to TfL’s own Impact Assessment, the new PSS equipment and fitting will conservatively cost our sector £500m to implement by October next year at a time of severely restricted budgets. We need to avoid the following – first, where our sector is forced to scrap equipment fitted to comply with the current Safe System due to a lack of understanding on whether this meets the PSS; second, re-fit kit in the future due to flaws with the new PSS requirement; thirdly, where disruption to supply chains across the UK occur due to unreasonable timelines that do not allow our sector to prepare for the new PSS in a timely and orderly manner.

We trust you will agree that these situations must be avoided. Not only would they unfairly penalise businesses who have already made investments in the Safe System to find this investment is now lost – something that will be devastating for small businesses in particular - they would also undermine the credibility of the Progressive Safe System. We are not assured that this is being treated with the due urgency required by TfL.

Having now scrutinised the published specifications and guidance, we set out our specific concerns in more detail in the attached annex to this letter. We would be grateful for your comments on how these matters can be resolved.

We also understand from the Metropolitan Police that a number of deaths involving HGVs in London can be attributed to suicide. As we have mentioned in our discussions, we have concerns about the welfare of our drivers in such circumstances. We would welcome further discussions with you about this issue.

Yours sincerely,

Richard Smith, Managing Director, Road Haulage Association

David Wells, Chief Executive, Logistics UK

Amanda Lane, Chief Executive, Association of International Courier & Express Services

Annex – Trade body concerns with the new Progressive Safe System requirement

Absence of a kit accreditation system
1) The lack of a system administered by TfL to accredit kits that comply with the PSS requirement is highly problematic. In simple terms, an operator should be required to acquire compliant equipment once and be assured that such equipment is compliant. The absence of an accreditation system administered by TfL to police this leaves such compliance open to interpretation, which is unsatisfactory. We therefore seek clarity on three issues:
a. where retrofitting is required, it is standard practice for operators to receive a “certificate of conformity” from a competent authority confirming that the retrofitted kit is type-approved to meet the new requirements and has been installed by a suitably-qualified fitter. We ask you to specify who the competent authority is so that liability is clearly understood.
b. it is not clear how operators can prove that existing kits already fitted on to HGVs comply with the PSS requirement. On liability grounds and to guard against abuse, it is not appropriate for an operator to self-certify that existing kits comply. We ask you to clarify how operators can be assured that existing kits comply with the PSS requirement.
c. we have concerns that equipment suppliers are marketing kits manufactured to meet the UNECE 151 regulation for new vehicles as suitable for retrofitting for TfL’s Blind Spot Information Systems (BSIS) purposes. Our reading of the BSIS specification however is that these marketing claims are incorrect – this is because the BSIS specification removes the “900mm dead zone directly adjacent to the side of the vehicle” which is permitted under UNECE 151. We ask you to clarify how this will be policed so that the correct equipment is fitted for BSIS purposes.

Lack of real-world testing
2) We have concerns about the lack of real-world testing of the new PSS requirement. We would like to draw your attention to Loughborough University’s report Development of the Transport for London Progressive Safer System which states that, of six “site tests” conducted, five were in controlled off-road conditions with just one conducted in a live road situation where we further note:
The route did not cover any roads in central London and as such all driving was conducted away from cycle superhighways, the cycle facilities that were present across the route were predominantly off road shared infrastructure on pavements or, to a lesser extent unsegregated advisory on-road infrastructure, denoted by painted lines. (p103)
Our concern is that the extent of the real-world testing is not sufficient. This is aggravated by further concerns that the BSIS specification does not list mobility scooters as a vulnerable road user. By contrast, the Department for Transport’s work to allow Longer Semi Trailers within the UK took over ten years, with extensive road trials and analysis to ensure their safe introduction. We would be grateful for your comments on how this concern can be addressed.

Unrealistic implementation timescales
3) With less than 260 working days until Phase 2 begins and well over 200,000 vehicles below the 3-star rating, this would require around 800 lorries each and every working day to be taken out-of-service for retrofitting – this has significant consequences for the efficient functioning of the logistics sector. ONS figures show the number of qualified fitters has fallen by 60,000 or 30% since 2019, with over 5000 unfilled vacancies over the past year, there is a lack of available fitters to install the new kit within the required timescales.

We would appreciate TfL publishing the steps it will take, plus its underlying analysis, on how this demand will be managed so that supply chain disruption is avoided. Given the very tight implementation timescales involved, it would be prudent for this information to be made available no later than Christmas 2023 and preferably sooner. This would assure our sector that compliant kit is available in sufficient quantities and can be fitted in time.

Published On: 09/11/2023 12:59:00


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