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DfT Consultation on Road Vehicles - Improving air quality and safety.

Freight on Rail thanks the DfT for the opportunity to comment on the consultation on the HGV safety element of the consultation.

Freight on Rail, a partnership of the rail freight industry, the transport trade unions and Campaign for Better Transport, works to promote the economic, social and environmental benefits of rail freight to local, devolved and central Government.

Consultation question 26

Lack of improvement in HGV safety should be evaluated
HGV involvement rate in fatal crashes on local roads has doubled in the past ten years.

Our ten year analysis of DfT Road Safety statistics, which show that HGVs are now twice as likely to be involved in a fatal collision on minor roads than they were ten years ago, demonstrates the benefits of reducing lorry miles. Despite only making up five per cent of overall traffic miles, HGVs are almost seven times more likely than cars to be involved in fatal collisions on minor roads.

Whilst cars are getting safer, HGVs continue to be dangerous in a collision because of their size and weight. The figures also reveal little or no improvement in the rates of fatal collisions involving HGVs on motorways and A roads. In 2014, on motorways, HGVs were involved in almost half (45 per cent) of fatal collisions although they only accounted for 11.6 per cent of the miles driven on them.  

Graph - Involvement in fatalities HGVs over 3.5 tonnes compared to all traffic
Source: Traffic statistics table TRA0104, Accident statistics Table RAS 30017, both DfT

2. Dangers of the 7ft longer semi-trailers under the DfT trials

7ft longer HGVs should only be allowed on designated routes in the capital on safety grounds

The 7ft longer HGVs, known as longer semi trailers, currently being trialled by DfT which it admits have bigger tail swings and blind spot, should only be allowed on local authority designated safe routes within the capital.

These longer HGVs are particularly dangerous for cyclists and pedestrians as the tail swing is double that of the standard 44 tonne artic. Currently there is no mechanism to stop them using unsuitable roads in the capital and the DfT does not even know what routes the LSTs are using. In urban environments where standard left or right hand turns are made, the out-swing of the rear of the trailer will up from 1.7m (5.5ft)on the standard 13.6 metre trailer  to 3.3m (10.8ft) on the LST under normal road conditions and this will occur in the driver’s increased blind spot. Many urban junctions could not accommodate such trucks without their entering ‘wrong lanes or mounting the footway or traffic islands. This will be particularly dangerous for all other road users who may get side swiped as it will not be obvious to them how the back of the lorry will swing out into another lane.

The assumptions for economic, safety and environmental improvements depend entirely on the prediction of a dramatic reduction in vehicles kilometres. However, the justification for longer heavier trucks is derived from high levels of load utilisation – in excess of that routinely achieved within the haulage sector. So until there is a rational basis for all existing HGVs to be used more efficiently, it is questionable how assumptions can be made that even bigger trucks will have higher utilisation than existing HGVs. Government figures show that nationally 30 per cent1 of lorries are driving around completely empty, a figure which has been consistent for some years.

The lorries in the LST trial are currently well utilised as it is a self-selecting audience taking part in the trial, but once these trucks become the largest standard permitted size - as is already being implied by the Society of Motor Manufacturers and Traders - they will be used for all jobs, whether small or large, exactly as currently happens with standard HGVs and the efficiency benefits will evaporate. Current industry practice is to buy the biggest lorry available and use for all jobs, big or small. (see chart below)

Goods moved by GB-registered HGVs, by type and weight of vehicle, 1990-2015 [DfT Table RFS0107

94% of UK HGV fleet operators had fewer than 10 vehicles and approximately 50% of operators were owner drives licensing just one vehicle who tend to get lower utilisation figures than the big operators.2 The latest DfT Domestic road freights statistics report states that, there has been a shift towards using larger HGVs with the tendency for the vast majority of HGVs to be purchased at the maximum size and weight permitted which optimises the position for the largest and heaviest loads, but creates part loading for other consignments. The proportion of freight lifted by HGVs over 33 tonnes increased from 83% in 1996 to 96% in 2016. In 2000, 22% of HGVs were between 31 to 41 tonnes the maximum allowed at the time. However, now 22% of HGVs are now at the new maximum weight allowed of 44 tonnes. In 2016 DfT statistics stated that only 34 per cent of standard HGVs on the roads are fully loaded by volume and 30 per cent are travelling around completely empty. Even load data from the trial fails to support this claim with the trial lorries fully loaded for only a third (34 per cent) of their journeys with the extra length not being used at all for around half of their journeys. 

The Technical Advisers Group are worried about the safety and cost implications for local authorities. Up until now, the DfT has not known what type of roads the LSTs are using and for how long. But, as a result of CBT, LGA and Technical Advisors Group’s requests, the DfT is now going to use GPS to monitor the trials going forward.

Image showing comparative lengths of lorries

3. The following DfT table shows the benefits of preventing collisions
Table shows the benefits of preventing collisions

4. Enforcement of road safety regulations

FTA Logistics report 2017 Logistics dashboard P11

HGV road side encounter prohibition rate percentages – mechanical checks 2015 30 per cent UK drivers only.

HGV road side prohibition rates- weight checks 46 per cent- UK drivers only



1. Source DfT empty running figures Table RFSO117 July 2017, 2015/2014 were 29%.
2. Source – Energy and Utility skills report 2013.


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