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Transport Select Committee call for evidence on road safety.

April 2019

Freight on Rail thanks the Transport Select Committee for the opportunity to comment on its inquiry into road safety.

In answer to the following two TSC questions

  • How effective is the Government’s current approach to road safety?
  • What interventions would be most effective at reducing the number and severity of road traffic accidents?
  1. Government should support rail freight in order to improve road safety

    Transferring freight from Heavy Goods Vehicles (HGVs) to rail reduces lorry miles and thereby reduces exposure to road collisions. So, supporting rail freight is a great way for the Government to reduce road deaths as HGVs are disproportionally involved in fatal road crashes because of their size and scale. The statistics show that cars are getting safer, but HGVs are not improving in the same way.
     
    Campaign for Better Transport has compiled figures for the last eleven years which show that overall road fatalities have reduced on UK roads; however the ratio of fatal road accidents involving HGVs compared with those involving cars has been climbing year on year 1.
     
    The figures depicted in the graph show the involvement of HGVs in fatal crashes compared to cars on motorways, A roads and minor roads for the last eleven years. They reveal little or no improvement in the rates of fatal collisions involving HGVs on motorways and A roads, and an increase in the case of minor roads.  There are many large, heavy lorries on roads which are often totally unsuitable for them, as the high rate of crashes on minor roads shows.
     
    The latest safety figures (2017) show the following:-
     
    • HGVs were nearly five times (455 per cent) more likely than cars to be involved in fatal crashes on minor roads
    • On average across all road types HGVs are almost three times more likely than cars. HGVs are 332 per cent more likely than cars on A roads
    • On motorways HGVs are almost four times more likely to be involved in fatal crashes than cars. 

    While actual figures vary from year to year the overall figures are consistent over the past 11 year which the following graph shows.
     
    Graph showing involvement in fataltities HGVs over 3.5 tonnes compared to all traffic
    (Source:Traffic Statistics table TRA0104, Accident statistics table RAS 30017 both DfT)
     
    It should also be noted that the latest DfT valuation of the benefits of prevention of road accidents puts the costs per fatality at over £1million 2.
     
  2. Figures on HGV involvement rates in critical incidents on the Strategic Road Network (SRN) make the economic and safety case for rail freight

    The average monthly figures for HGV involvement in critical incidents on the Strategic Road Network (SRN) from January to-November 2018 show the following: for incidents of more than five hours, the HGV involvement rate is 42.8 per cent of incidents and for incidents of more than ten hours the HGV involvement rate is 55.72 per cent; even though HGVs make up just under 12 per cent of motorway traffic miles in 2017. (source: Highways England HILO data 2018).
     
  3. Rail freight also reduces road infrastructure damage which can reduce road fatalities, especially for cyclists

    Poor road surfaces including pot holes can cause road accidents, especially for cyclists. Large HGVs are up to 100,000 times more damaging to road surfaces than a Ford Focus meaning some of the heaviest road repair costs are therefore almost exclusively attributable to the heaviest vehicles. Rail freight therefore reduces the road infrastructure costs for local, devolved and central Government . (source: 4th power law 3). 
     
    HGVs only meet about 11 per cent of their estimated allocated infrastructure costs through Vehicle Excise Duty (VED) and the user levy. Using the latest Department for Transport Mode shift benefit (MSB) values, the VED and RUL from all HGVs (£.34billion) 4 would not even meet the infrastructure costs for articulated vehicles alone (£1.62billion) 5.
     
    The current system does not distinguish between different types of HGV within a 3.5 to 44 tonne weight range.  The largest and heaviest HGVs (mostly but not entirely articulated) cause a great deal more road damage than smaller HGVs.

    See our detailed research https://bettertransport.org.uk/sites/default/files/18.03.26.MTRU-HGVs.pdf
     
  4. Further road safety dangers if longer semi trailers (LSTs) are allowed in general circulation.
     
    The Department for Transport (DfT) is undertaking a trial of 7ft (2.05 metres) longer semi-trailer trucks, which commenced in January 2012, even though it was opposed on safety groups by the vast majority of respondents. Local authority representative groups, road safety, cyclist and environmental groups all opposed the introduction of LSTs because of its massive tail swing 6.
     
    We believe that the DfT safety research, justifying 7ft longer lorries was flawed. Ever since then, Campaign for Better Transport has been campaigning to stop the LSTs using unsuitable urban roads.
     
    The reason for our ongoing concerns about the use of longer semi-trailers on minor roads, which make up 97 per cent of the road network, is because of the extended rear tail swing when they perform standard left and right-hand turns. The longer semi-trailers will need to use these roads, run by local authorities, to access freight depots. Many urban and local roads in the UK are unlikely to be able to accommodate such large vehicles, requiring them to perform movements that put other, more vulnerable, road users at risk, such as mounting kerbs or traffic islands, swinging over kerbs, traffic islands or adjacent lanes and entering adjacent lanes, parking bays or footways.
     
    The original DfT impact analysis in 2011 acknowledged that the longer semi-trailer, while meeting the existing turning regulations, did not have the same manoeuvrability performance as existing 44 tonne 16.5 metre trucks. The DfT claimed that active steer axles, which were claimed to allow longer semi-trailers to match existing HGVs’ turning performance, were being proto-typed. However eight years later, active steer axles are still not available and many traffic engineers do not consider that, given the length of the longer semi-trailers,that basic geometric rules mean that LSTs could not meet the performance of existing 16.5 metre trailers irrespective of axle technology. Two subsequent demonstrations in 2013 and 2016, organised by the DfT for Campaign for Better Transport and the Technical Advisers Group (TAG), showed the situation had not changed with regard to turning circles or even more importantly tail outswing using existing axle technology.
     
    We therefore believe that the only way to protect other road users from LSTs on minor roads, is for LSTs to only be allowed to use minor roads which have been designated suitable by the local authority concerned.  The costs of the analysis by local authorities to establish whether certain minor roads are suitable for LSTs should be borne by the road haulage operators running LSTs who benefit from the extra length.
     
    To safely accommodate these longer trailers, there could be a need or pressure to widen existing road junctions.  In fact representatives from the road haulage industry have already asked the DfT about widening junctions. Were this to happen it could have an even greater negative impact on people walking and cycling.  Wider junctions not only result in people walking having to cross further (and being more exposed), if there are nearby constraints, it can also lead to a loss of pavement space to accommodate these movements. Wider junctions also expose people to greater danger (walking and cycling) as they encourage all motor vehicles to travel faster through the junction.  Junctions are one of the most dangerous parts of the road network already and making them less safe would seem a backward step.
     
    Furthermore, with the removal of the hard shoulder and the introduction of shorter emergency refuge areas, the motorway network is becoming less able to accommodate LSTs safely.

    In answer to the following TSC question

     
    • Are there any areas where the Government’s current approach to road safety could be improved?
       
  5. Government should enforce existing road regulations

    Lack of compliance with road regulations puts other road users at extra risk
     
    • HGVs had a 39.1 overloading rate in road side checks in 2016, 45.5 per cent in 2015. Source FTA Logistics Report Dashboard 2018 from DfT data
    • UK HGVs roadside prohibition rates due to mechanical errors 27,8 per cent in 2016, 30.1% in 2015  - Source FTA Logistics report dashboard

    Further comments

    Direct Vision standards and new HGV cab designs
    The aim of this policy is to improve vision in HGV cabs to improve safety. Additionally the new designs will be more aerodynamic and will therefore reduce fuel usage as well as boosting driver comfort in the cab. Transport for London has been instrumental in lobbying for these changes.

    TfL releases interim Direct Vision Standard HGV star ratings

    EU to end brick-shaped truck cabs – saving lives and carbon emissions

    Conclusion

    HGVs continue to be considerably more dangerous in collisions than cars so modal shift to rail would not only have environmental and congestion benefits, it would also be safer and reduce the number of hours lost to road closures every year.

 


1. https://bettertransport.org.uk/sites/default/files/research-files/HGV-fatal-collision-rates-2007-2017.pdf

2. DfT RAS6001

3. Road-transport-technology.org/Proceedings/3 - ISHVWD/Vehicle wheel loads and road pavement wear - Addis .pdf

4. This calculated by adding £50 million from foreign vehicles paying the Road User Levy to the VED total for 2016 in the DfT table TSGB1311

5. This is calculated as 9 billion vehicle miles by artics (source: TRA3105) X 18p per mile for infrastructure costs from the MSB report

6. http://www.freightonrail.org.uk/7ftlongerHGVs.htm

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