Consultation response: Application of conspicuity markings to heavy vehicles

From Brake, the road safety charity

All queries, contact or call Zoe Ward on 01484 559909

Introduction

Brake is a national road safety charity working to protect all road users.

We are in favour of any measure to increase the visibility of any road user or road user’s vehicle. We are also in favour of any identified safety measure, ranging from extra mirrors to conspicuity tape, proven through solid research to improve safety, to be required to be fitted by statute.

We are grateful for the opportunity to respond to this consultation with this short, favourable response.

Q1. Is there a need to mandate conspicuity marking on some vehicles?

Yes. Existing requirements are too minimal for larger vehicles, there is well-founded research in favour of greater conspicuity, and it is cost effective.

It is also worth noting that the UK has –

·  Long hours of darkness, longer than in Italy, where they have passed this legislation.

·  Busy, fast roads, often intermingled with densely populated communities where everyone has a need to be aware of everyone else, and better visibility can help.

·  A disproportionate number of large goods vehicle fatal crashes compared with the goods vehicle fleet size. Many of these crashes are caused by driver tiredness and mechanical failure, which better conspicuity would not prevent. However, many of these crashes occur on major trunk roads, where it is essential, in the event of a crash, that the crashed vehicle is highly visible - to give other drivers as much advance warning as possible of a crash up ahead.

Q2. If conspicuity marking tape were to be mandated which vehicles should be included?

The cost of fitting conspicuity is small compared with the cost of a fatal crash, which is costed by the DfT at over £1m per fatality. We believe ECE 104 retroreflective tape should be mandatory on HGVs over 7.5t and on coaches and buses (line marked). It is particularly important that buses are visible to vulnerable road users, cyclists, motorbikers and pedestrians, as they are most likely to be spending most time in urban environments.

Q3. Is line marking acceptable or is there a need to mandate full contour marking?

The objective is to make the vehicle visible to all road users. Contour markings have the obvious advantage of clearly communicating in a split second the size and shape of a vehicle, whether it is the side or the rear. The side of the vehicle is just as important to communicate as the rear, it could be argued. For example, on roundabouts and at junctions, it is vital that other road users waiting to pull out, or seeing a large vehicle pull out in front of them, understand the size of the vehicle they are dealing with, as this enables them to correctly time their own movements. Brake would prefer full contour conspicuity. As a minimum, if line conspicuity is chosen on the side it should be combined with corner markings as well, and its effectiveness should be ascertained through further research. However, this would require costly investigation, when good research exists already, and a further change to regulations.

Q4. Would it be acceptable to allow colours other than red to the rear and amber/yellow to the side to be used?

Allowing different colours could cause confusion.

Q5. Do tractor units for use with semi trailers need conspicuity markings?

Yes, they become part of the vehicle.

Q6. Are there vehicles to which it would be difficult to fit markings?

It is unlikely that it would be impossible to fit any markings on any type of vehicle, although it may be harder on some than on others. Also, the more unusual the vehicle shape, the more important that its outline is apparent to other road users.

Q7. Are the costs quoted in the partial RIA representative of volume maufacture of reflective tape?

This is a question for the tape manufacturers and we would expect 3M and others to provide an accurate answer.

Q8. Are there any concerns regarding the durability of existing R104 tape?

The durability is as long, if not longer, than the life of a goods vehicle with a reputable operator.

Q9. Additional comment on conspicuity

Brake believes that motorbikers, and drivers whose vehicles have broken down on major trunk roads and motorways, should be required by law to wear high visibility clothing, in the form of a vest or conspicuously marked jacket. Brake also believes that all schools should be required by Government to issue children with a high visibility school bag, or high visibility jacket, and require pupils to use this item at all times if travelling to or from school on foot or bicycle.

Questionnaire answers

Brake answers Yes to all questions in 1 and 2.

Question 3 – Contour to both rear and sides

Question 4 – White should not be allowed on the rear and sides

Question 5 – Side and rear (sometimes tractor units travel on their own)

End/ September 2005