Some other things wrong withTfL’s “Towards a Road Safety Action Plan for London: 2020”

Let’s look at the rest of TfL’s “Towards a Road Safety Action Plan for London: 2020” It is basically the usual confusions, distortions and misguided mythology of “road safety” ideology. We have outlined some of the typical problems here, and, as always, suggest a look at: John Adams’ “Risk and Freedom: the record of road safety regulation” and a short discussion in his Managing transport risks: what works?” Let’s consider some of the points made in the TfL document:


The first words are: “London has achieved substantial reductions in casualties and collisions …”. What does “London” mean exactly? As far as “road safety” (RS) professionals are concerned, it is they who are basically responsible, although some road users who have responded to their publicity (the RS intervention least well supported by evidence) may be credited.  But historically, declines may be due to the users of benign modes of transport taking more care – to the extent of not walking or cycling and allowing children to travel independently. Insofar as a cyclists’ Safety in Numbers effect occurs – and the RDRF tends to support this idea, at least in certain conditions – this is not due to the efforts of RS professionals.

Adams’ work on the data collected by the father of road safety academic work, Reuben Smeed, indicates that declines in casualties may occur irrespective of RS interventions. This is a useful corrective to the smug sense of achievement that permeates documents like this.

Then of course we have: “relative to the rest of Great Britain, London’s road safety record is a good one”. But this is not comparing like with like. Other parts of Britain have far faster flows of motor traffic. London has congested conditions, which – as the theory of Risk Compensation suggests – leads to greater care taken by road users.

If we are to make comparisons of London and other cities, we could look at those in northern Europe with significant modal shares of cycling. These tend to have lower – sometimes far lower – rates of cyclists’ casualties per journey. But of course, because there is a far higher cyclists’ modal share, the overall numbers of cyclists casualties per head of the population may be
higher. As we point out in the last post , that would be seen by us as a better record of cyclists’ safety – but the RS lobby would see it as worse.

What TfL tell us is that is that there is a “continuing disproportionate number of pedestrian, powered two-wheeler and pedal cycle casualties”. What does “disproportionate” mean? Obviously
people outside cars are more prone to injury following collisions than people inside modern crashworthy cars. Why does this make the casualties among them “disproportionate”? Why should cyclists and pedestrians be singled out with a patronising “Vulnerable Road User” designation?

Some colleagues may feel that highlighting these groups inevitably leads to humane and civilised approaches to reducing danger for these groups. We doubt this: experience indicates that this approach is based on seeing these groups as a problem.

(An aside: Of course, there are fundamental differences between walking and cycling on the one hand, and motorcycling on the other. Motorcycling is inherently hazardous. It poses more of a danger to other road users and does not have the health and other sustainability benefits of the other modes. But these differences are neutralized by the RS paradigm , just as the difference between being hurt/killed/endangered and hurting/killing/endangering is neutralized throughout RS ideology. It is not just that so many Road Safety Officers seem to be keen motorcyclists.)

So why then is the “challenge” of the “disproportionate number of…casualties” of these groups “emerging”? The problems for these groups are primarily problems of danger from motorised
vehicular traffic, and “emerged” when Bridget Driscoll was killed by a motorist at Crystal Palace in 1896.

And the above is just what TfL refer to as the “Context”…


The approach builds upon the firm foundations of proven interventions”. Well, no, it does not. The works quoted above by myself and Adams show how these interventions are often not responsible for declines in casualties, and may have increased danger on the road.

We then have a clear victim-centred approach: “…we need to target risk by focusing on and tackling the specific road users and behaviours that are over-represented in the casualty data” . The problem with the victim-centred approach is that, in the hands of the RS lobby, it leads to victim-blaming.

We then get the targets, which as pointed out do NOT refer to the chances of cyclists or pedestrians having being hurt or killed.



These are mainly:

  1. “Invest in London’s roads to make them safer (sic)”.

(a) “High risk locations will continue to be identified across the road network” The definition of “high risk” is not what we have discussed with regard to the TfL junctions review for cyclists’ safety – but the usual RS definition based on having the right number of reported casualties. If junctions like Staples Corner, characterised by high speed, multi-lane motor traffic linking with motorway and dual carriageways, do not have pedestrian or cyclists casualties – because the danger there deters them from being there in the first place – will they be defined as “high risk”.?

(b) “TfL will work…supporting the installation of 20 mph zones and speed limits”. But this is “where appropriate”, and “in keeping with the wider functions of the local road network”. So if a transport planner decides that a road has a “function” which requires high speeds, that’s tough for reducing danger.

    2. “Commit to and improve London’s safety camera network.”

Essentially this is upgrading a dilapidated network. Remember, cameras have to be easily visible, and are only sited at locations where the right number, as decided by RS professionals, of “speed-related” casualties occur. At other locations you can carry on speeding. There is no mention of relaxing criteria to allow more average speed cameras or enforcing the new 20 mph areas.

3.“Actively lobby for improvements in vehicle design and greater innovation to deliver better safety”.

This – basically the design features of HGVs of preventing collisions involving pedestrians and cyclists with them – is an area where widespread discussion and some activity, largely initiated and pushed for by our friends in RoadPeace, has taken place. It can have potential, but needs to be linked with real controls on HGVs, such as automatic braking systems and/or recorders to be used
in the event of collisions.

There is reference to side guards, proximity sensors etc. in lobbying the EC – for new vehicles in the construction industry. Nothing about retro-fitting. This whole area of HGVs and cyclists/pedestrians has its importance – the RDRF has been actively involved in attempting to get solutions since 1994. But it must be noted that while half the cyclists in London are killed in collisions with HGVs, the proportion of cyclists KSIs involving HGVs is quite low (typically around the 7% level). We have a strong concern that the focus on these types of collision diverts attention away from the vast majority of danger for cyclists and all other road users, from inappropriate use of all motor vehicles, mainly cars. Of course, this should not detract from the HGV issue, with all sorts of measures, including enforcement operations on unsafe vehicles.

Insofar as “improvements in vehicle design” are concerned, there are issues such as automatic on-board speed governors on cars and black box recorders – discussed and with prototypes produced. Are they being considered under this heading? No sign of it.

On a minor point, the documents here states: “The Mayor and Commissioner will write to boroughs, developers and construction companies in London asking them to adopt the TfL/Crossrail safety standards for their operations and suppliers.” This is fairly straightforward and the kind of thing that should happen – but Boroughs already have been written to along these lines. An interesting measure has been to produce a practical module (with on-bike experience for drivers in “Safer Urban Driving”) in the HGV drivers Certificate of Professional  Competence (CPC). A number of these modules have to be completed by September of next year – but only a few hundred out of the 30,000 daily HGV drivers in London have had this
training so far.

    4.“Run an ongoing programme of communications campaigns”.

The most discredited of all “road safety” interventions. Motorists have been politely asked to obey laws such as those on speed for decades with no measurable result.

5.“Conduct an ongoing research programme to enable the right policies to be developed.”

The problem here is that if the objectives, aims and understanding of how “road safety” has operated are wrong, more “research” is not going to help.

6.“Ensure good quality, detailed data is provided to the public and stakeholders on a regular basis”.

But not, as we have seen in the last post, with any indicator of levels of cycle or pedestrian traffic to give a “rate-based” indicator referring to the actual experience of walking and cycling.


Here I have to pause and say that the approach of TfL in this document is just so fundamentally flawed , rehashing traditional RS (“road safety”) themes , just not pointing in the right direction – never mind the confusions about how and why casualty reduction has occurred, or the need for rate-based targets as the minimum indicator for the sustainable modes – that it may not be worth commenting further. However, here’s a go at some things that might strike the eye:

    A. “Pedal cycle risk peaks for those in their late twenties and early thirties” (p.16) How much of this is due to people being more likely to cycle in these age groups? How much due to greater risk taking by people in their early twenties for all kinds of activity? This is not discussed. The implication is again that a “target group” is there to be  identified as a problem.

B. “Why?” (p.22)

    Why indeed. We have a pie chart of causes  such as “Failed to look properly” which practitioners are familiar with as being assembled from police reports. But the different kinds of road users are not disaggregated here. Is there a concern that the level of blame which could accrue to the Great British (or London) motorist would be too great?
    C. Cyclists. (p.33)

Here we have the one mention of a rate: we are  supposed to have a “reduced rate of cycling casualties”. But are we, and by how much. We are also told that the aim of increasing cycling so that it at least doubles “is not met with a rise in cycling casualties” – meaning that the casualty rate reduction should be at least 50%.

Is that what it means? Or that increasing cycling to the targets of the Mayors of London is not on track ?  Or that TfL has just not thought about this issue?

Case Study: Cycle Safety (p.34). The poster shown was criticised at the time by the London Cycling campaign for showing cyclists in a supposed driver blind spot when they were not. A small detail you might think – but if criticism has been received and is based on reality, why not accept it and use an example with another poster?

    D. Safer roads (p.44).

Engineering to produce safer roads involves…creating an environment that encourages safer behaviour by all road users”. No, it does not. Highway RS engineering is very often
there to accommodate UNSAFE motoring. Cutting down roadside trees, installation of crash barriers, trief kerbing at roadsides, positioning lamp posts (themselves constructed to break in such a way that cars hitting them are not struck by the  breaking structure in a way which threatens the driver) away from places where errant motorists may hit them, etc. are there in ways which , if anything, encourages unsafe driving. The same generally does not happen for cyclists. (Although careless pedestrians  have been rewarded with padded lampposts to accomodate their careless behaviour in one location  )