Briefing by Richard Smith, Road Haulage Association (RHA) Managing Director
“New Direct Vision Standard rules will come into play later this year in London and we’re doing everything we can to help hauliers comply. Transport for London (TfL) is launching its ‘Progressive Safe System’ (PSS) for HGVs of more than 12 tonne gross weight operating in the capital from 28 October. This will apply to HGVs rated below three stars.
Keeping people safe on our roads is absolutely our number one priority. But we’re concerned about the timescales TfL has imposed amid doubts that the required kit will be available, and the practical and affordability challenges firms face to fit it. The new rules are causing a lot of uncertainty for firms entering and operating in London and we’re campaigning hard to ensure our industry’s voices are heard.
We’ve been working with fellow trade bodies to take wide-ranging industry views on the obstacles we need to tackle so that operators have the support they need to meet new safety criteria. Together with Logistics UK and the Association of International Courier & Express Services, we have been extensively lobbying TfL and London Councils. Hauliers affected by the upcoming changes consistently tell us that practical implementation of the new requirements from October are hugely challenging and in many cases not feasible.
This ranges from whether there’s enough equipment available ahead of the deadline, to whether there are enough qualified technicians available to fit it… It’s worth reminding ourselves that there’s a widening shortage of heavy vehicle technicians available to service our commercial vehicle fleets across the country – something we’re working hard to tackle through lobbying Government.
These are points we’re raising in our regular conversations with TfL and the Mayor’s office, including Seb Dance, the Deputy Mayor of London for Transport. This all comes against the backdrop of affordability – especially for smaller businesses. The cost-of-living crisis is squeezing our industry and we’re seeing a huge number of hauliers going bust.
More than 450 haulage firms went under last year – twice those in 2022 – amid rising operating costs (nearly 10 percent, excluding fuel) and significant falls in freight volumes (10 percent). We’ve warned that firms unable to comply in time might stop serving London at short notice which could lead to unforeseen problems in the capital’s supply chain and therefore its wider economy.
We’re urging TfL to carefully listen to industry feedback, and we call on them to announce that existing vehicles would not have to be retrofitted with new kit – instead phasing in the criteria so that new trucks will be fitted with the equipment through natural fleet replacement cycles. We’re also calling on them to announce a reasonable extension to the grace period to allow kit manufacturers more time to supply the industry with what it needs to comply with PSS. Our conversations with TfL and London councils continue – and we will keep the industry updated with our progress.
What you can do to get ready for PSS on 28 October
If you hold an HGV safety permit for a zero, one or two star rated HGV it will expire at midnight on 27 October. TfL has released information to help understand what’s needed to do to qualify for a safety permit from 28 October:
HGVs rated below three stars will need to install the Progressive Safe System, from 28 October 2024. You can find full details of the Progressive Safe System in our DVS Operator’s guidance. A summary of the seven requirements that make up the Progressive Safe System is set out below. Blind Spot and Moving Off Information Systems that are retrofitted to your vehicle must meet the performance requirements in our PSS technical specifications, and not UN regulations directly. See Link below for Technical Spec
Requirement 1: A Camera Monitoring System (CMS) must be fitted to the nearside of the vehicle, to eliminate the remaining blind spot at the nearside. A CMS can also be used as an alternative to fitting Class V and VI mirrors. TFL guidance states that an additional CMS does not need to be fitted where one already exists in the vehicle, or where the vehicle meets the standards set out in UNECE Regulations 151 and 159. This will apply where the same safety benefits are achieved, and may include a CMS fitted to replace mirrors, or as part of a Blind Spot Information System. TFL recommend that installers consider where to install cameras based on the size of blind spot that needs to be covered and to avoid causing an external projection that may encounter someone adjacent to the vehicle. In many cases, a mounting height above two metres may be appropriate, but installers should consider the context of the specific vehicle.
Requirement 2: Class V and VI mirrors, or a CMS that replaces the mirrors, or a combination of both, must be fitted to the front and nearside of the vehicle.
Requirement 3: A Blind Spot Information System must ensure full coverage down the nearside of rigid vehicles to detect vulnerable road users. They must not activate in relation to roadside furniture or stationary vehicles. This aims to prevent left turn collisions.
Requirement 4: A Moving Off Information System (MOIS) must be fitted to the front of a vehicle to warn the driver of the presence of a vulnerable road user and prevent collisions at the front blind spot zone when a vehicle moves off from rest.
Requirement 5: Side under- run protection must be fitted to both sides of the vehicle, except where this would not be practicable.
Requirement 6: Audible warnings must be fitted to provide an adequate warning to vulnerable road users when a vehicle is turning left, or right for left-hand drive vehicles. This makes sure that all vehicles can warn of an intended manoeuvre.
Requirement 7: External warning signage must be displayed on vehicles to provide clear visual warning of the hazards around the vehicle. TFLs operator’s guidance sets out that this must be clearly legible. TFL recommend larger (at least A3) size signs where possible, recognising that may not be possible for all vehicle designs. Operators where larger signage is not practical should do what works best for their vehicle, while making sure that signage used is clear and legible.
Making the case for change – help officials understand challenges
THREE things to help build the strongest case to secure the changes we need to help comply:
1) Complete a TfL survey expressing your readiness for the 28 October changes. The deadline is Monday 5 February (11.59pm).
2) Complete 10 questions we’ve produced in collaboration with Logistics UK and the Association of International Couriers & Express Services – Joint Industry DVS Survey.
This follows up on TfL’s survey to gather more information to build a full picture on our sector’s ability to meet the new DVS PSS requirements. Answers to this joint survey will be anonymised and collated to inform the conversations the three trade bodies are having with TfL. Please respond by Friday 23 February (6pm).
3) If you have a depot or premises based in London, please write to your local London councillor using our template letter:
- Go to: https://www.writetothem.com/.
- Enter your business or home postcode (this must be in London).
- Click the link on the right-hand side – ‘Write to all your councillors’.
- You will see a blank box. Copy and paste the text from the template letter into the box. If you would like to personalise the message to add your own experience, please do.
- Add your name at the bottom under ‘Yours sincerely’.
- Fill in your address details (this is mandatory).
- Click ‘Preview and Send’.
- Click ‘I’m happy, send it’.
- Check your email / junk folder for an email from WriteToThem. Click ‘Send the message to my Councillors’. You must do this final step, or your message won’t be sent.