Fourteen Points: Towards a Less Dangerous London Bus Service

Guest blog by Tom Kearney.

When is Year of the Safer Bus? At a meeting with Transport for London’s MD for Surface Transport Leon Daniels organised by Statutory Deputy Mayor Victoria Borwick on 18 September 2013, I asked Mr. Daniels why couldn’t TfL do what Manchester has already done: impose a 20 mph speed limit for all buses on its network and a 10 mph speed limit on streets with a high-density of pedestrians (like, erm, Oxford Street). Mr. Daniels’s ‘knee-jerk‘ response to my question seared itself onto my brain:

“We could run our buses more slowly [e.g: more safely] but that would cause them to run slower. We’re not going to do that because that would make them more expensive: Time is Money.” 

Time is Money. As the former director of a London-listed Mining Company and a mining operation in South Africa, I was shocked by Mr. Daniels response: if I had ever stated “we could operate more safely, but it would affect our bottom line” to the Health & Safety officials of either country where I’d been accountable as a Director and Board Member, my operation would have been shut down and I’d be on trial for Corporate Manslaughter. 

But not only is TfL allowed to get away with that complacent approach to the safety of its subcontracted bus operations, TfL’s “White Man’s Club” Bosses and their supporters (an unlikely coalition that includes The Mayor of London, Boris Johnson and the Labour Party) frequently hold up “London-style” Bus Operations as a model for the rest of the country to slavishly emulate.

Since I assume that most of the British Public would refuse to allow a bus operation to run reliably at the cost of killing and injuring more people, here are some actions TfL could implement immediately that would begin to deliver a less dangerous bus service. And, because less NHS and Police funds would be expended as result of these actions, it might actually cost less too.

Toward a Less Dangerous London Bus Service: 

1) TfL immediately adopts a Vision Zero Policy for its Bus Subcontractors.
In its excellent Feet First: Improving Pedestrian Safety in London Report, the London Assembly recommended that the Mayor adopt a Vision Zero approach to reduce KSIs on London’s roads. Simply put, a Vision Zero approach is a zero tolerance of any road danger and a complete rejection of the notion that road deaths and serious injuries are acceptable or inevitable. At present, the Mayor of London’s and TfL’s ‘ambitious’ KSI reduction goal is a 40% reduction on the 2005-2009 Average Annual KSIs by 2020. The 2005-09 Baseline average is 3626.6 Annual KSIs (about 10 KSIs per day). A 40% reduction of 1450.4 Annual KSIs (about 4 KSIs per day) would reduce KSIs in London to 2176.2 Annual KSIs (or 6 KSIs per day) by 2020. A stated goal of killing or injuring 6 people a day isn’t ‘ambitious’ at all: it’s pathetic. Based on TfL’s own published data, during the period 1 January – 30 September (calendar day 273) of this year, collisions involving TfL buses produced 275 KSIs (an average of over 1 KSI per day). If TfL enforced a Vision Zero Policy for its bus operations alone, it could achieve 25% of its murderous 2020 Daily KSI Reduction Target (4 KSIs per day) right now.

2) Subscription to CIRAS by Bus Sub Contractors is made an immediate and non-negotiable requirement by TfL.
The Confidential Incident Reporting and Analysis System has been available to TfL Train Drivers since 1999 and provides a confidential channel for them to report safety concerns which are then investigated by independent professionals. Bus Companies were invited to subscribe for their drivers in 2012 but, so far, and as the Head of CIRAS has already informed us, no bus company is a member. Why are the Mayor and TfL delaying on this?

3) A Chief Safety Officer for Surface Transport accountable to the Mayor of London and the London Assembly is immediately appointed to enforce danger reduction throughout Transport for London’s Bus Operations.
Coupled with its manifest failure to make danger reduction a priority for its bus operations, TfL’s dilatory stance on CIRAS just further evidences that the Commissioner of Transport for London and the MD for Surface Transport are examples of “regulatory capture” by the bus industry they are supposed to be regulating. Accordingly, the safety function for buses should be immediately removed from the Commissioner of Transport and his Surface Transport Subordinates. While the reason for this “regulatory capture” has multiple causes (in my opinion, the revolving door between TfL and its bus contractors is just one), an independent Chief Safety Officer (CSO) for Surface Transport needs to be appointed. The CSO would have the power to compel the Transport Commissioner and MD for Surface Transport to change contracts and operational practices that compromise safe bus operations. Why wouldn’t this CSO position need to cover TfL’s rail operations? Because, unlike TfL’s bus operations, the UK rail industry already has an independent regulator with no links to the companies it regulates, codified safety procedures and practices, and danger reduction policies like CIRAS membership already in place. In fact, it’s the law.

4) Make the TfL MD Surface Transport Job contingent on reducing Bus Collisions and KSIs involving TfL Buses
TfL’s MD for Surface Transport has, inter alia, responsibility for overseeing the performance of London’s bus fleet. London’s Olympic Year 2012, was one of the worst in recent memory for KSI injuries on London’s roads. Fatalities involving TfL buses increased by 83% at a time when London hosted the world. According to TfL’s own data, since Boris Johnson became Mayor, TfL Bus Collisions have increased every single year. The Chief Safety Officer for Surface Transport would review the MD for Surface Transport’s performance in reducing collisions every quarter and this review would be a factor in determining, inter alia, whether or not the MD for Surface Transport was retained or replaced.

5) Current Bus Contracts to be immediately amended to include Collision and KSI Reduction Targets that would increase every year.
Just as TfL has set an “acceptable level” of deaths and serious injuries on London’s roads at 6 per day by 2020, TfL should immediately amend bus contracts to set KSI reduction targets that would be increased every year and monitored by the MD Surface Transport and the Chief Safety Officer for Surface Transport.

6) Immediately Deduct the Costs of KSIs and Bus Collisions from TfL payments to Bus Subcontractors.
Under TfL’s “London-style” Quality Incentive Contracts, Busco Subcontractors can have up to 10 percent of their bus contract value deducted for failing to achieve contracted Excess Waiting Time (EWT) Targets. As already described by Bus Driver X, EWT Targets incentivise much unsafe bus driving behaviour. Quality Incentive Contracts contain no safety targets however. Making Bus Subcontractors immediately liable for all costs associated with collisions and KSIs taking place on their contracted bus routes would immediately concentrate the minds of Busco Managers on casualty and collision reduction.

7) Chief Safety Officer for Surface Transport to receive, approve and publish every KSI Incident Investigation carried out by TfL Bus Subcontractors.
From various FOIA Requests and Mayor’s Question Time Responses, TfL has admitted that:

  • It does not investigate bus collisions itself nor does it receive copies of its own subcontractors’ collision investigations; and, 
  • It does not keep records of how many bus company drivers have been prosecuted or convicted for KSIs. 

These reports would be submitted to, reviewed, approved and published by the Chief Safety Officer for Surface Transport on TfL’s website every quarter.

8) Chief Safety Officer for Surface Transport to inspect, analyse and approve the driver shift rotation practices of TfL Subcontractors
Bus Drivers have reported that fatigue brought on by shift changes is a problem. Since fatigue is a well-established cause of road casualties, TfL should be held responsible for the shift rotation practices of its subcontractors and these should be both inspected and approved by TfL on a regular basis. If shift rotation practices are found to contribute to KSI incidents (i.e., collisions resulting from driver fatigue), the Chief Safety Officer for Surface Transport will enforce changes.

9) Chief Safety Officer for Surface Transport TfL will collect and publish specific safety performance data about its Subcontractors.
Inter alia, we already know that TfL does not keep the key safety performance data about its Bus Subcontractors, e.g.:

The Chief Safety Officer for Surface Transport will collect and publish Bus Subcontractor Safety Performance Data and Actions Taken on a quarterly basis.

10) TfL to enforce a 20mph speed limit for buses on all roads in Central London 
Just like Manchester does. 

11) 10 mph for all buses in London’s West End, home to many of the highest pedestrian collision spots in London.

10 MPH for Buses within London’s “Red Square” – Oxford Street & Regent Street 

12) Bonuses of TfL Bosses will be directly related to reduction of KSIs. No bonuses paid for any period where KSIs increase.
Just like the UK Railway Industry.

13) TfL is to publish meaningful analysis of KSIs involving its buses every quarter.
The Casualty Data I successfully campaigned for TfL to publish every quarter is just a start. We deserve to see what TfL is actually learning from these incidents.

14) TfL to collect, analyse and publish the costs associated with all collisions involving its buses on a Quarterly basis
Collisions and KSIs cost the public money too…and it deserves to know how big this number is in real time.

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VZL comment:

We will be presenting this list to Ben Johnson, Senior Delivery Planning Manager at Transport for London, who we met last month. At the meeting he was adamant that TfL has a Vision Zero strategy. Well Ben, ALL the above are NECESSARY to ensure that the biggest killer on London Roads is managed in a way that lives are not sacrificed for the sake of efficiency, and of the pay packets of Hendy, Daniels and their pals.

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