Time for change?

Direct Vision Standard (DVS) was first launched by Transport for London (TfL) in October 2019, and implemented on 1 March 2021 as part of the Mayor’s Vision Zero scheme to eliminate all deaths and serious injuries from London’s roads by 2041. The scheme is targeted at HGVs over 12 tonnes and is enforced across Greater London, 24 hours a day, seven days a week.

DVS operates via an HGV Safety Permit Scheme in which a star rating system ranks the HGV vehicles from zero to five stars, based on how much vision the driver has directly through their cab windows. Currently a minimum rating of one star is required to qualify for the required HGV Safety Permit, with operators of zero star rated vehicles able to comply with the scheme and obtain a permit only by evidencing the fitment of additional safety equipment (the Safe System), including a camera monitoring system providing visibility down the near-side of the vehicle, sensors warning of the presence of vulnerable road users and an audible alarm warning cyclists and pedestrians of a vehicle’s intended left-turn manoeuvre. Operators of vehicles that fail to qualify and continue operating in the capital without a permit face being issued with a Penalty Charge Notice (PCN) of £550 for each day driven within the zone.

According to a report from TfL which examined performance of the scheme one year on from implementation, 191,769 permits were issued in the first year with the majority – 112,259 – issued to 0* vehicles and 4,768 to 5*. The safety of all road users remains a crucial priority for the logistics sector and while the report – issued in June 2022 – noted that, encouragingly, more than 94 per cent of HGVs in London were operating with a Safety Permit, recently announced changes to the scheme by TfL will see HGVs over 12 tonnes and with a star rating of zero, one or two needing to comply with updated requirements from 28 October 2024.

The Progressive Safe System (PSS) will replace the current Safe System: to maintain compliance beyond its October 2024 implementation, affected operators will be required to submit evidence that their vehicles are compliant with the new PSS requirements to then be issued with a new DVS PSS Permit Operators whose vehicles meet the relevant minimum three-star rating will be able to apply for a permit without taking further action to fit additional safety measures.

Following the announcement of the new PSS, TfL held a consultation period to which Logistics UK responded to highlight concerns and asks on behalf of members. In its response, the business group outlined how the lack of available specifications for the new system left operators unable to say if current kit will remain compliant in the future. In addition, Logistics UK asserted that operators should not be required to remove kit that had been purchased and installed in good faith for the current Safe System. The business group also called for grace periods for fleet operators if they can demonstrate that they need more time to fit the PSS, in addition to a look-up tool to help operators know which vehicles have a valid permit.

In a joint statement with RHA, Logistics UK expressed disappointment following the publication of the PSS technical specifications in September. Both organisations remain fully committed to improving the safety of all road users, and putting in place workable solutions that reduce the risk of road fatalities. However, significant frustration remains that operators will be required to replace equipment already installed by the sector in good faith to meet the current Safe System but which may not meet the revised standard, without any clear explanation on why existing kits may need to be replaced under the new requirements.

The business groups also highlighted how short lead-in times, a lack of available kit and a dire shortage of qualified fitters to install it will make it impossible for the industry to prepare and be ready for the implementation date next autumn, and called for assurances that further changes will not be necessary once the new equipment is installed.

Logistics UK, alongside RHA and other trade bodies, has continued to engage with TfL, the Mayor of London and other stakeholders to highlight the challenge this change presents for our industry. Most recently there have been joint meetings with London’s Walking & Cycling Commissioner and the Chief Operating Officer of London Councils, and we will shortly be writing to all senior TfL officials to reiterate our concerns and to seek reasonable solutions.

Logistics UK recognises the concern amongst our members on the pressing timescales of this change, so will continue to request the new PSS standard to apply to new vehicles only, or to vehicles which have not previously been fitted with safety equipment. Vehicles that are manufactured to the new United Nations Economic Commission for Europe regulations should also be permitted, with the timescales for the introduction of PSS to accommodate the fleet procurement cycle to deliver these vehicles.

For more information, please visit: www.logistics.org.uk