Last reviewed 24 October 2018
In 2017, the Mayor of London published proposals for, and invited comment on, a scheme to require all goods vehicles over 12 tonnes to obtain a safety permit before being allowed to operate in Greater London. It has now been confirmed that, subject to final approval, this will take effect on 26 October 2020, the same day that new, stricter emissions standards will apply to lorries in the Low Emission Zone (LEZ).
In this article, Richard Smith looks at how these safety permits can be obtained, the implications for goods vehicle operation and what operators need to do. A major caveat is that this article represents the state of affairs as it exists at the time of writing (October 2018); the necessary regulations will not be in place until sometime next year, so it is still possible that there may be changes.
As noted above, the permit requirement will come into effect on 26 October 2020 covering the area of Greater London and operating 24 hours a day 365 days a year — as for the LEZ.
The principal requirement for the issue of a permit will be that a goods vehicle over 12 tonnes complies with the new Transport for London (TfL) Direct Vision Standards (DVS) but there will also be a supplementary requirement to allow vehicles that cannot meet the DVS to continue operating. This supplementary requirement involves the vehicle complying with what is called the Safe System, based on the fitting of indirect vision devices and other safety equipment.
Exemptions from all or specific parts of the requirements will be permitted for certain types of vehicles.
Direct Vision Standard
The DVS rates goods vehicles over 12 tonnes on a scale of 0 to 5 stars based on how much the driver can see directly through the cab windows as opposed to through the use of indirect vision devices such as mirrors and cameras.
Vehicle manufacturers have been supplied by TfL with an approved technical protocol for the calculation of the DVS rating for Euro VI vehicles. To find out the star rating of their existing Euro VI-specification vehicle, operators will need to contact the manufacturer and provide details such as chassis number and date of build. TfL is currently working with manufacturers on the rating of older Euro IV and V vehicles and when this is finalised, the results will be available from the manufacturer in the same way as for Euro VI. However, since these vehicles will no longer meet the LEZ requirements after 2020, irrespective of their DVS, that might be a good time to replace them if not sooner.
TfL has released a set of interim DVS ratings for Euro VI trucks and these are said to be available at safertrucks.org.uk but at the time of writing, the server was not available.
The rating applies to the vehicle as it left the factory at first-stage manufacture. Vehicles built in stages will not be covered by the DVS rating, but the manufacturer should be able to help. If a vehicle has been subject to significant post-build modification that fact will need to be declared and it may be that it is not possible to obtain a star rating until a process to enable this is developed. Operators are advised to contact DVS@tfl.gov.uk for advice in this case.
Because of the wide variety of bodies and equipment that may be fitted to any given chassis, it will not be possible for manufacturers to quote a generic star rating for a vehicle range, only for a specific build. This means that operators making vehicle selection decisions will only be able to incorporate DVS into the decision-making process at a fairly late stage even though it will be part of the primary criteria.
If an existing vehicle has a DVS rating of 0, the alternative way to qualify for a safety permit will be to comply with the “Safe System”. This involves use of retrofittable safety measures designed to reduce the risks presented by large goods vehicles to vulnerable road users such as cyclists, motorcyclists and pedestrians. The Safe System builds on the existing Safer Lorry Scheme that requires such vehicles to be fitted with Class V and VI mirrors and side guards. As presently envisaged, it has three elements:
Blind spot elimination/minimisation — as in the Safer Lorry Scheme through Class V and VI mirrors or camera monitoring system.
Warning of intended manoeuvre — external audible left turn warning and pictorial stickers and markings.
Minimising consequences — side guards, again as in the current Safer Lorry Scheme.
As part of the system, it is also recommended (but not required) that drivers undergo specific training on the safety of vulnerable road users and the use and limitations of supplementary vehicle safety equipment. Such training may, of course, contribute towards the periodic training requirement for the Driver CPC.
The Safe System will be reviewed in 2024 to take into account new technology and safety equipment then available in the market for retrofitting but was not available in 2020. It will then become known as the “Progressive Safe System” and will include only retrofit equipment that is industry-recognised, and readily available on the market at that time. A possible interpretation of this is that equipment that was acceptable in 2020 may no longer be so in 2024 and it is not clear whether that would then mean the vehicle would no longer qualify for a safety permit.
Implementing the permit scheme
Permit issue will begin on 26 October 2019. One year later, any goods vehicle over 12 tonnes that does not have a safety permit will be banned from the LEZ. At this stage, the requirement for gaining a permit will be a DVS of at least 1 or compliance with the Safe System. From 2024 (exact date unknown as yet — possibly 26 October), vehicles will have to have a DVS of 3 or higher, or comply with the new Progressive Safe System that will be introduced that year.
At present no further information is available on either the application or enforcement process, though the permit is said to be free of charge and we can envisage the enforcement being integrated into the LEZ system.
What should operators do?
First, it has to be said that vehicles that do not enter Greater London will not be affected in any way by this, though operators are warned that the Mayor is lobbying for changes to the international regulations on vehicle safety and the European Commission is including consideration of Direct Vision for lorries in its review of the General Safety Regulation governing vehicle safety and design requirements.
Where vehicles do enter Greater London then the sooner operators start to plan for the safety permit the better. While not all the regulatory details are yet known, certain actions can be taken now. Permits will begin to be available in less than a year’s time and after that as the 2020 deadline nears both the TfL permit office and manufacturers may be expected to be extremely busy.
For now, operators should do the following.
Study TfL’s guidance on the safety permit at content.tfl.gov.uk.
Obtain from the manufacturer(s) a DVS rating for every Euro VI vehicle in their fleet.
For any Euro VI vehicle DVS rated as 0 and earlier spec vehicles that they intend to keep in service beyond October 2020, put in hand the fitment of such retrofit devices as may be necessary.
Where non-compliant vehicles can economically be replaced early then include DVS ratings in the selection process — remembering that in only five years the minimum acceptable DVS will be 3. An additional factor to be included in the consideration of relative costs will be that from October 2020 lower than Euro VI vehicles will be charged to enter the LEZ.
Apply for a permit as soon as possible after 26 October 2019.