What if the HSE ran the DfT? part II

In the previous article I looked at the hierarchy of risk control and the sorts of things the HSE might expect to be considered when attempting to reduce risks for cyclists.

In this section we are going to get rather cold hearted I'm afraid. If we are to continue imagining how the HSE might approach the topic of road safety then we must familiarise ourselves with one of the basic characteristics of their method, 'reasonably practicable'.

We would like to prevent all road deaths however it would not be practicable to do so. You would either

• Have to ban all motorised transport.
• Spend an incredibly huge amount of money to prevent as many as possible.

The plain fact of the matter is that society doesn't value a life high enough to justify the amount of spending that would be required. When we say value, we mean just that, cold hard cash, a few years ago the HSE did some research and found that we're willing to spend just over £1m to prevent a fatality. Add in the other costs such as emergency services and loss of output and the figure we arrive at is £1,778,000 per non-motorway fatality. The cost of serious injuries is £208,000 and the cost of slight injuries is £22,000. These figures are known as the Value of Prevention of Fatality/Accident. It's a tricky concept, the HSE describes it as...

VPF is often misunderstood to mean that a value is being placed on a life. This is not the case. It is simply another way of saying what people are prepared to pay to secure a certain averaged risk reduction. A VPF of £1,000,000 corresponds to a reduction in risk of one in a hundred thousand being worth about £10 to an average individual. VPF therefore, is not to be confused with the value society, or the courts, might put on the life of a real person or the compensation appropriate to its loss

This spreadsheet kindly tells us how many cyclists are injured. Multiply it all together and the figure we arrive at is £1,067,746,000 quite a large number. I'm willing to agree that approximating a true VPA/VPF figure is very difficult, so if we strip out the guesstimated part for a minute leaving only the actual costs of cycling accidents we get the figure £292,849,372. Of course government doesn't bear all the costs of an accident but eventually 45% of everything flows through the government's coffers, which would be £131m of our £292m. So depending on which figures you choose it would be considered reasonably practicable to spend between £131m and £1.067bn on cycling infrastructure.

Alternatively the HSE might say an amount proportional to the quantity of cycling should be spent, this article says £13.4bn was spent on roads and we know that cyclists account for 1% of distance travelled which means spending should be £134m (remarkably similar to the figure of £131m above). However, the government is trying to encourage cycling so we might expect them to spend a disproportionately high amount on cycling. Rather than distance though we could use a time spent travelling equivalence, in the previous article I used 12mph average speed for bicycles and 30mph for cars, both guesstimates, but it bumps the spending requirement up to £335m, kind of in the ballpark of the £292m mentioned earlier.

Even the HSE might blanche at spending £1bn per year on cycle infrastructure but a lower bound of £130m up to £300m seems reasonable, or indeed, reasonably practicable.When you consider that an accident is money down the drain year after year, but infrastructure spending keeps giving back, year after year and that what is good for cyclist will also be good for pedestrians to an extent, then the figures look even better.

What if the HSE ran the DfT?

As someone who had some H&S training and responsibilities in a prior life I would like to apply some of that thinking to the cyclesafe debate.

The Health & Safety at Work Act 1974 (HASWA) sets out some basics, Wikipedia sumarises them pretty well...

Duties of Employers

• Provision and maintenance of plant and systems of work that are, so far as is reasonably practicable, safe and without risks to health;
• Arrangements for ensuring, so far as is reasonably practicable, safety and absence of risks to health in connection with the use, handling, storage and transport of articles and substances;
• Provision of such information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of his employees;
• So far as is reasonably practicable as regards any place of work under the employer’s control, the maintenance of it in a condition that is safe and without risks to health and the provision and maintenance of means of access to and egress from it that are safe and without such risks;
• Provision and maintenance of a working environment for his employees that is, so far as is reasonably practicable, safe, without risks to health, and adequate as regards facilities and arrangements for their welfare at work.

Duties of Employees

• Take reasonable care for the health and safety of him/herself and of other persons who may be affected by his/her acts or omissions at work; and
• Co-operate with employers or other persons so far as is necessary to enable them to perform their duties or requirements under the Act.

I hope that's fairly clear. For the purposes of comparison the employers is the authority in charge of the highway and the employee the user of the highway.

So the authority has to ensure the design, construction and maintenance of the highway is safe and the employee has to use it responsibly.

The next thing we would need to do is undertake a risk assessment. We know that ~3000 people die on the roads each year but it would be useful to know the rate at which they die to help us to know where to allocate resources.

This tells us how many deaths per billion vehicle miles, but due to greatly different average speeds it's not that helpful so by using some guesstimated average speeds I've converted it to an average based on time exposed to danger

• Pedestrians - 37 per billion miles at 3mph = 111 per billion hours
• Cyclists - 36 per billion miles at 12mph = 433 per billion hours
• Motorists - 3 per billion miles at 30mph = 90 per billion hours

From this we see that cyclists are the most at risk of the main different types of road user (this is comparative data, I'm not saying cycling is dangerous). We might then decide that protecting cyclists should be given a proportionately higher priority due to this higher risk.

Next we'd go on to look at how we might reduce the risk to cyclists for this we would turn to the hierarchy of risk control

The beady eyed amongst you might notice (with a wry grin) right away that PPE is at the bottom of the hierarchy, due to it's ineffectiveness and reliance on mitigation rather than prevention.

Let's briefly run down the hierarchy and try and apply its teachings to the public highway

Elimination
I don't think it is either desirable or practical to eliminate all motor vehicles from the highway but we could certainly eliminate some journeys, close off more roads from motorised traffic or even reduce available parking spaces. Alternatively it could mean the elimination of cohabitation, by providing roads for non-motorised vehicles we eliminate the hazard, we could call these cycle lanes!

Substitution

Through a system of positive and negative incentives people can be persuaded to change their mode of transport. A very simple example would be the tax system as money talks better than most incentives. 

• A positive incentive might be an incentive for using cycles while commuting as I have discussed previously
• A negative incentive might be an increase to the marginal cost of motoring by scrapping VED and applying the cost to fuel duty, this would raise the cost of a litre of fuel by 10p

I don't think it would make a huge difference but it would have an effect.


Engineering
This is probably where most of the work can be done, cycle lanes, redesigning junctions, traffic flows, traffic lights, good engineering solutions won't let people make mistakes. From the HSE's guidance

Separate the hazard ... by methods such as enclosing or guarding dangerous items of machinery/equipment. Give priority to measures which protect collectively over individual measures.

There we find something the HSE is very keen on collective protection, it's good because it is usually fit and forget, if you want to protect people working at height you fit safety nets rather than relying on individuals to use their fall restraint harnesses correctly. Similarly, you build a segregated cycle lane rather than relying on drivers not to hit cyclists and pedestrians.

Administrative & Behavioural
Begin with training, tell people how they need to behave, provide laws and regulations as a framework, then provide supervision and discipline. This comes towards the ineffectual end of the hierarchy because it is largely self policing, drivers aren't constantly supervised so we have to trust them to behave well.

Personal Protective Equipment
At the very bottom of the hierarchy is the thing so many people seem to think is the answer to cycling casualties. Here's what the HSE have to say about PPE 

Only after all the previous measures have been tried and found ineffective in controlling risks to a reasonably practicable level, must personal protective equipment (PPE) be used.

The two types of PPE associated with cycling are

1. Hi viz clothing. The need for hi viz clothing just proves all the other parts of the hierarchy have failed. The risk has not been eliminated, substituted or engineered away, the cyclist is still placed in a risky area, and administrative solutions have failed because drivers don't concentrate enough to see a cyclist not wearing hi viz.
2. Helmets. Anyone who suggests helmets are the primary way to prevent cyclist injuries has obviously never had their granny tell them prevention is better than cure. As a cyclist I'd rather not get hit in the first place than rely on a helmet to protect me. Unfortunately, because the risk hierarchy is almost never implemented by road designers, I do have to rely on one.

The other side to this is what the HSE calls reasonably practicable, would it be reasonable to spend X to prevent Y. Would it be reasonable to spend £1m to redesign a junction to prevent 1 cyclist death? I'll look at that next time.

Edit: Part II available here