Select Committee on Transport, Local Government and the Regions Appendices to the Minutes of Evidence


Memorandum by The Society of Motor Manufacturers and Traders Limited (RTS 140)

INTRODUCTION

  1.  The Society of Motor Manufacturers and Traders Ltd (SMMT) is the leading trade association for the UK motor industry. It represents some 600 member companies ranging from vehicle manufacturers, component and material suppliers to power train providers and design engineers. The motor industry is an important sector of the UK economy. It generates a manufacturing turnover approaching £50 billion and supports around 800,000 jobs.

  2.  The motor industry gives the highest priority to the safety of its products. It is fully committed to the progressive improvement of vehicle design and the standard and availability of safety equipment. The development of airbags (front and side), anti-lock braking systems and side impact protection are all contributing to improved safety for vehicle users. The industry is also committed to continuing its work to improve pedestrian protection.

  3.  The motor industry is committed to encouraging the responsible use of its products and welcomes the House of Commons Transport Committee's inquiry into the nature and effects of illegal and inappropriate speed in the UK.

THE ROLE OF SPEED

  4.  Illegal and inappropriate traffic speed is an important factor in the number of road accident fatalities and injuries. The quantification of this relationship is very difficult, because of the diverse and dynamic features involved in any accident. This includes the vehicle, the infrastructure, driver behaviour and the impact of environmental factors like weather, location and time.

  5.  The Government has placed increased emphasis on speed as a contributory factor in accidents. The introduction of speed cameras at accident black spots is widely supported and has produced some encouraging results. There is, however, some concern amongst user organisations that a focus on speed and reliance on camera technology may distract attention away from some of the other important factors that contribute to accidents.

  6.  The SMMT would recommend that further work be undertaken to establish more clearly the role of speed in accidents.

ADVERTISING STANDARDS

  7.  The use of advertising is an important element in the marketing of motor vehicles. The extensive use of broadcast and print media to inform customers and establish brand value has traditionally focused attention on the content of any advertising. To ensure that advertisers demonstrate and promote a responsible approach to driving the motor industry fully supports and complies with the ITC Code of Advertising Standards and Practice for motor cars and driving. This states that:

    (a)  No advertisement may encourage or condone dangerous, inconsiderate or competitive driving practices or breaches of the Highway Code.

    (b)  References to power or acceleration in advertisements for motor cars or automotive products must not imply that speed limits may be exceeded and there must be no accompanying suggestion of excitement or aggression.

  8.  A detailed guidance note on the interpretation of this rule covers compliance with the letter and spirit of the Highway Code, the use of foreign settings, off-road sequences, the use of fantasy sequences, speed and acceleration, racing and rallying and the demonstration of safety features.

  9.  The Advertising Standards Authority has also produced specific rules covering motoring. In most cases advertising copy and story-boards are submitted to the authorities to be checked before they are published.

ADVERTISING COMPLAINTS

  10.  Information available from the ASA indicated that during 2000 it resolved 12,389 complaints, of these 533 related to the motoring sector. An examination of all adjudications made during 2000 reveals that only three complaints related to concerns about the depiction of speed and in all cases the complaints were not upheld.

  11.  In 1999 the ASA conducted its own research to assess how well the industry followed the strict rules in the British Codes of Advertising and Sales Promotion. A total of 714 advertisements were examined and 650 (91 per cent) were considered acceptable. 50 were regarded as having technical breaches, (minor problems in otherwise acceptable advertisements) and only 14 (2 per cent) were regarded as having broken the codes.

  12.  The report concluded that, "These encouraging results show a continuing improvement in compliance in this sector. In particular, advertisers appear to be moving away from excessive claims of speed and performance and concentrating on issues such as safety."

  13.  A review of the number of complaints investigated by the ITC during 1999 and 2000 reveals that seven out of 302 were related to motor vehicles. Only two of the complaints were related to concerns about the portrayal of speed in the adverts.

  14.  The motor industry recognises its responsibilities to promote appropriate attitudes to the use of its products. It is convinced that the advertising codes provide effective regulation that balances the need for effective marketing with corporate social responsibility.

SAFETY PROFILE

  15.  Motor manufacturers have increased the prominence of safety features within their advertising. This recognises the importance that customers place on safety and the progress that industry has made. Vehicle manufacturers have invested millions of pounds on meticulously recorded "crash tests" in which vehicles are deliberately destroyed.

  16.  Some individual manufacturers alone carry out over 1,000 crash tests in any one year. All new models have to meet exacting safety regulations before they can be launched on the market. More stringent EU impact tests take effect over the next few years for existing models and any new models.

  17.  The results from the recent European NCAP (New Car Assessment Programme), which look at the comparative crashworthiness of new cars, confirm that new cars are offering increasingly higher occupants and pedestrian safety standards.

EDITORIAL COMMENT

  18.  There are a large variety of specialist and lifestyle publications that give significant prominence to motor vehicles. In assessing the responsibility of the motor industry the Transport Committee should clearly distinguish between advertising paid for and directly controlled by manufacturers and the portrayal of their products by third parties.

PEDESTRIAN PROTECTION

  19.  The motor industry has sought to progressively improve the safety protection offered by the vehicles it produces. It shares the Government's commitment to reduce the number of people killed or injured on our roads. The Government's safety strategy, Tomorrow's Roads—Safer For Everyone, has established action plans and challenging targets to reduce deaths and serious injuries by 40 per cent overall and by 50 per cent for children.

  20.  The European motor industry has been in discussion with the European Commission on measures that can be introduced to improve the protection offered to pedestrians. During 2001 the Commission reached a negotiated and binding agreement with the Auto Industry that would deliver significant benefits for pedestrians involved in collisions with motor vehicles.

  21.  The agreement provides for a first phase of passive safety improvements to new car models from October 2005 at the latest. These will require vehicles to meet the testing procedures recommended by the European Commission's Joint Research Council. These requirements represent demanding technical challenges for industry.

  22.  Under the terms of the agreement a review of further pedestrian safety measures will be conducted in 2004. This will determine a second phase of improvements that will be introduced from 2010. The motor industry is confident that the measures adopted in the second phase will ensure that the overall safety improvements for pedestrians are equivalent to or better than those claimed for proposals made by the European Enhanced-safety Vehicle Committee (EEVC-WG17).

  23.  In addition to the major changes to the design and structure of new vehicles from 2005, the industry has also committed to early action to introduce further active safety measures. The industry has undertaken to introduce Anti-Lock Brakes (ABS) as standard on all cars from 2004, it will not fit rigid bull-bars on new vehicles from 2002 and, if agreed, it will introduce daytime running lamps on all cars from 2003.

  24.  The agreement reached between the motor industry and the European Commission will ensure that safety improvement for pedestrians will be introduced up to 3 years earlier than would be the case under a legislative route. The industry believes that if the conventional directive route were chosen, the final requirement would not be known until 2003, which would mean an implementation date in 2008. Legislators have long recognised that vehicle manufacturers require up to 5 years to design, develop and test major changes to the body structure of a vehicle.

  25.  The UK Government and other EU member states have acknowledged the substantial benefit that early action would deliver and have given their support for the agreement, as reflected in a recent unanimous vote in the Council of Ministers; (an opinion of the European Parliament is awaited).

INTELLIGENT SPEED ADAPTATION

  26.  There is increasing interest across Europe in the use of advanced electronics to help reduce vehicle speeds. These systems have become known as Intelligent Speed Adaptation (ISA). These systems can be either totally vehicle based or involve communications between the road infrastructure and the vehicle. There are currently three levels of action being investigated.

    —  Information to the driver that the vehicle is travelling above the permitted speed.

    —  Information to the driver of elevated speed and accelerator pedal resistance, but with the driver able to override the system.

    —  Interference with the engine management/fuel systems of the vehicle to reduce the vehicle speed to the maximum permitted with the driver unable to override the system.

  27.  Many of these systems are currently at a relatively early stage of development. Only limited testing has so far been undertaken and the real world implications of such measures have yet to be fully evaluated. The motor industry believes that there is much work still to do and that it could take around 15 to 20 years for such equipment to become commonly available in all volume classes of vehicles, provided there is customer demand for them. Situations where some vehicles in use are equipped for the system when others are not could itself bring additional risk.

  28.  The industry also has concerns about the legal consequences of intervening in drivers' decision-making process. In the case of ISA three liability areas play a decisive part.

    —  Product liability.

    —  Driver liability.

    —  Public authority liability.

  29.  Today there is a clear allocation of responsibility in these three areas. Manufacturers are responsible for products, drivers for their behaviour and authorities for defects in public facilities.

  30.  Following the installation of an ISA system, the situation is far from clear. Since drivers do not possess full freedom of action they cannot be expected to bear the entire liability for possible consequences. The public authority as the operator of the infrastructure and transmitter of the signal is also a participant and must bear appropriate responsibility for any occurrence since the driver may have been able to avoid the accident by driving faster at the appropriate moment.

  31.  The motor industry recognises the potential that ISA systems may have for improving road safety. They remain at an early stage of development and further progress would require substantial investment from public authorities in ensuring that there was an appropriate road infrastructure and information systems available.

  32.  The scale of investment and likely timescale for the full availability of appropriate infrastructure and vehicles suggests that more may be gained in the shorter-term from improved driver information, safety improvements to the existing infrastructure and effective enforcement of the existing speed limits.

  33.  The European Motor Industry (manufacturers and component suppliers) is working through ERTICO with national road administrations to examine whether it is possible to devise a European speed limit database. Without such a database no ISA of speed information system is possible. At the moment complete information on speed limits on all roads throughout Europe does not seem to exist anywhere though some of the Scandinavian countries are working on this.

WORKING WITH GOVERNMENT

  34.  The motor industry is supporting the DETR's THINK! Initiative with manufacturers seeking appropriate opportunities to reinforce awareness of the campaign. In addition manufacturers undertake a variety of local and community based programmes to raise the awareness of road safety issues and promote responsible driving.

ROADSAFE

  35.  The motor industry recognises a wider road safety responsibility. Individual companies are involved in a wide range of community initiatives to raise awareness of safety issues and to promote responsible driver behaviour. In addition the SMMT and its members are key sponsors of RoadSafe.

  36.  RoadSafe is a new road safety partnership of leading companies in the motor and transport industries in Britain, the Government and road safety professionals. It aims to reduce deaths and injuries caused by road accidents and promote safer driving. It has grown out of the respected Prince Michael Road Safety Awards.

  37.  Chaired by former transport minister Steve Norris, it has HRH Prince Michael of Kent as its Patron. It is working to support the Government's Road Safety Strategy by developing initiatives in partnership to achieve specific casualty reduction targets. It brings together representatives from Government, the vehicle and component manufacturing and road transport industries, road safety professionals and the specialist media to work together to find new approaches to reducing casualties amongst vulnerable groups.

  38.  RoadSafe will concentrate on developing support programmes and initiatives to meet the following DTLR strategy objectives:

    —  Work with road safety professionals to ensure road safety resources are used in schools.

    —  Increase access to road safety materials via the Internet.

    —  Support professional development of those who deliver road safety education, publicity and training through NVQ in road safety.

    —  Develop schemes for better information and advice for older drivers and older driver assessment—and issue revised leaflet.

    —  Set up inter-agency group on work-related road risk.

    —  Continue to publicise the dangers of driving whilst using a mobile phone.

    —  Continue research into the accident risk of business and commercial drivers and effective counter-measures.

    —  Work with professionals to support guidance on road safety best practice.

    —  Raise drivers' awareness of vulnerable road users through better training and testing.

    —  DTLR will produce a campaign planning guide to help activists at local level to stimulate maximum news cover and business support.

CONCLUSIONS

  39.  The motor industry places the highest priority on safety and has made progressive improvements in the design and structure of its products.

  40.  The industry recognises that inappropriate speed contributes to road accidents. There is concern that existing information and analysis does not allow the accurate quantification of this link and more detailed research would provide a sounder basis for policy evaluation.

  41.  The agreement reached between the European Commission and the European motor industry will deliver significant benefits to pedestrians far earlier than would be possible by following a legislative route.

  42.  The further development of Intelligent Speed Adaptation systems has the potential to improve road safety. They remain at an early stage and there are significant technical and legal issues to overcome. In the meantime efforts should focus on measures where results are more certain.

  43.  The motor industry takes every care to ensure that vehicles and their use are appropriately represented in advertising materials. The industry strongly supports the existing regulatory regime, which has demonstrated effectiveness.

January 2002.



 
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