Memorandum by The Society of Motor Manufacturers
and Traders Limited (RTS 140)
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
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
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.
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
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.
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
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
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.
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.
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 RoadsSafer 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
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
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).
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
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
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
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.
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
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
38. RoadSafe will concentrate on developing
support programmes and initiatives to meet the following DTLR
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 assessmentand
issue revised leaflet.
Set up inter-agency group on work-related
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.
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.