BIBA response to ‘A Safer Way’ consultation on making Britain’s Roads the safest in the World

15th July 2009

The British Insurance Brokers’ Association (BIBA) is the UK’s leading general insurance organisation representing the interests of insurance brokers, intermediaries and their customers.

BIBA membership includes 1700 regulated firms. Insurance brokers and intermediaries distribute nearly two-thirds of all UK general insurance. In 2007, insurance brokers and intermediaries generated £1.5 billion of invisible earnings and they introduce £22 billion of premium income into London’s insurance market each year.

BIBA is the voice of the industry, advising members, the regulators, the Government, consumer bodies and other stakeholders on key insurance issues.  BIBA provides unique schemes and facilities, technical advice, guidance on regulation and business support and is helping to raise, and maintain, industry standards. BIBA works closely with the Chartered Insurance Institute to provide training to those working in the industry and actively participates in helping the industry and its customers deal with some of the major issues of the day.


BIBA members provide professional advice to businesses and consumers, playing a key role in identification, measurement, management, control and transfer of risk.  They negotiate appropriate insurance protection tailored to individual needs and operate to a very high standard of customer service with the aim of ensuring peace of mind, security, financial protection and the professional advice required.


Our responses to the 20 questions set out are as follows:


           1. Do you agree that our vision for road safety should be to have the safest roads in the world.


2. Do you agree that we should define a strategy running over twenty years to 2030, but with review points after five and ten years? (Chapter 3)

3. Do you agree that our targets should be to reduce:

·       road deaths by at least 33 per cent by 2020 compared to the baseline of the 2004–08 average number of road deaths;
Do not disagree.

·       the annual total of serious injuries on our roads by 2020 by at least 33 per cent;
Do not disagree.

·       the annual total of road deaths and serious injuries to children and young people (aged 0–17) by at least 50 per cent against a baseline of the 2004-08 average by 2020;
Do not disagree.

·       by at least 50 per cent by 2020 the rate[1] of KSI per km travelled by pedestrians and cyclists, compared with the 2004–08 average? (Chapter 8)
Do not disagree.

4. We are proposing a set of indicators in order to help us to monitor performance   (Appendix A). Do you believe these cover the right areas? (Chapter 8)
Do not disagree.

5. We have identified a number of factors that may affect our ability to deliver road safety improvements in the future world we are planning for. Do you think we have taken account of the key risks and opportunities? Are there others you would add? (Chapter 3)    

No. We don’t think you have taken into account all of the key risks and opportunities.

High level of migration/immigration is a factor people used to driving on the right hand side of the road and with different attitudes and knowledge must be considered in the overall drive to deliver road safety improvements, also in some European countries roads coming in from the right have priority. In 2008, just over 18,000 foreign Vehicles were involved in accidents in the UK.

Geography – certain road junction are very dangerous, other due to the geography of the area, there accident “blackspots� must be dealt with which may involve major work to some area of land.


6. We think that the key challenge for road safety from 2010 is better and more systematic delivery, rather than major policy changes. Do you agree? (Chapter 4)

No, a major policy change on learner and inexperienced driver training is necessary, these areas should be introduced into the driving test:


– Hazard Perception training

– Attitude awareness

– Situated Judgement

– More relevant tests (eg. Night, Bad weather)


We also propose a review where more elderly drivers may be required to pass certain tests to ensure continued safe driving.


7. This consultation document sets out the current evidence on the key road safety challenges. Do you agree with our analysis? Would you highlight any others? (Chapter 2)


We agree with the evidence.


We agree with the analysis.


Your document point 33 refers to 160 people killed and 23,000 injured every year and this challenge is included. You also refer to your Think campaign, however despite these frightening numbers there has never been a campaign for uninsured drivers, we strongly urge the government to start an immediate campaign about the danger of driving uninsured, along with it’s illegality.

8. We are proposing a number of measures to support the effectiveness of the road safety profession. Do you think they will be effective? What else might need to be done? (Chapter 4)


No Comment.


9. Do you agree that an independent annual report on road safety performance, created on an annual basis, would be a worthwhile innovation? (Chapter 4)




10. Do you agree that the Road Safety Delivery Board should be tasked with holding Government and other stakeholders to account on the implementation of a new national road safety plan? (Chapter 8)




11. Do you agree that highway authorities reviewing and, where appropriate, reducing speed limits on single carriageway roads will be an effective way of addressing the casualty problem on rural roads? Are there other ways in which the safety of rural roads can be improved? (Chapter 5)


Yes, providing this is a test of reasonableness where a benefit can be proved and it is not perceived as an exercise of making money from speed cameras. 


Improving the layout of certain road and junction would be beneficial and rural roads should have a white line in the centre where possible to discourage people driving down the middle of the road which is the cause of many accidents/ Insurance claims.


The inclusion of ‘cat’s eyes’ style reflectors on rural roads would also improve safety.


12. How can we most effectively promote the implementation of 20 mph zone schemes in residential areas? What other measures should we be encouraging to reduce pedestrian and cyclist casualties in towns? (Chapter 5)

Clear appropriate signage. More cycles lanes so cyclists don’t have to share the road with motor vehicles or the pavement with pedestrians. However, rather than a unilateral 20mph limit we believe each site should be considered on its merits by a factoring process.


13. How can we provide better support to highway authorities in progressing


Co-operation with local authorities and police force who can identify specific black spots. 


14. What should Government do to secure greater road safety benefits from vehicles?


Take heed of the advice from Thatcham (the Motor Insurance Repair and Research Centre.)  Specifically regarding Electronic Stability Control, seat and head restraint safety and safe vehicle repair. 


15. Do you agree that, in future, crash avoidance systems will grow in importance and will have the potential to greatly reduce casualties?

No Comment as insufficient information.


16. How can we best encourage consumers to include safety performance in their purchasing decisions?


Support the EURO-N-CAP rating system and promote the issues with a government supported PR campaign.


17. We have highlighted what we believe to be the most dangerous driving behaviours. Do you agree with our assessment?

No, there appears to be too much emphasis on speed for every scenario, rather than driving too close. We would argue driving at, in excess of 70mph on a completely clear motorway is far less dangerous than a line of cars tailgating at 40mph on a packed motorway.


Time and space are essential in order to allow the driver to process information and to adjust his or her driving accordingly. It would be important to examine motorway / dual carriageway speed-related incidents to establish if the real cause was lack of vision & time due to tailgating. We suggest a publicity campaign to promote concerns are tailgating once this examination of the speed related incidents is concluded.             


18. What more can be done to persuade the motoring public that illegal and inappropriate speeds are not acceptable behaviours?


Further education in the driving test and a more young driver targeted campaign – eg. a digital marketing campaign on sites like max power. Better education on road safety like occurs at schools in France would be beneficial.

Ensure any offender can be ‘named and shamed’ waiving any right to anonimity. 


19. What more can be done to encourage safe and responsible driving?


Greater Penalties for uninsured and unlicensed drivers, the current penalty regime is inadequate. A major promotional campaign promoting tangible benefits eg seizure of uninsured vehicles need to take place.    


20. Should more be done to reward good driving? If so, what?

The No claims bonus system already exists for private vehicle keepers’ premiums are directly linked with claims and so the fewer the claims, the lower the premium. Any Government support with this message would be beneficial. This benefit could be included in any Government campaign.


Thank you for taking the time to consider our response. If you have any further queries please contact Graeme Trudgill, BIBA’s Technical and Corporate Affairs Executive for further information on 02073970218 or on [email protected] or Steve Foulsham, BIBA’s Technical Services Manager on 02073970234 or [email protected] or Peter Staddon, Head of Technical Services on 0207 397 0204 or [email protected]


Yours faithfully





Eric Galbraith

Chief Executive


Direct Tel:  020 7397 0201

Direct Fax: 020 7626 9676