Written evidence submitted by LensTech Company Limited (RSA0143)

 

The Transport Committee

Written evidence submitted by Lens-Tech Company Limited in regard to the Road Safety Inquiry.

 

Lens-Tech Co., is based in Southampton, UK and is the designer and manufacturer of Fresnel lenses for a range of products, including anti-blind-spot lenses, for an easy press-fit to a truck or van’s passenger window glass, to reveal and protect vulnerable road users in close proximity to the vehicle.

 

Countering the mirror blind-spot accident threat

 

  1. Recognised mirror blind-spots on commercial trucks and vans

 

  1. Improve driver view into mirror blind-spot zones to counter close proximity accidents between commercial vehicles and vulnerable road users (i.e. pedestrians, cyclists, motor cyclists and other small vehicles)

 

  1. Helpful commercial vehicle vision aids and strategies

 

  1. ‘At a glance’ visual acquisition speed versus visual acuity of a blind-spot hazard

 

  1. Proven mitigation of truck and van mirror blind-spot accidents over the last twelve years through the adoption of Fresnel (increased Field of View) lens use on commercial vehicles

 

  1. A Direct Vision Standard and Indirect Vision Devices

 

  1. Recommendation for action and consideration by the Committee

 

  1. Annex: References to information & relevant documentation

 

In more detail

  1. Due to the very high driving position in large trucks, a very limited field of view over the truck’s passenger window ledge is afforded to the driver and therefore it has long been recognised that dangerous close proximity visual ‘blind-spots’ exist which unfortunately cannot be brought into view through mirror reflection alone. Although in a different manner, a van driver’s vision is also restricted, not by height off the ground, but by the van’s side panelling, which again leaves a large mirror blind-spot, outwards and backwards from the van, starting just behind the passenger door’s window.
  2. Over the last 12 years, due in particular to two differing truck mirror blind-spot accident types, close attention has been brought to bear on vision aids that assist truck and van drivers. In the case of trucks operating in urban areas, the continually increasing number of left turning truck mirror blind-spot accidents, where cyclists in particular were killed or seriously injured, focused attention on a demand for increased visual devices to be fitted to trucks involved in city haulage.

2.1) The other common mirror blind-spot accident is known as a ‘sideswipe’ and this happens predominately on motorways when a truck makes a lane change manoeuvre without spotting a car which, at that moment, is positioned alongside the front of the truck cab, where it is completely hidden from mirror view.

  1. Visual devices introduced to counter the aforementioned mirror blind-spots include more and further improved mirror types, camera and monitor equipment, sensors and, in our case, self-adhesive Fresnel window lenses.

3.1) Truck mirrors are mandatory, well made and expensive although the kerb-side passenger over-door mirror’s reflected image is not easy for the driver to visually assimilate due to the fact that it’s inverted and elongated which makes for difficult driver appreciation.

3.2) Cameras provide good coverage into the mirror blind-spot zone, however visual appreciation of the images displayed on a monitor often prove difficult for the driver to quickly locate and comprehend without first averting eyes away from the window areas, especially during intensive ‘live’ and dynamic moving traffic situations. Dependence on electronic equipment alone is another aspect that also needs consideration, in case of power failure.

3.3) Passive, non-electronic, fail-safe Fresnel lenses offer an extremely economical visual solution that is well proven by the UK’s Department for Transport in trials completed by DVSA/(VOSA)and their Transport Research Laboratory (TRL), followed by repeated procurement through the Highways Agency and (during the last three years) Highways England, in order to counter strategic highway ‘sideswipes’.

3.4) Fresnel lenses are distributed by the RHA, FTA as well as many commercial vehicle parts resellers and have been championed by Transport for London (TfL), Transport Scotland, Highways England and the MOD.

  1. Whether driving an HGV or a van, speed of visual acquisition of any close proximity unseen hazard situated within a mirror blind-spot area is paramount. An ‘at a glance’ view of a vulnerable road user results in an immediate possibility for averting any danger.

4.1) Unfortunately, cameras and their monitors, while presenting an excellent image quality, actually cause a reduction in driver reaction time, due to the necessity for the driver to avert his gaze from the road in order to acquire the display screen and assimilate its picture, while managing a busy driver workload.

4.2) Fresnel lenses, on the other hand, are passive (non-electrical), quick and easy to press-fit inside the passenger window glass and economical. Most important of all though, the driver intuitively glances momentarily towards the passenger side window, the mirrors and the lens, when sensing a hazardous situation adjacent to his cab’s near-side. This extremely fast, ‘at a glance’ reaction time capability limits the driver’s workload with absolutely minimal need to avert the eyes from the road.

4.3) In summary, acquiring a lens or mirror view is considerably faster than the time it takes for a driver to locate a camera view from a display monitor situated in the cab. Furthermore, unlike a mirror, the Fresnel lens is non-reflective and therefore provides a, ‘through-the-lens’, non-inverted, wide angle view into the mirror blind-spot area. This entirely natural and direct, ‘eye to image’ view is easier for the human brain to comprehend and in turn quickens the driver’s decision making. This valuable, split-second, time saving can prove to be the difference between life and death.

  1. In 2006-7, following serious concerns regarding the consistently increasing number of ‘sideswipe’ accidents occurring on the UK’s strategic highways (motorways) predominately involving foreign LHD trucks, the Department for Transport tasked VOSA (now DVSA) with finding a method/device that would alleviate the truck mirror blind-spot and allow passing vehicles to be seen by the LHD truck driver before a lane change manoeuvre was attempted. VOSA decided that a specially designed Fresnel lens solution could remedy the problem and after detailed consultation with Fresnel lens manufacturers, a downward facing lens was designed that would provide an increased ‘Field of View’ so that the truck driver could see vehicles passing alongside the cab’s passenger door, in the adjacent lane.

5.1) In proving the case for Fresnel lens adoption, VOSA(DVSA) completed a major trial involving the production and issue of 40,000 lenses to foreign trucks entering UK through the major ports. Some months later the results of the trial were verified and the published report showed that during the trial period there was a 59% reduction in truck sideswipe accidents. On that basis, the case for Fresnel lenses as an important and effective anti-blind-spot visual aid was proven.

5.2) Throughout the last decade Fresnel lenses have continued to be regarded as the best and most economical method of ensuring that sideswipe accidents are reduced to a much lower level and indeed statistical records concerning ‘killed and seriously injured’ (KSI) involving truck lane changing accidents, positively reflect that fact.

5.3) Subsequently, Fresnel lenses were adopted by Transport for London (FORS) and very effectively used in countering left hand turning and other nearside truck ‘blind-spot’ accidents, involving vulnerable road users in London. The value of Fresnel lens adoption as a RHD truck anti-blind-spot vision aid, was further recognised by Crossrail during their various construction phases when they decided that trucks operating in London, as their contractors, were obliged to fit Fresnel lenses in order to gain entry to their sites as hauliers for deliveries and collections.

5.4) Further endorsements of note include contracts being awarded for Fresnel lens issue to truck operators in order to promote vulnerable road user, city-wide, safety initiatives, (for pedestrian & cyclist protection) by the likes of Transport Scotland. Likewise, Highways England, the Ministry of Defence, the Road Haulage Association & the Freight Transport Association all procure lenses for fitting to UK trucks and vans.

  1. A Direct Vision Standard (DVS) in regards to Heavy Goods Vehicles (HGV)is being advanced at European and Worldwide level (UNECE), which in turn seeks to identify Indirect Vision Devices that can be utilised as an acceptable aid to driver direct vision (i.e. direct driver eye view to the road through window glass).

6.1) Acceptable Indirect Vision Devices will most likely include mirrors, cameras and monitors, Fresnel lenses and other such driver visual aids.

  1. Based upon the evidence gained over the last 12 years on the effectiveness of Fresnel lenses, the latest of which enable an additional 30° downward view below the truck’s window ledge or a 30° back and outwards view behind a van’s side panelling as well as an easy, peel-back self-adhesive press-fit capability, we humbly request that the committee seriously considers recommending that the Government moves to adopt the fitting of Fresnel lenses to certain commercial vehicles as a mandatory Indirect Visual Device (or at least, as an advised Indirect Visual Device), to counter mirror blind-spot zones effecting trucks and vans.

May 2019

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  1. Annex:

References to information & relevant documentation

8.1) Information: Lens-Tech Co                                                                       Fresnel Lens Slide Presentation - 2018                                                                         http://www.lens-tech.com/UserFiles/File/1-FresnelLens-Tech-Slide.pptx

8.2) Report: US Department of Transport (DoT) –                                                                                                                                  Safe Fleet Transition Plan – Extract 2017                                                                                                                                                                                               http://www.lens-tech.com/UserFiles/File/1-VOLPE-LaunchingSafeFleetTransitionPlan.pdf

8.3) Report: Coroner’s Regulation 28 –                                                     To Secretary of State for Transport                                                                                 To Prevent Future Deaths - 2016                                                                  https://www.judiciary.uk/wp-content/uploads/2017/01/Sinnaiah-2016-0264a.pdf

8.4) Information: Highways England                                                             Fresnel Lens Contract – Department for International Trade - 2016 https://www.great.gov.uk/trade/case-study/643/lens-tech-uk-supply-hi-vu-fresnel-lens-to-highways/

8.5) Report: US Department of Transport (DoT) –                                                                                                                                    Safer Truck – Extract 2016                                                                                                                                              http://www.lens-tech.com/UserFiles/File/1-VOLPE-Cambridge-zExtractSaferTruck2016.pdf

8.6) Report: UK Department for Transport (DfT) –                                           Drivers Direct & Indirect Vision – Extract 2010                                                                               http://www.lens-tech.com/UserFiles/File/1-DfT-Phase1report-FinalversionP143-147.pdf

8.7) Report: UK Transport Research Laboratory (TRL) –                                       Vehicle Blind Spot Trial - 2009                                                                                  http://www.lens-tech.com/UserFiles/File/TRLreportPPR403-21.pdf

8.8) Information: UK Department for Transport (DfT) -                                                 VOSA truck blind spot video – 2008 https://www.youtube.com/watch?v=Bp5LfxcM1s4

 

8.9) Report: Select Committee on Transport - Parliamentary Business                          Memorandum from Freight Transport Association (FTA) – 2008                                   Highway Authority Initiatives – Distribution of Fresnel lenses by VOSA : See No: 5.  Targets for road accident casualty reduction: https://publications.parliament.uk/pa/cm200708/cmselect/cmtran/460/460we26.htm

8.10) Information: BBC News Channel -                                                                        Truck Lens for Spotting Cyclists – 2008 http://news.bbc.co.uk/1/hi/england/london/7290900.stm

8.11) Information: Daily Telegraph –                                                                       EU law preventing mandatory Fresnel lens fitting - 2008                                            https://www.telegraph.co.uk/news/uknews/road-and-rail-transport/3814352/EU-laws-stop-UK-Government-from-making-foreign-lorries-carry-safety-mirrors.html

8.12) Information: Transport for London (TfL) – London Cycling Campaign                                                                              Fresnel lens campaign – 2008                       https://lcc.org.uk/articles/lcc-says-well-done-tfl-for-fresnel-lenses-campaign-but-government-must-move-faster-on-implementing-eu-safety-mirrors-legislation