Mobiles on the move

Government proposals to tackle the increasing use of mobile phones by drivers will have implications for many employers, reports Howard Fidderman.

In a notable U-turn, the Department for Transport (DfT) is consulting on the introduction of an offence that would prohibit the use of any hand-held mobile phone or similar devices by drivers.1 Employers should note that the DfT intends that the offence will apply when anyone "causes or permits" the use of a hand-held mobile: "This should make it clear to employers that they cannot expect their employees to use a hand-held phone while driving," insists the DfT. Consultation will close on 25 November; the DfT plans to bring the legislation into effect in early 2003.

The Government's 2000 road safety2strategy recognised that mobile phones, while bringing benefits, are also a "real risk to road safety" and that "too many drivers are using their phones while on the move". Nevertheless, it rejected calls for specific legislation on the grounds that the police already had the powers to prosecute drivers who created risks by using a mobile phone while driving:

  • under reg. 104 of The Road Vehicles (Construction and Use) Regulations 1986.3 This prohibits people from driving a car on the road if they "cannot have proper control of the vehicle or have a full view of the road and traffic ahead". The offence carries a fixed penalty notice of £60 or, on conviction, a maximum fine of £1,000 (£2,500 for goods vehicles or vehicles adapted to carry eight or more passengers). Following a wide-ranging consultation exercise, the Government announced on 24 July 2002 that it would make reg. 104 an endorsable offence. The report on the consultation noted that "the most popular proposal for creating an endorsable offence was for use of mobile phones";4

  • for careless or inconsiderate driving, which can result, on conviction, in points on the driving licence and a fine; or

  • dangerous driving, which can lead to endorsement, disqualification or imprisonment.

    The case for a new offence

    The DfT has decided that there is now a case for specific legislation to ban the use of hand-held mobiles on two grounds:

  • the use of mobiles while driving is increasing; and

  • the research shows that such use presents significant risks.

    The risks of using a phone have been known about for almost as long as there have been phones in cars. In 2000, an independent expert group, chaired by Sir William Stewart, published a substantial review of research into the health effects of mobile phones.5 A small part of the report examined their use while driving, noting that: "Epidemiological studies provide compelling evidence that engaging in a mobile phone conversation impairs driving performance. Consistent with this evidence, epidemiological research points to an association between mobile phone use while driving and an increased risk of involvement in an accident."

    A 2002 report compiled by RoSPA for the DfT, which appears to have been important in persuading ministers to reverse their position,6 also reviewed dozens of pieces of research and came to similar conclusions (see box 2). In addition, the report summarised 19 cases reported in the UK press between 1988 and 2001 where deaths could be attributed to the use of mobiles while driving.

    The DfT's consultative document reaches a similar conclusion to the Stewart and RoSPA reports: "There is a comprehensive body of research into the effects of mobile phones and driving. There is strong experimental evidence that engaging in a mobile phone conversation impairs the ability to react to potentially hazardous road conditions.

    Consistent with the experimental evidence, epidemiological research points to an association between mobile phone use while driving and an increased risk of involvement in an accident." It points, for example, to 1997 and 2001 Canadian research that suggests the risk of a collision quadruples during the call and extends in a reduced form for several minutes after termination.

    Mobile use up

    The turning point for the Government, however, stems from the recognition in its 10-year road strategy that it would need to review the need for specific legislation "should we fail to persuade" people not to use mobile phones while driving. The DfT subsequently conducted four surveys between November 2000 and April 2002 that showed that the percentage of drivers using a mobile at the time of observation rose steadily from 1.5% to 2.2%, despite Government publicity campaigns since 1998 and pressure from safety organisations. The vast majority of such use is hand-held. The RoSPA report cites two studies showing that 37% and 39% of drivers use mobiles at some time while driving. The situation appears to be far worse among company car drivers: one of the studies - carried out by the RAC7 - found that over three-quarters of company car drivers used a mobile while driving.

    A more recent study, from Godfrey Davis (Contract Hire) Ltd - not covered by RoSPA - found that 73% of company car drivers had a hands-free phone in their car, and 18% a hand-held phone. Among hands-free users, 47% frequently took or made calls while driving, 40% occasionally, 10% infrequently and only 3% said they would never do so. Drivers with hand-held phones used them far less: 44% would never take or make a call; only 6% did so frequently, 20% occasionally and 29% infrequently.

    The DfT research revealed a gap between what drivers believe and what they do: seven in 10 drivers "consider it unacceptable to use a mobile phone while driving", although many admit to doing so, and only a quarter said they would never answer a call while driving. The DfT also cites a survey that found nine in 10 people agreed that there should be a ban on hand-held use while driving.

    It is also clear, albeit unacknowledged, that the Government is responding to pressure over the past three years from politicians and campaign groups such as RoSPA. There have been attempts in parliament to enact such a ban before. Lord Davies of Oldham, who is the President of RoSPA, secured a second reading for his Bill in the House of Lords in July 1999;8 most recently, Janet Anderson introduced a Bill in the Commons in November 2001.9 Unfortunately, they have all been private members' Bills, rather than Government initiatives, and have all failed due to lack of parliamentary time and Government support.

    THE NEW OFFENCE

    All in all, things have now reached the point where the DfT "is concerned that too many drivers are using their phones while on the move". It adds that, "with the increase in ownership of mobile phones, the indications are that a significant number of drivers are ignoring the risks. In the circumstances, the Government has decided that a specific prohibition may now be necessary."

    The DfT's proposed offence will make the use of a hand-held mobile phone while driving a specific offence under The Road Vehicles (Construction and Use) Regulations 1986. The offence will cover hand-held devices that permit two-way communication. This applies whether the medium is through speech or other forms of data, such as text messages, or via other types of devices - for instance, radio microphones. However, it will not affect in-vehicle equipment that supports driving.

    The DfT states that it "does not consider that the phone needs to be physically held in a driver's hand in order to commit an offence. This would prohibit the use of hand-held phones used with an earphone and microphone whether using a wire, or wireless, connection. Even though they can be used 'hands-free' to some extent, these still require the user to hold the phone in order to press buttons or to read a message on the phone's screen. Nor should a driver escape prosecution because a phone was being held to the ear by other means (for example, a shoulder)."

    Scope of the offence

    The offence will extend to drivers of all motor vehicles on any road to which the public have access in Great Britain (ie not Northern Ireland). The offence would apply in all circumstances other than when a vehicle is parked with its engine switched off; using a mobile when stopped at traffic lights or in a traffic jam would still be an offence.

    The DfT's initial view is to reject the use of exemptions from the offence, even for:

  • the police and the emergency services to use hand-held phones if necessary and in the course of their duties - they can, claims the DfT, always use hands-free phones instead; and

  • "very short-term" use, such as to tell the caller to "hold on while I stop".

    The offence will not, however:

  • require mobiles to be switched off while driving. This would, the DfT says, be difficult to enforce;

  • apply to anyone who calls a mobile that is answered by a person driving at the time, although it is not clear whether or not this is consistent with the DfT's intention to apply the offence to employers that "cause" the use of a phone while driving;

  • restrict passengers' use of a mobile (unless they are holding it for a driver); or

  • affect the ability of bus and coach drivers to use a microphone to make emergency announcements.

    HANDS-FREE SETS

    The most questionable aspect of the DfT's proposals is the decision to exclude hands-free phones from the new offence. Such a move would be consistent with nearly all of the 34 countries identified by RoSPA that have laws banning the use of hand-held mobile phones while driving. Of these, only Portugal also bans hands-free use. In addition to the 34, New Delhi bans hand-held and hands-free use, and six states in the US have partial or total bans on hand-held use. A further three countries and 39 states in the US are considering legislation.

    By hands-free, the DfT means a phone that does "not require the driver to significantly alter their position in relation to the steering wheel in order to use it. It should be permanently wired into the vehicle and use one or more speakers permanently fixed in the vehicle; or be plugged into a unit in the vehicle (commonly a cradle in the dashboard) thereby directly connecting it to fixed speaker(s) in the vehicle".

    The DfT's proposed exclusion of hands-free sets, however, runs contrary to the research evidence. The Stewart report noted that: "Current experimental evidence suggests that there is little or no justification for the assumptions that the detrimental effects of phone use on driving are ameliorated by hands-free operation, a conclusion supported by the limited epidemiological evidence relevant to this question. There is therefore no strong empirical justification at present for the enactment of a policy or legislation that differentiates between the use of hand-held and hands-free sets in motor vehicles."

    Cognitive demands

    The Stewart report's observations on hands-free use reflect the cognitive demands of a telephone conversation, rather than just the physical operation of a phone. "There is little point in stressing the inadvisability of using hand-held phones if the greater part of the associated risk is also present when hands-free equipment is used." The RoSPA report similarly noted that although hands-free phones can reduce physical distraction, and that voice-activated systems and speed dialling reduce the time required for dialling numbers, "these systems still cause substantial cognitive distraction, resulting in significant driver impairment".

    The Government's 2000 road safety strategy noted that: "use of hand-held sets reduces both control and attention." The DfT claims it "recognises" research showing that using a hands-free phone is distracting and increases the risk of an accident. It believes, however, that to include hands-free use would be "largely unenforceable" and that it would therefore be impractical to include such use in the scope of its proposals. This position was foreseen by the Stewart report: "While an argument might be made for focusing on legislation on the more detectable of these two modes of use - it is of course much easier to detect the use of a hand-held set than a hands-free set - such an approach runs the risk of seeming to condone, or at least to tolerate, the use of hands-free phones." In short: "We conclude that the detrimental effects of hands-free operation are sufficiently large that drivers should be dissuaded from using either hand-held or hands-free phones whilst on the move."

    And, to an extent, this is the DfT's strategy. The Highway Code,10 revised in February 1999, states that: "You must exercise proper control of your vehicle at all times. Never use a hand-held mobile or microphone when driving. Using hands-free equipment is also likely to distract your attention from the road. It is far safer not to use any telephone while you are driving - find a safe place to stop." A 2000 Government campaign and leaflet includes similar sentiments (see box 3).11

    Advice from the AA and RAC on hands-free use is more flexible, but adheres to the same principles (see box 4). The Road Haulage Association (RHA) supports the offence, as proposed. Chief executive Roger King said: "For some while, we have been advising operators to inform their drivers of the dangers of using a hand-held mobile phone while driving and to take steps to ensure that such activity is discontinued." But he cautioned: "Communication between the driver and his operating base is absolutely essential to maximise the efficiency of modern transport logistics. Trucks have, for years, used CB radios, which have largely been superseded by the mobile phone. The RHA believes that installation of a properly engineered hands-free system, provided it is used responsibly, does not constitute a road safety hazard." The RHA also believes that where a company has trained its drivers on the use of hands-free telephones, the employer should not be liable for any consequent misuse.

    Should eating while driving be banned?

    Many of the opponents of a ban on mobile phones question the singling out of mobile phones from other driver distractions. The AA disputes that a specific law is necessary. Bert Morris, the AA's public policy manager, says: "There are many other in-car distractions that can be just as dangerous as talking on the phone. We cannot have a law banning the use of mobiles without one to ban eating, smoking, drinking, applying make-up or shaving for that matter." The law, he said, needs to be clear that all are "potential killers". In 1999, the Association of Chief Police Officers displayed a similar obsession with food. Claiming that existing legislation was sufficient, it added that specific legislation could weaken the police's ability to prosecute similar offences - such as eating while driving.

    Lord Carter, in a 1999 House of Lords debate, claimed: "Research cannot tell us the level at which any of these or similar activities causes enough distraction to cause an accident, and that is why it is better to have a blanket power to tackle all of them, rather than singling out one type of activity for special legislation."8 This view was supported a year later by Lord Whitty, then the roads minister, who told the House of Lords that, in addition to the use of mobile phones, "it is also true that equivalent problems such as eating, combing one's hair and generally waving one's arms about can equally lead to a loss of control. That is why the police believe that those general powers would cover the use of mobile phones." He cautioned, however, that: "I accept the advice of the police for the moment. We will see whether their powers prove to be adequate."12

    There is no dispute that there are many other in-car distractions for drivers. In terms of equipment, the Highway Code points out that, in addition to mobiles: "There is a danger of driver distraction being caused by in-vehicle systems such as route guidance and navigation systems, congestion warning systems, PCs, multi-media etc. Do not operate, adjust or view any such system if it will distract your attention."

    The arguments appear to focus on the value and extent of such distractions, and whether or not the law could in any case adequately deal with them. For example, we have seen earlier that the new offence "will not affect in-vehicle equipment that supports driving"; nor would it be practicable - let alone desirable - to ban conversations with passengers in a car.

    There is also limited comparative research into the extent of various distractions. The Stewart report noted that experimental evidence showed that: "The impairment [created by using mobile phones while driving] appears to be greater than that associated with merely listening to a radio or engaging a relatively 'automatic' task such as repeating back words heard over the phone; is evident during a casual conversation; increases along with the mental workload imposed by the conversation; is greater in elderly drivers; and is unaffected by mode of phone use (hand-held versus hands-free)."

    But none of the studies reviewed by the Stewart report looked at the effects on conversation with a passenger. "Thus it remains to be established whether an in-car conversation that places a cognitive load on the driver equivalent to that imposed by a mobile phone call has similarly detrimental effects on performance." The report adds that there are good reasons to believe the effects will be less: a passenger can monitor the road situation and pace the call accordingly, as well as offering a second pair of eyes. The Government's 2000 road safety strategy added that "conversations in cars and listening to the radio are not necessarily distracting".

    Effect on employers

    The DfT's attempts to estimate the costs and benefits of introducing the proposed offence are flawed by the fact that it does not know how many road accidents involve mobile phones. Instead, it gives as an example a total of £112.38m saved if 1% of all road accidents were prevented by the new law (see table 1 below). Abroad, only Japan can provide statistical evidence as to the effect of a ban. This covered the 12 months immediately before and after legislation was introduced and found that the numbers of traffic accidents and people injured in traffic accidents with drivers using a mobile phone both fell by half. Fatalities fell by 20%. Clearly, employers and their insurers would share some of the benefits from such a reduction.

    Table 1: The Value of Avoiding Road Accidents16

    Type of road accident

    Value of avoiding

    Single accident

    1% of all accidents

    Fatal injury

    £1.1m

    £37.4m

    Serious injury

    £129,000

    £47.73m

    Slight injury

    £10,000

    £27.25m

    Damage only

    £1,400

    n/a

    Total

    n/a

    £112.38m

    The police already carry out some enforcement in respect of the use of mobile phones while driving. Extrapolating the results of two police campaigns in the UK on mobiles in 2001 to all 51 forces, it calculates that the current legislative provision could result in 40,000 fixed penalties annually. The proposed offence would result in higher levels of enforcement; the experience of seatbelt legislation allows the DfT to estimate that the new offence could result in 100,000 fixed penalty notices each year and 5,000 prosecutions. Given that some studies have revealed company car drivers as showing a disproportionately high tendency to use a phone while driving, employers (or their staff) would expect to pick up the tab for such offences.

    Unfortunately, the report does not cover costs for employers. For example, it excludes the costs of dashboard mounting (between £100 and £300 per car) because it sees this as a separate issue and the DfT does not, in any case, want to be seen to advocate the use of hands-free mobile phones while driving. Nor does it cover the financial and other benefits that employers would receive if the proposals resulted in fewer road accidents among their staff.

    Employers will, in any case, need to address the issue of mobile phones and driving as a result of moves by the HSE to implement the recommendations of the Government's Work-related Road Safety Task Group (see box 5). As a first, they will need to ensure that mobile phones are covered in their driving policies. Information on company driver policies is scant: RoSPA surveyed 54 large companies it thought likely to have mobile phone policies, but received just 17 replies, 14 of which had policies on the use of mobile phones while driving. RoSPA reports that the 14 were aware of the risks of being involved in an accident when using a mobile and the legal implications. Although the policies varied, "there were strong similarities overall". Nearly all banned hand-held use while driving; some required the phone to be switched to a message service, with the messages accessed only when parked.

    Many companies, however, also provided hands-free kits to enable staff to use phones under limited conditions while driving. This suggests, claims RoSPA, that employers "believe the risks can be managed in some circumstances. Or they may be balancing the risk against the business needs of the company and concluding that the risk of using hands-free phones is not sufficiently large to completely ban their use while driving".


    Box 1: The important questions for consultation

  • Should there be a specific offence to ban the use of hand-held mobile phones by drivers?

  • Should the proposed offence exclude hands-free phones?

  • Should there be any exemptions from the proposed offence?

  • Should the offence be subject to penalty points and discretionary qualification?


    • Box 2: The RoSPA Research

    The DfT's consultative document refers to research that was commissioned and funded by its predecessor, the Department for Transport, Local Government and the Regions. The research, which was carried out by the Royal Society for the Prevention of Accidents (RoSPA), reviews dozens of studies since 1969. The results are not always one-way traffic; some, for example, found that drivers could partially compensate by increasing their levels of concentration. Overall, however, the report concludes that using a mobile phone while driving impairs driving performance in terms of:

  • maintenance of lane position;

  • maintenance of appropriate and predictable speed;

  • maintenance of appropriate following distances from vehicles in front;

  • reaction and braking times;

  • judgment and acceptance of safe gaps in traffic; and

  • general awareness of other traffic.

    RoSPA stresses that much of this research has looked at hands-free phones, concluding that they "still distract drivers and impair safe driving ability". This applies even when driving automatic cars.

    RoSPA points out that that there is less evidence that using a mobile phone while driving increases the risk of an accident. This is mainly due to failure to record whether drivers were using a mobile at the time of an accident. Even so, it concludes there is enough evidence from epidemiological studies and crash reports to conclude that drivers who use mobile phones while driving have higher accident rates than those who do not. For example:

  • a 1997 study of 699 drivers in New England looked at their mobile phone records on the day of the accident and the preceding week, and concluded that the risk of a collision was four times higher when using a hand-held or hands-free phone than when not using one;

  • a 1997 review by the US National Highway Traffic Safety Administration of the US's fatal accident reporting system and police reports identified the use of mobile phones as growing factors in crashes. In Oklahoma - one of only two states that records the presence of mobiles in cars - found that 10% of the mobile phones present in vehicles were being used at the time of the crash;

  • a 1998 study of 223,137 traffic accidents in the US found a mobile phone in 4% of the vehicles involved in a fatal accident. Furthermore, 8% of drivers were using the phone at the time of the crash. Drivers using a mobile were nine times more likely to be involved in a fatal accident than drivers who did not; and

  • RoSPA's own collation of press reports shows 20 fatal accidents where the use of a mobile phone by a driver was reported to have been a factor.

    RoSPA adds that other reviews, conducted mainly in the mid-1990s, reached similar conclusions. Of particular interest is the Stewart report on the health effects of mobile phones. This concluded that: "There is one substantial established risk to health from mobile phone technology, namely through the increased incidence of motor vehicle accidents when drivers use mobile phones. Since the chance of an accident appears to be equally elevated for hands-free and hands-held use, this effect is almost certainly due to the distracting effect of the conversation."

    		•

    Box 3: DfT advice on mobile phones and driving.13

    Drive responsibly

    When used properly, phones in cars can have many benefits. They can provide valuable security and help in an emergency. However, they are distracting if used while driving and this increases the risk of an accident.

    Drive safely

    To drive safely you must concentrate. Talking on the phone distracts your attention from the road and this can lead to an accident. You cannot be in full control of your vehicle if you are using a mobile phone while driving.

    Never use a hand-held phone while driving

  • You are not in full control of your vehicle if you are holding a mobile phone while driving.

  • Keep the phone switched off. Only use the phone after you have stopped in a safe place.

    It is best not to use a hands-free phone while driving

  • Using a hands-free phone while driving will distract you.

  • Although you may think that a hands-free phone will enable you to control the vehicle, your mind will not be fully on your driving. It is not like talking to a passenger, who is aware of the traffic conditions and can see what is happening while you are driving.

  • Avoid taking calls. But if you must, say you are driving and end the conversation quickly. Otherwise you will put yourself and other road users at risk.

    Use a message service and take regular breaks

  • For your own safety and that of other road users, use voicemail or divert calls so that messages can be left for you while your phone is switched off.

  • Find a safe place to park to make a call or receive messages. On a long journey take regular breaks to help you relax and reduce tiredness. But remember you cannot stop on the hard shoulder of a motorway except in an emergency.

    Employers

  • Do not ask your staff to carry out two demanding tasks at the same time. It can be an offence for employers to require employees to use mobile phones while driving - you are asking them to drive while not in proper control of the vehicle.

  • If it is essential for your staff to be contacted while they are driving, tell them to use voicemail or call diversion and to stop regularly to check messages and return calls.

    Installation of hands-free equipment

  • Hands-free equipment should be installed according to the manufacturers instructions and should follow the British Standards Institution's "Guide to in-vehicle information systems" (DD 235:1996).


    • Box 4: The RAC and AA advice on mobile phones

    Advice issued by the AA14 as far back as 1998 advised drivers: "If you have a hands-free phone, it's best to stop before making a call. If you must make a call using a hands-free phone, keep the call simple, slow down, don't overtake and stop the conversation if driving becomes difficult . . . Control the car. You're in the car, so insist on phoning back if the conversation becomes complicated or emotional, or if traffic conditions worsen." It further suggested drivers use message services.

    The AA advised callers to help the driver and be responsible for safety. "Check whether the person you've called is driving, and let him or her control the car . . . If bosses want drivers to receive or make calls from their cars, they should provide hands-free phones."

    The RAC15 advises: "Drivers should avoid using hand-held mobile phones while on the move. If possible, switch your mobile phone off during your journey and use its message facility instead. If you do leave a phone switched on and you receive a call, advise the caller that you are driving and keep the call brief. Concentrate on the road at all times when using a hands-free phone and display similar caution when using other in-vehicle systems."


    Box 5: The work-related road safety task group

    The HSW Act requires employers to safeguard the safety of their employees and the others affected by their undertaking. This applies to employees driving as part of their employment, although it has, in practice, remained a largely theoretical application.

    This is set to change. The Government's Work-related Road Safety Task Group recommended in October 2001 that employers address road-related risks as they would all other workplace risks to health and safety; the HSC accepted most of the recommendations in May 2002, and the HSE is currently working on an implementation strategy (HSC heads for the highway). One recommendation was that guidance for employers be produced on managing at-work road safety; among other things, this would cover mobile phones.


    Box 6: HSB road risk conference

    Health and Safety Bulletin is running a one-day conference in central London on 29 November on managing occupational road risk (MORR). The speakers include RoSPA's Kevin Clinton, who will talk about the RoSPA research covered in this article, and Sharan Bains, the HSE's head of policy on work-related road safety.

    The conference will cover:

  • the Government's proposals on mobile phones and driving;

  • the implications for employers of the report of the Government's occupational road risk task group;

  • how to implement a successful MORR strategy;

  • alcohol and drug impairment;

  • driver fatigue;

  • how employers should investigate at-work road accidents; and

  • MORR at the Post Office.

    Details: tel: 020 7347 3574, website: www.conferencesandtraining.com; email: conferences@lexisnexis.co.uk.

    		•

    1"Mobile phones and driving - proposal for an offence of using a hand-held mobile phone while driving", 20 August 2002, www.roads.dft.gov.uk/roadsafety. Comments should reach David Peagam by 25 November 2002 at DfT, Road Safety Division, Great Minster House, 76 Marsham Street, London SW1P 4DR, tel: 020 7944 2046, email: roadsafety@dft.gsi.gov.uk.

    2"Tomorrow's roads - safer for everyone: the government's road safety strategy and casualty reduction targets for 2010", March 2000, DETR, www.roads.dft.gov.uk/roadsafety/strategy/tomorrow/.

    3SI 1986 No.1078, as amended.

    4"Report on the review of road traffic penalties", Home Office/DfT, www.homeoffice.gov.uk/ppd/oppu/traffic.pdf.

    5"Mobile phones and health", report of the independent expert group on mobile phones, chair William Stewart, the National Radiological Protection Board, www.iegmp.org.uk/report/index.htm.

    6"The risk of using a mobile phone while driving", RoSPA, tel: 0121 248 2000, www.rospa.com/pdfs/road/mobiles/report.pdf.

    7"RAC report on motoring 2001", RAC Motoring Services.

    8Hansard, 9 July 1999, House of Lords, col. 1170.

    9Hansard, 14 November 2001, House of Commons, col. 881.

    10"Highway Code", The Stationery Office, £1.49.

    11"Mobile phones and driving", www.think.dft.gov.uk/mobile/index.htm.

    12Hansard, 6 July 2000, House of Lords, col 1596.

    13This is an abridged version of the "Mobile phones and driving" leaflet in the DfT's "Think! Road safety" series, www.think.dft.gov.uk/mobile/index.htm.

    14www.aapolicy.com/news/release_view.cfm?id=359.

    15www.rac.co.uk/carcare/advice/general_help/responsible_driving.

    16The calculations and costs that the DfT bases the figure in this table on are set out in "Highways economic note no.1", DFT, www.roads.dft.gov.uk/roadsafety/hen2000/index.htm.