Leanne Gower

HM Coroner for the County of Northamptonshire Our ref:

110 Whitworth Road Your ref:

Northampton Date: 6 January 2015
NN1 4HJ

FAO Mr H Shah

Dear Mr Shah,

RE: LEANNE CARMEN GOWER (DECEASED)
REGULATION 28 CORONERS REPORT

| refer to your letter dated 19" November 2014 to my officer, and
accompanying regulation 28 Report expressing concerns regarding various policies and
would reply as follows:

1. Department of Transport Design Manual
National Guidance HD 28/04 is published by the Department for Transport and the

Highways Agency for use on the Motorway and Trunk Road network. As such, it is without
the remit of the County Council to review.

However, | would comment that in the period 2001 to 2004, Northamptonshire saw
considerable changes to its principal road network as a result of the government's national
programme of trunking and detrunking. This consisted of the A45 (from M1 Jn 15 to A14)
becoming a trunk road and sections of the A6, A428, A43, A45 and A47 ceasing to be
trunk roads and becoming part of the county A road network

This has resulted in two very different networks: Trunk Roads and Motorways which (with
the exception of the A5) consist mostly of Motorways or motorway style dual carriageways
with limited junctions, often grade-separated and relatively modern, designed roads (M1,
M45, A14, A45 and A43).

This contrasts with the county principal road network which are local A roads the majority
of which have evolved historically with limited design and consist of numerous junctions, a
mixture of urban/rural environments, and varying levels of horizontal and vertical
alignment.

2. Northamptonshire County Council (NCC) Skidding Resistance Policy

The County Council's policy and utilisation of SCRIM data modifies the Department of
Transport guidance for use on the County Principal Road network. NCC considers that
strict application of HD28/04 is too stringent for a local road network because the national

www.northamptonshire .gov.uk

4% Northamptonshire
ey County Council

document does not provide suitable guidance for roads designed for lower speeds and
lower traffic volumes.

The current NCC policy was first issued in 2009 and was last reviewed in 2013/14 to take
into account all latest available national advice and guidance. This latest review has yet to
be formally signed off so we will take this opportunity to look at our Skidding Resistance
Strategy again to see if any further changes are required or improvements can be made.

3. Red Route Working Party and Red Route Process
This is the working party referred to in your report and the process is more of a strategy

rather than a policy. The process has been in place since 2000 and the working party
meets on a monthly basis with expert practitioners from Northamptonshire Highways,
Northamptonshire police and Northants Fire & Rescue Service.

The Red Route process has evolved over the years and an annual review of routes,
interventions, working practices and inclusion of SCRIM data ensures that the most
effective strategy is in place. This means that the process is already subject to regular
review.

| have attached some additional information relating to the Red Route Strategy by way of
further explanation including some more specific information regarding the A508 and
perspective around the use of non-injury collision data which was an issue raised during
the inquest.

Yours sincerely

Strategic Manager Transport and Highways

RED ROUTE STRATEGY

Red Route Process

By virtue of a known and significant collision/casualty history around 40
routes in the county are designated as ‘Red Routes’ and are each subject to
an investigation by a working group panel comprising expert practitioners from
Northamptonshire Highways, Northamptonshire Police and Northants Fire &
Rescue Service. The Panel meets on a monthly basis in order to survey and
profile Red Routes using an evidence led process derived mainly from data
recorded by the police when attending personal injury collisions. This
analysis ensures that interventions are directed to where they are most
effective by implementing appropriate engineering, educational or
enforcement measures, either in isolation or in combination. Non-injury
collision data held by the police is retained in a form that is of no evidential
value for analysis purposes and is therefore not considered by the Panel. An
explanation of the police non-injury collision recording policy is provided later
in this report.

The Red Route process has been in place since 2000 and has contributed to
the good progress we have made in reducing road casualties as well as
ensuring that we can address emerging trends, patterns and areas of
concern. Significant casualty reductions were achieved during the early years
of this strategy with vehicle technology and legislation providing considerable
influence together with our own effective interventions directed towards
collision cluster sites, speeding motorists, and anti-social driving habits.
Elements of these still prevail but it was always anticipated that a plateauing
effect in casualty numbers would occur as they reached unprecedented low
levels and we experience ever diminishing returns on road safety investment.
In order to identify our most collision affected routes we use a ‘risk mapping’
process as advocated by the Road Safety Foundation. Collision cluster sites
in the county have greatly diminished and this process ensures that we focus
our activity on route and area-based interventions. The Red Route process
has therefore evolved over the years to meet these challenges and an annual
review of routes, interventions, working practices and inclusion of SCRIM data
ensures that the most effective strategy is in place

Casualty Progress

There have been significant improvements in road safety in Northamptonshire
over the past 20 years.

In 2013 there were 330 KSI casualties compared to 348 in 2012, a decrease
of 5%. Overall, 2013 represents the record low for all types of casualty
(1,585). In addition, the number of young driver KSI casualties, at 28, is the
second lowest since records were introduced in 1960.

The greatest progress in casualty reduction has been achieved over the
longer term by comparing 2013 with the government baseline years of 1994-
98. The average number of people killed or seriously injured during this
period in Northamptonshire was 773 per year compared to 330 in 2013, a
reduction of 57%.

During the same period all categories of vulnerable road user groups have
fallen significantly and, in particular, young driver KSI casualties by 68%, child
KSI casualties by 75%, car passengers by 77% and pedestrian KSI casualties
by 54%.

This has been achieved against a backdrop of increased vehicle usage, and
ownership of registered vehicles rising nationally by almost 10 million.

Non-Injury Collision Data

The police no longer routinely attend or record non-injury collisions and the
Department for Transport do not require this information from local
authorities. It is therefore a fact that the vast majority of damage only
collisions are not recorded by the police and anecdotal information is
notoriously unreliable. Reports of non-injury collisions to the police are noted
on a messaging log and tend to provide the briefest of detail. The absence of
precise, validated and corroborated locations for incidents therefore renders
any attempt to accurately identify collision sites with any degree of
confidence. It should also be born in mind that, for the purposes of the Road
Traffic Act, the most insignificant damage to a vehicle or property would
constitute a non-injury collision. Provided that all the conditions of the Act are
met then there is no obligation for a motorist to report a non-injury collision to
the police.

Where non-injury collisions are recorded by the police, details are again very
brief and held in their administrative system for reference purposes. Reports
are not forwarded to Northamptonshire Highways and we do not have the
resource capacity to input the detail on our database. To put this in context
we currently input around 1200 personal injury collisions per year on our
database and the police file around 2,500 non-injury collisions in their

system. This is in hard copy form and presents no opportunity to interrogate,
validate or analyse the information. We spend a great deal of time validating
the data contained within personal injury collision forms in order to ensure that
the information available on the database has a high degree of accuracy.

Non-injury data is therefore extremely limited, unreliable and lacks scientific
rigour to determine meaningful interventions. As an evidence led process our
analysts are also mindful that erroneous data could potentially create danger
on the road network rather than reduce it as well as divert funding away from
more serious concerns on the network.

A508

The collision history along the whole route (M1 to Stony Stratford) is such that
it is constantly monitored and has benefited over the years from a range of
measures which have included static safety cameras, reduced speed limits
and major junction re-engineering. We are also aware that local and national
analysis clearly indicates that the vast majority of collisions are not due to any
action (or failure) by the highways authorities but by human behavioural
factors which we continually strive to fully understand and find ways to

address. When the Red Route process was first introduced in 2000 there had
been 73 personal injury collisions including 5 road deaths in the previous 3
years, compared to 31 personal injury collisions (2 road deaths) in the most
recent 3 years to date. There has therefore been a significant improvement in
the safety record of this route, and against a backdrop of increased traffic
flow.

Conclusion

The Red Route process undergoes regular assessment and appraisal by the
members of the Panel in order to maintain best practice and value for money.
In addition, an annual review of all the routes is undertaken to ensure that
resources are directed to where they the most needed. We will continue to
ensure that effective procedures are under constant consideration.

Safer Roads Team

NORTHAMPIONSHIRE i] i] Unit 27 - 29 Cornwell Business Park
[ | ce Salthouse Road
Brackmills

Northampton

Mr H Shah
Assistant Coroner
110 Whitworth Road
Northampton
NN1 4 HJ
07 January 2015

Dear Mr Shah

Leanne Carman Gower (deceased)
Letter to prevent future deaths

Further to your Regulation 28 report of 19 November 2014 I have noted your
concerns and I provide the following information in response.

Actions taken

I have reviewed our position in relation to the collation, checking and provision of non-
injury, damage only collision data and can clarify the position of Northamptonshire
Police with regard to this.

Procedure

When a member of the public telephones to report a road traffic collision, the following
information will be obtained:

e Has anyone been injured?

e Is there any danger requiring immediate action by any of the emergency
services?

e Is there any obstruction to traffic?

e Are there allegations of offences being made against another driver/person?

e Do the circumstances warrant the attendance of a police officer?

If the answers to all the questions are negative the caller will be informed of the
provisions of Section 170 Road Traffic Act 1988 and the drivers’ responsibilities to
exchange:

names and addresses

details of the owners of the vehicle

vehicle registration marks

the fact that the police will not be attending and no police collision report will be
prepared.

Requirements

All Police Forces have a requirement under the Department for Transport regulations
to record data on all collisions involving death or personal injury on the public
highway, and in which one or more vehicles are involved. This data is called ‘Stats 19’
and is used for the purpose of delivering casualty reduction and road improvements.
The format of the reporting ensures that it nationally consistent.

The ‘Stats 19’ data collected by Northamptonshire Police is sent to Northamptonshire
County Council for collation and onward transmission to the Department for Transport.

There is no requirement by the DfT for Police Forces to record non-injury damage only
collisions. In line with the procedure above, damage only collisions which are reported
to the police will be noted on the command and control log and given an incident
number. In most cases, unless necessary, no further action is taken.

Position of Northamptonshire Police

At a meeting of Chief Officers on 16 September 2011 it was agreed that damage only
collisions would only be recorded where road traffic offences were disclosed. This
decision was implemented in January 2012 and the procedure outlined above took
effect.

Overview of the reporting and recording of road traffic collisions.

The question is raised that the policy of dealing with damage only collision information
should be reviewed to determine if the use of such information could contribute
positively to reducing casualties.

This question needs to be put into the national and local context in order to inform
what, if any, action should be taken to utilise damage only information.

Reference is made to the following document ‘Reported Road Accident Statistics’
SN/SG/2198 updated 24 October 2013, a Parliamentary briefing paper. This
document acknowledges that the STATS 19 database figures are recognised as being
an incomplete count of both collisions and casualties, although figures on fatalities are
generally acknowledged to be robust.

It is apparent that the system has flaws due to underreporting by those not able to or
not wishing to notify police of their involvement in a collision. There are other reasons
for underreporting of personal injury collisions but with regard to damage only
collisions, it is believed that the scale of underreporting may be even greater.

Research into the extent and nature of underreporting is ongoing but has not yet been
conclusive in terms of the scale of the problem. Chapters 5 and 6 of ‘Road Accidents
in Great Britain 2008’ provide a summary of research findings into this issue at that
time. In July 2009 the UK Statistics Authority published their assessment of road
casualty statistics and they too concluded that the underreporting of road collision
casualties is a significant and intractable problem.

Bearing in mind the issues recognised to exist with the reporting and recording of
personal injury statistics, the recording of damage only data presents even greater

difficulties. There is a working partnership between Northamptonshire Police and
Northamptonshire County Council to reduce road casualties and the following
comments have been made by EEE Road Safety and Sustainability Team
Leader, Northamptonshire Highways:

‘The police no longer routinely attend or record non-injury collisions and the
Department for Transport do not require this information from local authorities. It is
therefore a fact that the vast majority of damage only collisions are not directly
recorded by the police and anecdotal information is notoriously unreliable. Reports of
non-injury collisions to the police are noted on a messaging log and tend to provide
the briefest of detail.

The absence of precise, validated and corroborated locations for incidents therefore
renders any attempt to accurately identify collision sites with any degree of
confidence. It should also be born in mind that, for the purposes of the Road Traffic
Act, the most insignificant damage to a vehicle or property would constitute a non-
injury collision. Provided that all the conditions of the Act are met then there is no
obligation for a motorist to report a non-injury collision to the police.

Where non-injury collisions are recorded by the police, details are again very brief and
held in their administrative system for reference purposes. Reports are not forwarded
to Northamptonshire Highways and we do not have the resource capacity to input the
detail on our database.

To put this in context, we currently input around 1200 personal injury collisions per
year on our database and the police file around 2,500 non-injury collisions in their
system. This is in hard copy form and presents no opportunity to interrogate, validate
or analyse the information. We spend a great deal of time validating the data
contained within personal injury collision forms in order to ensure that the information
available on the database has a high degree of accuracy.

Non-injury data is therefore extremely limited, unreliable and lacks scientific rigour to
determine meaningful interventions. As an evidence led process our analysts are also
mindful that erroneous data could potentially create danger on the road network
rather than reduce it as well as divert funding away from more serious concerns on
the network’.

Conclusion

There is no statutory requirement to collect, collate and analyse damage only data. If
this activity were to be graded in terms of necessity and weighed against policing
priorities, then it would likely be given a very low priority. Current financial conditions
and the requirement to make significant savings would also make the need to fund
staff time to deal with damage only data difficult to justify. Consequently I would not
recommend that formal steps be taken to collate and analyse damage only data within
this organisation. My conclusion supports the decision of Chief Officers taken in
September 2011.

However I do acknowledge the concerns raised by the Coroner and propose instead to
highlight this issue to the small group of officers, located around the county, who have
taken on a role as road safety problem solvers. I will brief them on the circumstances
of this particular incident and ask that, as part of their role, they informally report any
concerns that they become aware of in relation to collision locations. Where it

becomes clear that a pattern is emerging or the number of incidents is unusual,
further investigation will take place via the Safer Roads Team.

Senior Traffic Management Officer
Safer Roads Team