The Hard Truth

The deception of road safety in South Australia.

 

The recent announcement in South Australia to commence stage 2 of the Heavy Vehicle Inspection Scheme (HVIS) is another example of regulatory agency failure to understand how to address road safety.

The debacle this scheme represents is reminiscent of recent operations which also failed to properly articulate why they were conducted and what safety benefits would be delivered. It can best be summed up by Dr DaShanne Stokes: “Truth is hard, propaganda is cheap”.

The problem

A stated objective of stage 1 of the SA HVIS was “to identify, monitor and mitigate un-roadworthiness as a causative factor in crashes on South Australian roads, and to increase heavy vehicle safety”.

Progression to stage 2 is based on evidence that 62 percent of heavy vehicles failed a change of ownership inspection.

No information was proffered as to how many vehicles were inspected, the severity of the non-conformity, minor or major, and what items the non-conformity related to, suspension, lights, tyres etc. More critically, no information on the safety outcomes from the schemes operation has been sited.

There are more than 250 reasons for rejection in the National Heavy Vehicle Inspection Manual that can result in a vehicle being deemed non-conforming. The limited information available about the scheme on the Department of Planning, Transport and Infrastructure (DPTI) website does not define roadworthiness or for that matter ‘un-roadworthiness’.

They do not differentiate a safety critical item, a non-conformity which is likely to cause harm, from an item that simply does not meet the safety standards.

An example would be failing a roller brake test; it should be deemed a safety critical item. A broken tail lamp cover is not safety critical and is extremely unlikely to result in harm. No evidence is provided that the SA HVIS to date has had any effect on reducing serious injury and death.

As the graph below depicts rates of death (yellow trend line) are declining in South Australia.

In May 2017 the DPTI released a Heavy Vehicle Inspection Scheme Regulatory Impact Statement (HVIS RIS). The DPTI provided no evidence or justification that the introduction of a periodic inspection regime for ‘higher risk’ vehicles will reduce either fleet non-conformity rates or contribute to a reduction in heavy vehicle fatalities and in particular those related to mechanical failure as a causal factor.

The HVIS RIS did not clearly articulate how the inspection scheme will achieve the objective of improving heavy vehicle safety or address the cost impacts on industry or the South Australian community.

The stated success of the scheme was a reduction in a single road death per annum.

It was not clear whether this was where that death could be directly attributable to a non-conformity related causation in a heavy vehicle. Nor how the prevention of that death could be linked back to the HVIS.

The HVIS RIS lacked any evidence that vehicle standards non-conformities detected during an inspection reduced the risk of heavy vehicle incidents.

There was insufficient evidence whether an inspections scheme would contribute to improved heavy vehicle fleet roadworthiness and would therefore improve road safety.

Examining the detail

The HVIS RIS assessment of the annual economic and social cost of road crashes to SA, claimed it would be around $9 million per annum.[1] It indicates that the government costs will range from $183 to $259 per inspection. This in fact does not represent an accurate assessment of the economic and social cost of the scheme as it fails to include significant costs in terms of opportunity cost and productivity loss to industry.

At face value the RIS is devoid of any substantial evidence to warrant introducing a compulsory inspection scheme.

A quick review of the NTC Final Heavy Vehicle Roadworthiness RIS June 2015 (NTC RIS) provides data to assess the economic cost of inspection schemes. It identified that government inspection costs in South Australia were $656.[2] Based on this data a more accurate estimate of cost to conduct inspections in SA is $24.3 million (37,000 x $656). This is more than 2.5 times DPTI’s assessment.

In addition, the NTC RIS identified that the operator cost of a heavy vehicle inspection would be in the vicinity of $2,194 per vehicle. It can be estimated that the real cost to the heavy vehicle industry will be in the order of $81 million (37,000 x $2,194) per annum. This is nine times the cost provided in the HVIS RIS analysis.

Using a very unsophisticated methodology the RIS analysis underestimates the schemes cost by a magnitude of almost twelve times ($81m + $24.3m/ $9m = 11.7).

There is a litany of other failures within the SA HVIS RIS, including:

*          The proportion of crashes attributable to heavy vehicles compared to light vehicles, for which no inspection regime exists

*          The portion of the economic and social costs of road crashes that is attributable to mechanical failure in heavy and light vehicles

*          Evidence of any causal link between increasing heavy vehicle registration rates and crashes and specifically crashes with mechanical failure as a causal factor

*          The RIS discussed monetised and quantifiable impacts. It is almost impossible to validate or dispute this analysis given the lack of a clear methodology and cursory treatment to costs and benefits provided within the RIS.

The RIS claimed it was developed after broad heavy vehicle industry consultation but only listed five industry representative organisations, potentially collectively comprising a membership of 2,000.

Consultation with industry on the HVIS RIS represented just 3 percent of the fleet (65,000) potentially affected by the inspection scheme.

No monitoring and review processes were described, including measurement of the performance of the personnel inspecting heavy vehicles, the policy outcomes being achieved (injuries prevented, and lives saved) and determining the realised costs to industry and the South Australian community.

The solution?

The heavy vehicle industry should request that DPTI revisits its decision to proceed with stage 2 until it has evidence and a clear risked-based approach to the inspection of heavy vehicles, including:

Accurately identify that a problem exists regarding mechanical failure as a causal factor in road incidents that warrants inspecting the entire SA heavy vehicle fleet.

Identify the safety critical items that cause serious incidents related to mechanical failure.

Define high risk heavy vehicles based on the above critical safety items data collected.

Develop an inspection scheme which focuses on high risk vehicles and inspects critical safety items.

Develop an effective method to evaluate the success of the introduction of a critical risk inspection scheme to provide industry and the community an assurance that road safety is being improved.

This work could be facilitated in conjunction with the NHVR completing the work associated with the National Heavy Vehicle Roadworthiness Program.

The heavy vehicle industry and the South Australian community have been duped by the previous government hell-bent on introducing a scheme with no evidence that a problem existed with heavy vehicle roadworthiness. This includes no information that stage 1 of the SA HVIS is reducing serious injury and death from non-conforming heavy vehicles.

South Australians deserves far more transparency and accountability in regard to road safety.

Certainly, we should expect better from our public institutions, those that lead them and the Ministers responsible for them.