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Composed by John Lamarra; When we arrived at Marsham Street we were concerned that the Minister felt it necessary to require instructors to re-sit part 1 of the register qualifying examinations and equally concerned that he thought that instructors he had approved might not know what a hazard was. We also had concerns that the scoring in the hazard perception test was flawed and loaded against the expert driver.

When we left Marsham Street none of these concerns had been dispelled but moreover we left the meeting with a frightening realisation that those who are in charge of road safety have a very different view of what constitutes safe driving from our own.

The Minister did say that he was prepared to review the situation regarding the requirement for driving instructors to re-sit the part 1 exam, and that he did not close the door on any of our proposals. This in itself would have given us some grounds for optimism but what we discovered about the Minister's and the DSA's view of good driving left us with a feeling of trepidation. We quickly learned that the hazard perception test does not pretend to look for hazard perception and anticipation, as we know it. The ‘hazard perception' test looks for a reaction to a ‘developing situation' and is therefore no more than a ‘reaction' test. In short the Minister and the DSA think that reacting to something that has started to happen is better driving than anticipating that event.

During the meeting, we discussed our objections to the proposal to require existing instructors to re-sit part 1 of the qualifying examinations. Peter Dolan, however, insisted that we were not being required to re-sit part 1 although, when pressed, he conceded that there was no difference between the part 1 and the one that he was proposing that we sit.

In justification of requiring instructors to re-sit part 1 both the Minister and Peter Dolan cited information from learners that they were not being taught either hazard perception or being prepared for the hazard perception test. The Minister insisted that some people had not been given any hazard perception training at all.

Peter Dolan dismissed earlier reports that a survey had shown that 80% of learners had received hazard perception training and said that their information came from customer focus group meetings. When challenged that the minutes of these meetings showed very few comments and that those which were made indicated clearly that instructors would have liked to know more about the test, Peter did not pursue the issue. Neither were we offered any explanation as to why this very relevant information was not acted upon.

When pressed, he was unable to explain how all these learners who had received no hazard perception training still managed to pass the driving test and did not offer any argument to our contention that it was inconceivable that any driving examiner would issue a pass certificate to anyone who could not recognise and deal with a hazard. Neither did he argue against our assertion that it would be intolerable and inexcusable to maintain a system of driver testing which did not demand those hazard recognition skills.

We conclude that the Minister is satisfied that the testing system does adequately seek hazard perception skills and that candidates without these skills will not pass a driving test. By inference it was obvious that the learners who allegedly had no hazard perception training must have demonstrated these skills adequately to pass the test. We were not offered any explanation as to how these candidates were supposed to have acquired these skills without training.

The Minister, anxious to justify his position, said that he has spoken to a lot of sixth formers who have assured him that the experience of the hazard perception test had assisted them greatly in their awareness of and perception of hazards. Peter Dolan thought that it should be of great assistance to learners in their practical lessons if they had had experience of the hazard perception test, as it would educate them in what to expect in their lessons.

The Minister was perhaps a little surprised to hear that we too speak to a lot of sixth formers who had informed us that they treated the hazard perception test just as they would treat any other computer game and that they saw that the way to beat the test was to learn the clicking technique. Both the Minister and Peter Dolan were a little stunned when we reminded them that DSA had given assurances that it would not be possible to pass the hazard perception test without first having taken plenty of driving lessons and without having plenty of experience.

We felt obliged to inform the Minister that hazard perception training should be done as we have always done it — even long before the term ‘dynamic hazard' had been thought of — in the car as part of a good course in driver training. Neither the Minister nor Peter Dolan argued when we reminded them that we train people to recognise hazards because their lives depend on it and not because they have to sit a test. Neither of them argued when we insisted that hazard perception training to us was about developing a real-life skill and that this was primarily done in a real-life situation. We further pressed that the primary mode of testing for a life-skill must be in a real-life situation and carried out by real and discerning driving examiners. We stressed that virtual testing and virtual training could never equal real-life experience.

We put it to the Minister that we were in favour of his inviting instructors to sit the hazard perception test for experience sake but we stressed that we would not accept that there was any need for instructors to prove that they could recognise a hazard. We put it to the Minister that if there were any instructors on the register who could not recognise a hazard then it was entirely his fault.

We reminded the Minister that we had advocated that instructors get experience of the test and indeed that we had co-operated with Prometric in arranging for groups of instructors to attend various test centres for this purpose. Peter Dolan was surprised to hear that we had this agreement with Prometric and even more surprised to hear that DSA had prevented us from going ahead with it.

We remain deeply concerned that Minister actually believes that we do not teach hazard perception and even more worrying is his belief that sitting the test would make the slightest difference to that if it were true. He must surely see that we would not survive on the road if we could not recognise hazards well in advance of any normal driver since we must have time to instruct the learner. Does he believe then that we have these skills and are not teaching them? If this were the case our conduct would be seriously deficient and irresponsible. Does he not realise that people who are so irresponsible are unlikely to change their habit because they have passed a computer test.

What concerned us most was the fact that the Minister was convinced of the fairness of the scoring on the hazard perception test. He stressed that he had seen the system run and had been shown exactly where the scoring windows were. He was satisfied that the test was a fair assessment of a driver's ability to recognise a hazard. He gave us his assurances that the scoring window opened at the time when a driver would need to take some action. He stressed that all a candidate needed to do was click when the hazard started to develop to score maximum points.

We put it to the Minister that we were actively prevented from discovering for ourselves what he had been allowed to and that our views were based on the only information available to us and we reminded him that the information we had was given to us by the DSA.

If we were to believe the Minister's description of the scoring in the test then the DSA's information has to be seen as being grossly misleading and inaccurate since the two versions were manifestly different.

In defence of our position, we referred the Minister to the CD-rom issued by the DSA which gave the DSA's version of the scoring in the hazard perception test. We highlighted the sequence in which a cyclist was approaching a parked car-transporter and that the advice given on the CD was that a driver should react when the cyclist turned round to look back. This was the indication that he might change direction.

Our concern was heightened when the Minister enthusiastically justified awarding five points for clicking at this time and advocated that this was indeed the correct moment for a driver to react because this was when the hazard started to develop. He said that all that was needed was to click at this point to ensure a high score. Again we surprised the Minister when we referred to the clicking technique described in Despatch. He was obviously totally unaware that even the DSA recommended clicking three times and asked Peter Dolan, “Three times? For the same hazard?”

The Minister did not offer an answer when we questioned what would happen if the cyclist did not turn round. We were not corrected when we enlightened him that to wait to this time to react was bad driving and we were convinced that every driving examiner in the land would mark a fault for such a late reaction. The Minister did not argue with our assertion that it was more than likely that a cyclist about to collide with a parked lorry could be expected to pull out to avoid it and that we did not really need to wait for the cyclist to look back to reach this conclusion. The Minister did however comment that in London many cyclists might mount the pavement and pass the lorry on that side.

We put it to the Minister that he was advocating that drivers should take no action until a hazard starts to develop. He stressed several times that this was the point when a candidate needed to click to score maximum points. He was unmoved when we, expert drivers, pointed out that if we clicked when we think we should, that is when we saw (perceived) the hazard we scored zero points.

The Minister said that he had arranged for several hundred MPs and Lords to try the test and claimed that all were happy with what they saw. We argued that this was because they were making the same mistake he was by reacting when the hazard started to develop rather than anticipating it, as good driving requires. We put it to the Minister that what he had and what he advocated was a reaction test.

We explained to the Minister that safe drivers anticipate a hazard and we informed him that this is no less than driving examiners and road safety demanded. We referred to advice given to test candidates in DSA publications, “You will not pass the test if you react suddenly rather than anticipating a hazard”.

We took some comfort from the Minister's promise to review his position but we are not convinced that this meant that he will change it. We are deeply concerned that the Minister and the DSA have moved away from advocating the safer driving skill of “anticipating what other road users are going to do and how they could affect you” to advocating that “you should not do anything about a hazard till it moves at which time you will have two seconds to sort it out”. If this is the case then only a fool heeds the two-second rule.

If the Minister intended that the test was to be a reaction test then he has misnamed it. If it is a test of a driver's reaction then it has no place in the driving test which is supposed to be road safety orientated.

Criticism of the Process

. Introduction

1.1. The Driving Instructors Scottish Council represents many of Scotland 's driving instructors. It is a fully democratic body with no paid officials and no executive committee.

1.2. The Council's administrative committee is elected annually and is responsible for conveying the Council's views to other road safety interests including the Driving Standards Agency.

1.3. The Council's views and policies are decided at full Council meetings only.

1.4. Like instructors from all parts of Britain, Scotland's instructors were outraged at the false and misleading comments made in the Consultation documents, ‘Driving Test Fees And Other Matters'.

1.5. The Council must also express the strongest possible protest at the way matters of great importance to instructors were hidden away in these documents presumably with the intention of rendering them unnoticed by consultees. It will have been understood by the authors of the document the many consultees will have only a cursory glance at the document and consequently make an equally cursory response. It will also have been understood by the authors that most of the consultees would have little or no knowledge of driving instruction or the workings of the Register of Approved Driving Instructors.

1.6. This Council believes that these factors were used to achieve apparent support for legislation which the authors of the consultation documents will have known would be decried by the instruction industry. The authors of the document gave neither heed nor weight to the expert view in this matter.

2. History

2.1. Over all its years, the driving instruction industry has made great efforts and gone to great lengths to press the controlling government department to improve the efficiency and the effectiveness of the Register of Approved Driving Instructors. Indeed, it was pressure from professionally motivated instructors seeking to ensure a quality of service for the learner driver, which brought the register into being in the first place. This was achieved despite vigorous opposition from the then Department of Transport .

2.2. The industry has always shown itself willing to accept controls in order to facilitate the enforcement of instructional standards. Enforcement, it has to be said that none of the controlling departments has ever delivered. Very few of the initiatives came from either the DoT or the DSA.

3. Misinformation

3.1. It is against this background that the industry's vigorous opposition to the assertions which were the justification for compelling existing instructors to re-sit the Part 1 qualifying examination should be measured.

3.2. Assertions that:-

• instructors might not know how to recognise a hazard and therefore, need to prove this through a dubious exam
• this inadequacy in instructors was responsible for the accidents involving new drivers
• instructors need to be forced to seek self development,

3.3. All of these assertions are false and offensive. No one working in or with the industry can be in any doubt of that. An apology is required from those who made such defamatory suggestions.

3.4. The assertion that instructors might not be able to recognise a hazard is rendered indefensible when it is realised the Driving Standards Agency has already approved instructors hazard perception skills when they were tested during their entry exams (Part 2 Driving test) and check-tests. I quote from a letter from Tim Barnatt of the DSA who replying on behalf of Gary Austin ;

“We do not keep statistics on marks given in core competencies on check tests or reasons for failing check tests and ADI part two tests. 

The core competencies in a check test are used to assess an instructors overall performance.  Markings in these core competencies reflect how well the instructor has structured the lesson.  Part of this is measuring whether the instructor has recognised hazards and how they have been dealt with .” [1]

3.5. This statement makes the suggestion that ADIs need to sit yet another test, to prove what has already been proven, illogical and unnecessary in the extreme. It is exactly this type of nonsense that leaves the DSA open to accusations that their motives are financially based and undermines their potential for influencing road safety.

4. Flawed Justification

4.1. It is now clear that this legislation was based upon and justified on the grounds of:-

• a dubious survey of learner drivers
• incomplete or otherwise misleading guidance in the consultation document highlighted by the withdrawal of claimed support for the proposal by some of the consultees after clarification by the industry.
• dubious, if not convenient, interpretation of comments from consultees such as, “we would support any move which can be shown to improve road safety” as meaning “we think ADIs should re-sit their qualifying exams.”
• a dubious list of consultees numbering some 3000 most of whom have no working knowledge of the register.
• untenable claims that a return of 82 replies of which only 59 addressed the ADI question and of these only 27 were in favour can be regarded as support for the move.

5. DSA Approved?

5.1. The Driving Standards Agency would have it believed that they have approved and recommended to learners the services of instructors who cannot drive.

5.2. Could instructors survive on the roads if they could not recognise a hazard?

5.3. Could applicant instructors pass the Part 2 examination if they could not recognise a hazard?

5.4. Could instructors regularly achieve high grades on the check-tests if they could not recognise a hazard?

6. New Driver Accidents

6.1. The Driving Standards Agency is responsible for testing candidates for a substantive licence to ensure that they are safe to drive unaccompanied.

6.2. If new drivers have been inadequately trained, it is the remit of the driving test to detect this and refuse the candidate a licence.

6.3. Would the Driving Standards Agency claim that an un-trained candidate would not be detected by their examiners?

6.4. Does the Driving Standards Agency believe that its examiners cannot identify a hazard and is this why they are asking examiners to sit the Hazard Perception Test?

6.5. Can instructors be held responsible for the behaviour of their clients after they have left their influence?

6.6. Can an examiner be held responsible for the conduct of a candidate after he has issued a certificate of competence?

6.7. Can anyone really associate crashes involving only one vehicle which was being driven deliberately at excessive speed with lack of training?

7. Continuous Professional Development

7.1. Self development is not a new phenomenon for instructors.

· They have been attending meetings and seminars for this purpose for as long as there has been a register of approved driving instructors.

· They have bought a proliferation of publications regularly issued and re-issued by the Dot and the DSA.

· They have accompanied their clients on test to ensure consistency with driving examiners.

· They have developed their own system of continuous professional development.

7.2. Driving instructors have to adapt the training they give to take account of changing road environments and vehicle developments. Consequently instructors are often teaching well in advance of the requirements of the DSA which is historically painfully slow to catch up with developments. This is not because the examiners are not up to date, but because the political constraints under which the DSA must work prevent anything remotely approaching a rapid response to developments.

8. Conclusions

8.1. It is quite clear that something went very seriously, hopefully not fraudulently, wrong with the consultation process that preceded the presentation to Parliament of a seriously wrong piece of legislation. Legislation which is not required. Legislation, which was justified on the bases of false assertions. Legislation, which was justified on the basis responses, some of which were indefinite and possibly from misinformed and misguided consultees. (ref paragraph 4.1)

8.2. The Driving Instructors Scottish Council is anxious to re-affirm its commitment to the development of good instruction and its earnest desire to see a spirit of co-operation between itself and the DSA. This was made explicitly clear in our Chairman's remarks to Conference 2002 and appeared to be reciprocated by Gary Austin .

“ John Miller , chairman of Driving Instructors Scottish Council, told conference that DISC had set itself a target for the year since its last conference. This was to setup a national programme of Continuous Professional Development for driving instructors in Scotland .

This was now well underway and had proved to be very popular with instructors.

He said that the year ahead will see new objectives set and one of these is certain to be an even closer working relationship with the Driving Standards Agency. John told conference,

“We must work together. One cannot work without the other if we are to go forward in the greater pursuit of road safety.” [2]

Gary Austin agreed that “There was a need to work in partnership”. [3]

8.3. The Council is not, however, prepared to accept defamatory attacks on the integrity of the instructors it represents.

8.4. The Council is of the opinion that road safety is best served if there is positive, meaningful and respectful dialogue between the examining industry and the training industry and that the problems experienced in the lead-up to the preparation of this legislation would have been avoided if the views of the industry had been given serious and respectful consideration.

8.5. The Council looks forward to establishing this atmosphere in future dealing with the DSA.

8.6. The Council would welcome an enquiry into the conduct of the consultation process to establish whether:

· There is a need to have so many consultees who have virtually no connection with the matter on hand.

· To establish why an issue of such importance was given so little prominence in a consultation documents.

· To establish whether there existed any real support from consultees for the proposal to require instructors to re-sit Part 1 of the qualifying examinations for the Register of Approved Driving Instructors.

· To establish whether appropriate weight was given to the comments made by the instruction industry and whether these were unambiguously conveyed to Ministers.

[1] Letter (19th January 2004).

[2] Conference Report 2002

[3] Conference Report 2002

"In order to continue to put pressure on the Minister and MPs we are asking
every individual instructor within our associations to send a letter - not
an e-mail - to their own MP asking for answers to the questions raised by
our document, "Criticism of the Process".

The Minister will have to bring the statutory instrument before Parliament
for a vote. If this happens, the Government will win because of their
majority. If we act now we can prevent things going as far as a vote and the
legislation could be lost.

The united front we have shown in bringing about the adjournment debate must
not be lost. We must retain this momentum and go forward to challenge this
ludicrous proposal Action speaks louder than words. We would therefore urge
everyone to write these letters of objection in order to keep the pressure
on and obtain a no-vote situation."

John Miller
Chairman

Tel- 01698 854101  / e-mail john.miller@clara.co.uk