We have been inundated with e-mails from Wales to Aberdeen all, so far, expressing disgust at the Minister’s proposal to require existing ADIs to re-take their entry qualifying examination Part 1.

If the Minister presses ahead with his plan, all existing driving instructors will receive a letter requiring them to re-sit Part 1 within 12 months of receiving the letter.

ADIs will be allowed three attempts the first of which will be free. Second and third attempts will cost £50 each.

Examiners are also to be required to sit the exam but will have 5 years in which to pass.

The Driving Instructors Scottish Council has already been in touch with ADIs and individuals around the country and an extensive database is being collated. Everyone, so far, has expressed strong objections to the proposal.

DISC is presently preparing a response to the proposal, which will be posted to this site very soon. When this is available, we would ask every ADI to write to his local MP in these or similar terms and ask for his or her support.

Our response to the proposal to force driving instructors to re-sit Part 1 qualifying examinations

Printable version of document

1. Introduction

1. The Minister of Transport is presently taking steps to force driving instructors to re-sit exams required of applicants for registration as approved driving instructors.

3. They are already subject to regular checks, by the Driving Standards Agency, of their continuing high standards of knowledge and instructional ability.

4. Instructors have requested access to these examinations for the benefit of their own experience and development.

5. There is no need to force instructors to take the tests and put them under the threat of removing their livelihood if they fail.

6. Instructors also contend that both the multiple-choice and the hazard perception elements are flawed and are detrimental to road safety.

2. History

7. The Council has welcomed and endorsed previous measures aimed at improving the performance of driving instructors and the register. Indeed the Council and other associations in the industry were instrumental in demanding and formulating the proposals for these changes often against the initial and sustained opposition from the DSA.

8. The Council has, however, strenuously opposed the compelling of existing ADIs to re-take the entry qualifying examinations. The Council’s view have been made clear to DSA officials from the time the proposal was first raised for consideration until as recently as October 2003 when it met DSA officials. The Council’s reasons for opposition are detailed below.

9. The Council has repeatedly warned the DSA of failings in the multiple choice and hazard perception elements of the ‘Theory Test’. These are detailed below.

3. Policy statement

2. that it fully supports any move to allow instructors access to the theory test for learner drivers and applicant driving instructors.

3. welcomes the move as being helpful in identifying any problem areas in an instructor’s knowledge and an aid to designing modules for the provision of that knowledge within our ongoing system of continuous professional development.

4. objects strongly to measures that force instructors to do what they have always wanted to do and have repeatedly asked to do but have been prevented from doing by the Minister.

5. objects to the inference in the Ministers statements that poor instruction is a major factor in the causation of road accidents in new drivers. No evidence has been provided to support this inference.

4. The consultation process

4.1. Document title

1. We strongly criticise the tactics used by the Minister in the way he hid an issue of importance behind much lesser issues. The Minister titles his document, “Fees for driving tests and other matters”.

2. If there was no intention to ‘hide’ the issue of changing legislation to force driving instructors to re-sit exams they have already passed at their qualifying stage, this legislation was evidently considered by him to be less important than the need to raise test fees.

4.2. Omissions

1. The Minister omitted advice to consultees that the driving instructors’ associations have already begun a system of continuous professional development.

2. He did not make it clear that approved driving instructors have already satisfied him of their high levels of skill and knowledge in what the Ministry has described as an exacting qualifying process[JL1].

3. The Minister also neglected to advise consultees that the industry had requested access to the theory tests and this was denied. Consequently, many instructors could have had no personal experience of the theory tests and were therefore unable to fully advise their clients.

4. The Minister failed to state in the consultation document that Prometric[1] had ultimately agreed to allow approved driving instructors access to the theory tests.

5. The Minister also failed to provide consultees with evidence that those instructors who have undertaken the new Part 1 examination (theory test and hazard perception test) have any better performance figures than those who have not.

6. The Minister did he offer any evidence that those learners who have taken and passed the hazard perception test show any better performance figures than those who did not.

4.3. Invalid Process

1. We therefore feel that the consultation process was flawed and that consultees were misinformed and misguided.

5. Theory Tests

5.1. Multiple choice

1. Many learner drivers have taken and successfully passed the theory test with little or no tuition in a car.

2. It is our experience that these learners, who have scored well in the multiple-choice examination, have very little understanding of the material they have studied to pass the test.

3. Equally evident to driving instructors is the fact that there is little connection made by these learners between the knowledge ‘demonstrated’ in the multiple-choice exam and its application on the road.

4. Instructors are satisfied from the evidence we have that the provision of the theory test bank to learners has diverted them from studying the Highway Code.

5. The DSA has vigorously opposed the industry’s calls for an experiment that would compare the performance of candidates who have passed the multiple-choice exam with their performance in an oral exam where no options were offered.

6. The DSA’s refusal to investigate instructors’ concerns seems to indicate awareness on the their part that the tests do not adequately fulfil their remit and a reluctance to accept the consequences of that awareness.

5.2. Hazard perception test

1. The DSA correctly defines a hazard as, “anything that may cause you to change your speed or direction”.[2]

2. The DSA also correctly refers to “bends, junctions and roundabouts, traffic lights and crossings”[3] etc as hazards.

3. The advice given by the DSA to candidates for the in-car test is that they must, “avoid reacting suddenly to road or traffic conditions rather than anticipating them”.[4]

4. The hazard perception test, however, requires candidates to record only ‘developing’ hazards. That is hazards where they have to take action.

5. Hazards as defined in the DSA’s official guide are ignored by the hazard perception test.

6. To score highest marks a candidate must wait until something is happening (reaction) rather than to ‘click’ when something might happen (anticipation), the latter being the safer option on the road and the one advised in DSA publications.

7. Comments made to instructors by their clients indicate that young candidates view the test as an arcade game that can be ‘beaten’ through a technique of ‘double clicking’ rather than knowledge.

8. As recently as October 2003 the Council raised this issue with The Chief Driving Examiner at its meeting in Edinburgh. Assurances were given that our concerns were unfounded and that there was no need to ‘double click’ to be sure of scoring.

9. The Winter 2003 issue of Despatch says, “Some candidate’s are only clicking once when they first see the hazard and not responding when the situation changes or develops.”

10. Consequently, experienced drivers including instructors and police drivers have found that they score badly in the hazard perception test because they anticipate hazards rather than waiting for them to develop, as the test requires. This means that they are ‘clicking’ when they see a potential hazard and this is regularly before the ‘scoring window’ opens.

11. The Council has advised the DSA of this on numerous occasions but they have neglected to act.

6. No confidence

1. Consequent with the above arguments, the Council has no confidence in either part of the theory test’s ability to assess a candidate’s real and useable knowledge and is, therefore, concerned that driving instructors could lose their livelihood as a result of the failings in the test.

2. The Council also has grave concerns that the exams are detrimental to safety of new drivers and sees no evidence that requiring driving instructors to take these exams will achieve anything more than to make it appear that the Minister is tackling the problem of new-driver-accidents.

7. Balancing accounts

3. The Council is concerned by the Minister’s prediction that 80% of instructors will pass the test and the fees raised from the remaining 20% will offset the cost of the exams for those who pass first time. This strikes the Council as being remarkably convenient accounting.

4. The Minister does not say how he arrives at the figure of 80% of instructors passing the exam first time.

5. If he has any evidence to support this presumption, then he cannot justify testing them. One would have expected him to simply test the 20% he expects to fail.

8. New-driver-accidents

6. The Minister says, “Those in favour of requiring ADIs to undertake a modern HPT assessment suggested that it was important that instructors demonstrably possessed high levels of a skill where research had indicated that weakness was closely associated with accident involvement.”

7. The Council rejects the implication that new-driver-accidents are the result of poor training. It is well established that a major factor in road accidents is driver attitude.

8. Drivers are free to ignore their training after passing the driving test and many are consequently involved in single vehicle accidents.

9. The Minister is being less that honest to suggest that the responsibility for new driver accidents rest with instructors when he and only he has given the new driver the licence to drive.

10. The law requires that a driving test candidate satisfies the examiner that he is “competent” to drive. Presumably, therefore, a candidate who passes has demonstrated that competence.

11. It is difficult, therefore, to argue that a candidate who has passed a driving test has not been properly trained. It must then be conceded that the driving test has failed.

9. Instructional standards

1. The Driving Instructors Scottish Council actively encourages instructors to develop their skills. The Minister has been dilatory in this area.

2. The Minister, “Is responsible for maintaining and checking the standards of all ADIs”.[5] If the quality of instruction is poor as the Minister leads us to believe, he is entirely responsible for it and is guilty of misleading the learning public when he advises them to use an approved driving instructor telling them that, “ADIs must reach and keep up a high standard of instruction”.[6]

3. The Minister is also guilty of misleading driving instructors who regularly submit to checks on their “continued ability to give instruction” and who have believed that passing these checks was an indication that their instruction was still up to that high standard.

4. Since instructors pay for these checks through their registration fees, the Minister’s comments must be seen as an admission that he has been demanding registration fees under false pretences.

10. Conclusion

1. There is no evidence that learner drivers taking the theory test perform any better on the roads than those who did not.

2. There is no evidence that instructors who took the theory tests perform any better than those who have not.

3. There is no evidence that can justify the expense preparing and laying the legislation before Parliament, when the same result could have been achieved through discussion and co-operation.

11. Action

1. DISC encourages every ADI and ADI association to strongly protest through their MPs. Only if the industry unites in this can we have any hope of stopping this unjust and unjustifiable legislation.

2. DISC therefore urges everyone to act now. Do not leave it to others to fight this deceitful, degrading and insulting process.

[1] Contractors responsible for delivering the theory test

[2] “Road Sense”, the official guide to hazard perception

[3] “Road Sense”, the official guide to hazard perception

[4] “Your Driving Test” DSA publication

[5] “Your Driving Test” DSA publication

[6] “Your Driving Test” DSA publication