General remarks. 1 IRTAD is a permanent Group on Road Safety Data and their Analysis of the International

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1 IRTAD s remarks on WHO Discussion Paper Developing voluntary global performance targets for road safety risk factors and service delivery mechanisms (version 14 February 2017) 1 IRTAD welcomes the initiative of the World Health Organization to draft a Discussion Paper on developing voluntary global performance targets for safety performance indicators and delivery mechanisms. The subject of collecting and monitoring relevant safety performance indicators has been at the core of IRTAD s work since its creation. During October 2016, IRTAD launched a Working Group on Safety Performance Indicators, which aims to review and summarise current practices; identify key commonalities in definitions, methods and procedures; and produce a number of recommendations for achieving the goal of having scientific-based comparable indicators at the international level. IRTAD offers its capabilities to further elaborate the recommendations included in the discussion paper, cooperate with WHO on the further development of the process of target setting, and participate in the development of the announced guidelines on data collection. General remarks We propose to reconsider the formulation of the title of the Discussion Paper, and in particular the term road safety risk factors, since it does not seem to be appropriate given the core areas that the targets are intended to address. Setting targets for achieving safer roads and mobility, safer vehicles and safer road users implies a sense of positivity that is somewhat lost in the current title. Targets for safety performance indicators seems more neutral and conceptually correct. The principles of Safe System are a starting point for WHO for road safety improvements in all countries in the world, and they are at the core of initiatives such as the Plan for the Decade of Action. IRTAD welcomes this, but there are doubts about the way that these principles have guided the Discussion Paper. By way of an example, it is not obvious that a three-star road, using irap ratings, can be regarded a safe road from a Safe System perspective. In its present form, the Discussion Paper places most emphasis on the setting of targets, and little on the quality of safety performance indicators. Examples of this are the definition of indicator on point 18, as well as points 16 and 17, where the logical time sequence for developing targets seems to have been reversed: point 16 sets criteria for developing targets, and point 17 states that for each voluntary global target one or more 1 IRTAD is a permanent Group on Road Safety Data and their Analysis of the International Transport Forum. It gathers around 80 members representing governmental agencies, safety research institutes, universities, NGOs, industry and others from 40 countries. 1

2 indicators will need to be developed. We believe that safety performance indicators constitute a crucial tool for describing (and perhaps explaining) progress in the number of road crashes and casualties, as well as selecting and evaluating road safety measures. Countries should be encouraged to collect these indicators according to the best available methods, and to use them beyond target setting. It is understood that this Discussion Paper tries to encourage all countries in the world (point 7). Because major differences between them can be observed, it will not be easy to set identical meaningful targets that at the same time will be considered ambitious and realistic for every individual country. IRTAD recommends considering working with regionspecific targets, reflecting the differences between stages of development in the different regions in the world. The use of improvement targets (e.g. 10% per year) seems to be an attempt to address regional differences instead of working with absolute values of indicators. IRTAD recommends to further elaborate the idea of working with regional targets, and also with regionalised safety performance indicators. We have doubts about the feasibility of using 2018 as baseline. This seems to be incompatible with the fact that the final agreement on targets is due in November 2017 (point 14), and that enough time is needed for developing the guidelines on data collection by technical experts (footnote 11 and carry out measurements. IRTAD recommends using 2018 to develop common methodologies on how to measure safety performance indicators, and that countries be encouraged and supported to measure a new baseline in IRTAD has the view that a common methodology that is widely (universally) used is the only opportunity to get comparable results for participating countries. Moreover, from an efficiency perspective, a common methodology is to be preferred, compared to a situation in which every individual country develops its own set of indicators and measures them individually and most probably differently. An important aspect of monitoring progress is how frequently safety performance indicators should be measured. The reporting frequency of five years proposed on point 21 seems to be too long to allow a convenient monitoring, particularly considering the time frame of barely more than ten years. On the other hand, since the frequency might be related to the complexity/costs of collecting each indicator, perhaps it should be discussed to arrive at an appropriate frequency for every individual indicator. IRTAD recommends that countries collect before and after values of safety performance indicators whenever a new road safety measure is implemented to affect drivers behaviour. General criteria for SPIs IRTAD considers Defining and monitoring voluntary global performance targets (page 5) as a key component of this Discussion Paper, and suggests to elaborate more on the issues raised on this section. IRTAD recommends to draft an Annex to the document that: Further operationalises in a comprehensive and concise manner all relevant background and definitions. 2

3 Elaborates on the relationship between criteria set on point 16 and target values proposed in table 1. Is the target of reducing by 10% the proportion of vehicles exceeding the speed limit consistent with our knowledge of the effectiveness of available road safety measures for speed management? Should countries look at past national trends of safety performance indicators when setting targets? How has the need for evidence of achievability at the country level been taken into account? Similarly, elaborates on the relationship between criteria on point 17 and selected safety performance indicators. Gives definitions of outcome indicators and intermediate indicators. Stresses the need to systematically use safety performance indicators in road safety strategies. Every road safety action needs to have an associated indicator to monitor progress and assess effectiveness. These indicators need not necessarily be among the ones selected on table 1, as long as they meet the required criteria. In general, IRTAD recommends including all definitions within this Discussion Paper and not to refer to another document, such as the WHO Global status report. Road safety management To have an action plan and to have a lead agency are important components of road safety management. IRTAD recommends to be more specific on both items and to indicate something about the quality of a plan and organisational structure. A good plan in itself is not enough, it is important to assess if it is really implemented and how progress of implementation is monitored. Additional important aspects include the existence of local, regional and national bodies for the coordination of activities related to road safety, evidence-based management of road safety and the existence of permanent funding sources. The World Bank report of Bliss and Breen (2009) is an important reference in this topic. Safer roads The infrastructure related SPI is fully based on irap ratings. Road authorities in several countries and road safety professionals have expressed concern about this approach. IRTAD recommends to assess if this concern is justified before decisions are being made on an infrastructure-related SPI. It should also be noted that in many countries these ratings do not cover the whole network. The indicator on new roads explicitly refers to the irap system, but the Discussion Paper includes also the comment or another equivalent system of rating, leaving room for other similar assessment systems. This could be used by countries that have developed their own assessment systems, but then the question of comparability arises, i.e. what is the equivalent of 3 stars in the systems adopted by a given country? An alternative to these issues could be to use indicators and targets referring to specific road features; examples may include: % of existing roads with a speed limit of 100 km/h or higher that have two carriageways separated by a median barrier; % of existing roads with a speed limit of 100 km/h or higher that are prohibited to pedestrians and comprise grade-separated 3

4 crossings for pedestrians; % of rural roads network equipped with safety barriers. The application of technical standards in the design and construction of roads may also be considered. The indicator on the whole network again refers to irap ratings, and presupposes the availability of these ratings for the whole network, which, as aforementioned, it is not always the case, next to questions related to the validity of RAP-ratings for individual countries. It also presupposes the availability of exposure data (kilometres driven, traffic volume) for all road user categories. Unfortunately, many countries do not have this kind of data. Finally, if irap assessments are to be used, it is recommended to revisit the idea of using a three-star road as a target, based on the perspective of Safe System thinking. Safer vehicles IRTAD supports the idea to produce only safe vehicles, by meeting specific UN Regulations. However, this only affects countries that have not yet adopted UN Regulations on vehicle safety. Furthermore, the proposed indicators cover only new sold vehicles. Consideration should be given to the technical status of used vehicles, comprising both already existing vehicles in the national stock and used vehicles imported from other countries. IRTAD proposes to develop a new perhaps more sophisticated safety performance indicator for all countries in the world. For this purpose, the following data might be of value: Equipment rate of vehicles in stock with certain acknowledged driver assistance systems or vehicle safety systems. Results from technical inspections, covering essential safety aspects (brakes, seat belts, suspension and steering). Age structure of the vehicle fleet. Lastly, it should be noted that no consideration is given to powered two-wheelers, which represent a large share of the national vehicle fleets of many low- and middle income countries, and also reflects a serious road safety problem in many of these countries. IRTAD recommends to include powered two-wheelers in a vehicle related performance indicator. Safer road users We believe that targets for safer road users should address: quality of legislation, actual behaviour and preventive actions. Actual behaviour and, to a certain extent, quality of legislation are considered in the Discussion Paper. We propose expanding the set of indicators to include preventive actions, for instance by using the classical three E s scheme: enforcement, education and engineering. We also believe that a recommendation should be made for countries to collect disaggregated safety performance indicators by type of road (outside/inside urban areas) and type of vehicle. More attention should be paid to vulnerable road users, whose importance is indeed acknowledged in the background of the Discussion Paper. This could be achieved, for example, by introducing specific indicators related to children and perhaps elderly road users: use of 4

5 child restraint systems, actual behaviour, school zones, facilities for pedestrians and cyclists residential zones (traffic calming), cycle lanes. Reducing speeding Regarding the indicator on national legislation, IRTAD supports the idea of considering speed limits not only on urban roads, but also on rural roads. The indicator on actual behaviour that has been chosen (% over speed limit) largely depends on the speed limit in a country. Countries with low speed limits might have a higher noncompliance rate than countries with higher speed limits and still be safer. This might also be the case of alcohol related indicators. Reducing drinking and driving IRTAD suggests to use an indicator for drinking and driving based on the share of exposed drivers with a BAC over the limit. Data should come from police checks using a sound sample. Only if good statistics are available in a country, would it be feasible to to develop a SPI on crash statistics. Consequently it is important to understand that a target/spi cannot be simply the proportion of road deaths related to alcohol divided by the total number of road deaths. This ratio also comes down if the number of alcohol-related fatalities increased and the number of other fatalities increased with a higher rate. Therefore, the target should be more correctly based on the absolute number of fatalities. Furthermore, the wording proportion of deaths attributable to alcohol might imply a subjective assessment on causality; it might be better to measure if active participants in a road crash are over a legal limit. Based on the above,, we suggest rewording the target as Reduce by 10% per annum the number of fatalities in alcohol-related crashes or to reduce by 10% per annum the number of kilometres travelled under the influence of an illegal BAC. Post-crash response The target and the indicator on "the average time from serious injury to first contact with emergency care provider" seem too simplistic to represent a complex phenomenon. Moreover, a clear definition of emergency care should be provided. The target specifies an annual decrease regardless of the initial value of this indicator; but contrary to other indicators one cannot expect this one to approach zero. The document should encourage each country to define its own target time taking into account local conditions, and then regularly monitor this indicator. 30 April