Proposals to Amenddriving Licence Standardsfor Vision, Diabetes and Epilepsy: Annex III

Proposals to amend driving licence standards for vision, diabetes and epilepsy: Annex III to Directive 91/439/EEC and 2006/126/EC

Response from Brake, the road safety charity 7 March 2011

About Brake Brake is an independent road safety charity, dedicated to stopping death and injury on UK roads and caring for people bereaved and seriously injured in road crashes. Brake carries out research into road users’ attitudes on a range of road safety issues, delivers road safety education to thousands of people in their communities, and provides a range of services for road safety and fleet safety professionals. These include news bulletins, information sheets, workshops and conferences that disseminate international research and information on effective policies and best practice initiatives.

Introduction

Having good eyesight is one of the most fundamental requirements of safe driving. Being an experienced, responsible and skilled driver is meaningless if you are unable to spot hazards in time due to poor eyesight. Poor driver eyesight kills, and each death is devastating to the people involved. These deaths are also costly: the average economic value of preventing each death on our roads is £1.6 million1.

Although the exact extent of casualties resulting from defective driver eyesight is not known, the impact of poor eyesight on a person’s ability to drive safely, and therefore their crash risk, is well documented through academic research.2 In addition, Brake has numerous case studies of deaths and injuries that have resulted from poor driver eyesight, including accounts of the devastation caused to families.

Because the stakes are so high, it is vitally important to ensure that all drivers have an appropriate standard of visual acuity and field of vision, and are not suffering from conditions that hamper safe driving. In order to achieve this, regulatory changes to bring the UK into line with the EU Directive should address the non-scientific method that is used to test driver eyesight in the UK. Determining acceptable standards of sight that are required for drivers to be considered safe on the roads is meaningless unless drivers are tested accurately for these standards and tested regularly to ensure they continue to meet them.

Brake therefore recommends that all drivers should be required to have their eyes tested by a qualified medical practitioner for visual acuity and field at the start of their driving career (ideally before obtaining a provisional licence) and thereafter at regular intervals of at least every 10 years, but ideally more often. At the very least, drivers should be required to produce evidence of a recent eye test covering the above elements at the same time as renewing their licence photocard on a 10 yearly basis.

1 Road Casualties Great Britain 2009, DfT, 2010 2For example, Johnson, C.A., & Keltner, J. L. (1983). Incidence of visual field loss in 20,000 eyes and its relationship to driving performance. Archives of Ophthalmology, 101, 371-375. Brake also disagrees that the standards for visual acuity should be reduced as a response to the EU Directive; the visual acuity standards stated in the Directive are a minimum level, not a stipulation. The Directive should be used as an opportunity to strengthen regulation on driver eyesight for the benefit of road safety, not to weaken it.

ANNEX D We propose to implement regulatory and administrative changes to introduce the revised standards. Question 1 - Vision Do you agree that these new standards should be applied? Yes......  No ...... x

If you disagree your views should be supported with the appropriate scientific evidence. Please attach that to your response.

Regulatory changes to bring the UK into line with the EU Directive should address the inadequate method currently used to test driver eyesight in the UK, since the Directive states than an appropriate assessment should be in place to ensure drivers have adequate visual acuity to drive safely. Brake also disagrees that the standards for visual acuity should be reduced as a response to the European Directive.

Why the number-plate test is inadequate The number-plate test is not a scientific method of testing visual acuity, and it cannot test for other aspects of vision that are important for safe driving, such as field of vision.

There is significant academic evidence that the number-plate test is not an accurate test of how well a driver can see distance3. It is not standardised, nor validated, so cannot deliver consistent results. Depending on the sequence of letters and numbers in the number plate, and conditions such as weather and lighting, the ease of reading it will vary4. The scientific and established method for testing visual acuity is the Snellen test, which is not currently a requirement for drivers.

The International Council of Ophthalmology recommends that driver eyesight tests be performed by an ophthalmologist and include visual acuity, visual field, contrast sensitivity, glare sensitivity and ocular motility5.

The proposed amendments do not address the fact that the majority of class one drivers are never tested for visual field, as the EU directive mandates they should be. The number-plate test only checks for visual acuity, and it is not an accurate measure of this.

3 Visual acuity and legal visual requirements to drive a passenger vehicle, Kiel AW, Butler T, Alwitry A, 2003, an d Currie Z, Bhan A, Pepper I, (2000) Reliability of Snellen charts for testing visual acuity for driving: prospective study and postal questionnaire. BMJ 321, 990-992, and Charman WN (1997) Vision and driving – a literature re view and commentary. Ophthalmic and Physiological Optics, 17 371-391. 4 Eye Health Alliance, 2011 5 The 30th World Ophthalmology Congress Sao Paulo, Brazil, International Council of Ophthalmology, 2006 Brake’s recommendation on the method of eyesight testing Brake recommends that all drivers have to provide evidence from an qualified medical practitioner that their eyesight meets minimum standards, including for visual acuity using the Snellen test and visual field. Other European countries already have this regulation in place such as the Republic of Ireland and Finland. Optometrists could also test for contrast sensitivity, glare sensitivity and ocular motility which are all important for safe driving6, and some of which the proposals recommend including in future regulation.

Why regular testing is important For class one drivers there is currently no regulation to ensure that their eyesight meets minimum standards specified by the directive throughout their driving career. Class two drivers are subject to more rigorous standards and testing, but Brake is concerned that the classifications themselves are increasingly blurred. Many people who drive for work on a regular or even daily basis, such as couriers or sales people, are not subject to the same level of testing or sight standards as group 2 drivers, yet still have greater exposure to risk than those who do not drive for work.

Once group 1 drivers have passed their test, they are only required prove that they can see well enough to drive safely and to the minimum standards set out in the directive in a very limited number of circumstances, such as if they self-report that they have an eye condition to the DVLA. This reliance on self-reporting is an ineffective way to ensure that all drivers have safe standards of eyesight throughout their driving career. Research shows that people may lose up to 40% of their sight before they even realise they have a problem7. Surveys have also shown a lack of understanding among drivers of the vision standards required of them.8 A system of self-reporting also leaves the door open to drivers who know they would fail the test, but are worried about losing their licence and so deliberately fail to report.

Brake’s recommendations on regular eyesight testing The only way to make sure that drivers still have adequate vision in the years after they pass their test is to make eye sight testing mandatory at intervals throughout the time that they hold a licence. Brake recommends that drivers should have to provide proof that they have had their eyes tested by a medical professional and that they meet minimum standards for visual acuity and field on a regular basis. This should happen at least every 10 years, coinciding with drivers renewing their photocard. This would be a simple and inexpensive step that would vastly improve driver eyesight in the UK. Brake also recommends that once drivers reach the age of 70 and have to self-certify that they are fit to drive, they should be required to submit evidence from a medical professional that they have a safe and legal level of eyesight.

As a secondary measure, Brake also recommends that the Department for Transport conducts widespread publicity campaigns to encourage drivers to have their eyes tested by every two years, which is the regularity for testing recommended by the

6 Eye Health Alliance, 2011 7 World Glaucoma Day, International Glaucoma Association and Royal National Institute for the Blind, 2009 8 Pointer JS (2007) Poor recognition of the UK minimum driving vision standard by motorists attending optome tric practice. Ophthl. & Physiol. Opt. 27 238-244 NHS9. Brake also recommends that the DVLA includes a clear reminder to drivers that they should get their vision checked at least every two years when they are renewing their tax disc (online or in paper format).

Why standards for visual acuity should not be reduced The European Directive calls for visual acuity of no less than 0.5. It does not call for the standardisation of visual acuity at 0.5. Commission Directive 2009/113/EC states that “the Member States are allowed to impose standards that are stricter than the minimum European requirements, as laid down in Annex III point 5 to Directive 2006/126/EC”.

Brake is concerned that this directive should not be seen as an opportunity to reduce the minimum standards for driver eyesight given that the stakes are so high.

The proposed lower distance of the number-plate test, 17.5 metres, is equivalent to the stopping distance of a vehicle travelling at just 25mph. This would be a decrease of one-fifth of the current distance. Brake does not understand the logic of lowering existing standards, when steps are clearly needed to strengthen the system, to ensure compliance with the Directive, and to contribute to safer driving and safer roads for everyone.

Question 2 – Diabetes Do you agree that these new standards should be applied? Yes...... x (see clause) No ......  Brake would only support aspects of the new standards that relax the rules if consult ation with medical experts confirms that there won’t be a negative impact on road saf ety.

If you disagree your views should be supported with the appropriate scientific evidence. Please attach that to your response.

Question 3 – Epilepsy

Do you agree that these new standards should be applied? Yes...... x (see clause) No ......  Brake would only support aspects of the new standards that relax the rules if consultation with medical experts confirms that there won’t be a negative impact on road safety.

If you disagree your views should be supported with the appropriate scientific evidence. Please attach that to your response. Thank you

Further comments:

Section 5.1 Other changes

9 Look after your eyes, National Health Service, 2011 This section mentions other minimum standards for medical conditions that must be met to obtain a licence.

As well as recommending that drivers should be required to undergo regular, professional eyesight testing, Brake recommends regular testing for obstructive sleep apnoea (OSA), particularly among class 2 drivers.

OSA is caused by obstruction to airflow during sleep. It causes suffers to frequently wake up during the night to re-start breathing. The condition is more likely in obese people and people with weak muscles around the airways, which can be associated with diabetes. OSA sufferers are often tired during the day and are more likely to fall asleep at the wheel and lose control of their vehicle. Sleep-related crashes often result in death or serious injury, as they tend to occur at high speeds, with the driver is unable to take any preventative action, such as braking, before the collision. OSA suffers are seven times more likely to crash than non-sufferers.10

Research suggests that OSA is particularly prevalent among class 2 drivers due to sedentary lifestyles meaning higher obesity rates. Undiagnosed OSA may affect nearly one in six lorry drivers11. Up to 80,000 HGV drivers in the UK may be putting their own lives and the lives of others at risk by driving while suffering from sleep apnoea12. OSA is an easily treatable condition once it is diagnosed, but the UK lacks regulation to ensure that drivers, especially class 2 drivers, are routinely tested.

10 Sleep Apnoea Trust, Website: www.sleep-apnoea-trust.org 11 Howard, Mark E., Desai, Anup V., Grunstein, Ronald R., Hukins, Craig, Armstrong, John G., Joffe, David, Swan n, Philip, Campbell, Donald A. and Pierce, Robert J. ‘Sleepiness, Sleep-disordered Breathing, and Accident Risk F actors in Commercial Vehicle Drivers’, American Journal of Respiratory and Critical Care Medicine, 2004: 170, p p. 1014-21 12 Based on DfT figures showing there are approximately 500,000 active HGV drivers in the UK