Have your say on making London's lorries safer: London HGV Safety Permit Scheme

Closed 23 May 2019

Opened 26 Apr 2019

Results Updated 7 Oct 2019

Between 26 April and 23 May 2019, we consulted on the final scheme proposals for our Heavy Goods Vehicle (HGV) Safety Permit scheme, including the permit application process, safe system requirements and enforcement of the scheme. This consultation was the fourth and final consultation on the Direct Vision Standard and the principles of an HGV Safety Permit, alongside consultation on the Traffic Regulation Order (TRO) used to implement the scheme.  

A total of 25 responses to the Phase 2c consultation and statutory notice were received. This included 13 responses from stakeholders. They were overall in favour of the scheme as presented.

Key positive comments included:

  • Improving safety for vulnerable road users
  • Increasing the use of direct vision and safety systems seems like a sensible approach
  • I think lorries should be made safer
  • I support these proposals. I think it is very important to ensure London is dominated by walking, cycling and public transport rather than by HGVs
  • We welcome the introduction of the Direct Vision Standard applied from October 2020 as a first step towards making safer lorries the ‘norm’ in London

A more detailed analysis of the results can be viewed in our consultation report and response to issues raised report.  

Consultation report (PDF 458KB)

Response to issues raised report (PDF 204KB)

Our next steps

The responses received were carefully considered by London Councils Transport and Environment Committee on 13 June 2019. The committee agreed to proceed to make the Amendment Order to implement the HGV Safety Permit Scheme.  

Permits for the scheme will be free of charge and available from 28 October 2019.  Enforcement for the scheme will begin in October 2020.  

Further information is available at www.tfl.gov.uk/direct-vision-standard

Results Updated 19 Jun 2019

On 13 June 2019, London Councils’ Transport and Environment Committee, as the order making authority, considered the responses to this consultation (Phase 2c), before agreeing to proceed to make the Amendment Order to implement the HGV Safety Permit Scheme. The agenda and papers can be found at: https://www.londoncouncils.gov.uk/node/35784

A full consultation report and response to issues raised document will be released in summer 2019.

Results Updated 12 Jun 2019

On 13 June 2019, London Councils’ Transport and Environment Committee, as the order making authority, will consider the responses to this consultation (Phase 2c) before deciding how to proceed with the scheme. The agenda and papers can be found at: https://www.londoncouncils.gov.uk/node/35784

We will update this webpage again once a decision has been made.


Consultation on further Scheme proposals and statutory Traffic Regulation Order (TRO)

In September 2016, the Mayor announced his intention to use the world's first Direct Vision Standard (DVS) for Heavy Goods Vehicles (HGVs) to improve the safety of all road users, particularly vulnerable road users, such as people walking, cycling and riding motorbikes.   

The DVS forms part of the Mayor's Vision Zero approach to eliminating all deaths and serious injuries from London's roads by 2041. Using a star system, the DVS rates HGVs from zero (lowest) to five (highest) stars, based on how much a driver can see directly through their HGV cab windows.  

Research shows that between 2015 and 2017, HGVs were disproportionately involved in fatal collisions with people cycling (63 per cent) and walking (25 per cent) on London’s streets, despite only making up four per cent of the miles driven in the Capital. Restrictions in the HGV driver’s field of vision, or ‘blind spots’, have been identified as a significant contributory factor in collisions, although other factors play their part.  

We have worked closely with stakeholders and industry, using feedback from three previous rounds of consultation to develop proposals on the DVS and its implementation through the HGV Safety Permit Scheme. The Consultation reports and Responses to Issues Raised documents from these consultations are available via the links below.  

On behalf of the Mayor and London Councils we are now seeking your views on our finalised proposals for the Scheme and on changes to the Traffic Regulation Order (TRO) that would be used to implement the Scheme 

Our proposed Scheme would require HGVs over 12 tonnes to hold a Safety Permit to enter or operate in Greater London from 26 October 2020, unless exempt. Permits will be free of charge. They will be issued to vehicles meeting the minimum DVS star rating threshold: one star after 26 October 2020 and three stars from 26 October 2024.  

Vehicles not meeting the minimum star rating threshold, or which have not been rated under the DVS, will need to demonstrate the vehicle will be operated in compliance with a defined safe system to improve its overall safety in relation to people walking and cycling close to the vehicle. These vehicles will be issued Safety Permits with “safe system” conditions requiring the fitting of mitigation measures.  

The proposed safe system includes specific industry recognised mitigating measures such as sensors, camera systems and visual warnings. The safe system would evolve over time, and will be consulted on in 2022 in order to consider any advances in technology.  

Enforcement of the Scheme would be by Automatic Number Plate Recognition (ANPR) cameras whereby vehicles without a Safety Permit, would be issued a Penalty Charge Notice (PCN). There will be additional on-street and intelligence-lead enforcement.  

It is proposed that Safety Permit issuing will commence on a voluntary basis from October 2019 and enforcement of the Scheme by PCN will commence on 26 October 2020.  

Detailed information about our final proposed scheme, the legal copy of our Traffic Regulation Order (TRO) and a full Integrated Impact Assessment are included as part of the consultation material.  

The consultation process to date

A phased consultation approach has been taken at key stages of the development of the Scheme proposals:

Phase 1 (January to April 2017) – we set out the case for HGV driver direct vision and consulted on the Mayor of London’s outline proposals to introduce a DVS for HGVs in London and the principles of the Standard itself. We have considered all of the responses and a full analysis can be found in the Consultation Report and the Responses to Issues Raised document. The responses showed that, in general, there is support for the principle of a DVS.

Phase 2a policy consultation (16 November to 24 January 2018) - we outlined how we set the proposed DVS star rating boundaries and the process by which different options for implementation were assessed and used to develop the preferred HGV safety permit scheme. We considered all of the responses and a full analysis can be found in the Consultation Report and the Responses to Issues Raised document. The responses showed support for the proposed Permit Scheme approach.

Phase 2b – Further scheme proposals (8 January 2019 to 18 February 2019) – we consulted on further HGV Safety Permit Scheme proposals including the Permit application process, safe system requirements and enforcement of the Scheme. We considered all of the responses and a full analysis can be found in the Consultation Report and the Responses to Issues Raised. Feedback from this consultation showed overall support for the proposals.

Listening to consultation feedback, we have made some key change and updates to our proposals and taken them forward to the Phase 2c consultation:   

  • Safe System – we have provided clearer guidance on the requirements for the safe system mitigating measures
  • Progressive Safe System – we have committed to consulting on the progressive safe system in 2022 ahead of its introduction in October 2024
  • Driver Training – we have clarified that driver training, while highly recommended is not a mandatory requirement for obtaining a permit. A list of providers of will be included on the permit application portal
  • HGV Safety Permit – Safety Permits will be issued automatically to HGVs that meet the minimum DVS star rating (one star in 2020) once the online application has been completed. During the pre-compliance year (October 2019 to October 2020) Safety Permits for HGVs not meeting the one star rating or un-rated, and so required to fit the safe system, will be issued within 28 days following approval of the safe system evidence pack. Once enforcement of the scheme begins in October 2020, the turn-around period will be shortened and a system put in place for expedited applications. Further details on this will be communicated later this year. We have also provided details on the appeals process where a permit application is refused.
  • Enforcement – we have provided further guidance on the enforcement process for the scheme
  • Appeals Process – we have provided details on the appeals process regarding any PCN issued under the Scheme   

Phase 2c – Final Scheme proposals and Statutory Traffic Regulation Order (TRO) consultation (this consultation) – this sets out the final package of proposals for consultation, taking into account the feedback from Phase 2b.   

It is proposed the Scheme is implemented by using an existing TRO operated by London Councils in connection with the London Lorry Control Scheme (LLCS). This consultation also includes a statutory consultation on an order (the Amendment Order) to make the necessary changes to the 1985 TRO to accommodate the HGV Safety Permit Scheme alongside the LLCS. This will not in any way change the existing LLCS. If approved, the Permit Scheme will become mandatory from 26 October 2020 and will be able to be enforced by PCN. Any objections to the Amendment Order, clearly specifying the grounds for objecting, must be made by Thursday 23 May 2019 

Next steps  

Once this consultation has closed, we will review and fully consider all of the feedback received.  

We then plan to submit the final proposals for the HGV Safety Permit Scheme and implement the scheme.    

Supporting documentation

Consultation document - (this consultation Phase 2c) (PDF 401KB)

Appendix 1 - Definition, production & validation of DVS for HGVs (PDF 7.44MB)

Appendix 2 - HGV Safety Permit Guidance for operators (PDF 189KB)

Appendix 3a - DVS Integrated Impact Assessment cover note (PDF 198KB)

Appendix 3b - Integrated Impact Assessment of the preferred scheme (PDF 1.06MB)

Appendix 4 - Phase 2b cost and business impact assessment report (PDF 445KB)

Appendix 5 - Heavy Goods Vehicle survey (PDF 1.66KB)

Appendix 6 - HGV Safety Permit exemptions list (PDF 36KB)

Appendix 7 - HGV Safety Permit evidence of effectiveness (PDF 3.35MB)

Appendix 8 - DVS Phase 1 Consultation Report (PDF 387KB)

Appendix 9 - DVS Phase 1 Response to Issues Raised PDF 39KB)

Appendix 10 - DVS Phase 2a Consultation Report (PDF 849KB)

Appendix 11 - DVS Phase 2a Response to Issues Raised (PDF 74KB) 

Appendix 12 - DVS Phase 2b Consultation Report (PDF 901KB)

Appendix 13 - DVS Phase 2b Response to Issues Raised (PDF 344KB) 

Appendix 14 - Notice of proposal for Amendment Order (PDF 133KB)

Appendix 15 - Greater London Traffic Order 1985 amendment Order 2019 (PDF 217KB)

Appendix 16 - Copy of 1985 Traffic Order (PDF 18KB)

Appendix 17 - Copy of 1985 Traffic Order with Amendment Order changes (PDF 132KB)

Appendix 18 - Copy of statement of reasons for Amendment order (PDF 138KB)

Appendix 19 - Copy of proposed LLCS & HSP scheme policy statement (PDF 177KB)

Appendix 20 - Copy of proposed HGV Safety Permit conditions (PDF 186KB)

Appendix 21 - Map of roads affected by Amendment order (PDF 237KB)

Have your say

If you have any comments on the final proposals for the HGV Safety Permit Scheme please complete the short online survey below. If you wish to object to the Amendment Order please clearly specify your grounds for doing so.  

Alternatively, you can email us at consultations@tfl.gov.uk with Direct Vision Standard consultation phase 2c in the subject line or write to us at FREEPOST TfL consultations.

Please give us your views by Thursday 23 May 2019 

Paper copies of all the consultation materials can be requested by emailing consultations@tfl.gov.uk, or writing to FREEPOST TfL consultations.


  • All Areas


  • Anyone from any background


  • Safer Lorries
  • Direct Vision Standards