Call for evidence on Home Office type approval of road traffic law enforcement devices: background information and responses to questions
Updated 26 April 2024
Applies to England, Scotland and Wales
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About the call for evidence
Background
Home Office Science is responsible for delivering services to support the assurance of equipment used in frontline policing and other operational environments. The core services include:
- Home Office type approval (HOTA) which covers road traffic enforcement devices such as speedmeters and breath testing equipment
- certification of Personal Protective Equipment (PPE) where Home Office Standards exist, for example body armour and fire-retardant overalls
The operating model for the delivery of these assurance services has evolved over several decades and opportunities for improving the system have been identified.
A programme of work has been established to review current approaches and implement a more cost-effective and resilient operating model that fosters innovation and delivers robust assurance of equipment.
Scope
This call for evidence (CFE) is to support a review of HOTA of Road Traffic Law Enforcement Devices (RTLED) used by the police and other law enforcement agencies in Great Britain. The CFE is designed to gain insights into stakeholder experiences of HOTA and to invite any suggestions for improvements that the Home Office could consider.
HOTA provides assurance that the device is accurate, precise, consistent and reliable and that its evidence can be relied on. Under section 20 of the Road Traffic Offenders Act 1988, in proceedings concerning certain traffic offences [footnote 1] records or measurements made by equipment for traffic law enforcement can be admissible as evidence subject to the following conditions: the equipment is a type approved by the Secretary of State, and that any conditions subject to which the approval was given are satisfied.
The scope of this CFE will cover RTLEDs as described in The Speedmeter, Traffic Light and Prohibited Lane Enforcement Camera Handbook v2.0. The Handbook contains a description of the technical requirements to be met for consideration of type approval of certain types of speed, traffic light and prohibited lane enforcement equipment which are prescribed devices for the purposes of the road traffic legislation.
HOTA of breath testing devices and drug-testing devices are out of scope of this CFE.
Details
The CFE was launched on 15 January 2024 and will close at 11:59pm on 14 February 2024.
We would like to hear from a broad cross-section of stakeholders that are involved in road traffic enforcement, users of HOTA devices and road safety charity organisations. We would particularly welcome responses from organisations who are involved in the supply and testing of HOTA RTLED devices.
The CFE is open to the public and we would welcome suggestions of who else we can contact. We will ensure that we inform organisations representing victims from road incidents of this CFE.
We also invite you to share and advertise the CFE with others who may benefit by answering this CFE.
Welsh language version
A Welsh translation of the survey is available. Please download and email your response to sandtassurance@homeoffice.gov.uk before the deadline 11:59pm on 14 February 2024.
General questions and answers
1. I don’t currently supply HOTA equipment, but I am considering it, should I respond?
Yes, we would welcome views from organisations considering HOTA.
2. What topics does the call for evidence cover?
The call for evidence is split into the following sections:
1. contact details and type of organisation you belong to
2. information on your organisation (intended to be completed by organisations that provide HOTA products and services)
3. evidence on the impact of HOTA on road safety
4. your experience of HOTA processes
5. your experience of HOTA testing requirements and guidance
6. suggestions for improvement that you would like the Home Office to consider
7. any other information you would like to make the Home Office aware of
3. Why do we need an RTLED call for evidence?
The CFE will ensure that information can be elicited from stakeholders in an open and transparent manner and that evidence can be properly assessed and considered by the Home Office.
4. Why does the call for evidence ask for information about me and my organisation?
If we have this information we can better understand your perspective and, if relevant, the market place under which you operate.
We may wish to ask you further questions about your feedback and will use the contact information provided to facilitate this, but only with your consent.
5. Do I have to respond to every question?
No. There are no mandatory questions.
6. Will my responses prejudice any current or future HOTA applications?
No.
7. What will happen once the survey ends?
The information which has been collected will be evaluated by the Home Office and a summary report of the feedback will be published. The timescale for producing the report will depend upon the volume of responses which are received.
We also intend to hold another event with Intelligent Transport Systems UK to discuss these findings with interested parties.
8. Will all suggestions for improvements be taken forward?
We will carefully consider all suggestions from respondents; this will be used as evidence for alternative models and approaches.
We cannot commit to taking forward all suggestions.
9. Will commercially sensitive information submitted be subject to release under the Freedom of Information Act?
Under the Freedom of Information Act 2000 (FOIA) we might be asked to release the data that you have provided to us under a Freedom of Information request. Any individual has the right to request recorded information which is held by a public authority under the FOIA. The FOIA contains various exemptions and exclusions from the right of access to information that ensure a proper balance is achieved between the right to know, the right to personal privacy, the delivery of effective government, and other important private interests such as protection of commercial interests, and information provided in confidence.
Whilst the Department handles FOIA requests on a case-by-case basis, we shall consider engaging the relevant exemption(s) in the Act to withhold any information that may be commercially sensitive and / or where to release such information would be a breach of confidence but will respond to any FOI in accordance with the legislation.
If you want your response to be considered as commercially sensitive or as having been provided in confidence, please mark it as such but we cannot guarantee that the exemption(s) in the FOIA can be utilised in all circumstances.
Data that you tell us is commercially sensitive and provided in confidence will be stored securely and deleted once no longer required. All reports containing such data will be reported only in aggregate, anonymous form.
Questions and answers from engagement event
A CFE engagement event was held on 17 January 2024.
1. Will the benefits of the programme’s investment be captured? It is a challenge to express some benefits as cashable benefits, for example saving lives.
Yes. The CFE will gather the baseline evidence needed to build a business case for a new and sustainable assurance operating model. This will include qualitative and quantitative evidence of HOTA, both on road safety outcomes and economic factors.
The business case will then identify expected benefits and measures so this can be monitored and evaluated.
2. Defence Science and Technology Laboratory (Dstl) engagement and response times feel like the major bottleneck in the HOTA process. What is the Home Office vision for improving this?
We’ve set out our vision for the programme which is to collaboratively design and implement a sustainable assurance system for operational equipment. Any new operating model would need to address key challenges around resourcing, capacity, and demand. We will seek to deliver this iteratively so stakeholders benefit from early improvements.
Dstl are key partners in delivering the programme and are proactively working with the Home Office to identify and introduce rapid improvements – for example streamlining internal processes, training more people, and reviewing the HOTA Handbooks that this CFE will feed into.
3. Are Dstl involved with this review process as they are a key stakeholder? Is the Home Office open to consideration of the use of alternative assurance services?
Dstl are a strategic partner for the Home Office and closely involved with this work, including membership of our governance board. They are working closely with us to implement improvements and develop strategic options for the programme, including the use of alternative assurance services.
Working with Dstl and other partners we are open to exploring the possibility of using other providers.
4. Please can you clarify the scope of the call for evidence: does it just address criminal offences, or would it also have implications for civil offences and certification of approved devices?
The Home Office supports all aspects of improving road safety, however our core remit is around enforcement and prevention of motoring offences as outlined under section 20(2) of the Road Traffic Offenders Act 1988.
We recognise that the technologies used to facilitate both criminal and civil enforcement will in some cases be similar and would welcome feedback on areas of alignment.
5. The level of investment needed in HOTA drives up product prices and there is a high barrier to entry, could it be a priority to reduce the cost of the HOTA process?
It is a priority to have a sustainable cost model for HOTA, and we are keen to understand more about the distribution of costs in the supply chain.
We hope through the CFE to create a baseline picture from which we can develop options for a sustainable operating model.
6. I am involved in type approval in New South Wales, Australia, and dealing with the same constraints as yourselves; are you open with sharing outcomes and lessons learnt with overseas agencies?
We will summarise the results from the survey and publish them on GOV.UK.
We are open to discussions and sharing lessons and best practice with international partners, especially where there is alignment on policy objectives.
7. Would an evaluation of using test results from other European test institutes, as for example NMI [footnote 2] or METAS, [footnote 3] be possible to lower costs for approvals and speed up the processes?
We already work with organisations such as NMI in the Netherlands and are open to considering options for working with international partners where policy objective and standards align.
8.One key issue which requires intervention is clarifying which test houses the Home Office and Dstl will accept test reports from. There is a very outdated list of ‘accepted’ test houses which restricts manufacturers from using alternative UKAS test houses.
Thank you for raising this.
We are aware that there are some restrictions in the current system, we are looking to make rapid improvements to ease bottlenecks and will review this as soon as possible.
9. Will you be happy to use this forum to keep industry up to date with progress?
Yes, absolutely, we aim to reach as many people as we can.
10. Will the Home Office prioritise approval based on pull demand from the police?
Any sustainable operating model would need to be designed to scale to match demand from end users to the volume of applications for either new or modified devices from manufacturers.
Working with end users, part of our vision is to make priorities and operational requirements clearer to industry to foster innovation and give an indication of demand.
11. I have a question about this CFE, who should I contact?
Please email your enquiry to sandtassurance@homeoffice.gov.uk