Call for evidence outcome

Call for evidence summary: Home Office type approval of road traffic law enforcement devices

Updated 26 April 2024

Executive summary

This Call for Evidence (CFE) is part of a programme of work which has been established by Home Office to review the assurance services for equipment used in frontline policing and other operational environments. 

The scope of this CFE was to review the Home Office type approval (HOTA) assurance of road traffic law enforcement devices (RTLED). 

Through multiple choice and open questions, the CFE gathered information pertaining to the HOTA RTLED economic environment; how HOTA supports road safety outcomes; the experiences of participants with regards to the testing requirements, documentation and business processes; and suggestions for improvement.

The CFE was open to responses between 13 January, 2024 and 14 February, 2024.  A total of 35 responses were received from a range of stakeholders representing government organisations, end users, suppliers and charitable organisations involved in road safety.  The responses have now been reviewed and analysed.  This document provides a summary of the responses received.

The survey’s results suggest that the HOTA system has strengths, namely being sufficiently robust to support law enforcement outcomes and engender public trust in the evidence from RTLED equipment.  However, respondents felt time delays and process inefficiencies are hindering HOTA, expressing a desire for improvements in collaboration, communication and documentation.

The detailed evidence and insights gained from this CFE will inform recommendations to improve the HOTA RTLED assurance system which will be taken forward by the programme working closely with our stakeholders.

Introduction

The Home Office is responsible for the assurance of equipment used in frontline policing and other operational environments.  The core services include:

• 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, irritants 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 sustainable and resilient operating model that fosters innovation and delivers robust assurance of equipment.

This CFE will support a review of HOTA of RTLED used by the police and other law enforcement agencies in Great Britain (which covers England, Wales and Scotland). The CFE was designed to gain insights into stakeholder experiences of HOTA and to invite any suggestions for improvements that the Home Office could consider.

The scope of this CFE covers 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 road traffic legislation. HOTA of breath testing devices and drug-testing devices were out of scope of this CFE.

The Home Office launched CFE on 13 January 2024 and it closed on 14 February 2024.  The survey asked 19 questions across categories covering:

• Respondents details
• HOTA RTLED economic environment
• Impact on road safety outcomes
• Experiences of the HOTA RTLED process
• Experiences of the HOTA RTLED testing requirements and guidance
• Improvements to the HOTA RTLED end-to-end process
• Any other evidence

Questions within the CFE were discretionary.  Responses were reviewed and will help to inform the Home Office’s consideration of potential short and longer-term improvements to the HOTA RTLED system.

Acknowledgements

The Home Office would like to thank all respondents to this CFE and the National Police Chiefs’ Council Roads Policing Portfolio, Road Safety Support and Intelligent Transport Systems UK who supported the CFE activity.

Summary of responses

The Home Office received 35 responses to the CFE. Of these, 34 were received from public and private organisations, and one was received from an individual.

By organisation category, and noting that some organisations are associated with more than one category, the number of responses received to the survey were:

Organisation	Responses
Direct end user *	16
Equipment manufacturer	9
Third sector organisation	6
Other government organisation	3
Equipment agent / supplier	2
Testing facility	2
Other	2
Standards organisation	1
Other industry partner	0

*identified as a stakeholder who directly utilises RTLED to facilitate activities

Responses to the HOTA RTLED economic environment

A sequence of questions in this category sought to understand the economic environment under which organisations operated.  The questions were intended for organisations who provide HOTA RTLED products and services.  The following represents a summary of the information received:

• The majority of respondents (62.5%) were from large organisations who have more than 250 employees.  The other respondents were evenly split between micro (<10 employees), small (<50 employees) and medium (<250 employees) companies.
• The CFE received responses from UK-based organisations and from organisations who are based in international locations, including Australia, the EU and the USA.
• The majority of respondents (60%) said that they utilised a UK agent for HOTA equipment support.
• Most respondents (55%) said that their company marketed RTLED in the UK and overseas.  Some respondents (33%) indicated they market RTLED in the UK only.
• Nearly half of respondents (43%) stated that their HOTA RTLED revenue in FY 2021/22 was from UK sales only and the same amount stated that this was from overseas sales only.

The following are the benefits respondents felt HOTA brings:

• HOTA provided credibility for products: a means of demonstrating that organisations had met high standards of accuracy and reliability
• facilitated market entry and expansion by offering a competitive edge and reassured UK and international clients of product compliance with stringent requirements
• historically, having a HOTA product facilitated a fast-tracked type approval in other countries.

Conversely, several responses commented on the diminishing reputation of HOTA, due to what were perceived to be overly stringent and outdated requirements.  Also, it was noted that although a device was fit for purpose in the UK, it may have technical limitations for requirements in overseas markets.

Responses to impact on road safety outcomes

Question: “How are road safety outcomes affected by the HOTA system in relation to RTLED?”  

The evidence from the survey indicates that HOTA is relied upon for court prosecutions and for identifying drivers who may benefit from education to improve their road safety.

The responses show that the deployment of HOTA RTLED equipment has positive impacts such as:

• a reduction in recorded collisions
• an observable shift in driver behaviour
• speed compliance; and
• a meaningful contribution to Vision Zero ^{[footnote 1]} and other road safety targets

Respondents noted that HOTA is trusted and relied upon by:

• law enforcement agencies for the purpose of improving road safety
• the public as a means of producing robust and accurate information
• the judicial system to provide robust evidence in court prosecutions; with associated benefits being a reduction in the number of appeals and a reduction in costs from the involvement of law enforcement agencies (LEAs) and expert and technical witnesses; and
• the National Driver Offender Retraining Scheme (NDORS) to identify drivers who may benefit from participating in their education schemes to potentially change driving behaviour and improve road safety

Several emerging challenges and opportunities for the HOTA system were recorded including:

• a rise in the submission of evidence concerning potential traffic offences by the public, via platforms such as “Operation Snap ^{[footnote 2]}” and “Single online Home (SOH) ^{[footnote 3]}”
• HOTA requirements can limit the ability to introduce enhancements from advanced technologies; and
• the potential to collect and utilise data via RTLEDs to inform decision making on road safety

Responses to experiences of the HOTA RTLED process

Question: “Please consider your (or your organisation’s) current experiences of the HOTA RTLED process and provide evidence of a) positive factors b) negative factors.”

Whilst respondents found the RTLED HOTA process to be well documented and traceable, issues relating to time delays in the system and the HOTA process were raised.

Specifically, the responses identified time delays that:

• disrupt the delivery and/or maintenance of RTLEDs for operational use
• hinder innovation and cause RTLED equipment to be obsolete at the time of HOTA approval; and
• reduce the procurement options for operational policing and local government bodies

A second challenge identified was the HOTA process itself including:

• observed discrepancies in phases, timelines and contact points
• rigidity; and
• the system does not facilitate communication between parties in the process to resolve issues

Responses to experiences of the HOTA RTLED testing requirements and guidance

Question: “Please consider your (or your organisation’s) current experiences of HOTA testing and guidance requirements for RTLED and provide evidence of a) positive factors b) negative factors.”

The issues raised with the available testing and guidance requirements are focused upon their clarity and relevance.

In particular, the responses identified difficulties with documentation including:

• perception of being developed without collaboration or engagement with stakeholders
• overly prescriptive, leaving little scope for alternative solutions and / or innovation
• difficult to understand and to apply to specific RTLEDs
• not updated regularly therefore populated with redundant requirements

Respondents said the strengths of the guidance and testing requirements are that:

• they lead to high standards of device performance and reliability; and
• provide assurance and public reassurance that RTLEDs are fit for purpose and evidentially sound

Responses to improvements to the HOTA RTLED end-to-end process

Question: “Please outline any suggestions for improvements you would like the Home Office to consider that would help any aspect of HOTA end to end process.  Within responses, please state why.”

The suggested improvements which are raised predominantly cover the HOTA process, communications and requirement documentation.

Better communication through collaborative working across the community is seen as an enabler to:

• understand requirements needs and resolve problems
• design and implement effective process changes
• progress technical innovations
• better prioritise submissions according to complexity and need; and
• monitor the progress of assurance applications

The responses suggest HOTA process improvements could be made by:

• allowing devices to be used for dual or multiple functions (e.g. average speed and automatic number plate recognition (ANPR))
• becoming outcome-focused as opposed to specification focused
• creating a fast-track process for minor-modifications
• allocating contact points and timescales for each process stage
• introducing a means to appeal a decision
• maintaining regularly reviewed and updated standards and/or using alternative standards for certain requirements
• exploring changes to resourcing assurance activities, including administration and tasks performed in laboratories and/or testing facilities
• developing a continuous verification process for installed devices; and
• developing a ‘world / universal’ certification standard that all manufacturers must meet.

Any other evidence

Question: “Please outline any additional inputs not captured previously, which you would like the Home Office to consider about any aspect of HOTA RTLED?  This may include considerations to account for and enable future technologies or innovations.”

Further suggestions concentrate on the scope and content of the HOTA requirements as well as the wider application of RTLEDs.

Suggested changes to the HOTA requirement scope include:

• using Artificial Intelligence (AI) based technology to detect “other” offences such as not wearing a seat belt or using a mobile phone whilst driving
• utilising new cameras and technologies to enhance ‘back office’ processing
• accepting hardware and software components which have proven reliability in volume production; and
• removing the need to provide a full circuit diagram and/or to test specific pieces of hardware

Finally, several respondents suggested reviewing alternative international assurance models to inform future HOTA system enhancements and the use of simulation for testing requirements.

Appendix A

This section provides the list questions asked within the CFE:

Respondent details

1. Your name

2. Your email address

3. Your phone number

4. What is your role within your organisation?

5. What is the name of your organisation?

6. Which category best fits your organisation?  (Options were equipment manufacturer, equipment agent / supplier, testing facility, standards organisation, other industry partner, direct end user, other government organisation, third sector or charitable organisation, other.)

HOTA RTLED economic environment

7. Which of the following options would best describe your company size? (Options were micro, small, medium or large)

8. Where is your organisation primarily based?

9. Do you utilise a UK agent for HOTA equipment support?

10. Does your company market RTLED?

11. What was your annual revenue for HOTA RTLED in FY 2021 to 2022?

12. What percentage of this was overseas sales?

13. What percentage of this was UK sales?

14. Does your organisation benefit from HOTA when promoting products?

Impact on road safety outcomes

15. How are road safety outcomes affected by the HOTA system in relation to RTLED?

Experiences of the HOTA RTLED process

16. Please consider your (or your organisation’s) current experiences of the HOTA RTLED process and provide evidence of a) positive factors b) negative factors.

Experiences of the HOTA RTLED testing requirements and guidance

17. Please consider your (or your organisation’s) current experiences of HOTA testing and guidance for RTLED and provide evidence of a) positive factors b) negative factors.

Improvements to the HOTA RTLED end-to-end process

18. Please outline any suggestions for improvements you would like the Home Office to consider that would help any aspect of HOTA end-to-end process?

Any other evidence

19. Please outline any additional inputs not captured previously, which you would like the Home Office to consider about any aspect of HOTA RTLED?

Footnotes

1. https://visionzero.global/ ↩

2. Operation Snap is the police response to the increasing submissions of video evidence from members of the public to witnessed driving offences such as dangerous driving and driving without due care and attention. ↩

3. Single online Home is a digital contact platform that allows the public to report crimes online. ↩