With an estimated 190,000 vehicles minimum requiring PSS compliance by October 2024, never has there been more opportunity for the safety technology suppliers, but very sadly, never more opportunity for mis-selling. With PSS suppliers hawking the industrial estates and hosting their nationwide PSS shows, the PSS selling frenzy has begun in earnest.
And in all this rush for London readiness, it seems our usually savvy fleet operators are asking precious few questions. Truly, the urgent is crowding out the important. Yes, the good exists in the PSS market but if your timetable allowed it, you’d soon encounter the bad and the ugly. But a supplier would say this of the competition, I hear you say, and what’s his angle? Yes, I’m a supplier but I’ve a heart for the operator too, and the finer PSS requirements are an onerous read at best, but knowing those requirements inside-out as I do, what better time for some plain-speaking PSS buying advice! And I offer this because when your vehicle is spot-checked post-October 2024, and if any non-compliance is noted by the ‘PSS police’, your supplier will likely be long-gone, and it’ll be you who’ll be fined and your vehicle off-roaded. You’ll be the one left holding your PSS pup, and I do actually care about that.
Current Issues with PSS Installations
Fleet engineers and owner drivers already fitted out with the latest PSS are already citing illfitted cameras that do not cover the blind spots, expensive protruding cameras being smashed off by trees and truck washes, exposed cabling and wiring, drill holes compromising vehicle waterproofing warranty, low-res screens offering only the faintest of nearside views, annoying audible alarms constantly alarming in the cab in non-critical situations, and most concerning of all perhaps, systems with audio on/off buttons (an absolute TfL NO-NO) with the PSS rep nonchalantly advising, ‘You can always turn off the beeping if it annoys you.’ I kid you not!
This is an unexaggerated snapshot of the current PSS landscape. Compliant kit and installs are few and far between. So, how do you avoid the PSS heartache? Hopefully, the following condensed PSS shopping list will serve you well.
Essential PSS Buying Guide
Firstly, the kit must conform to the clear TfL criteria as laid out here. The kit must be tamper-proof, must ignore inanimate objects and warn drivers of the presence of vulnerable road users (VRUs) in the blind spot. Practically speaking, the kit should also be driver friendly, robustly designed for the harsh LGV environment, carry no onerous aftercare, and of course deliver on value for money, and more on that towards the end.
But it is having a clear understanding of the following finer points of PSS operation and TfL compliance that will dictate whether your PSS rep stays or goes. It is right here where so many PSS customers unwittingly stumble, where so much of the mis-selling is taking place and where so many drivers are already cursing their bleeping PSS bleepers! Get the next two minutes right and it will be a massive step forward for drivers and management alike.
MOIS Moving Off Information System (EC reg 159)
Primarily, the MOIS front detection system must not audibly alarm when the vehicle is stationary (rightly considered a non-dangerous situation) no matter the surrounding VRU activity. In all such instances (see right), the driver is to be given a visual only signal in the cab. MOIS must audibly alarm only when the
vehicle begins moving and detects any VRU activity within the 2 metre forwards detection zone up to 3MPH.
EC reg 159 wording is unambiguous. ‘High-urgency warnings during a driving situation are only justified should the probability for an accident be high – otherwise vehicle drivers tend to ignore the system alerts. Should lower urgency information signals be activated sufficiently early, however, it may help the driver rather than annoy them….Furthermore, this regulation asks for an additional signal which shall be given when the collision becomes imminent, e.g. when the vehicle accelerates from rest and the pedestrian or cyclist is located directly in front of the vehicle.’ P4: 0.3-0.5
Mirroring this EC 159 demand, TfL tells us on pages 4-5 of its now-finalised MOIS document: ‘When stationary, MOIS shall inform the driver of the presence of VRUs who are within or about to enter the critical blind spot area in front of a stationary vehicle and that might be endangered if the vehicle were to move off, by means of a visual signal. The MOIS shall not issue a collision warning if the vehicle is in the ‘at rest’ condition.‘ In other words, with the vehicle stationary, there is to be a (visual) low intensity signal only that informs the driver of VRU activity to the front, followed by a different and more urgent (audio) signal if the vehicle begins moving forward and a collision is imminent.
Yet, so many PSS-equipped vehicles are bleeping away whilst sat safely at pedestrian crossings and traffic lights and when travelling slowly and safely through busy pedestrianised areas. I’ve sat in the cabs myself and it’s a horrible experience. Such systems are non-compliant and a ‘PSS police’ vehicle check just waiting to happen.
BSIS Blind Spot Information System (EC reg 151)
Likewise, the BSIS side and corner blind spot detection system must not audibly alarm when the vehicle is
stationary (again a non-dangerous situation) and neither should it audibly alarm when both vehicle and VRU are travelling in a straight line along the same trajectory below the mandated 18MPH cut-off speed.
Yes, you read right! All the while the vehicle and VRU are travelling in parallel (as we see above), the VRU should trigger a visual warning only in the cab, NO MATTER THEIR PROXIMITY TO THE VEHICLE. Says the TfL BSIS technical document on page 5, ‘When a vehicle and a VRU are travelling in the same direction on a parallel path to each other, they can continue to do so for an infinite time without collision even if they are in close proximity. This situation does not constitute an imminent collision.’
And not only that, EC reg 151 page 4 points 0.3 – 0.5 tells us BSIS should audibly alarm only when the vehicle itself turns inwards towards the VRU or upon activation of the left indicator. Right, we see another everyday example of inner-city VRU activity. The driver is in forward motion but is also turning AWAY from any potential danger.
Therefore, the system should again remain silent and should audibly alarm ONLY when the driver turns INWARDS from the parallel and towards the VRU. To reiterate, parallel travel is not unduly dangerous and therefore does not warrant an annoying audio alarm, escalating to ‘intensely annoying audio alarm’ over the course of the driver’s day. This change in vehicle trajectory inwards towards the VRU to activate the higher intensity audio warning is electronically achievable, it works very well and is the only sensible way forward.*
Benefits of New AI Technology
The blessed audio silence offered by the new ai technology is seen as key to reducing sensory overload in the cab. The fact this electronics is achievable and such systems can now ignore street furniture and can stay silent whilst ‘at rest’ and in parallel driving situations is ultimately what’s driving the TfL PSS mandate. VRU detection systems that alarm only when detecting imminent danger (says the research, says the EC, says TfL) will reduce driver anxiety and should reinstate in the driver’s mind that vital awareness of VRU activity around their vehicle – an awareness that drivers once had but has largely been eradicated as a result of the old technology beeping at every lamp post.
Grasping these lesser understood aspects to PSS compliance and insisting on clarity in these vital areas from your PSS rep is key to securing the correct system and will also guarantee a far less noisome drive. And don’t be fobbed off by the rep telling you the kit can alarm in these situations, ‘because it’s so much safer that way,’ or because ‘that TfL shower has made the rules so confusing, etc, etc.’
The official wording is clear, and any system that audibly alarms with the vehicle at rest or when driving in parallel does not comply and will likely be picked up by the authorities in due course, and once again, will make dire enemies of your drivers.
Voice Alerts vs Beeping Alerts
And finally, on the matter of opting for voice alerts or beeping alerts (TfL leaves the choice open), it is our experience as safety equipment suppliers that clear voice direction rather than a beeping alarm triggers a far more decisive response from the driver. ‘PEDESTRIAN LEFT!’ or ‘BEEP! BEEP! BEEP!’ The voice choice is obvious, especially considering all the other in-cab beeping today such as weigh-loader warnings, tyre pressure monitoring, refrigeration temperatures, hill start warnings, over-revving, traction loss and even telematics driver-scoring beeping! Add a beeping PSS alarm into the mix, and the potential life-saving alarm will simply get lost in the haze.
TrafficAngel Can Assist You
Insist on an exact understanding from your PSS rep on how their system works, and if it ticks the boxes, insist on a free trial, check install quality, and existing customer references. PSS is a big investment, it’s important you buy right. And if the system you choose meets the above requirements, has no audio mute button, alerts the driver to kit failure, is fitted according to TfL guidelines and carries the correct paperwork, you’re pretty much London PSS compliant.
If your system meets the above, has no audio on/off button, alerts on kit failure, is fitted according to TfL guidelines and carries the correct paperwork, your vehicle is pretty much compliant. Full PSS conformity as far as the pre-requisite safety technology is concerned comprises left turn alarm, 7 inch screen offering a full nearside view of the vehicle, correct signage to the rear plus full PSS. Editorial space prohibits the full PSS list but TrafficAngel can advise you further.
Vehicle Case Study
The vehicle right has one internal camera and two external cameras all safely mounted away from harm and ideally positioned to cover all the blind spots. Fitting time using two competent engineers just under 3 hours. Customer references available. Updated website coming soon. For further information, call TrafficAngel on 01825 768555.
A professional video will also soon be online showing the system working exactly as it should including positive driver feedback. The haulier is delighted!
I hope this article has been helpful and that you now understand the finer requirements of PSS. How the VRU might contribute to road safety is beyond the scope of this article, but inner-city drivers especially have a great deal to say on that! Another article, maybe.
Thank you for reading.
* TfL is currently looking to finalise its position on whether pedestrian trajectory should also play a part in triggering an audio warning, but to allow this loophole has already created all manner of false triggering in the cab which is presumably the reason pedestrian trajectory plays no part in the overarching EC directive on BSIS 151.
