This just in:
-------- Original Message --------
Subject: ASA Investigation 100896
Date: Fri, 25 Feb 2005 09:00:56 -0000
From: "Joseph Hind" <email@withheld>
To: "Paul Smith" <psmith@safespeed.org.uk>
Dear Mr Smith,
We have completed our investigation into the complaints we received about the recent Department for Transport
advertising. A number of points were raised but our investigation was necessarily focussed only on the factual accuracy of the
advertising. We have no powers to influence the overall theme that an advertiser uses in its advertising (unless it falls into a
banned category) and in this instance we had to decide if the advertising was misleading to viewers. We found that the figures
quoted were within an acceptable range of accuracy and received evidence from the advertiser to show they were based on
sound research.
We accepted that the advertiser considered carefully how to portray the statistics so they would be easily understood by
viewers and that there was no intention to mislead. We noted that the figures were more accurate for children than people in
general, as shown by the onscreen text. We felt the message was clearly intended to make drivers slow down when in a 30
mph zone. We noted that other aspects of the DfT campaign are focussed on factors other than speed. We did not consider
the advertisement had breached the Advertising Standards code as the statistics used were rounded only to make the
message of safety more clear.
We passed our findings to the ASA council who agreed with our decision. We will therefore not take any further action at
this time. I appreciate this may not be the response you were expecting but I hope you can understand why we came to our
decision.
Thank you for contacting us. It is always useful to get feedback on advertisements.
I have attached the full DfT response to your complaint for your further information which deals with some of the issues in
more details.
Regards,
Joseph Hind
Broadcast Investigations Executive
The attachment contains the following:
ASA Reference: 100896
Responses from the Department for Transport (DfT):
1)
Brings road safety into disrepute.
The implied claims in the advertisement are false, misleading and oversimplified. It is dangerous to distribute misleading road safety information. Much of the public recognises the claims to be false and misleading and this brings official road safety into disrepute.
We confirmed the robustness of the statistics with both Professor Steve Ashton who originated the stats in '79 and experts at the Transport Research Laboratory (TRL) a respected, independent, research body. They have been involved with all of the decisions made as the advertising has developed and have given their full approval as have the stats team here at DfT. Ashton's original analysis put the risk of a person being killed at 40 mph at about 90%. Reanalysis of the data in the 1980 paper by Pasanen and Salmivaara in 1993 indicated that the risk of a pedestrian being killed was about 35% at 30 mph and 85% at 40 mph. At an impact speed of 30 mph the risk of a child being killed will be less than 35%, whilst at 40 mph it is slightly less than 85%. Ashton has advised DfT that in round figures, it is probable that about 4 out of 5 (80%) of children struck at 40 mph die whereas at 30 mph about 4 out of 5 (80%) survive.
Every crash differs, but the statistics only vary marginally. Our aim here is to provide the public with an easily digestable statistic which clearly shows the dangers of driving over the speed limit using figures which relate directly to speed limits. There are limits to the detail that can be illustrated in a 30" commercial and because of this we have developed further materials such as a booklet and poster which support the facts stated and go further in explaining the facts behind speed limits.
There is no evidence to suggest the public finds the claims to be false and feedback received by DfT from the general public has been positive.
2)
Claims of deaths and injuries at different impact speeds are very unlikely to be accurate.
The Minnesota study [3] found serious limitations in the interpretation of data in the Ashton Mackay and Pasanen studies. According to the Minnesota study:
30mph impact implies about a 5% probability of death for a child pedestrian.
40mph impact implies about a 25% probability of death for a child pedestrian.
The logic behind the use of Professor Ashton's findings is provided above (1). The statistics used were those that were available at the time of developing the advertising and are supported by the Department's statistics department and the Transport Research Laboratory.
3)
Children are less likely to die at particular impact speeds than adults.
Since the Think campaign advert chooses to illustrate its claims with a child pedestrian, it is most important that figures and claims apply to child pedestrians. We do not know exactly which research the claims are based upon, but one study [3] shows that the child fatality risk is considerably lower at spot impact speeds. Most studies fail to distinguish pedestrian fatality risk by age group. Did the Think campaign use an appropriate study that identified child pedestrian risks?
Please see the response covered in complaint (1). The statistics given are based on a child being hit at 30 vs 40. Based on Professor Ashton's findings, if an adult were hit at a speed of 40mph the likelihood of them being killed would rise to about 90%.
4)
Real-world figures for child pedestrian road injuries and deaths are very highly inconsistent with the implied claims.
Latest DfT figures for child pedestrian injuries and deaths in built up roads (30 and 40mph speed limits) [2] are as follows:
Killed: 61
Injured: 12,308
Proportion killed: 0.49%
If the implied claim were true, AND we had high degrees of compliance with the 30mph speed limit 2,461 child pedestrians would have died in these crashes.
Even on “non built up roads” (50, 60 and 70mph speed limits) the proportion of child pedestrians killed in 2003 was 4.8%. If the implied claim were true we would have expected 100% to have been killed on these roads.
Speed is a factor in 12% of road accidents, but not the only factor, hence why the THINK! campaign communicates road safety messages not only on speed but also on drink and drug driving, fatigue and pedestrian safety. It is impossible to link all KSI (killed and seriously injured) figures for children directly with the probability of them dying at an impact speed of 40 vs 30. The complainant's figures are misleading as they work on the basis that all collisions below the speed limit will occur at 30mph. This is not the case as collisions will happen at a wide range of speeds below 30mph with differing implications for the probability of a death occuring.
5)
Speeding (exceeding a speed limit) is commonplace. Other factors must be of far greater importance to pedestrian safety.
Official Department for Transport figures [4] show that speeding is endemic with (for example) 58% of cars exceeding the 30mph speed limit at sample sites. If speeding was dangerous in the way that the advertisement implies than the proportion of child pedestrians that die in collisions would be many times higher.
Far more important factors include: driver attention, slowing down (often far below the speed limit) in areas of danger, and braking before impact.
The research paper Excessive speed as a contributory factor to personal injury road accidents published on the Department's website in September 2004 identifies excessive speed as the most frequently recorded contributory factor for fatal road accidents, and also a significant factor in many other road accidents. As mentioned in response (4) speeding is therefore one priority for the DfT's THINK! campaign along with a number of others. However, the Ashton research demonstrates that whatever the causation factor of the accident (whether speed or another factor or combination of factors) the probability of death of the pedestrian is directly related to the speed the car was travelling at, at the time. The commercial does not suggest that the only important factor of pedestrian safety is child road safety. However, child road safety is a particular concern for Britain in comparison to other European countries and the Government's target of reducing child KSIs by 50% by 2010 reflects that.
6)
The implication that roads with a higher speed limit than 30mph are unsafe for pedestrians is false.
If we take the advertisement’s claim at face value, we should assume that roads with higher speed limits than 30mph must be unsafe for pedestrians. Clearly this isn’t so.
The commercial is not intended to imply that roads with faster speed limits are dangerous to pedestrians. However, 40mph speed limits in urban areas are most suited to dual carriageways and main traffic routes which are not substantially used by vulnerable road users and have adequate footways and crossing places.
The Department's Road Casualties Great Britain 2003: Annual Report shows that it is on urban roads that the majority of casualties occur, including over 90% of pedestrian and pedal cyclists casualties. 30mph limit zones are purposely employed in areas where there is particular interaction between motorised vehicles and the more vulnerable road user groups. Indeed in some town centres and residential areas 20mph speed limits are implemented and research indicates that the number of accidents involving injury to children in these circumstances may be reduced by two thirds
7)
The final claim: “It’s 30 for a reason” is not related in any way to the content of the advertisement.
We agree that: “It’s 30 for a reason”, but since the speed limit predates the research on which the advertisement draws, it is quite impossible that the information presented in the advertisement is the original reason for the speed limit.
The 30mph speed limit is a good compromise for many roads in urban areas with a high hazard density.
A 30mph limit was introduced in built-up areas in 1934 to provide for the safety of pedestrians and drivers. Other roads had no speed limits until 1965 when a national upper limit of 70mph was introduced.
The advert does not state that the Ashton research was the original reason for the introduction of speed limits. The advertising underpins the rationale behind the use of speed limits as research shows the public are more open to road safety measures when they understand the logical reasons behind them.
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