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19-Feb-26

To: Lorna Murphy, Director of Buses, TfL

From: Kevin Mustafa

RE: Why do the Mayor and TfL refuse to protect London's Bus Drivers from Institutionally Unsafe Working Conditions?

Sent: Thursday, February 19, 2026 1:20 PM


cc: Transport Commissioner; Deputy Mayor for Transport; Deputy Mayor for Social Justice and Communities, London Victims' Commissioner; TfL Walking and Cycling Commissioner; TfL Board Secretariat; TfL SSHR Panel Secretariat; TfL Chief Safety Officer; TfL Director of Bus; TfL Head of Insights and Direction; TfL Chief Operations Officer; London Assembly Transport Committee Members; CEO, London TravelWatch; Dan Tomlinson MP; Ben Coleman MP; Katie Lam MP; Olly Glover MP; Ruth Cadbury MP; Catherine Atkinson MP;  Workplace Colleague Network - London Bus Forums; Sharon Graham - Unite the Union; Journalists; Bus Drivers; Campaigners


Dear Ms Murphy,

 

Thank you for your perfunctory response. Kindly note that I have recirculated it to everyone who was copied on my original email, as I have also  done with my response today.

 

As you probably know from my earlier letters to City Hall and TfL (cf. Speaking out against London Buses' Culture of Fear, 19 August 2021), my decision to quit the buses and campaign for the Bus Drivers' Bill of Rights was inspired by the fact that, six years ago today, Bus Drivers were being abandoned by their Bus Operator employers, Unite the Union, TfL and the Mayor when they started getting sick and dying from Covid-19.  Your response confirms that, despite at least 76 Bus Drivers dying from Covid-19, nothing has changed. 

·       TfL has yet to conduct "a short-term review of shift lengths, patterns and rotas of London bus drivers" recommended by the UCL Institute of Health Equity in March 2021 and agreed by TfL to complete "by summer 2021";

·       One in Four London Bus Routes still lack Toilet Facilities at one end for Bus Drivers;

·       Compared to 2024, in 2025 the number of Bus Drivers taken to hospital from Assault/Vandalism incidents increased by 17%. 

Since (a) the Mayor has sole responsibility for Policing in London and (b) the unanimous London Assembly Motion called for the Mayor and TfL—

 

 "to issue a public apology to Mr Hehir and to apply pressure to Metroline to reinstate Mr Hehir or provide appropriate compensation for his dismissal"

 

—I think you'll find your complacent restatement of TfL's long-standing policy of ignoring Bus Driver welfare is deeply out-of-sync with both the Mayor's legal obligations and the public mood

 

According to TfL's own data, over the period 1 January 2014-31 December 2025, an average of 7 Bus Drivers per month were reported by TfL as having been injured in Assault/Vandalism incidents on London's buses, of which over one driver per month was taken to hospital. 

 

Since I know that many Bus Drivers don't report injuries they receive on duty, I believe TfL's numbers are underestimates. 

 

Over the same 11-year period, an average of 15 people per month were reported injured from an Assault/Vandalism incident on buses and about 4 per month were taken to hospital.  

 

I'd wager TfL's numbers of passenger injuries from Assault/Vandalism incidents are also underestimates. 

 

TfL's data also reveal that Bus Drivers accounted for 41% of all reported injuries from Assault/Vandalism incidents and 46% of all those taken to hospital.

 

As you no doubt know, over the period for which TfL has made bus safety data available for public scrutiny, Bus Drivers—on average—have only constituted an infinitesimal (0.0011%!) of the total number of annual Bus Passengers.  Hence, I think you'll agree with me that the fact that Bus Drivers are 80,000 times more likely than a passenger to be injured and 40,000 times more likely than a passenger to be taken to the hospital in an Assault/Vandalism incident on London's buses demands that TfL do more than just abdicate responsibility for Bus Drivers' safety and security. 

 

TfL's numbers reveal an obvious fact: Bus Drivers are not just casual victims of Assault/Vandalism incidents on London's buses, they are the primary victims of this increasing violence.

 

Given this well-evidenced risk, when a Bus Driver chooses to intervene to defend a Bus Passenger against Assault/Vandalism and is subsequently dismissed for gross misconduct—and the Mayor, TfL and Unite the Union do nothing—the outcome of this complacency undermines the safety of London's Bus Network for which the Mayor and TfL are legally accountable. 

 

And TfL's decision to side with Metroline against Mark Hehir—i.e., against someone who TfL's own data shows had the highest risk of serious injury and the most to lose from intervening in an Assault/Vandalism incident—simply re-broadcasts a clear message, that I've been familiar with— 

 

(a) since Bus Drivers started to sicken and die around me from Covid-19 6 years ago this month, and;

(b) each time the Mayor fails to respond to Bus Drivers' reasonable demand to incorporate the Bus Drivers Bill of Rights into TfL's Framework Bus Services Agreement:

 

—TfL takes no responsibility for the security and safety of London's Bus Drivers

 

Since we already know that TfL's  "incident reporting system does not specifically collect data relating to disciplinary outcomes" regarding Bus Drivers, your statement that it "would not be appropriate for TfL to intervene" rings hollow: the public record shows that TfL completely washes its hands of how Bus Drivers are disciplined by their employers.

 

The London Assembly Motion also calls on the Mayor and TfL—

 

"to set out clear guidance for transport workers protecting passengers."

 

I do hope the London Assembly Members copied here will take note of the clear guidance your response conveyed: 

 

TfL will support any Bus Operator which fires a Bus Driver who chooses to risk injury to protect Bus Passengers against Assault/Vandalism incidents on London's buses.

 

Why do the Mayor and TfL refuse to protect London's Bus Drivers?

 

Yours sincerely,

 

Kevin Mustafa

London Bus Safety Campaigner

Founding Member - Bus Driver Bill of Rights Campaign

-----------------ATTACHMENT------------------

From: Bus Ops FOIs & Inquiries <BusOpsFOIsInquir@tfl.gov.uk>

Sent: Friday, February 13, 2026 1:13:07 PM

To: Kevin Mustafa

Subject: RE: Subject Intervention Requested: Dismissal of Bus Driver Mark Hehir

Dear Kevin,

Please see below a response to your email from Lorna Murphy.

Dear Kevin,

Thank you for your email. As you are aware, bus services in London are delivered by private operators, such as Metroline, under contract to TfL. Operational matters, including staffing and employment decisions within individual companies, sit with those operators. As this issue relates to Metroline's internal employment processes, it would not be appropriate for TfL to intervene. You may wish to raise your concerns directly with Metroline so they can address them through their established procedures.

Yours sincerely,

Lorna Murphy 

06-Feb-26

By email and blogpost

Ross Moorlock, Chief Executive OfficerBrake Charity 
PO Box 18896
Sutton Coldfield B73 9BL
cc: Transport Commissioner; Deputy Mayor for Transport; Deputy Mayor for Social Justice and Communities, London Victims' Commissioner; TfL Walking and Cycling Commissioner; TfL Board Secretariat; TfL SSHR Panel Secretariat; TfL Chief Safety Officer; TfL Director of Bus; TfL Head of Insights and Direction; TfL Chief Operations Officer; London Assembly Transport Committee Members; CEO, London TravelWatch
6 February 2026Dear Ross Moorlock,
RE: Will Brake Charity speak up for London's and the UK's Vanished Bus Victims"? 
Since it appears that London Assembly Members Keith Prince (Reform) and Neil Garratt (Conservative) have recently uncovered a scandal that proves TfL has been misleading the public and press about the actual number of victims "killed in or by a bus" in London each year,  Brake Charity's recent Press Release—"Brake partners with TfL to continue support for people impacted by serious road traffic collisions in London"—is very timely.   
As the survivor of critical injuries I received from a TfL Bus on Oxford Street in 2009, upon learning that Brake Charity had been awarded a £905,000.00 TfL contract to support London road crash victims or their surviving families, I thought you might consider it worthwhile to use some of this public money to convince the Mayor and TfL to be honest about the number of victims they claim are "killed in or by a bus" in London in TfL's benchmark road safety reporting publications.  
Since Brake Charity is already being paid by TfL under its new contract, I prepared this Briefing Note for your information, review and—if you're inspired to respond—comment, which, like this Briefing Note, I will make public. 
Background 
1. For over a decade, TfL's Contracted Bus Operation has accounted for a disproportionate number of London's Pedestrian Road Crash Victims. 

Any transparency shown by TfL about the frequent deaths and serious injuries generated by its contracted bus fleet is the direct result of a policy forced upon London's Local Transport Authority (LTA) by Mayor Boris Johnson in 2014. TfL's reluctant transparency came about only after it been regularly receiving (a) bad press generated by my 'relentless' volunteer research and campaigning and (b) public scrutiny from London Assembly members, namely Victoria Borwick, and Richard Tracey (Conservative), Caroline Pidgeon (Liberal Democrat), Jenny Jones and Darren Johnson (Green).  

Analysis of the Bus Safety Performance Data (called—interchangeably—"IRIS" or "SHE" Data) that TfL has published every quarter since 2014 evidences—

  • there have been, on average, over 26,000 recorded TfL bus crashes per year—that's an average of at least 72 potentially-lethal bus crashes per day—with 2024 witnessing the highest number of recorded crashes (nearly 29,000 or 79 per day) since 2014 (nearly 25,000 or 68 per day).
  • at least 10,818 people have been injured in a collision involving a TfL Bus, of which 3557 victims have been 'taken to hospital'.  In his responses to many Mayor's Questions, the Mayor has repeatedly confirmed that TfL has no idea if these victims who have been compelled to be taken to hospital from injuries sustained "in or by a bus" have recovered fully or suffer from life-changing injuries or have passed away.  Accordingly, the veracity of any serious injury figure published by TfL involving its contracted bus fleet is, quite frankly, dubious; 
  • at least 137 people have been killed in preventable Bus Safety Incidents in London—113 from collisions, 16 from onboard falls and 9 from other safety-related incidents (e.g, deaths from ill-defined but safety-related 'activity', 'near misses', personal injuries').
  • about 10 percent of all vehicle-related pedestrian fatalities in London have resulted from a collision involving a TfL Bus — in 2024, that horrifically large percentage increased to 15%.
Since the public record shows that TfL's contracted bus fleet— 
(a) now only accounts for about 1 percent of all vehicles on London's roads at any time (down from about 3 percent in 2014), and;
(b) these vehicles' presence on London's roads and ridership have steadily declined since 2014;  
 
—it is obvious that an increasingly disproportionate amount of Brake Charity's services to 'people impacted by serious road traffic collisions in London' will be rendered to victims of TfL's contracted public bus operation. In fact, the public record also shows that, over the past decade, preventable bus collisions resulted in an average of over one person per day being taken to hospital. and—based on TfL's 29 May Press Release about 2024's bus collision fatalities—more than one person per month taken to the morgue.  
TfL's 'Vanished Bus Victims' Scandal 
2. TfL has been misleading the public about the number of people "killed in or on a London Bus" since, at least, 2018.
Since Brake has long been a member of TfL's—non-transparent, in my view— Vision Zero Reference Group, you'll already know that in his July 2018 Transport Strategy, the Mayor pledged to measure London's progress on Bus Safety Performance according to this unique-to-London—Vision Zero metric, i.e—
"for no one to be killed in or by a London bus by 2030"
To chart 'progress towards the Mayor's Transport Strategy', since 2018, TfL's benchmark "Casualties in Greater London" reports have purported to show the number of people "killed in or by a bus", clearly evidenced by the two images below that I have extracted from TfL's latest (2024) "Casualties in Greater London" report. 

Since TfL's official annual bus fatality totals and the 2010-14 baseline are frequently cited by the Mayor and TfL in official reports and press releases—and, as a direct consequence—in Government and media reports—you might appreciate my firmly held conviction that each time the Mayor or TfL quote numbers and baselines that purport to reflect everyone "killed in or by a bus" in London, those numbers should be based on fact.  

3. Keith Prince AM's scrutiny of TfL's 2010-2024 Bus Fatality Data 

In October 2025 (and confirmed by the Mayor in his response to Question 2025/3723), Keith Prince requested TfL to provide him with the raw 2010-14 bus fatal incident data that it used to populate the information published in, inter alia, TfL's "Fatalities in Greater London 2024" Report. Despite the fact that Keith Prince later requested the Mayor to compel TfL to publish this raw data on the London Assembly website for public scrutiny, the Mayor failed to honour Keith Prince's request.  However, I am grateful Keith Prince shared both TfL's 21 November 2024 cover email and its attached data directly with me. 

Based on my analysis of the information TfL provided to Keith Prince directly for scrutiny, below please find my findings that I hope will encourage further actions by Brake Charity.

4. TfL's 2010-14 Baseline cannot be accurate

Below please find the 21 November 2025 correspondence from TfL to Keith Prince AM. 

From: Members Correspondence <MembersCorrespondence@tfl.gov.uk> 

Sent: Friday, November 21, 2025 4:21:11 PM

To: Keith Prince <Keith.Prince@london.gov.uk>

Subject: Follow up from bus safety discussion

Dear Keith,

Thank you for meeting with us last month to discuss our bus safety data. We hope that you found this helpful and productive.

As requested, we have compiled a spreadsheet showing the bus fatalities that are included in table 3 of the data annex (Bus-involved fatalities), we have included the date, borough, collision location and causality mode of travel. Please note, this only includes police-reported (STATS19 fatalities) and doesn't include non-STATS19 fatalities such as medical incidents and fatalities resulting from collisions on private land.

Unfortunately, the raw data which we have used in the spreadsheet is only available from 2017 onwards.  This is because bus casualty data is part of a 'Bus or Coach' category as per the Department for Transport STATS19 modal categories. In 2017 TfL agreed with the Metropolitan Police Service (MPS) to split out bus and coaches to enable better monitoring of incidents relating to our buses, this means that from 2017 a flag was included for London buses in the police form which could be used to identify bus-involved fatalities. Prior to 2017, bus involved figures are estimates based on modelled data, so raw data records are not available to share.

Some of the other requested information, such as the bus route and operator, is not recorded in STATS19 and as such could not be included in the attached. 

Please let us know if you have any further questions. 

Kind regards,

[NAME WITHHELD]

Government Relations

11th Floor, Palestra, SE1 8NJ

Despite the Mayor repeatedly stating (cf. Question 2025/4415 from December 2025) that TfL uses a 2010-14 Baseline to, inter alia

—this email confirms that TfL has no reliable raw bus fatality data that underwrites this key Vision Zero and Bus Safety Performance baseline. Furthermore, the fact that TfL admits that it's using STATS19 Data to represent the number of people "killed in or by a bus" each year proves that TfL knows it is citing a mere subset of a larger group of fatalities.  If you review the Bus Safety Data Guidance that TfL issued hastily and without explanation in early November 2024, STATS19 criteria allows TfL to exclude victims—

 "killed in or by a bus" from "collisions on private land, noncollisions (e.g. death due to medical episodes or slips, trips and falls on a bus), incidents outside the Greater London boundary and death occurring after 30 days."  

While those exclusions might produce inaccurate bus fatality datasets acceptable to the DfT (cf. RAS0601, which shows 521 fatal road collision incidents involving a "Bus or Coach" from 2015-2024), TfL's use of knowingly smaller STATS19 datasets to reflect the total number of people "killed in or by bus" for each year to "measure progress towards the Mayor's Transport Strategy bus involved fatality target for 2030", is frankly, simply intentionally misleading. As you know, both the Mayor's Transport Strategy and the 2030 target are unique-to-London and there is no statutory, legal or moral requirement for TfL to publish less-robust STATS19-defined figures for these reports that relate exclusively to TfL's 'progress towards the Mayor's Transport Strategy bus involved fatality target for 2030.'

5. TfL is intentionally excluding documented incidents of people "killed in or by a bus" in its official reports that claim to show the total number of people "killed in or by a bus".

My reconciliation of the raw 2017-2024 data TfL emailed to Keith Prince on 21 November 2025 with the IRIS Data TfL has published on its website quarterly since 2014 reveals that, since 2017, TfL has failed to report 21 documented incidents of "people killed in or by a bus". This means that, for the past 7 years (at least), TfL has failed to acknowledge the deaths of at least 1 in 4 of the total number of people that have actually been "killed in or by a bus". 


Allow me to walk you through the incidents of "people killed in or by a bus" each year from 2017 to 2024 that TfL has chosen to ignore in its "Casualties in Greater London" reports which, as you surely know, serve as the primary reference for anyone who scrutinises or reports about Road Safety in London. 

In 2017, TfL states that 8 "people were killed in or by a bus", but TfL excluded the following 4 fatal incidents:

  • the 11 March 2017 death of an elderly male pedestrian who was killed in a collision involving a Route E6 Bus operated by Metroline (Greenford Depot) under contract to TfL in Hillingdon Borough;
  • the 28 April 2017 death of an adult male passenger who was killed after an assault on a Route 189 bus operated by Metroline (Cricklewood Depot) under contract to TfL in Westminster Borough;
  • the 29 June 2017 death of an elderly male pedestrian who was killed in a collision involving a Route 216 bus operated by RATP (Fulwell Dept) under contract to TfL in Surrey County;
  • the 16 December 2017 death of an adult male passenger who was killed after falling on a Route R11 bus operated by Go Ahead (Orpington Depot) under contract to TfL in Bromley Borough.
In 2018, TfL states that 12 "people were killed in or by a bus", but TfL excluded following 4 fatal incidents:

  • the 1 April 2018 death of a third party driver of unknown sex and age who was killed in a collision involving a Route 61 bus operated by Stagecoach (Bromley Depot) under contract to TfL in Bromley Borough;
  • the 23 July 2018 death of an elderly female passenger who was killed in an "activity incident" on a Route W8 bus operated by Metroline (Potters Bar) under contract to TfL in Enfield Borough;
  • the 17 September 2018 death of a passenger of unknown sex and age in an "activity incident" on a Route 318 bus operated by Arriva (Enfield Depot) under contract to TfL in Haringey Borough;
  • the 6 November 2018 death of an adult male passenger after falling on a Route 32 bus operated by Metroline (Edgware Depot) in Brent Borough. 
In 2020, TfL states that 7 "people were killed in or by a bus", but TfL excluded the following 5 fatal incidents:

  • the 12 February 2020 death of an adult male pedestrian in a collision involving a speeding Route 191 bus operated by Go Ahead (Northumberland Park Depot) under contract to TfL 'near' Edmonton Bus Station in Enfield Borough;
  • the 14 March 2020 death of an adult male pedestrian in a collision involving a Route 96 bus operated by Stagecoach (Plumstead Depot) in Dartford; 
  • the 16 March 2020 death of an elderly male passenger after falling on a Route 106 bus operated by Arriva (Ash Grove Depot) in Haringey;
  • the 4 June 2020 death of a third party driver/occupant in a collision with a Route 209 bus operated by Transport UK (Twickenham Depot) in Richmond Upon Thames Borough. 
  • the 22 October 2020 death of an elderly female passenger who was killed after falling on a Route 35 bus operated by Go Ahead (Camberwell Depot) in Southwark.
in 2021, TfL states that 5 "people were killed in or by a bus", but TfL excluded the following fatal incident:
  • the 10 August 2021 death of an adult female pedestrian named Melissa Burr who was killed in a collision with a Route 507 bus operated by Go Ahead (Waterloo Depot) at Victoria Bus Station in Westminster Borough. The Evening Standard reported that the Mayor had issued a 'sincere apology' to Melissa Burr's family because TfL "wrongly suggested [she] may have been at fault for her death", an apology the Mayor confirmed in his response to Question 2024/3450. In my view, with all the information about the systemic causes of Victoria Station deaths now in the public domain, TfL's decision to exclude Melissa's Burr's death from the 2021 dataset demands further scrutiny.
In 2022, TfL states that 9 "people were killed in or by a bus", but TfL excluded the following fatal incident:
  • the 18 December 2022 death of an adult male pedestrian named Stephen Mitchell who died after he was critically injured in a collision with a Route 363 bus operated by Go Ahead (Peckham Depot) in Southwark on 26 November 2022.  Similar to Melissa Burr's death, the fact that there is so much in the public domain about the ghastly circumstances surrounding Mr. Mitchell's death, and the fact that the Bus Driver was found guilty  calls into question TfL's decision to exclude his death from the 2022 datasets and demands further scrutiny. 

In 2023, TfL states that 6 "people were killed in or by a bus", but TfL excluded the following 2 fatal incidents: 

  • the 12 March 2023 death of an adult male passenger after a collision involving a Route 79 bus operated by RATP (Edgware) in Harrow;
  • the 15 December 2023 death of an elderly female pedestrian named Grace Mecaley who was killed in a collision involving a Route 212 bus operated by Go Ahead (Northumberland Depot) under contract to TfL at Walthamstow Bus Station in Waltham Forest Borough. Since TfL had a Notice of Contravention served to it by the Health and Safety Executive as a direct result of this incident—a document, by the way, that both the Mayor and TfL have both yet to provide for public scrutiny—similar to the exclusion of Melissa Burr and Stephen Mitchell from TfL's official fatality data for 2020 and 2022, TfL's justification for excluding Grace Mecaley's death from 2023's official fatality data demands a cogent explanation. 

In 2024, TfL states that 13 "people were killed in or by a bus", but TfL excluded the following 4 incidents:

  • the 27 January 2024 death of an elderly female passenger after an "activity incident event" while on a Route 55 bus operated by Stagecoach (Leyton Depot) in Westminster;
  • the 11 February 2024 death an adult male pedestrian after a collision involving a Route 158 bus operated by Arriva (Edmonton Depot) in Enfield;
  • the 20 June 2024 death of a Bus Occupant of unknown sex and unknown age—an incident that is published in TfL's "Road Fatalities in Greater London since 2019" spreadsheet, but does not appear anywhere else on the TfL site;
  • the 30 December 2024 death of an elderly male passenger who died after falling on a Route 5 bus operated by Go Ahead (River Road Depot) in Newham on 15 March 2024. 

Since we already know that (a) at least 1 in 4 bus victims have been ignored in TfL's 2017-2024 official dataset and (b) TfL refuses to provide the raw data to support the data it cites for "people killed in or by a bus" for the period 2010-2016, I reckon that 21 unacknowledged bus deaths is already a serious underestimate of the total number of victims that TfL has chosen to ignore over the period 2010-2024.  In fact, if you've had the opportunity to read my unacknowledged 2 December 2025 Letter to Mayor Sadiq Kahn (#VisionZero: Why is TfL allowed to ghost people who've been killed or seriously injured "on or by a bus" in its annual official Road Casualty reporting?), you'll immediately recognise the names of 2 vanished bus victims from 2010-16. 

  • Saba Mirza (31), who was critically injured on a Zebra Crossing in a collision involving a Route 46 bus operated by Metroline under contract to TfL on 25 November 2016, but, I understand from her family, died while still in hospital in early January 2021. How many more vanished victims like Saba Mirza are there? 
  • Ezarhul Islam (73), who fell and suffered critical injuries after, judging from the Coroner's 16 June 2016 Regulation 28 Report, a Go Ahead 191 Bus moved suddenly without warning on 23 October 2015, but died while still in hospital in December 2015. In its IRIS Data, TfL recorded the cause of his death as "Medical" and didn't include the incident in its "killed in or by a bus" total for 2015.  Since 1 January 2014, TfL has recorded 69 Bus-related Fatalities with "Medical" identified as the causal factor for death. How many of these "Medical" deaths actually represent vanished bus victims like Mr. Islam?  Based on last month's response to Question 2026/0028, the public will never know because the Mayor has refused to instruct TfL to investigate. 

6. How Brake Charity can Help TfL's and the UK's Vanished Bus Victims

From my quick reconciliation of the raw 2017-2024 Bus Fatality data Keith Prince received from TfL on 21 November 2025 with (a) the documented incidents of people "killed in or by a bus" found in TfL's published  Bus Safety ("SHE/IRIS") Data and Road Safety (STATS19 ) Data  and (b) some AI-assisted Web searching, it would appear that, since 2010, there are at least 23 people whose deaths "in or by a bus" were in vain because—

  • Key Vision Zero Safety Target Baselines were created;
  • Executive Bonuses were determined and paid;
  • Official narratives about "Progress" on Vision Zero appeared in Press Releases that were dutifully reported by the local and national press;
  • Evidence was submitted by TfL to at least three London Assembly Bus Safety Investigations and also, to the Department for Transport;

—and these specific documented preventable deaths "in or by a bus" were not acknowledged by TfL to have taken place at all. 

While TfL press spokespeople callously dismiss these ignored vanquished lives as "a small number of other fatalities" and TfL Board Documents negligently classify all bus deaths as "small numbers of low probability events", as the CEO of the leading national charity providing support to Road Victims, can I assume that you will not dismiss TfL having ignored at least 23 victims "killed in or by a bus" since 2010 in its benchmark road safety publications as merely the data geek pedantry of a highly-motivated Bus Crash Survivor but rather treat it as the breach of public trust by the Mayor and TfL that I think it clearly represents?  I might add, for governance of the Mayor's Vision Zero Programme and also for these victims' families, I think the Mayor's and TfL's acknowledgement of these 23 victims "killed in or by a bus" is precisely the point of Vision Zero. 

Accordingly, for a public bus fleet that is entirely within TfL's control, but—

—I think the Mayor's Vision Zero metric "for no one to be killed in or by a London bus" makes obvious sense.  But—as you are no doubt aware—since the Lord Peter Hendy rejected Lord Hampton's 'Vision Zero for Buses' Amendment to the Bus Services [No. 2] Bill on 13 October 2025, Transport for London stands out as the only Local Transport Authority in the country with a Vision Zero Policy that claims to use this "killed in or by a bus" metric to measure its public Bus Safety Performance.  
But the stark difference between the official annual bus fatality totals TfL is reporting to the public and the press versus the actual number of "people killed in or by a bus" demands that the Mayor act now to compel TfL to report the truth about the annual number of these incidents. 

Thanks to my years of volunteer campaigning and relentless scrutiny by London Assembly Members like Keith Prince and Neil Garratt, there is now so much TfL Bus Safety Performance data available in the public domain that there's no longer any excuse for the truth to be just another victim of TfL's contracted bus operation. I know that was not the case sixteen years ago today when I was searching for TfL Bus Safety Performance Data on my laptop from my hospital bed while I was still being fed through a stomach tube: I could find no TfL Bus Safety Performance Data in the public domain.  
In closing, I've got a few final questions for you and the Charity you lead. 
Will Brake Charity?—
  • Campaign for the Mayor and TfL to understand that the first step toward supporting those 'impacted' by the frequent deaths and injuries generated by London's contracted public bus operation will be for both to acknowledge that these fatal incidents have occurred at all and have them appear in TfL's Annual Road Casualty publications, Monthly Board papers and the baselines TfL uses to measure 'progress' against for Vision Zero 'bus-involved fatalities and determine annual bonus payments for its executives.  It is not acceptable that the Mayor and TfL have been allowed to claim credit for 'progress'—and TfL's executives have been receiving larger bonus payments—for meeting Vision Zero targets that are not based on the actual number—or published Vision Zero Target—of people "killed in or a by a bus".
  • Meet with the Bus Drivers who are leading the Bus Driver Bill of Rights Campaign. I ask, because I know that TfL's secretive Vision Zero Reference Group of which Brake Charity is a member, has representatives from political lobbying groups from the Bus, Taxi and Car industries, but lacks any members who can speak with authority about the well-evidenced "institutionally unsafe" conditions that TfL Bus Contracts inflict on London's Bus Drivers.  And given your recent public comments about the Government's new Road Safety Strategy, I urge to you also to 'be brave' and instruct your charity to begin to understand and campaign to change the systemic safety problems that have plagued TfL's contracted surface transport operation for decades that undermine the ability of a Bus Driver to operate with duty of care for passengers and other road users.
  • Read the Evidence Submissions from London and UK Bus Drivers to the Bus Services [No. 2] Bill.  If you are not familiar with Bus Drivers' key systemic safety concerns, these well-evidenced submissions are a good place to start.  I'll make it easy for you—
  • Watch the videos produced by Bus Drivers posted on the new @BetterBuses YouTube Channel. For more information about his new grassroots driver-led initiative, please read my unacknowledged 16 January 2026 Open Letter to Elly Baker (Labour), Chair of the London Assembly Transport Committee. 
  • Campaign for the DfT to revise its STATS19 bus fatality data definitions to conform to London's Vision Zero "killed in or by a bus" metric, a more robust metric that actually reflects the "Safe Systems" approach upon which the Government claims its recently-published Road Safety Strategy is based.  Based on what we've recently discovered in London, we know that DfT's data showing 521 fatalities from a "Bus or a Coach" for the period 2015-2024 has to be a smaller number than the actual number of road safety-related fatalities that have been generated from the country's bus and coach operations over that period.  Because Lord Hampton raised the issue of the defects of STATS19 reporting for Bus Fatalities in the House of Lords on 13 February 2025, Lord Hendy's response on that date—"in respect of accidents away from public roads, which I will go away and have a close look at. I am not familiar with that nuance, but it is clearly important" —confirms that the Minister knows about STATS19's definitional defects and suggests that the Government's primary road safety dataset for Bus and Coach Fatalities is neither robust nor accurate. I hope Brake Charity can convince Lord Peter Hendy to do more than just "look at" the manifestly obvious and easily solvable problems surrounding STATS19 definitions that have resulted in many of the UK's bus victims to be excluded from the statistics upon which laws and policies are determined.
TfL's contracted bus fleet constitutes about 25% of the public buses in the United Kingdom and delivers over half the country's bus journeys.  If Brake Charity succeeds in using the public funds it receives under its contract from TfL to compel more scrutiny of Bus Safety Performance Reporting by the UK's largest Local Transport Authority, I am confident TfL's longest-serving Commissioner-now-Minister will get up to speed on the 'nuances' to make Bus Safety Reporting more transparent and truthful at a national level. And, since the Lord Hendy is now actively opposing Lord Hampton's Vision Zero (120D) and LTA Bus Safety Reporting (120E) Amendments to the English Devolution and Community Empowerment Bill, there's no time like the present for Brake Charity to act to help TfL's and the country's past and future Vanished Bus Victims. 
Yours sincerely,
Tom Kearney#LondonBusWatch E: comadad1812@gmail.comTwitter: @comadadBluesky: @comadad.bsky.socialYouTube: https://www.youtube.com/@BetterBuses and https://www.youtube.com/@tomkearney955 2018 Winner, Community Hero Award — The Johns Hopkins University Alumni Association2016 Winner, Transport - Sheila McKechnie Foundation SMK Campaigners Award


29-Jan-26
By email and blogpost
Elly Baker, ChairLondon Assembly Transport CommitteeCity HallKamal Chunchie WayLondon E16 1ZE16 January 2026
cc:  London Assembly Transport Committee Members; CEO, London TravelWatch; Transport Commissioner; Deputy Mayor for Transport; Deputy Mayor for Social Justice and Communities, London Victims' Commissioner; TfL Walking and Cycling Commissioner; TfL Board Secretariat; TfL SSHR Panel Secretariat; TfL Chief Safety Officer; TfL Director of Bus; TfL Head of Insights and Direction; TfL Chief Operations Officer
Happy New Year Elly Baker.
I thought you, your fellow London Assembly Transport Committee Members and all of the TfL senior officers copied here might like to scrutinise, and, if of interest, perhaps subscribe to a new free YouTube channel called @BetterBuses.


https://www.youtube.com/@BetterBuses
The  channel has been established by London Bus Drivers who support the grassroots volunteer Bus Drivers Bill of Rights Campaign and will focus on the Human Factors impacting Bus Safety Performance that make TfL's contracted bus operation "institutionally unsafe" for Bus Drivers and Londoners. 
In addition to featuring speeches in support of the Bus Drivers Bill of Rights given by your fellow Committee Members Keith PrinceNeil Garratt and Caroline Russell at the 5 November 2025 Protest at TfL Headquarters, the channel now features thoughtful videos from London and UK Bus Drivers that will:
(a) evidence how—in contrast to other safer transport sectors—TfL does not place a high priority on Human Factors in how public services are contracted, managed and controlled in London, and;(b) offer evidenced-based suggestions as to how TfL's known ignorance of Human Factors that negatively impact Bus Driver Working Conditions can be mitigated. 

The first three episodes have been published:
Episode 1: Human Factors and the Future of Bus Safety — "If a system allows you to make an error it is a bad system.  If a system induces you to make an error, it is a really bad system."
Episode 2: Londons' iBus Radio System: Fit for purpose? — Bill of Rights No. 8. ⁠"The Right to drive without being forced to answer radio messages and texts from Controllers whilst in motion"
Episode 3: Worse & Better Communication - "You can either blame—or learn—it's very hard to do both"

I understand that some new episodes addressing—
(a) TfL's failure to consider Human Factors in how Bus Door Controls are designed that makes Driver error inevitable, and (b) how to fix these known problems.

— will soon appear on @BetterBuses, and subscribers will automatically be notified when each new episode becomes available.
Yours sincerely,

Tom Kearney#LondonBusWatch E: comadad1812@gmail.comTwitter: @comadadBluesky: @comadad.bsky.socialYouTube: https://www.youtube.com/@BetterBuses and https://www.youtube.com/@tomkearney955
Blog:  www.saferoxfordstreet.blogspot.co.ukBus Services [No. 2] Bill Evidence Submission [July 2025]:  https://bills.parliament.uk/publications/61937/documents/6837London Assembly Transport Committee Investigation [April 2024]: https://www.london.gov.uk/about-us/londonassembly/meetings/documents/s110115/Appendix%201%20-%20Letter%20from%20Tom%20Kearney%20received%2015%20December%202023.pdf 2018 Winner, Community Hero Award — The Johns Hopkins University Alumni Association2016 Winner, Transport - Sheila McKechnie Foundation SMK Campaigners Award
By email and blogpost
Sir Sadiq KhanMayor of LondonCity HallKamal Chunchie WayLondon E16 1ZE 
cc: Transport Commissioner; Deputy Mayor for Transport; Deputy Mayor for Social Justice and Communities, London Victims' Commissioner; TfL Walking and Cycling Commissioner; TfL Board Secretariat; TfL SSHR Panel Secretariat; TfL Chief Safety Officer; TfL Director of Bus; TfL Head of Insights and Direction; TfL Chief Operations Officer; London Assembly Transport Committee Members
2 December 2025Dear Sir Sadiq,
Your refusal to respond—or even acknowledge—my Open Letter of 12 September 2025—Will TfL's 'Safety Scandal' serve as your only Legacy?—suggests that you and your TfL appointees reckon that a longstanding policy of contemptuously ghosting me will dissuade me from going public about my volunteer research about TfL's "Institutionally Unsafe" Surface Transport Operation.
Noting that one of your ghosting appointees recently virtue-signalled about a World Remembrance Day for Road Traffic Victims event, I thought it was timely to ask you—as TfL Chair—Why is TfL allowed to ghost people who've been killed or seriously injured "on or by a bus" in its annual official Road Casualty reporting? 
Here's the Problem—
A. TfL is Misleading the Public on Bus KSI Data: Despite TfL claiming since March 2018 that it measures Bus KSIs to include everyone "killed or seriously injured on or by a bus", TfL consistently applies a STATS19 definition to this metric, which allows TfL to exclude people —
"killed on on by a Bus", inter alia, by "collisions on private land, noncollisions (e.g. death due to medical episodes or slips, trips and falls on a bus), incidents outside the Greater London boundary and death occurring after 30 days". 
The most recent example of TfL publishing this misleading KSI metric can be found on page 30 of TfL's "Travel in London 2025" Annual Overview that will be presented tomorrow to the TfL Board. 



Are TfL Board Members aware that Figure 17 is Misleading? 

B.  TfL excludes 20% of Bus Fatalities from its Annual Road Casualty Reporting. 
After years of downloading and reviewing the Bus and Road Casualty data that TfL publishes on its website, it's obvious that Figure 17 must be constructed from STATS19 datasets that TfL knows have excluded about 20% of the preventable fatalities "on or by a bus" that have occurred over the period.




Does the TfL Board know that TfL's Bus Casualty Data excludes 1 in 5 Victims?
Accordingly, Figure 17 cannot possibly include the total number of deaths "on or by a bus"—including—among the dozens of other fatal incidents TfL's official Annual Road Casualty Reports similarly ignore—the preventable deaths of:
Ezarhul Islam (73), who fell after a Go Ahead 191 Bus moved suddenly without warning in October 2015, but died while still in hospital in December 2015. Because Mr. Islam died 30 days after  his death—which resulted in the Coroner issuing a "Prevention of Future Deaths" Order in June 2016—TfL recorded his death as a "Medical" in origin and didn't include the incident in any official Road Casualty reporting, including Figure 17.  Since 1 January 2014, TfL has recorded 69 Fatalities with "Medical" serving as the cause. How many of these "Medical" deaths represent Bus Injury Victims like Mr. Islam, who died 30 days after the incident?  
Saba Mirza (31), who was critically injured on a Zebra Crossing by a Metroline Route 46 in November 2016 but, I understand, died while still in hospital in January 2021 (i.e., after 30 days). By the way, the collision incident that eventually killed Saba Mirza is not recorded in any of TfL's published Bus Safety Performance records, including "TfL Bus Drivers critically injuring pedestrians on Zebra Crossings"
A Male Pedestrian (41) hit by a speeding Go Ahead Route 191 Bus at Edmonton Green Bus Station in February 2020. 
Melissa Burr (32) hit by a Go Ahead Route 507 Bus at Victoria Bus Station in August 2021. 
Stephen Mitchell (60), killed while trying to board a Go Ahead Route 363 Bus in Peckham in November 2022. Until London Assembly Member Keith Prince reported the fact that the Bus Driver was convicted for "causing death by driving without due care and attention" in 2025, on its website TfL previously recorded the incident as a non-fatal "Collision" Incident where the victim required "No Treatment".  Since 1 January 2014, TfL has recorded 3053 Bus Collision Incidents where the victim required "No Treatment".  How many of these incidents resulted in the death of the victim where the Bus Driver was convicted? 
Grace Mecaley (74) hit by Go Ahead Route 212 Bus at Walthamstow Bus Station in December 2023. 
Note: The Bus Stations where the unknown Male Pedestrian, Melissa Burr and Grace Mecaley were killed by TfL Buses, are—in principle—held to a much higher Health and Safety standard than public roads. Given the Mayor's Vision Zero 'ambition', how can TfL justify failing to report any preventable incident where someone has been killed "on or by a bus" at a Bus Station? 
C. TfL excludes 80-85% of Serious Injuries from Buses from its Annual Road Casualty Reporting
The KSI data TfL shown in Figure 17 is based on Serious Injury data that is substantially lower than the annual data which can be extracted from the Bus Casualty Data that TfL publishes on its website every quarter.  Using "Taken to Hospital" as the only reasonable proxy for Seriously Injured, and given that the Mayor admitted to Neil Garratt (AM) that—
'TfL does not receive ongoing updates on the status and health outcomes of people who were previously involved in bus incidents and has no information about the health status of members of the public up to eight years after an incident' 
—the vast difference between TfL's published annual Serious Injury figures and TfL's published "Taken to Hospital" data suggests that TfL's official Serious Injury data has to be a number that TfL executives simply invent. This chilling discrepancy demands a clear and evidence-based explanation that neither you nor TfL seem capable of delivering.   


Does the TfL Board know that TfL's Serious Injury from Buses data only reflects about 20%
of those Reported Injured who've been Taken to Hospital?


D. Lack of Data Integrity results in TfL and the Mayor misleading the public about the Real Danger of its Contracted Public Bus Operation.
Building upon a recent press statement by former TfL Board Director and Safety Panel Chair, Michael Liebreich, 'the way TfL spins the data on bus safety in London is reprehensible. Despite the Mayor's Vision Zero target targeting "no deaths in or by a bus by 2030", TfL knowingly uses a defective STATS19 dataset to (a) design bus safety policies (b) measure Bus Safety Performance against Vision Zero targets (c) determine management bonuses that excludes around 20% of bus deaths, such as those that occur in private bus stations.
Whenever deaths go down, TfL talk about reductions in deaths (2023), but when they go up they talk about KSIs (2024), and the numbers for serious injuries are (a) internal figures that are never independently audited (b) inexplicably lower than the number of people Bus Operators report to TfL are sent to hospital after being injured in recorded and reported preventable bus safety incidents.  
Despite a Vision Zero Programme being in place since July 2018, the reality is TfL buses killed 16 people in 2024—the highest annual figure since 2009, despite a 20% reduction in bus journeys since then. The reality is that London has the least safe bus system of any major European city, and TfL and the Mayor are manipulating data so that Londoners didn't know it.'
Here's the—start of a— Solution:
E.  "Radical Transparency" and Vision Zero
On 21 December 2023, Neil Garratt AM asked you a question:
"On 11 September 2019, a former TfL Board Director and Safety Panel Chair told the London Assembly Transport Committee and your Deputy Mayor for Transport: "We owe it to the victims of that accident [Sandilands] and we owe it to victims of accidents on the buses and on other parts of the network to get to the bottom of exactly how this organisation is run. How does it deal with this sort of situation? What happened? Why did it happen? How did they do that audit? What lessons can we learn about how to do audits? How can we make sure that we are delivering the radical transparency that is the only way to deliver Vision Zero? I am not trying to be difficult or unpleasant or cause problems, but I can tell you now that if you do not deal with that culture and if you do not have robust audit processes, you will get nowhere near to Vision Zero. Nowhere near to Vision Zero." Since (a) bus collisions remain at the same level (about 80 per day) as when you announced your Vision Zero Programme in July 2018 and (b) casualties from buses are now higher than when you took office, will you commit to a policy of "radical transparency" on bus safety?"

In your response, you stated —

"Transport for London (TfL) has no higher priority than the safety of its customers, staff, and those affected by its operations, and continues to strive to reach the ambitious Vision Zero targets."

I need not remind you that, 

  • since you've been Mayor, your Vision Zero Target for Buses that "no one to be killed on or by a bus by 2030" has been going the other way.

  • on 3 July 2025, your own Transport Commissioner admitted to the London Assembly that—

 "until this year...the Bus Companies would still be penalised if they curtailed or did not meet their performance requirements because of the hot weather or because they were taking action to support Driver Welfare"

As TfL chair, you can begin to reverse your failing Bus Safety record around today by immediately—

1) Issuing a Formal Apology to each of the families of Saba Mirza, Stephen Mitchell, Melissa Lamb and Grace Mecaley—all killed "on or by a bus" under your watch as Mayor and TfL Chair—with a full explanation as to why—since their loved ones' deaths "do not meet STATS19 criteria"—TfL did not include their incidents as part of (a) "the underpinning data source for all road safety policy and from which Transport for London (TfL) built its evidence base for the Bus Safety Standard (BSS)" (b)  "TfL's road safety targets and baseline" (c) in the determination of executives' bonuses for achieving safety targets in, respectively, 2016, 2021, 2022 and 2023, (d) Figure 17. 


2) Publishing a Consolidated Annual Figure for people "killed on or by a bus" in London. 


Your explanation as why you refuse to order TfL to perform the simple task of publishing a consolidated annual figure that shows all the people "killed on or by a bus" is, frankly, contemptuous of the families of the over 100 victims who—while you have served as Mayor and TfL chair—have been killed "on or by a bus", as well as of the at least 9698 victims who've been sent to hospital from preventable Bus-related injuries over the same period.  A truly just Vision Zero Policy would not impose on the families of victims—or on victims themselves—the obligation to interrogate TfL's dubious datasets in order to discern the actual number of how many people have been killed "on or by a bus" in London. Both you and TfL are wittingly adding insult to injury: have you no shame?


3) Instructing TfL to conduct a Independent Data Integrity Audit of all TfL's published Bus Safety Datasets


Since at least 2022, Keith Prince has been asking you instruct TfL to conduct an Independent Audit of the Integrity of TfL's published Bus Safety Performance Data. 


March 2025 - Vision Zero: Bus Safety Data Integrity Audit


November 2024- Vision Zero: Independent Data Integrity Audit of TfL Bus Safety Data


March 2022 - Independent Audit of TfL's Quarterly Bus Safety Data


Given the obvious problems associated with TfL Bus Safety Data reporting—I've only described a few above—your repeated refusal to even countenance Keith Prince AM's reasonable 'ask' brings to mind a statement that Lord Hampton —"who recently sponsored five, ultimately unsuccessful, safety-related amendments to the Better Buses Bill in the House of Lords"—made to the press about your refusal to inscribe the London Bus Drivers Bill of Rights into TfL's Framework Bus Contract
"TfL will probably say 'we don't recognise this because nobody's brought this to our attention'.
"But if it has been brought to their attention and they're not doing anything about it, that's a very different thing."

Under your watch as Mayor and TfL Chair, you've presided over a Surface Transport Operation that has produced— 

  • at least 100 deaths from preventable Bus Safety Incidents;
  • 76 deaths of Bus Drivers from Covid-19; and, 
  • 7 deaths from the 2016 Croydon Tram Crash at Sandilands.

While Bus Safety's obviously been a 'very different thing' at TfL since at least 2001, and despite all your virtue-signally about Vision Zero, you've done nothing to rid TfL of its "Institutionally Unsafe" Culture.  In fact, even TfL's dubious datasets evidence that you've made it worse
TfL's 'Safety Scandal' will be your Legacy.
Yours sincerely,
Tom Kearney#LondonBusWatch E: comadad1812@gmail.comTwitter: @comadadBluesky: @comadad.bsky.social
Blog:  www.saferoxfordstreet.blogspot.co.ukBus Services [No. 2] Bill Evidence Submission [July 2025]:  https://bills.parliament.uk/publications/61937/documents/6837London Assembly Transport Committee Investigation [April 2024]: https://www.london.gov.uk/about-us/londonassembly/meetings/documents/s110115/Appendix%201%20-%20Letter%20from%20Tom%20Kearney%20received%2015%20December%202023.pdf 2018 Winner, Community Hero Award — The Johns Hopkins University Alumni Association2016 Winner, Transport - Sheila McKechnie Foundation SMK Campaigners Award

By blogpost
Sir Sadiq KhanMayor of LondonCity HallKamal Chunchie WayLondon E16 1ZE 
cc: Transport Commissioner; Deputy Mayor for Transport; Deputy Mayor for Social Justice and Communities, London Victims' Commissioner; TfL Walking and Cycling Commissioner; TfL Board Secretariat; TfL SSHR Panel Secretariat; TfL Chief Safety Officer; TfL Director of Bus; TfL Head of Insights and Direction; TfL Chief Operations Officer; London Assembly Transport Committee Members
12 September 2025Dear Sir Sadiq,
RE: Will TfL's 'Safety Scandal' serve as your only Legacy? 
While I was reading the BBC's 31 August thoughtful report "Oxford Street to go car-free for a day", a couple of horrific and all-too-familiar reports popped up on my twitter feed


— and I asked myself: what will serve as Sadiq Khan's legacy as Mayor of London and TfL Chair? 
You were elected in 2016 with a Manifesto Pledge—echoed by all the 2016 Mayoral Candidates—to pedestrianise Oxford Street.
Meanwhile, based on data from Mayor's Questions from Hina Bokhari AM you provided last year (cf. MQ 2024/3119 [OCT24] and MQ 2024/4047 [DEC24], we know that, over the 8-year period from May 2016 to May 2024, TfL reports that 129 people were killed (4) or seriously injured (125) by vehicles on Oxford Street.  
That's more than 1 person killed or seriously injured per month by a vehicle on Oxford Street since you were elected with a promise to put an end to "the shaming death toll of Oxford Street's buses"
A quick analysis of your data reveals that, of those 129 recorded KSI incidents, TfL Buses—a fleet of vehicles over which you have control—have been involved in three-quarters of the incidents with fatal outcomes (3) and almost a third (34 of 125) where the victim was seriously injured. Even more alarming, your data shows that the frequency of these KSI incidents on Oxford Street are now 20 percent higher than when you declared your Vision Zero Programme in July 2018. 
Your data does not include any KSI incidents which occurred after 31 May 2024, including—obviously—the (so far, unreported) 31 August crash, the crash on 22 August (cf. "Oxford Street accident: Man rushed to hospital after crash") and many other reported KSI incidents on Oxford Street and its close vicinity (e.g. 28 July 2025 - "London Regent Street horror with pensioner fighting for his life after bus crash", 4 June 2025 - "Oxford Street bus crash leaves woman critically injured.", 14 April 2025 - "New Oxford Street van crash: Cyclist fighting for life"). And, as you already know, your data also doesn't include any information about whether the Bus Crash Victim died after 30 days from serious injuries. 
Following TfL's 4 September KSI Bus Crash at Victoria Station, I was pleased to see some granular reporting about your Bus Safety Record published by Westminster Extra
"While Sadiq Khan has been mayor and TfL [Transport for London] chair, about every six weeks someone has been killed in a London bus safety incident. Three in four of these deaths are the result of a bus collision. In 2024 someone was killed in a preventable bus safety incident every three weeks. Except for a short period during the Covid-19 pandemic, recorded crashes have been stuck at an eerily predictable 80 bus crashes per day for the past five years."
Since that's all TfL's data taken from the March 2024 London Assembly Transport Committee Investigation—and recently published by the House of Commons in evidence submitted by me and several London and UK Bus Drivers—as TfL Chair, you are—no doubt —also familiar with these well-evidenced facts:
  • analyses of years of TfL's published casualty data reveal that TfL Buses—which (a) constitute about 1 percent of the vehicles on the road at any time, and (b) are solely contracted by TfL—were involved in 15 percent of all pedestrian fatalities from Road Vehicles in London in 2024, an increase from the ghastly 10 percent annual average from 2014-2023. 
  • when benchmarked to its 'World City' peers by Imperial College, year-after-year London consistently appears at the bottom tercile for Bus Collisions. 
Yet, despite all this information that's available in the public domain, you have repeatedly stated—as you did in your recent response to Question 2025/2079 [JUN25] from Neil Garratt AM—that, "since 2016, TfL's Bus Safety Programme has made considerable progress."  
Would it not be more accurate and respectful to the victims and their families to describe this chilling increase in deaths per bus mile, as a "catastrophic and unacceptable failure", rather than "considerable progress"?
While you have served as Mayor of London and TfL Chair—
    • every day over 3 people have been hospitalised from a preventable bus safety incident, 1 of which is due to a collision.
    • deaths "on or by a bus" have risen from 12 in 2016 to 16 in 2024, despite at least an 8% fall in the number of bus miles driven. 
    • at least 100 people have lost their lives from preventable safety incidents "on or by" TfL buses.  
    • and—at least— 76 Bus Drivers lost their lives to Covid-19 and 7 passengers were killed in the Croydon Tram Crash, both safety catastrophes that, despite the many serious questions about TfL's poor oversight of these crises that remain outstanding, you are obviously desperate to close the books on
Despite any upcoming media-friendly stunts you plan to pull on Oxford Street, your shameless public opposition to—— confirms that you're well on the way to having TfL's Safety Scandal represent your true legacy.
I plan to visit Oxford Street on 21 September.  If you'd like to hear first-hand what it's like to be treated contemptuously by TfL after I bled out critically-injured in a near-death coma courtesy of a TfL bus on 'Europe's Busiest Shopping Street', I'd welcome the chance to meet you for the first time ever.  And since (a) I've researched TfL's "Institutionally Unsafe" Franchised Surface Transport Operation 'relentlessly' since 2010 (b) I successfully campaigned for TfL's long-standing Bus Safety polices—i.e, TfL publishing its Bus Safety Performance Data every Quarter (2014) and its funding access of access to Confidential Safety Reporting (CIRAS) for London Bus Drivers (2016)— and (c) your senior executives at TfL have refused to engage meaningfully with me since 2018, given your failing Vision Zero 'ambition', as TfL Chair, you might find meeting with one of the thousands seriously injured by TfL's franchised public bus operation since 2009 a useful demonstration of your stated commitment to the need for good governance and transparency in the state's oversight of public transport services. 
Yours sincerely,


Tom Kearney#LondonBusWatch E: comadad1812@gmail.comTwitter: @comadadBluesky: @comadad.bsky.social
Blog:  www.saferoxfordstreet.blogspot.co.ukBus Services [No. 2] Bill Evidence Submission [July 2025]:  https://bills.parliament.uk/publications/61937/documents/6837London Assembly Transport Committee Investigation [April 2024]: https://www.london.gov.uk/about-us/londonassembly/meetings/documents/s110115/Appendix%201%20-%20Letter%20from%20Tom%20Kearney%20received%2015%20December%202023.pdf 2018 Winner, Community Hero Award — The Johns Hopkins University Alumni Association2016 Winner, Transport - Sheila McKechnie Foundation SMK Campaigners Award










16-Aug-25


Three "Rights" listed in the London Bus Drivers Bill of Rights

  • The Right to a safe work schedule without any forced overtime or loss of pay 
  • The Right to a decent and proper rest break in the working day 
  • ⁠⁠The Right to be treated with dignity and respect by our employers, TfL and the public 

— underscore the extent to which the system in which TfL negotiates, agrees and enforces its Bus Performance Contracts is broken. But there's something deeply broken about a Public Surface Transport System the compels its own workers to be complacent about Fatigue even before they start the job.

Among TfL's Bus Contractors a Fatigue-inducing Practice of forcing new Bus Drivers to sign away their right to a legal 48-hour working week has been quietly normalised. Drivers are compelled to give up this right—not after settling in and understanding the full implications of the job—but on Day One, during their Induction. 

And the form they're made to sign leaves no room for debate.

"As an Employee of [INSERT TfL BUS OPERATOR NAME HERE] , I agree of my own free will and individual choice to opt out of the average maximum working week of 48 hours contained within the Working Time Regulations 1998. If you wish to withdraw from this agreement, please speak to the Trainer on your Induction."
This sounds reasonable at first glance, but if you bother to take a closer look, the cracks in the façade will quickly appear. The form doesn't ask for consent — it assumes it. There is no box to tick "NO," no space provided for the Driver to object and no explanation is provided for what this 'agreement' actually means in practice. It is a pre-written obligation that's disguised as a choice. And the timing? Just as the hopeful new recruit walks into the job for the first time.

This document doesn't only reflect bureaucratic complacency: it is coercion wearing a smile.


The Illusion of "Free Will" to choose Working Hours.


The document's phrasing is deliberate: "I agree of my own free will and individual choice." This is legal theatre. A performance designed to bypass the spirit of worker protections by putting the burden of refusal on the most vulnerable: new Bus Driver hires.


This form: which asks New Bus Driver Hires to opt out of the legal 48-hour weekly working limit is given to the prospective employee before he or she even officially starts, usually a few days or a week ahead of his or her induction day. On Induction Day, the Operators assiduously check if all pre-employment forms—including this one—are completed and signed. If anything is missing, your application may be paused or even stopped altogether. For some documents, Bus Operators might offer assistance. But with this one, the approach is more blunt: "Sign it, and if you want to opt back in later, sort it out after you've started."


Yes, there's technically a process that allows a Driver to withdraw consent the future.  But even this opt-out comes with its own catch. The form specifically states:

"I understand that this agreement will continue unless I decide to terminate it by giving four weeks notice in writing addressed to my Operations Manager." 

In plain English: if you don't want to agree now, you're either out of the running — or locked in for four weeks of whatever hours the company demands—with no guarantees of ever receiving a manageable schedule.  

This is not informed consent. This is institutional pressure hiding behind a paper shield.

A Legal Loophole Becomes Standard Operating Procedure.


The Working Time Regulations 1998 were designed to protect workers from burnout and exploitation. At their heart is the 48-hour average weekly limit — a safeguard for both physical and mental health. But these regulations include an "opt-out" clause that employers can use — provided the worker consents.
And therein lies the catch. Consent should be both informed and voluntary. But in TfL's  dark corner of the UK transport industry, consent is to a signature at the end of a line you cannot edit. It has become so normalised that many Drivers no longer question it. They simply accept that if they want the job, they sign the form — and brace themselves for 50, 55, or even 60-hour weeks, often with unpredictable shifts and only the bare minimum of legal rest between them.

No Perks. No Overtime Pay. No Choice.


In most industries, working beyond the legal average might come with off-setting mitigations, e.g. overtime rates, time-off in lieu of extra time served, extra holiday, or even a simple recognition from one's managers. But for TfL Bus Drivers, the message is stark: Do More for Less. Drivers working well beyond the 48-hour threshold receive no extra pay. There are no perks for opting out — only pressure. And once you've signed the opt-out, your Bus Operator employer's expectation is that you'll continue to put in those excessive hours indefinitely. Yes, the form says you can withdraw from the agreement—but let me underscore—that burden is placed on the individual Driver, someone who is more than likely still finding his or her feet in a difficult and hierarchical working environment. Few Bus Drivers will feel empowered to walk into a Manager's office and say: "I've changed my mind."
A Broken Industry Founded Upon Broken Promises.

Bus driving is already one of the most demanding jobs in London.  Drivers manage thousands of passengers a day, navigate unpredictable traffic, deal with verbal abuse and threats, and are still expected to maintain perfect punctuality despite impossible schedules. It's no wonder the industry is facing a recruitment and retention crisis.


And yet, instead of addressing these systemic issues — poor pay, long hours, safety risks, understaffing — TfL's solution has been to permit its Bus Contractors to lean harder on the people who show up every day. This opt-out form is a symptom of a deeper systemic disease:  tt reveals how TfL contracts its Bus Contractors to treat time, energy, and health as infinite resources that they can consume without human costs so that Bus Users are satisfied and Bus Companies are profitable. The opt-out form shows how easily "choice" becomes manipulation when the power dynamics are skewed entirely in favour of the unaccountable.  And this form proves that exploitation doesn't start after a London Bus Driver gets behind the wheel:  it starts the moment he or she is handed a pen.


The Fight for Change Begins with Awareness.


If the Mayor and TfL are serious about fixing London's well-evidenced record of failing Bus Safety Performance, they must start with Transparency.  The Mayor and TfL must prevent Bus Contractors from pretending that this opt-out form is a fair agreement.  They must stop Bus Operators from assigning "free will" to Bus Drivers decision to sign it when they know it's anything but.   And the Mayor, TfL and the Bus Operators must stop expecting workers to sacrifice their wellbeing in Silence.  London's 'world leading' Public Bus Network only runs because of its Drivers.  Without them, the city doesn't move.  The least these Drivers deserve is respect: and that starts with giving them a real choice about their working hours, not a rubber stamp that condemns them to a working life hobbled by Fatigue.


When 'Protection' Becomes Permission.


In theory, Unite the Union— the only union TfL recognises representing London's bus drivers — should be the first line of defence against the kind of exploitation I just described.  In principle, Unite the Union should be standing between Bus Drivers and any Employer what attempts to undermine their rights.   The fact that the 48-hour week opt-out clause exists today is, in my opinion, ample evidence of on whose side Unite the Union stands...and has stood for decades.  If Unite had been doing its job, a Bill of Rights wouldn't be necessary.
The pressure for Bus Drivers to sign the opt-out of a 48-hour week is a systemic fact, and the implications upon Working Conditions are serious: yet it appears Unite has complacently allowed this opt-out clause to thrive without any challenge.  
No formal objection. No legal pushback. No 'grassroots' campaign from Unite to demand a restructured, transparent opt-in system.
If Unite truly represented the interests of its Bus Workers, it would demand:

  • That all Working Time Agreements present a real choice:  with a clear 'yes or no' checkbox.
  • That opting in or out does not affect Bus Workers' Job Offers or Career Progression.
  • That Bus Drivers can challenge unrealistic rotas without the fear of being disciplined or isolated by their managers.

When Unite the Union—the very institution that's meant to stand up for London's Bus Workers—has complacently accepted the Employer's line for decades, then something is deeply broken...and unjust.


The Bigger Picture
The reality: before a London Bus Driver even starts up an engine, he or she is already being asked to surrender a fundamental workplace right:  not through open dialogue, but through a form that's presented to him or her as a perfunctory formality.

The message is clear: if you want the job, you'll play by the rules that are already well stacked against you. And if those rules exhaust you, or endanger your well-being or others in your bus or on the road? That's your fault: you've already signed away your leverage.


What makes the current situation worse is the silence from those who should be shouting the loudest.  A Union that turns a blind eye, or worse, plays along, isn't protecting anyone. It's simply helping to keep TfL's contracted 'Killing Machine' running day-in, day-out.


This isn't about paperwork: it's about power. And until the Mayor and TfL start asking the right questions—and demanding real accountability from Bus Operators and Unite the Union—Bus Drivers will keep being pressured to drive fatigued and powerless to change things.


And increasing numbers of lives and livelihoods will be lost as a result of a Franchised Public Bus Operation—under the complete control of the Mayor of London—that refuses to make Driver Welfare and Public Safety a Priority.


26-May-25
By email and blogpostCaroline Russell AMLondon AssemblyCity HallKamal Chunchie WayLondonE16 1ZE26 May 2025

Dear Caroline Russell,


RE: The Mayor's 7 May 2025 Response to the London Assembly's 13 February 2025 London Bus Driver 'Bill of Rights' Petition 

Kindly note that I am forced to write to you anonymously because the poor TfL Bus Safety Performance and Bus Driver Working Conditions issues I highlight publicly here today might get me fired from my job as a TfL Bus Driver.  In any case, this bit of public reporting of my concerns about the Mayor's and TfL's poor safety oversight of London's Contracted Bus Operation will certainly get me disciplined, and my family and I cannot risk that. 

I note the Mayor responded to your 13 February 2025 Submission of our Bill of Rights Petition (letter attached) on 7 May 2025.

Since you put yourself at the front of our 29 January 2025 Bill of Rights March from Victoria Station to Parliament, you know what 'Rights' we are demanding, i.e.,—

 1.⁠ ⁠The Right to a safe work schedule without any forced overtime or loss of pay

 2.⁠ ⁠The Right to a decent and proper rest break in the working day

 3.⁠ ⁠The Right to drive a safe and well-maintained vehicle

 4.⁠ ⁠The Right to clean, serviced toilet and rest facilities on all bus routes

 5.⁠ ⁠The Right to report safety concerns without fear of retribution from TfL or employers

 6.⁠ ⁠The Right, when seriously ill and covered by a doctor's note, to not be harassed into coming into work until fit to do so

 7.⁠ ⁠The Right to relevant and timely safety training

 8.⁠ ⁠The Right to drive without being forced to answer radio messages and texts from Controllers whilst in motion

 9.⁠ ⁠⁠The Right to have all company rules in writing and clearly displayed

10.⁠ ⁠⁠The Right to be treated with dignity and respect by our employers, TfL and the public

11.⁠ ⁠The Right to Working Air Cooling in our cabs in the summer heat 

12.⁠ ⁠The Right to Working Heaters in our cabs in the cold of winter

Because our lived experience proves that (a) we do not have these Rights and (b) we have no remedies to invoke when we are denied them by our employers, we are asking that they be inscribed into TfL's Framework Bus Contract so that the Rights are unambiguously established and will apply universally to all London Bus Drivers in a single, publicly-accessible document that the (1 January 2016) TfL Framework Bus Contract represents.

If you had the opportunity to scrutinise Deputy Mayor Seb Dance's 11 May 2025 Response to Bus Driver Activist Kevin Mustafa's 10 December 2024 Letter or any one of the Mayor's Responses to Questions 2025/0580 to 2025/0592 provided to Keith Prince AM from 28 February -12 March 2025, you'll see that the Mayor's 7 May 2025 Response to you is just the same regurgitation of the fact-free gaslighting that he, his Deputy and TfL have been dishing out since the Mayor's 21 January 2025 Response to Question 2025/0089 from Thomas Turrell AM.

Kindly note that even a cursory scrutiny of the Mayor's official reason for rejecting the Bill of Rights, i.e—

"Many aspects of the proposed 'Bus Drivers' Bill of Rights' are already covered by existing agreements, actions or legislation."

—will reveal City Hall's repeated refusals lack any granular evidence to support them.

Why

Because even a little scrutiny of what appears to be a hastily-assembled collection of factoids that purport to evidence the existence of the Bill of Rights, negates City Hall's and TfL's ill-conceived assertion that these Rights exist at all

Based on our lived experience as London Bus Drivers and thousands of facts on the public record thanks to dozens of Freedom of Information Requests, at least two London Assembly Transport Committee Investigations (2017 and 2024) and hundreds of Mayor's Questions since 2011, we are confident that "arm-waving" statements from City Hall and TfL like—

"Relevant legislation includes, but is not limited to, the Health and Safety at Work Act (1974), the Workplace (Health, Safety and Welfare) Regulations (1992), Working Time Regulations (1998), Management of Health and Safety at Work Regulations (1999), and the Equality Act (2010)."

and

"Further regulation is provided by the need for all bus operating companies to hold a valid Public Service Vehicle Operator Licence and to adhere to requirements set by the Traffic Commissioner and administered by the Driving and Vehicle Standards Agency (DVSA)." 

and so on... 

— are intended solely to confuse the London Assembly and the public.

Will the London Assembly assiduously scrutinise all these statements from the Mayor, his Deputy and TfL? 

"already covered by existing 'agreements'"

  • What agreements? 
  • Between what parties? 
  • Where are these agreements recorded and available for public scrutiny?
  • Which "Right" or "Rights" contained in the Bill of Rights do these agreements to which the Mayor refers establish? 
  • To which specific clause in which specific "agreements" can a London Bus Driver refer when he or she is denied the "Right" or "Rights" founded upon said agreement(s)?
  • Do all these alleged agreements to which the Mayor refers apply uniformly across all of London's Bus Contractors and treat all London Bus Drivers equally
If the Mayor continues to refuse to provide substantive documentary evidence to support his claim about all alleged "agreements" he claims establish the existence and application of the Bill of Rights for all London Bus Drivers, isn't the Mayor just gaslighting the public body whose sole job is to scrutinise him and the institutions over which he has authority?
"already covered by existing...'actions'"

  • What—exactly—is an "action"?  
  • Where are said "actions" recorded, between whom are they agreed, and to whom do they apply? 
  • Are these "actions" published and available for public scrutiny? 
  • Which "Right" or "Rights" contained in the Bill of Rights do these "actions" to which the Mayor alludes establish? 
  • To which specific clause in which specific "actions" can a London Bus Driver refer when he or she is denied the "Right" or "Rights" founded upon said "action(s)"?
  • Do these "actions" apply uniformly across all of London's Bus Contractors and treat all London Bus Drivers equally?

If the Mayor continues to refuse to provide documentary evidence to support his claim about all the alleged "actions" he claims establish the existence and application of the Bill of Rights for all London Bus Drivers, isn't the Mayor merely gaslighting the London Assembly?

"already covered by existing...'legislation'"

  • The Mayor cites various legislative acts but does not reference specific clauses, why? 
  • Which "Right" or "Rights" contained in the Bill of Rights does this said legislation establish? 
  • To which specific clause in which specific legislation can a London Bus Driver refer when he or she is denied the "Right" or "Rights" founded upon said legislative act(s)?
  • If Bus Drivers are being denied Rights guaranteed by Legislative Acts, aren't TfL Bus Contractors breaking the law? 
  • If the Mayor of London, as TfL Chair, is permitting TfL Bus Contractors to break the law, isn't he just an accomplice? 

If the Mayor continues to refuse to provide documentary evidence to support his claim about all the "legislation" that establishes the existence and application of the Bill of Rights for all London Bus Drivers, isn't the Mayor gaslighting you? More importantly—if what the Mayor has stated is true and can be backed up by evidence—is he knowingly permitting TfL Bus Contractors to break the law? 

As you know well, the Bill of Rights we're demanding derive directly from the lived experiences of London Bus Drivers. The Mayor claims we already enjoy them, but he refuses to cite:

(a) the Specific Clauses of the any Existing Agreements, Actions or Legislation that Guarantee London Bus Drivers those Rights 
and, more importantly—
(b) the Specific Remedies available to Bus Drivers when we are denied them.

As a publicly-elected official whose sole purpose is to scrutinise the Mayor of London and the institutions over which the Mayor has authority, we believe it is incumbent upon you and the London Assembly to reject the Mayor's contemptuous response and subject it to some meaningful scrutiny. 

The penultimate paragraph of the Mayor's letter to you—

"TfL encourages any London bus driver who feels his or her rights are being infringed to raise their concerns with their employer, their union, or TfL directly. This can also be done via an anonymous reporting system, The Confidential Incident Reporting & Analysis Service, which is available to all drivers."

—should provide you with some encouragement that being on 'the right side of history' on Bus Safety occasionally bears fruit. 

On 17 September 2014, your Green Party Predecessor Darren Johnson asked Mayor Boris Johnson a simple question about Bus Safety—

Unlike Tube Drivers, the drivers of buses in London do not have access to a Confidential Incident Reporting & Analysis System (CIRAS), where employees can confidentially register individual concerns about work colleagues, working  practices, and other activity which presents a safety hazard, or fails to apply good systems of risk management with the assurance that these safety concerns will be investigated by an independent body.   Will you immediately order TfL to make subscription to CIRAS a condition of continuing to be an approved supplier for TfL London bus contracts and other related services?

And the argument put forward by Mayor Boris Johnson to reject Darren Johnson AM's reasonable request  —

There are already robust systems for reporting and investigating safety issues and incidents across the bus network. Assurance is provided by audits of operator reporting and investigating procedures, as well as regular reviews of reported data. All London bus operators have their own established procedures in place.

— seems remarkably (and contemptuously) similar to Mayor Sadiq Khan's to you on 7 May.

As I suspect you already know, after further campaigning from Darren Johnson joined by Assembly Members from the Liberal Democrat (Caroline Pidgeon AM) and Conservative Parties (Richard Tracey AM, Victoria Borwick AM), Mayor Boris Johnson was shamed into extending Confidential Safety Incident Reporting to TfL Bus Drivers in January 2015  and—after TfL delayed (obstructed?) implementing the Mayor's order for a year—CIRAS was officially extended to Bus Drivers by TfL at its cost in January 2016.

Given the dozens of Mayor's Questions about the Bill of Rights Conservative Assembly Members Keith Prince AM, Neil Garratt AM and Thomas Turell AM have put forward since we started the Bill of Rights Campaign at TfL Headquarters on 5 November 2024, and additional questions from Liberal Democrat AM Hina Bokhari, from my simple Bus Driver's perspective it would appear that you've got at least a quorum of Assembly Members that would support you putting a Bill of Rights Motion in front of the Assembly for a debate and a vote.

To be honest, we are disappointed by the fact that, since 29 January 2025, you haven't been inspired to (a) ask any Mayor's Questions about the Bill of Rights or (b) present a Bill of Rights Motion to allow all Assembly Members from all Parties to reveal their public positions about our reasonable demands.   Now, more than ever, we need you to work with other London Assembly Members to pressure the Mayor to stop gaslighting the London Assembly about the Bus Drivers Bill of Rights.  Your predecessor Darren Johnson's success in obtaining Confidential Safety Incident Reporting for London Bus Drivers against Mayoral and TfL's public gaslighting is a good example of the kind of "about-face" that's possible when both facts and common sense are on your side. 

Given the fact that 2024 saw a doubling of 2023's number of people killed 'in or by a bus' , the Mayor's Vision Zero 'ambition' for that chilling number to be 'zero by 2030' appears to be nothing more than a virtue-signalling fantasy.  Much like the Confidential Safety Incident Reporting for London Bus Drivers that the Mayor of London and TfL once vociferously opposed but now are publicly cheerleading, we believe that the the Bill of Rights we're demanding is just common sense that the Mayor and TfL will come around to embrace when the public narrative they've been pushing is revealed, as it was with Confidential Incident Safety Reporting for London Bus Drivers, to be manifestly incorrect. 

You marched at the head of our procession to Parliament on 29 January 2025. 



You met us in front of City Hall on 13 February 2025 to receive our Bill of Rights Petition. 




We look forward to you to continue supporting us in our efforts to convince the Mayor about the lethality and negligence of his and TfL's public rejection of the London Bus Driver Bill of Rights.

Lives and Livelihoods are stake here:  we continue to expect that you'll remain on the 'right side of history' on the London Bus Drivers Bill of Rights. The facts, common sense, and London Bus Drivers are on that side too.

Yours sincerely,


—An Anonymous London Bus Driver





20-May-25
By blogpost                                                                                                        20 May 2025
London Bus Alliance
c/o Michael Roberts, Chief Executive, London TravelWatchcc: Mayor of London; Transport Commissioner; Deputy Mayor for Social Justice and Communities, London Victims' Commissioner; Walking and Cycling Commissioner; TfL Board Secretariat; TfL SSHR Panel Secretariat; London Assembly Transport Committee Members; House of Commons Transport Committee Members; Sharon Graham - Unite the Union; Eddie Dempsey - RMT Union; Gary Smith - GMB Union; Barry Gardiner-MP; Sian Berry - MP, Gareth Bacon - MP, Tom Kearney (@comadad); London Bus Alliance Members

Attachment: London Bus Alliance Letter to TfL (13 May 2025)
Dear Mr. Roberts,

RE: Improving London's Bus Services
We are writing to you because you serve as Chief Executive of London TravelWatch, the sponsor of the London Bus Alliance and the initiator of a 13 May public letter (attached, for ease of reference) addressed to Lorna Murphy, Director of Buses at Transport for London (TfL). 
By means of introduction, we represent the London Bus Drivers Bill of Rights Campaign, an independent group of London Bus Drivers, the very people delivering the service about which London TravelWatch and London Bus Alliance's Members have had so much to comment over the years. 
To be frank, we are dismayed by the contents of your letter and the "research" which it references——which only highlights the issue of slow bus journey times in London—because it fails to make any mention of the—
a) Well-evidenced and long-known Poor Working Conditions of London's Bus Drivers;b) Poor Operational Safety Performance of London Buses  
 
We Bus Drivers know that these Poor Working Conditions are a direct result of "Institutionally Unsafe" Excess Waiting Time/Mileage-based Financial Performance Incentives that have been embedded in TfL Bus Contract Performance Incentives since 2001. Because TfL's Bus Contractors are only paid for the time their buses are being driven by us and—at that—only when we are compelled to meet contracted Timeliness Targets, TfL has designed a public bus franchise model we know does not put safety first. Why? Because all the system's financial rewards flow solely from the timely performance targets that the London Bus Alliance obviously feels are paramount to all others, Safety and Bus Driver Wellbeing included. 
Since London TravelWatch claims to represent the interests of London's Public Transport Users, surely you know that TfL's own published data reveals that, since 2014—
  • An average of 3 people a day have been hospitalised from a preventable Bus Safety Incident, at least one of which involves a Bus Collision;
  • About every 5-6 weeks, someone has been killed in a preventable Bus Safety Incident, mostly from Bus collisions. In 2024, there was such a death every 3 weeks.
  • For the past decade, 1 in 10 Deaths from Road Traffic Incidents in London has involved a TfL Bus.  Based on TfL's published data it also appears that, Based on 2024's preliminary figures, we believe that chilling ratio shrank to 1 in 7.  Do you agree with me that is an appalling level of lethality for public service vehicles that represent less than 1 percent of the total number of vehicles driving on London's streets at any given time?
  • Since this Mayor was elected, over 100 people have been killed in preventable Bus Safety Incidents, 70% from collisions. 
Simply put: for a public transport body to contract a shared public transport service that uses shared transport paths only for timeliness and mileage proves that the Mayor of London wittingly presides over a public bus operation that's risking lives and livelihoods for the convenience of bus users.  Do London TravelWatch or the London Bus Alliance speak for the tens of thousands of people whose lives and livelihoods have been adversely affected by TfL's Lethal Bus Franchise Model over the past decade? Your collective silence about Bus Safety Performance in London speaks volumes.
On Tuesday, 5 November 2024, London Bus Drivers organised a March and Rally to TfL Headquarters to demand that the Mayor and TfL immediately endorse a London Bus Workers' Bill of Rights:
 1.⁠ ⁠The Right to a safe work schedule without any forced overtime or loss of pay 2.⁠ ⁠The Right to a decent and proper rest break in the working day 3.⁠ ⁠The Right to drive a safe and well-maintained vehicle 4.⁠ ⁠The Right to clean, serviced toilet and rest facilities on all bus routes 5.⁠ ⁠The Right to report safety concerns without fear of retribution from TfL or employers 6.⁠ ⁠The Right, when seriously ill and covered by a doctor's note, to not be harassed into   coming into work until fit to do so 7.⁠ ⁠The Right to relevant and timely safety training 8.⁠ ⁠The Right to drive without being forced to answer radio messages and texts from       Controllers whilst in motion 9.⁠ ⁠⁠The Right to have all company rules in writing and clearly displayed10.⁠ ⁠⁠The Right to be treated with dignity and respect by our employers, TfL and the public11.⁠ ⁠The Right to Working Air Cooling in our cabs in the summer heat 12.⁠ ⁠The Right to Working Heaters in our cabs in the cold of winter

By incorporating the Bus Drivers' Bill of Rights in TfL's Framework Contract for Bus Services, the Mayor would have restored the time that lethal Bus Contract Incentives have taken away from London's Professional Bus Drivers to perform their jobs safely and with duty of care.  
On 11 March 2025, Seb Dance, London's Deputy Mayor for Transport, formally rejected the Bill of Rights, to which I responded on 28 April (cf. That TfL's Franchised Bus Operation is "Institutionally Unsafe" is a fact, Mr. Dance!).  In my response to the Deputy Mayor, kindly note the closing paragraph—
"We are calling on you and the Mayor to meet with a delegation of Bus Drivers and Campaign Representatives in a Public Forum—like the London Assembly or House of Commons Transport Committees—to agree (a) a timeline where TfL will to write the Bus Drivers' Bill of Rights into its Framework Bus Contract and (b) how TfL plans to enforce and monitor these Rights being respected and adhered to by its Franchised Bus Operators  This meeting will need to be televised and recorded for public scrutiny.  We are not asking for what already exists. We are demanding what has never been delivered by TfL, its Franchised Bus Contractors or Unite the Union: a Safe, Respectful, Transparent and Accountable Working Environment for those who keep London moving on the UK's largest and longest-running Franchised Public Bus Network."
If City Hall, the London Assembly and/or the Commons Transport Committee deign to host the Bus Safety Public Forum we've requested—as of today, we've not had any acknowledgement from any one of these public institutions—we'd obviously welcome representatives of London TravelWatch and the London Bus Alliance to be included in the discussion. You might be interested to know that a respected and highly-effective transport campaign group—the London Cycling Campaign (LCC)—spoke in favour of our Bill of Rights demands on 5 November 2024.  If your publicly-funded organisation could be motivated to follow and research our concerns—like the LCC has done for years—we believe you'd come to a similar humane conclusion. 
Let us be clear there will be no improving London's "Bus Passenger Experience" without first improving the Bus Driver Experience, and the Mayor of London has publicly stated he's not planning to do that. In rejecting our reasonable Bill of Rights demands, the Mayor's provided us with the explanation that TfL giving London's Bus Drivers a safe system in which to work would "mean diverting resource away from delivering further improvements to London's bus services to the potential detriment of both staff and customers."  Perhaps your organisations can explain how TfL guaranteeing—inter alia—that its Bus Drivers will have—
  • Access to Toilets at the end of every Bus Route;
  • Bus Cabs below 40c in the summer and above Freezing in the winter; and
  • Working Schedules and Rotas that don't Ensure Driver Fatigue
— would be to the detriment of London's Bus Customers? 
As you are now aware, London's twenty-thousand-plus bus drivers serve as the foundation of TfL's bus service, yet their welfare is ignored in all discussions about the future of London's Buses and, surprisingly, Vision Zero: in our view, London TravelWatch, the London Bus Alliance and the Mayor of London are equally—and perhaps wittingly—ignorant in this regard. 
Accordingly, we are calling on London TravelWatch and all stakeholders in the London Bus Alliance to:
  • Publicly Acknowledge the crucial role of London Bus Drivers in London TravelWatch's and London Bus Alliance's future publications and/or public discussions about improvements to London's Bus Services;
  • Assure the Public that they—like the LCC—recognise the direct link between Bus Driver Working Conditions and Bus Safety Performance;
  • Campaign Publicly for the Mayor to write the London Bus Drivers' Bill of Rights into TfL's Framework Bus Services Contract.
If your organisations truly want to improve Public Bus Transport in London, it is imperative for them to start engaging meaningfully with the people who drive Buses. 
Since this is a public letter, we look forward to your public reply. 
Yours sincerely,
Kevin MustafaOn behalf of the London Bus Drivers Bill of Rights Campaign
Bill of Rights Petition:https://www.change.org/p/mayor-of-london-write-the-bus-drivers-bill-of-rights-into-bus-contracts-now






28-Apr-25
28 April 2025By blogpost & emailMr. Seb Dance, Deputy Mayor for TransportCity HallKamal Chunchie WayLondon E16 1ZE

cc: Mayor of London; Transport Commissioner; Deputy Mayor for Social Justice and Communities, London Victims' Commissioner; Walking and Cycling Commissioner; TfL Board Secretariat; TfL SSHR Panel Secretariat; London Assembly Transport Committee Members; House of Commons Transport Committee Members; Sharon Graham - Unite the Union; Eddie Dempsey - RMT Union; Gary Smith - GMB Union; Barry Gardiner-MP; Tom Kearney (@comadad)

Dear Mr. Deputy Mayor,
Thank you for your delayed 11 March 2025 response (attached) to my 10 December 2024 Open Letter to the Mayor of London urging him to act immediately in support of the London Bus Drivers' Bill of Rights Campaign.
That TfL's franchised Surface Transport Operation is "institutionally unsafe", is not an "assertion": it is a fact evidenced by (a) Justice Fraser's 27 July 2023 Sentencing Remarks (b) thousands of pages of documents released through Mayor's Questions and Freedom of Information Requests and—most importantly—(c) the lived experiences of thousands of Bus Drivers who work today in conditions that compromise their safety, dignity, health and wellbeing.  It is also evidenced by TfL's own published Bus Safety Performance Data, which clearly shows that 2024 was the most lethal year from preventable Bus Safety Incidents since 2009. 
The existence of Legislation, Policies and various London-wide and Local Agreements which touch upon the issues raised by the Bus Drivers Bill of Rights, as you've outlined, is not in dispute. But please allow me be clear: it is TfL's longtime failure to (a) monitor the enforcement and/or (b) permit the outright ignorance—of the protections offered from these by the holders of London's Bus Franchise Contracts that serves as the catalyst for this long-overdue Campaign.  While TfL and its Chair do nothing but gaslight the publicBus Drivers report well-evidenced unsafe conditions brought about by, inter alia, Excessive Fatigue, Unsafe Scheduling, Poor or No Access to Welfare Facilities, Broken Speedometers, Defective Mirrors and a Toxic Culture in which Bus Drivers who raise safety concerns are victimised or disciplined by their employers. Our concerns do not arise from rare events: they are frequent systemic problems that cannot be brushed aside by the City Hall with references to existing frameworks over which TfL—as London's sole public bus franchise contractor—claims it has control but clearly chooses not to have any accountability.  
The Bill of Rights is not theoretical wishlist: it's reasonable and practical response developed solely by London Bus Drivers to a broken system—
London Bus Drivers' Bill of Rights
 1.⁠ ⁠The Right to a safe work schedule without any forced overtime or loss of pay 2.⁠ ⁠The Right to a decent and proper rest break in the working day 3.⁠ ⁠The Right to drive a safe and well-maintained vehicle 4.⁠ ⁠The Right to clean, serviced toilet and rest facilities on all bus routes 5.⁠ ⁠The Right to report safety concerns without fear of retribution from TfL or employers 6.⁠ ⁠The Right, when seriously ill and covered by a doctor's note, to not be harassed into coming into work until fit to do so 7.⁠ ⁠The Right to relevant and timely safety training 8.⁠ ⁠The Right to drive without being forced to answer radio messages and texts from Controllers whilst in motion 9.⁠ ⁠⁠The Right to have all company rules in writing and clearly displayed10.⁠ ⁠⁠The Right to be treated with dignity and respect by our employers, TfL and the public11.⁠ ⁠The Right to Working Air Cooling in our cabs in the summer heat 12.⁠ ⁠The Right to Working Heaters in our cabs in the cold of winter

If the protections we demand you claim are already in place for Bus Drivers were working in practice, there would be no need for this Campaign. But they are not—and the rising anger among London's Bus Drivers makes that clear.
You cite TfL's engagement with Unite. While that relationship is important, it cannot be used as a shield against the voices of drivers themselves, who are constantly proving to us that their concerns are not being heard or addressed by anyone, include those within Unite structures who are empowered to act. Our Campaign has emerged from the ground up because the existing mechanisms you cite as mitigants have obviously—and perhaps deliberately?—failed to deliver any meaningful positive change for decades.
On TfL Surface Trasport, Vision Zero will remain an empty slogan until the people responsible for delivering it—London's Bus Drivers—are (a) Provided with the Rights, Protections, and Working Conditions to which you already agree they are entitled and (b) Protected by having those Rights reflected in TfL's Framework Bus Services Contract.  TfL acting on our Demand is not a matter of Public Relations: it is a matter of Public Safety on which TfL is clearly failing.
We are calling on you and the Mayor to meet with a delegation of Bus Drivers and Campaign Representatives in a Public Forum—like the London Assembly or House of Commons Transport Committees—to agree (a) a timeline where TfL will to write the Bus Drivers' Bill of Rights into its Framework Bus Contract and (b) how TfL plans to enforce and monitor these Rights being respected and adhered to by its Franchised Bus Operators  This meeting will need to be televised and recorded for public scrutiny.  We are not asking for what already exists. We are demanding what has never been delivered by TfL, its Franchised Bus Contractors or Unite the Union: a Safe, Respectful, Transparent and Accountable Working Environment for those who keep London moving on the UK's largest and longest-running Franchised Public Bus Network.
I look forward to your response. 
Kindly note that I have copied the Mayor, some relevant City Hall and TfL Executives, the London Assembly and Commons Transport Committee Members and some UK Bus Workers' Union leaders to this email.
Yours sincerely,
Kevin MustafaCampaign Lead, Bus Drivers' Bill of Rights Campaign




16-Apr-25

It is an honour to be invited to address the 82nd RMT Bus Workers' National Industrial Organising Conference (NIOC). 
 
This is the fourth Conference I've attended since 2019 and it's a pleasure to be in Exeter as your guest this morning. For those of you who don't know me, I'm a self-employed London businessman who, in my free time, campaigns to improve Transport for London's "institutionally unsafe" Franchised Bus System, which, in my view, is precisely the Negligent Public Bus Contracting Model this Government will take nationwide if its Buses Bill passes unamended through the House of Commons.
 
At last year's pre-election NIOC at Cleethorpes, I asked a question:
 
Will Labour Unions make Labour's "Better Buses" Plans 'better' for Bus Workers and Public Safety?
 
Since the Government's Buses Bill has just completed its passage through the House of Lords after having the only amendments that dealt with improving safety and Bus Driver Working Conditions rejected by the Minister, I regret to inform you all that the answer to that question today is a resounding No. Please note that these 4 rejected Amendments were proposed by a single Cross-Party LordLord Hampton. Since no substantive Amendments intended to improve Bus Driver Working Conditions or Safety were proposed, co-sponsored by or even supported by Labour Party Lords, after all the excellent Resolutions I've seen passed by RMT Bus Worker NIOCs over the years, what just didn't happen in the Lords on the Government's Buses Bill provokes one to ask: just exactly who does the RMT think its friends are in Westminster? 
 
As it passes from the Lords to the Commons, the Government's Buses Bill is, as of today, silent about the many concerns about Bus Safety and Poor Working Conditions these conferences have raised year after year.  However, if the RMT and other Bus Workers' Labour Unions mobilise quickly, the Government's Buses Bill doesn't have to be silent about improving Bus Safety and Bus Driver Working Conditions. 
 
I think we can all agree that the Government's Bus Services [No. 2] Bill is an important piece of legislation. We all hope it will herald a significant increase in the provision of public bus services across the country. But it is also an important bill in terms of the nature of those bus services and, whether they will—as a first priority—be safe and permit Bus Drivers to perform their jobs exercising Duty of Care for their passengers and other road users. 
 
With this goal in mind, prior to the Buses Bill entering the Lords, Lord Hampton consulted with several London Bus Drivers, former TfL Board Director and Safety Panel Chair, Michael Liebreich and myself, to propose 4 Amendments that would begin to address the Bill's silence on Bus Safety and the Poor Bus Driver Working Conditions.
 
The 4 Amendments were as follows—
 
Amendment 1. Confidential Safety Reporting — that any Bus Operator running a Public Bus Service enabled by the Bill be subscribed to a Confidential Safety Reporting Scheme like CIRAS or its equivalents. Thanks to a campaign I initiated in 2014, TfL agreed to fund CIRAS to extend its contracted Bus Drivers access to CIRAS in early 2016.
 Amendment 2. Bus Safety Incident Reporting — that any Public Transport Authority (PTA) taking control of its Public Bus Services through franchising or direct ownership will be obligated to publish its Bus Safety Performance Data every quarter. Thanks to my successful campaigning backed by Conservative, Liberal Democrat and Green Party London Assembly Members, TfL has been reluctantly publishing its Bus Safety Performance Data since 2014
 Amendment 3. Bus Driver Hours — that the Working Hours of Bus Drivers should conform to those of UK Lorry Drivers.  Amendment 4. Safety Qualifications of Public Transport Authority Officials — that any Public Transport Authority Official made responsible for Franchising Public Bus Services under the Act will possess basic IOSH and/or NEBOSH certifications.  
During the debates that took place in the Lords from mid-December until earlier this month, the Government's Junior Transport Minister—Lord Peter Hendy—claimed to welcome interventions on matters of safety from the Lords, yet, he, on behalf of the Government, still rejected all of Lord Hampton's Safety Amendments. 
 
Why?
 
After all, Transport for London—the largest and longest-running PTA Bus Franchise Operation in the United Kingdom-has—please allow me to repeat myself—funded its contracted Bus Drivers' access to Confidential Safety Reporting—specifically CIRAS—since 2016, and TfL has published granular Bus Safety Incident Data every Quarter since 2014.  
 
During the debates in the Lords, Lord Hendy even mentioned that, following London's good example, both Transport for Greater Manchester (TfGM) and Transport for Wales (TfW) have subscribed to the Confidential Safety Incident Reporting Service, CIRAS. The Minister did not make it clear if those PTAs' prudent actions applied to Bus Drivers, and I'd recommend RMT verify the Minister's public statement.  Do TfGM's and TfW's subscriptions to CIRAS, like TfL's, apply to these PTAs' contracted Bus Drivers? This is not a minor point:  for years, TfL offered its Tube and Train Drivers access to CIRAS, but, alarmingly, TfL did not extend its CIRAS subscription to cover its contractors' Bus and Tram Drivers
 
The Minister also mentioned that, following London's good example—and, I hasten to add, only following direct pressure from RMT Bus Branch Secretary Lee Odams—TfGM apparently now publishes its Bus Safety Performance Data. Again, I think it'd be worth the RMT's time to investigate the veracity of Lord Hendy's public statement, because I can't find any Bus Safety Performance Data on both the TfGM and BEE Network websites. 
 
So why did the Junior Transport Minister, on behalf of the Government, reject the inclusion of (a) Confidential Safety Reporting for Bus Drivers and (b) Compelling Local Authorities to publish Bus Safety Performance data into its Buses Bill?
 
On driver hours, a lorry driver in the UK is restricted to 90 hours of driving in a two-week period, but bus drivers in the UK are permitted (and often do) 130 hours. How can this number of hours behind the wheel be safe?
 
As for mandatory safety qualifications for those handing out and managing franchises, these are not expensive or time-consuming courses—in fact many of our trade unions offer them to members for free. So why not ensure that those Local and Regional Council Authorities contracting, managing and enforcing the Bus Franchises this Bill will make possible will be trained in the safety implications of their work?
 
Why are Lord Hendy and the Government so reluctant to support having long-established best safety practices long in place in the Rail, Air and Maritime Sectors appear in the Buses Bill? 
 
Well, the new bus services that will be rolled out across the country are to be based on the London Bus Franchise Model. But the fact is—and as I've underscored every time I've addressed these events—the London Bus Franchise Model has a chronic and well-evidenced safety problem.
 
Last year, at least 16 people were killed 'by or on' London public buses in preventable safety incidents (mostly crashes, the balance from onboard falls), the highest figure since 2009
Chart: Courtesy of Michael Liebreich

TfL's death-by-bus figure is certainly higher: the STATS19 data produced by the Met Police and published by the DfT does not include deaths inside buses or on private land, such as bus garages or depots. Transport for London keeps its own figures for the number of people actually killed 'on or by a bus'—which are higher—but for its own—untransparent—reasons, TfL fails to reconcile its actual bus fatality data with STATS19's undercount.  
Nonetheless, from the data TfL's been compelled to publish, we know:
  • Since 2014, about 1 in 10 deaths on the roads of London have involved TfL buses, a fleet that constitutes—corrected for mileage buses cover—about 1 percent of the vehicles on London's roads at any time. 
  • International benchmarking undertaken by Imperial College consistently finds London in the lowest third of comparators for bus safety every year, suggesting that London has been— for years—the worst Bus Safety Performer in Europe. 
  • In 2023 and based on STATS19 (undercount) data, TfL says that there were 258 people killed and seriously injured by buses in London—that is 258 families put through unimaginable trauma. Trust me, I know personally what that entails.  In 2017, TfL says that there were 259 people killed and seriously injured by buses in London.  After 6 years of a Vision Zero Programme much-touted by Lord Hendy's boss, the Senior Minister of Transport Heidi Alexander when she served as London Mayor Sadiq Khan's Deputy Mayor for Transport from 2018-2021, TfL's own published data shows, despite a reduction in total Bus Mileage, Buses and Bus Drivers, casualties from Preventable Bus Safety Incidents are now higher today than when Mayor Khan took office in 2016. 


NB: TfL put the dotted line there to distract you...2024 TfL Bus Deaths are 77% higher than 2022!
Thanks to the data transparency that my public campaigning has forced on the UK's largest and  longest running PTA Bus Franchiser, for every Injury reported on TfL's Franchised Bus Network since 2014, we know the Date, Location (by Borough), Bus Route, Bus Operator, Bus Garage of Operator involved in the incident, the Severity of the Injury and also the Sex, Age Group and Transport Mode of the Victim.  
While TfL's published Bus Casualty data does not represent a perfect or even necessarily complete set of preventable casualties "by or on a TfL bus" for over the past decade, it is still substantially more robust than anything the DfT collects or publishes about Casualties from Preventable Bus Safety Incidents. Nonetheless, the flawed undercount the DfT chooses to publish should still ring alarm bells for us. 
 
Based on the DfT's published data, Buses and Coaches kill pedestrians at a substantially higher rate than either these vehicles' numbers or presence (i.e., mileage run) on UK roads would predict.  For the period 2019-2023—the last period for which DfT has published data
  • Buses and Coaches have killed, on average, about 20 pedestrians per year;
  • Buses & Coaches have accounted for 3.4% of Total Pedestrian Fatalities in the United Kingdom but only account for 0.34% of the total number of vehicles in the UK and only 0.57% of the total vehicle miles in the UK;
  • Accordingly, based on analysis of DfT's published data—Bus & Coach Lethality is 10 times higher than what these vehicles numbers on the road would predict and more than 5 times higher when these vehicles presence is corrected for their mileage;
Remember: STATS19 Data is an undercount, so those lethality rates don't include incidents of pedestrians killed at Bus Stations or on non-public roads or Passengers killed in preventable onboard bus safety incidents.  And, in direct contrast to TfL's Data, the DfT's STATS19 data does not let us know which Bus Operator was involved, which Depot the Bus Operated from or most details about the victim. The DfT Data also combines Bus and Coach incidents, which I think creates more confusion than clarification. 
Lord Hampton's Amendment would have made publishing of 'TfL-style' granular Bus Safety Performance Data about every UK public bus a legal obligation for any PTA adopting the London Bus Franchise Model, but Lord Hendy, on behalf of the Government, opposed it.
 
Why?
 
Well, I suspect it's because the London Bus Franchise Model was, essentially, created and perfected under Lord Peter Hendy's leadership when he served as TfL's Managing Director for Surface Transport (2001-2006) and then as London's Commissioner of Transport (2006-2015). A bus contracting system that I think can safely be called the Minster's 'Legacy' is a Bus Franchise Model that financially rewards bus companies for vehicle-miles driven ("mileage"), timeliness and speed, but not for safety, while failing to ensure decent working conditions for drivers. 

It's a bus contracting system that produces these poor safety outcomes through faulty design, a system described by former TfL Board Director and Safety Panel Chair Michael Liebreich as "institutionally unsafe".  London Bus Drivers' categoric rejection of this unsafe model is evidenced today in their increasingly-public demands for the Mayor to amend TfL's Framework Bus Contract to include a Bus Drivers Bill of Rights that, I think we'd all agree, are just human rights.
London Bus Workers' Bill of Rights

1.⁠ ⁠The Right to a safe work schedule without any forced overtime or loss of pay2.⁠ ⁠The Right to a decent and proper rest break in the working day3.⁠ ⁠The Right to drive a safe and well-maintained vehicle4.⁠ ⁠The Right to clean, serviced toilet and rest facilities on all bus routes5.⁠ ⁠The Right to report safety concerns without fear of retribution from TfL or employers6.⁠ ⁠The Right, when seriously ill and covered by a doctor's note, to not be harassed into coming into work until fit to do so7.⁠ ⁠The Right to relevant and timely safety training8.⁠ ⁠The Right to drive without being forced to answer radio messages and texts from Controllers whilst in motion9.⁠ ⁠⁠The Right to have all company rules in writing and clearly displayed10.⁠ ⁠⁠The Right to be treated with dignity and respect by our employers, TfL and the public11.⁠ ⁠The Right to Working Air Cooling in our cabs in the summer heat 12.⁠ ⁠The Right to Working Heaters in our cabs in the cold of winter

I note that two Resolutions that will be voted at this Conference directly address the Bus Drivers Bill of Rights and, if these are passed, I know London's Bus Drivers would very much appreciate RMT's public support for their demands for the Mayor to amend TfL's Framework Bus Contract to include these Rights. 
 
During the Buses Bill debates in the Lords, Lord Hendy repeatedly claimed that the DVSA and the Traffic Commissioners provide adequate safety regulation of bus operators and services.  
 
Let us examine the Minister's claim: the DVSA's remit does not cover bus operations or operators: it licenses vehicles and drivers. The Traffic Commissioners do licence bus operators, but their total annual budget, nationwide, amounts to less than £1.8 million. Simply put, Transport Commissioners have no resources to undertake bus crash investigations, and no resources to engage with the bus industry on safety improvements. In their latest annual report, the Traffic Commissioners admit to failing on seven out of the twelve measures in their Service Level Agreement, and they describe the difficulty in recruiting and retaining staff.  To me, it appears that the Transport Commissioners represent a demoralised and failing service, and I would encourage the RMT to ask MPs to scrutinise the Government's position with direct reference to Lord Hendy's recent statements to the Lords.
 
If the Government had really wanted to turn this catastrophic situation around—other than increasing the budget of the Traffic Commissioners by an order of magnitude—a good starting point would have been for the Government to have supported including Lord Hampton's Four Amendments, i.e,—

(i) Confidential Safety Reporting; (ii) Timely and Accurate Safety Data Publishing by PTAs; (iii) Limiting bus driver hours; and, (iv) Ensuring Public Officials those designing, awarding and enforcing bus franchise contracts had safety qualifications 

—in its Buses Bill. 
 
However, after listening carefully to the debate, and considering Lord Hendy's summary rejections of Lord Hampton's 4 Safety Amendments, I think you'll agree with me that that this Government must use its Buses Bill to go much further on Bus Safety. 
 
There is currently no independent national agency that's responsible for investigating Public Bus Crashes, and for a Public Transport Mode, that makes the UK Bus Sector's lack of independent safety oversight 'worst in class'.  Rail has the Rail Accident Investigation Branch. Air has the Air Accidents Investigation Branch. Shipping has the Marine Accident Investigation Branch. Bus crashes are investigated by the bus operators themselves, unless someone is killed, in which case the Police and Coroners step in, but their interest is only in establishing liability. There is no systematic learning from bus crashes, aimed at improving bus safety year by year. 
 
Let me give you a recent example of how systemic learning from bus crashes is being missed.  Recently, the mainstream media was filled with reports about the trial and conviction of a 76-year-old London Bus Driver for killing an 83 year-old pedestrian in near Woolwich Arsenal Tube in September 2021.  Thanks to the Bus Casualty Data TfL has published since 2014, we know that the incident occurred on 11 September 2021 and involved a Route 291 Bus operated by Go Ahead London under franchise to TfL. 

The press coverage of the trial reported that the jury was told —
 
'Traffic collision experts concluded that the Bus Driver began turning while his view was obscured by another bus' 
 
and "a pillar inside the bus also created a blind spot but the driver could have moved his head and upper body to look around it".
 
You got that right? 
  • a "turning bus"
  • "obscured vision"
  • a "pillar inside the bus" that "create a blind spot" that required the driver "to move his head and upper body to look around it" to see a pedestrian crossing the road in a designated pedestrian crossing.
Throw in the added systemic safety factors that we know plague London Bus Drivers, e.g.—
  • the well-evidenced possibility that this 76 year-old driver might have been suffering from fatigue
—and I think you'll agree with me that the fact there was no independent safety investigation to identify the systemic causes of this incident that require mitigation simply guarantees it will happen again. In fact, based on the information London Assembly Member Keith Prince—a Tory, by the way, who, in my objective view, has been the biggest supporter of Bus Drivers on the Assembly since he was elected to the Public Scrutiny Body in May 2016—discovered about the prevalence of the defect on the make and model of the Bus involved, I suspect that crashes caused by this Blind Spot had already happened thousands of times before 11 September 2021.
 
After the press reports about the Bus Driver's trial, Keith Prince asked the Mayor to identify (a) the make and model of the Bus "with the blind spot" involved and (b) how many of this model were now serving in London's Franchised Bus Fleet. The Mayor was transparent enough to identify the exact make and mode of the bus—an ADL Enviro400—but he refused to provide the actual number serving in TfL's fleet, instead 'sign-posting' Keith to a useful page on the TfL Website that contained comprehensive data about TfL's Bus Fleet.  
After accessing the data on that page, I understand why the Mayor was reluctant to provide this information directly to the Assembly Member:
Out of the total fleet of TfL Buses (8776), 2819 (32%) are ADL Enviro400s, so we know that 1-in-3 TfL Buses have the same Blind Spot that allowed Go Ahead London Bus Driver to kill a pedestrian on 11 September 2021. Looking more closely at London's Bus Fleet Data, 4901 (56%) of TfL Bus Fleet are ADL Enviro Models (i.e., 200 or 400), so I'd presume the "blind spot" is a feature of the older ADL models (200s) too. On this basis, I think it's logical to deduce that more than half of London's Bus Fleet have the same Blind Spot that appears to have been a causal factor in a London Bus Crash that killed a pedestrian in September 2021.    
Sentencing the Bus Driver at the Old Bailey last month, the BBC reports the Judge said the incident was a "momentary error" and 76 year-old Bus Driver did not intend to hurt, let alone kill, the 83 year-old pedestrian.  The Bus Driver was then convicted of causing death by careless driving and sentenced to 15 months' custody, suspended for two years, 12 days of rehabilitation activity and was disqualified from driving for three years.  A London Bus Driver will spend his remaining few years on earth being punished after being blamed for killing someone as the result of a known systemic safety problem.  
 
In principle, an Independent Crash Investigator would have identified the known Blind Spot—found in over half of the Buses in London's Franchised Bus Fleet today—decades ago after the first similar crash involving that Bus Model. That Independent Investigator's report would have identified the Blind Spot as a systemic issue that required immediate mitigation and that, no doubt, would have inspired further investigations as to how a known safety hazard was deliberately designed into a British public bus. Instead, because there was no blame-free Independent Investigation—as would been conducted the Rail, Air or Maritime sectors—this known danger is now present in over half of London's Franchised Bus Fleet and will continue to be ignored as it has been for decades. Without an Independent Bus Crash Investigator, a Bus Driver was blamed for—just like in the Croydon Tram Crash—an "accident waiting to happen".  In my honest opinion, the RMT would be well advised to explore Lord Hendy's and London Bus Executives' connection to that "institutionally unsafe" Surface Transport Operation too.  An acorn does not fall from the tree. 
 
Since TfL's casualty data published since 2014 shows an average of at least 1 person a day is sent to the hospital from a Bus Collision, lethal crashes like that 11 September 2021 fatal collision are inevitable.  Before we allow the Commons to pass a bill that proliferates new London-style bus services around the country, we should be mandating the appointment of independent inspectors to investigate any death involving a bus, with a view to learning from each and every one and eliminating their causes.
There is already a good recent Parliamentary precedent for such prudent action. Under the Automated Vehicles Bill 2024, the Secretary of State was mandated to appoint inspectors to investigate autonomous vehicle incidents. These vehicles, and hence incidents involving them, don't even exist yet. But bus crashes do exist and, as we have seen, they already take a terrible toll in terms of killed and seriously injured.   
Lastly, unions should be pushing to make it illegal for any PTA to enter into a Bus Franchise Contract with a bus operator that includes explicit financial rewards for timeliness and speed or penalties for late operation or excess wait time. These are the contracts TfL has had in place with its Bus Franchises since 2001 and they are obviously lethal.  TfL's Bus Franchise Contracts—which pressurise Bus Drivers to drive at speeds beyond those that traffic conditions comfortably allow—only sometimes adjusted for the need for smooth driving, stops and time to provide mandated levels of service for wheelchair users and others of restricted mobility—are "institutionally unsafe". In other words, it doesn't matter how well-meaning or well-trained its participants may be, these Bus Franchise Contracts are inevitably going to result in deaths and serious injuries.
 
I am pleased to see all 4 of Lord Hampton's Amendments have appeared as Resolutions to be voted on at this year's NIOC. 
 
I note that a recent RMT Press release reported that 80% of Bus Workers surveyed wanted access to a confidential Incident Reporting System. 
 
I am also pleased to see a Resolution here today calling for RMT's Executive "to actively campaign for the creation of an Independent Bus Crash Investigation Unit based on the models that have served the Rail, Air and Maritime Sectors for decades."
 
I'd also like to highlight that same RMT recent press release reported that 90% of Bus Workers surveyed support the creation of an independent bus accident investigation branch, similar to that which exists in rail.
 
If these 5 Resolutions are passed today—and I hope they will be—the RMT faces a massive challenge to get these 5 Amendments into the bill because, based on Lord Hendy's actions in the Lords, a Labour Party Government with a 157-seat majority actively opposes seeing substantive Bus Safety and Safe Bus Driver Working Conditions Protections in its Buses Bill.  
 
In this regard, an action in by Lord Hampton in the Lords might just provide us with some limited hope that opposing the Government's 'negligent' position on Bus Safety can win.  At the Bill's final stage in the Lords—and I assume motivated by the Government's continued rejection of his 4 Amendments—Lord Hampton proposed a fifth Bus Safety Amendment— 
 
"Implementing a Vision Zero programme" "The Secretary of State must work with bus service providers, trade unions, professional bodies, and appropriate training institutions to implement a Vision Zero programme within the bus sector, modelled on best practice in the industry, with the aim of eliminating serious injuries in the course of bus operations."
 
Although Lord Hendy swiftly indicated the Government's opposition to this Amendment, Lord Hampton insisted upon a vote, and it won by a safe margin of 240 to 148.  Note: not a single Labour Peer voted in favour of Lord Hampton's "Implementing a Vision Zero programme" Amendment. 
 
So, for now—and no thanks to the Labour Party—"Safety" does appear on the face of the Buses Bill in a Vision Zero Amendment that, unlike Lord Hampton's 4 rejected Safety Amendments, doesn't really commit a reluctant Government to do anything substantive.   I will be very curious to see how a Labour Government that is clearly opposed to defending Public Safety and Bus Driver Working Conditions in its Buses Bill will attempt to kill this "Implementing a Vision Zero programme" Amendment in the Commons. 
 
Given Lord Hendy's role (a) in overseeing the creation of the 'institutionally unsafe' Bus Franchise System that we have endured in London since 2001 and (b) in pushing his Government's intention to get this Bill on the statute books as quickly as possible, I have no doubt that the RMT Executive will face highly-choreographed resistance from Senior Transport Minister Heidi Alexander and Junior Transport Minister Peter Hendy to dissuade even Labour Party MPs who should know better from supporting these 5 Amendments that put Safety on the face of the Government's Buses Bill.  
 
It is imperative that RMT join with other Bus Workers' Unions to make as much noise as they can about London's Poor Bus Safety Performance record and well-evidenced Poor Bus Driver Working Conditions and let the UK public know that the well-evidenced Safety Scandal that is TfL longest-running Franchised Bus System represents a stark warning of what will happen across the country if Labour MPs fail to compel their Government to put protecting Public Safety and Bus Driver Working Conditions on the face of their Government's Buses Bill. 
 
The RMT's 25 March press release—"Underpaid, Overworked, Ignored—RMT members demand urgent reform for bus industry"—is an excellent start. But letters, briefing notes and requests for meetings with Labour MPs who expect your union funds to help win their seats need to be sent from the RMT now.  The RMT's best chance to "urgently reform the bus industry" lies in its ability to convince a majority of Labour MPs to go against their Ministers and Party and get 5 Amendments—
  • Confidential Safety Reporting
  • Bus Safety Incident Reporting
  • Limiting Bus Driver Working Hours
  • Safety Qualifications of PTA Officials
  • Creation of Independent Bus Crash Investigation Branch
—into the Government's Buses Bill. 
 
As London's well-documented and painful experience proves, lives and livelihoods will depend on the RMT's success in preventing this Labour Government from Nationalising London's Negligent Bus Franchise Model. 
 
Thank you for your time. 


Tom Kearney
#LondonBusWatch
E: comadad1812@gmail.com
Twitter: @comadad
Bluesky: @comadad.bsky.social
 

23-Mar-25

From: Kevin Mustafa 

Subject: Urgent Concerns Regarding Bus Safety and Driver Fatigue

Date: 23 March 2025 at 10:31:17 GMT

To: Lorna Murphy - TfL Director of Buses <lornamurphy@tfl.gov.uk>, Andy Lord - TfL Commissioner <AndyLord@tfl.gov.uk>

Cc: Tom Kearney, Neil Garratt <Neil.Garratt@london.gov.uk>, Keith Prince <Keith.Prince@london.gov.uk>, Caroline Russell <caroline.russell@london.gov.uk>, peter skinner <skinnerzboy@yahoo.co.uk>, Lorraine Bus Driver <lorraine.robertsoniz@hotmail.com>, "bishopmi@me.com" <bishopmi@me.com>, James Rossi <jamesrossi268@outlook.com>, Michael Liebreich <michael@liebreichassociates.com>, "billofrights@hotmail.com" <billofrights@hotmail.com>


Dear Lorna , Andy

I am writing to formally raise serious concerns regarding ongoing safety issues within the London bus network, particularly related to unsafe buses and increasing levels of driver fatigue. These issues pose a direct threat to both passengers and drivers, and Transport for London (TfL) must take immediate action to address them.
Bus Safety Concerns
London bus drivers are consistently being asked to operate vehicles that are not fit for service. Reports of faulty brakes, malfunctioning speedometers, defective doors, and steering issues are regularly ignored or dismissed by operators. Drivers who refuse to take out unsafe buses under Section 44 of the Employment Rights Act 1996 are facing disciplinary action, creating a culture where safety is sacrificed for operational convenience.
TfL must enforce stricter compliance measures and hold operators accountable for putting unsafe buses on the road. A public transport system that prioritizes profit over safety is not acceptable.
Driver Fatigue and Its Dangers
Fatigue is another critical issue that is being ignored at an operational level. Long shifts, inadequate recovery time, and high-pressure scheduling mean that drivers are regularly behind the wheel while physically and mentally exhausted. Scientific research and real-world incidents confirm that fatigue is as dangerous as driving under the influence—yet TfL continues to allow scheduling practices that put drivers and passengers at risk.
We demand the following immediate actions:
1. A full, independent review of bus safety procedures, ensuring that vehicles with mechanical faults are not allowed on the road.

2. Stronger protections for drivers refusing unsafe buses, ensuring that they are not penalized for prioritizing safety.

3. A comprehensive fatigue management plan, including limits on excessive working hours and mandatory recovery time between shifts.

4. An urgent review of shift patterns and scheduling practices, to ensure they align with TfL's duty of care towards its workforce.


TfL must recognize that bus safety and driver welfare are not negotiable. A failure to act will only lead to more incidents, more risk to passengers, and further damage to the reputation of London's public transport system.
I request a formal response outlining TfL's position on these issues and the steps being taken to address them. I look forward to your urgent attention to this matter.
Best regards,Kevin Mustafa
London Bus Lead Safety CampaignerMob 07950257398Bill of Rights Petition:https://www.change.org/p/mayor-of-london-write-the-bus-drivers-bill-of-rights-into-bus-contracts-now
21-Feb-25


Michael Liebreich stopping traffic at London Bus Drivers' 
Bill of Rights March to Parliament Square (29 January 2025)

Are you a Londoner? Do you ever come to London on business or for leisure, or as a tourist? Then this post is for you.

You might find the sight of a red London bus reassuring. You should find it terrifying. In an annual benchmarking study carried out by Imperial College, London scores consistently in the lowest tercile for safety, probably the least safe bus system of any major European city.

I was on the board of TfL and chaired the Safety Panel, and I know why: the system under which TfL contracts out bus services to private companies is "institutionally unsafe". Payment is tied entirely to the number of passenger route miles and to keeping up with the bus in front.

As congestion has increased and inflation has eaten bus company margins, pressure on bus drivers to speed has increased. Drivers work in conditions none of us would accept: lack of toilets, overheated cabs in summer; frozen cabs in winter; pressure to drive extra shifts up to 13-days in a row; insufficient time between shifts; and so on.

The Mayor and TfL have tried to deflect attention from all this, and from its impact on safety, but the data does not lie. As you can see from the attached chart, in 2024 there were 16 preventable deaths involving TfL buses - the highest number since 2009, Boris Johnson's first year as Mayor, despite bus journeys in London declining 17% over that period.

In 2017, as part of Vision Zero, Sadiq Khan announced that no one would be killed on or by a London bus by 2030. He has only been on track during the pandemic years, when London's buses ran reduced services. On current trend he will fail by a country mile.

Why does this matter today, and what can you do?

First, London bus drivers are campaigning for TfL and the bus companies to adopt, promote and enshrine in contracts a 12-point Bus Drivers Bill of Rights. There should be nothing controversial about it - all are basic rights that any decent person would want drivers to have. I feel so strongly about this, I have marched with the drivers, alongside Unite the Union. Everyone should sign their petition here.

Secondly, as it stands, the "Better Buses Bill" that the government is pushing through Parliament right now, would extend the "institutionally unsafe" London bus franchise model across the country. If you worry about London's appalling bus driver working conditions and pressure to speed leading to the same safety outcomes nationwide, please write to your MP, demanding that safety be put at the heart of the Bus Services [No. 2] Bill. 

  • Demand regular, timely, independently audited safety data across all bus services in the UK. 
  • Demand a guarantee of decent working conditions for drivers: toilets, access to a confidential whistleblower service, and the rest of the Bus Driver Bill of Rights.
  • Demand an independent investigator for bus crashes in the UK, as we have RAIB for rail crashes and the AAIB for aircraft crashes.

You can find your MP here.

Michael Liebreich

Originally Posted by the author on LinkedIn (19 Feb 2025).  Published here with the author's permission. 

Michael Liebreich served on the Board of Transport for London (2012-18) and as the Chair of the Board's Safety, Sustainability and Human Resources Panel (2016-18).  

20-Jan-25

1. London accounts for about one half of UK Bus Journeys and one quarter of the UK's Bus Fleet.


Source:  DfT 


2. TfL Buses are ten times more lethal than their presence on London's roads would predict; since 2014, 1 in 10 RTC Fatals and 1 in 10 Pedestrian Deaths in London have involved a TfL bus.


Sources:  Mayor of London; TfL; London Assembly 

 

3. TfL's sole metric of bus contract performance is a time-based "Excess Waiting Time"/Headway calculation that independent benchmarking shows London—

  • in the highest tercile of its 'world city' peers for Bus Punctuality and Profitability per Bus;
  • in lowest tercile of its 'world city' peers for safety (collisions per km); 
  • London has the least safe public bus system of any major European city.

Sources:  Mayor of London; TfL; London Assembly; Imperial College


4. TfL has never conducted any analysis or safety risk assessment of its (a) Bus Franchise Model, (b) Bus Contract Financial Incentives or the (c) iBus System it uses to measure contract performance

 

Sources: Mayor of London, TfL; London Assembly 


5. Bus Driver Fatigue is a well-evidenced systemic problem, with the latest independent study showing 1 in 3 bus drivers reporting a near-miss due to fatigue and 1 in 6 Bus Drivers having fallen asleep at the wheel while driving a bus;

 

Sources: Mayor of London; TfL; London Assembly; Loughborough University 


6. Bus Collisions (2016-2023) - London averages of over 26,000 collisions annually (2023: over 28,000 - so, getting worse) from which — 

  • about 1200 people are hospitalised per year
  • 1 person is killed about every month (2024). 
  • 80 to 100 people are sent to hospital per month from Preventable Bus Safety Incidents (80% Collisions, 20% Onboard Trips & Falls), 20 of these victims with serious and/or life-changing injuries;
  • People killed and seriously injured from Bus Safety Incidents (80% Collisions, 20% Onboard Trips & Falls) are now higher than 2016 despite a) the total number of bus miles has fallen b) the total number of bus users has fallen (c) the total number of buses in London's contracted bus fleet has fallen (d) the total number of Bus Drivers has fallen (e) since 2016, the Mayor of London has announced 3 'world leading' Bus Safety Programmes and a Vision Zero Programme.

Sources: Mayor of London; TfL; London Assembly

 

7. 25% of London Bus Routes don't have a toilet at 1 end for Bus Drivers.

 

Sources: Mayor of London; TfL; London Assembly

 

8. TfL has agreed with Bus Operators and Unite the Union that Bus Drivers don't need a toilet on any route round trip that lasts up to 150 minutes - this was agreed without a single bit of data (i.e, Human Factors Study, HSE Risk Assessment).

 

Sources: Mayor of London; TfL; London Assembly


9. TfL has evidence of (at least) 12 million (est.) Annual Bus Speeding incidents on file that it does not share with the Police; From January 2017 to January 2024, nearly half (44%) the Bus Collision Deaths occurred in 20mph (or less) zones.

 

Sources: Mayor of London; TfL; London Assembly


10. Since January 2016, more than 1 pedestrian per month has been injured by a TfL Bus hitting them in a zebra or pelican crossing.

 

Sources: Mayor of London; TfL; London Assembly

 

11. Since 1 April 2015, an average of 6 people per month (2022-23: 8 per month- getting worse) have been injured after being struck by a Bus Wing Mirror. 

 

Sources: Mayor of London; TfL; London Assembly

 

12. TfL received the highest Health & Safety Fine ever in July 2023 for HSE Failures on the Croydon Tram, a contracted surface transport operation that was founded, managed and monitored by TfL's Bus Executives.

 

Sources: Department of Justice; Mayor of London; TfL; London Assembly; Press Reports


13. While Sadiq Khan has been Mayor, 16 Pedestrians have been killed or seriously injured while in Traffic "Refuges";

 

Sources: Mayor of London; TfL; London Assembly

 

14. TfL does not report Law-Breaking by Bus Drivers to the Metropolitan Police for, inter alia

  • Running Red Lights
  • Speeding

Sources: Mayor of London; TfL; London Assembly

 

15. TfL Bus Drivers had the highest rate of death (per 100 thousand) from Covid-19 for any UK Profession (that includes Doctors, Nurses and Healthcare workers)—

  • Over Two-Thirds of the TfL Bus Drivers who died from Covid-19 did so after the first Lockdown;
  • TfL data shows Bus Drivers were still dying from Covid-19 through 2022, after which it stopped collecting this information; 
  • TfL has never requested any of its Bus Operators to provide a Covid-19 Garage Risk Assessment.

Sources: Mayor of London; TfL; London Assembly; University College London

 

Notes to Sources:


1. Analysis of published DfT Data— 

 

In March 2023, 30,154 buses were operated by local bus services in England, with 8,788 of them in London

 

https://www.gov.uk/government/statistics/annual-bus-statistics-year-ending-march-2023/annual-bus-statistics-year-ending-march-2023

 

2.  Analysis Data Extracted from TfL's "Casualties in London" Reports; DfT Annual Bus Statistics; TfL "Travel in London" Reports; London Assembly Investigations; Mayor's Questions

 

"Buses contracted to Transport for London (TfL) constitute approximately 2% of total motorized road traffic in Greater London. This includes all buses, not just TfL-contracted ones, but TfL buses dominate the category."

 

https://content.tfl.gov.uk/technical-note-07-what-are-the-trends-and-patterns-of-bus-and-coach-traffic.pdf?t&utm_source=perplexity

 

"The percentage of TfL buses in total traffic has seen fluctuations over the years. In 2019/20, buses constituted about 1.2% of motorized road traffic in Greater London. This percentage dropped significantly during the pandemic in 2020/21 to 0.4%, reflecting reduced public transport usage. By 2022/23, the percentage had rebounded to around 1.5%. This indicates a recovery trend but still not reaching pre-pandemic levels."

 

https://content.tfl.gov.uk/travel-in-london-2023-trends-in-public-transport-demand-and-operational-performance-acc.pdf?t&utm_source=perplexity


London Assembly: https://www.london.gov.uk/about-us/londonassembly/meetings/documents/s110115/Appendix%201%20-%20Letter%20from%20Tom%20Kearney%20received%2015%20December%202023.pdf


3. Mayor's Questions, TfL's published Bus Performance Data, Internal Bus Operator Communications

 

https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/refusal-benchmark-londons-safety-performance-world-city-peers

 

5 Year Data (2015-2019)

 

https://www.london.gov.uk/questions/sites/default/files/3828%20Refusal%20to%20Benchmark%20Londons%20safety%20performance%20attachment.pdf

 

4. https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/vision-zero-tfls-bus-tendering-system-and-ksis-bus-safety-incidents

 

5.  http://content.tfl.gov.uk/bus-driver-fatigue-report.pdf 

 

6.  https://tfl.gov.uk/corporate/publications-and-reports/bus-safety-data

 

7.  https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/lack-toilet-dignity-london-bus-drivers-name-borough-where-toilet-not-provided-end-bus-route

 

8. https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/negligence-and-toilet-priority-classification-agreed-between-tfl-unite-union-and-its-bus-contractors

 

9. https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/speed-compliance-tool-information-contained-recent-go-ahead-london-training-video


https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/bus-collision-deaths-20mph-or-lower-zones-2016-q1-2024;


https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/vision-zero-speed-compliance-tool-data-and-ksi-incidents

 

10. https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/nimi-reports-and-tfl-bus-drivers-critically-injuring-pedestrians-zebra-crossings-1-january-2016-11

 

11. https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/vision-zero-pedestrians-struck-bus-mirrors-1-january-2018-30-september-2023

 

12. https://www.judiciary.uk/wp-content/uploads/2023/07/R-v-TfL-270723.pdf

 

13. https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/vision-zero-bus-collision-ksis-crossing-islands

 

14. https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/signal-passed-danger-spad-3


https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/vision-zero-speed-compliance-tool-data-and-ksi-incidents

 

15. https://content.tfl.gov.uk/initial-assessment-of-london-bus-driver-mortality-from-covid-19.pdf;


https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/number-bus-workers-who-died-covid-19-march-2020-november-2023;


https://www.london.gov.uk/who-we-are/what-london-assembly-does/questions-mayor/find-an-answer/update-employers-bus-workers-who-died-covid-19-march-2020-june-2023

 

10-Dec-24

By email and blog post


10 December 2024

Sadiq Khan, Mayor of London and TfL Chair
City Hall
Kamal Chunchie Way
London E16 1ZE 


cc: Transport Commissioner; Deputy Mayor for Transport; Deputy Mayor for Social Justice and Communities, London Victims' Commissioner; Walking and Cycling Commissioner; TfL Board Secretariat; TfL SSHR Panel Secretariat; London Assembly Transport Committee Members; Tom Kearney (@comadad)


Dear Mr. Mayor,


On 3 December I received a response (below) to my 29 October Open Letter (TfL's 'Safety Scandal' will be your Legacy! An Open Letter to the Mayor of London from Kevin Mustafa) from your Deputy Seb Dance that confirmed to me that both TfL and you appear to be incapable of showing either the compassion or the concern that are urgently required to reform TfL's "institutionally unsafe" Bus Operation. 


In order to ensure that TfL Bus Drivers are provided with working conditions that will allow them to drive safely and with duty of care, as Mayor of London and TfL Chair, you have both the legal authority and statutory responsibility to incorporate the London Bus Drivers' Bill of Rights into London's Framework Bus Services Contract.  But your longstanding refusal to honour the previous Mayor's 1 February 2016 commitment to "update TfL's bus contracts to include new safety incentives" within "three months" confirms that both Bus Drivers' and the public's safety are not your priorities. 


Frankly speaking, I know that London's Bus Drivers believe that your refusal to replace TfL's "Time is Money" Bus Contract incentives with those that protect Bus Driver Working Conditions is a betrayal of the principles upon which the Labour Party and the union movement that created it are founded.  I am convinced that your failures to act as a prudent and responsible TfL Chairman have cost the lives of at least (now) 87 people in preventable Bus Safety Incidents, as well as 76 Bus Drivers from Covid-19 during your time in office. While your allies in the London Labour Party ignore TfL's Safety Scandal, London's Bus Drivers will not be letting you and your Deputy bamboozle them with the kind of gaslighting so evident in your Deputies' public statements over the years. 


And we will not stop until you (a) write The London Bus Drivers' Bill of Rights into TfL's Framework Bus Contract and (b) ensure these commonsense actions are undertaken by TfL and its Bus Contractors without delay.


Yours sincerely,



Kevin Mustafa



Attachment 1: London Bus Drivers' Bill of Rights

Attachment 2: 3 December 2024 Letter from Deputy Mayor, Transport

 

London Bus Drivers' Bill of Rights

 

1. The Right to a safe work schedule without any forced overtime or loss of pay

2. The Right to a decent and proper rest break in the working day

3. The Right to drive a safe and well-maintained vehicle

4. The Right to clean, serviced toilet and rest facilities on all bus routes

5. The Right to report safety concerns without fear of retribution from TfL or employers

6. The Right, when seriously ill and covered by a doctor's note, to not be harassed into coming into work until fit to do so

7. The Right to relevant and timely safety training

8. The Right to drive without being forced to answer radio messages and texts from Controllers whilst in motion

9. ⁠The Right to have all company rules in writing and clearly displayed

10. ⁠The Right to be treated with dignity and respect by our employers, TfL and the public

11. The Right to Working Air Cooling in our cabs in the summer heat 

12. The Right to Working Heaters in our cabs in the cold of winter

 

 

 




  

22-Nov-24


One of over Ten Thousand TfL Bus Crash Survivors since 18 December 2009 (Photo: Tom Edwards)

Remember Remember the 5th of November

Thanks to you London Bus Drivers, I know I sure will.

Back on 18 September 2013, I attended a meeting here in Palestra House initiated by Victoria Borwick AM and hosted by the then-MD for Surface Transport, Leon Daniels, now a Director of TfL Bus Contractor RATP. 

At that meeting, Daniels proudly announced that the reason why TfL's management of London's Public Bus Services was so successful was because its Bus Contracts work on a single overriding principle that "Time is Money", which guaranteed faster and more reliable bus journey times for London's Bus Users.

Thanks to Victoria Borwick's successful lobbying of Mayor Boris Johnson, we now have over ten years of published TfL Bus Safety Performance Data that clearly indicates how those "Time is Money" Contracts are doing—

  • An average of three people a day are hospitalised from a preventable Bus Safety Incident, at least one of which is a collision;
  • About every five to six weeks, someone is killed in a preventable Bus Safety Incident, mostly from collisions; 
  • For the past decade, one of every ten Deaths from Road Traffic Collisions in London has involved a TfL Bus.
  • For the past decade, one of every Deaths of Pedestrians from Road Traffic Collisions in London has involved a TfL Bus. 
  • Since this Mayor was elected, at least eighty-seven people have been killed in preventable Bus Safety Incidents, mostly collisions. 
  • This year, over 1 person per month has been killed in a preventable Bus Safety Incident, mostly collisions.

But London's Bus Users are happy that London Buses are frequent and reliable and—quite often— too fast.

The people in the building behind us don't often advertise the lethal trends contained in TfL's published data, but—at long last— London's press is starting to take an interest.  

In addition to the Mayor's "Vision Zero" Programme, TfL also crows about the at least four 'world leading' Bus Safety initiatives it's announced since 2016.  But since TfL's own published data reveals that the number of people killed and seriously injured from preventable bus safety incidents is now higher than when this Mayor took office in May 2016, it's clear to anyone who bothers to pay attention that none of TfL's 'world leading' Bus Safety programmes are working. 

Why

Because the "Time is Money" Financial Incentives in TfL's "Quality Incentive [Bus] Contracts" haven't changed since they were first rolled out by TfL in the summer of 2001. 

And because Headway and Mileage still serve as the only performance metrics in TfL's "Time is Money" Bus Contracts, it doesn't take a rocket scientist to figure out if TfL is financially incentivising its Bus Contractors to prioritise Headway and Mileage—while their Buses share roads with increasing numbers of cars, lorries, cyclists, pedestrians and scooters—that London Bus Drivers' ability to drive with duty of care is, frankly, impossible.  

And TfL blame the Victims and Bus Drivers for the tens of thousands of preventable Bus Safety Incidents that are the inevitable result of "Time is Money" Bus Contract Incentives.   

Inevitable? 

Yes! Inevitable.

You see? Bus Operators have long told us that sixty percent of the cost of running a bus is the cost of the Driver.

In the "Time is Money" Bus Contract environment that has prevailed in London since 2001, any money earned by the Bus Operator, and any time saved to make the Bus System more efficient, is "time" that is being robbed from the Bus Driver to do his or her job safely and with duty of care.

The Framework Contract TfL uses today is dated 1 January 2016.

That means TfL's Bus contracts are silent about—

But these Bus Contracts are very loud about "Time is Money".

London's Poor Working Conditions and London's ghastly record of Bus Safety Performance will never change until this Mayor puts an end to TfL's "Time is Money" Contracts. Just like the previous Mayor of London promised to do 'over the next three months' on 1 February 2016. 

In fact, the twelve simple "Rights" shown in the London Bus Driver Bill of Rights

1. The Right to a safe work schedule without any forced overtime or loss of pay

2. The Right to a decent and proper rest break in the working day

3. The Right to drive a safe and well-maintained vehicle

4. The Right to a clean, serviced toilet and rest facilities on all bus routes

5. The Right to report safety concerns without fear of retribution from TfL or employers

6. The Right, when seriously ill and covered by a doctor's note, to not be harassed into coming into work until fit to do so

7. The Right to relevant and timely safety training

8. The Right to drive without being forced to answer radio messages and texts from Controllers whilst in motion

9. ⁠The Right to have all company rules in writing and clearly displayed

10. ⁠The Right to be treated with dignity and respect by our employers, TfL and the public

11. The Right to Working Air Cooling in our cabs in the summer heat 

12. The Right to Working Heaters in our cabs in the cold of winter 

—provide perfect evidence of the fact that TfL Bus Contracts have been taking the time away from London's Professional Bus Drivers that's required to perform their jobs safely and with duty of care, and converting that time (i.e., "money") saved into profits for Bus Operators.

The Bill of Rights being demanded by London Bus Drivers are just Human Rights that TfL's "Time is Money" Bus Contracts have taken away from them just so London's Buses are convenient for Bus Users.

And now London Bus Drivers have decided that the "time" for being abused by these "Time is Money" Bus Contracts must end NOW.

It's about time

It's always been about time.

Thank you for your time today.

 



TfL: Time's Up on Dangerous Bus Contact Incentives!


01-Nov-24

By email and blogpost

 

Elly Baker, Chair

London Assembly Transport Committee

City Hall

Kamal Chunchie Way

London E16 1ZE

1 November 2024

 

cc: London Assembly Transport Committee Members, Tom Kearney #LondonBusWatch

 

RE: 5 November London Bus Drivers' Protest at TfL Headquarters - Open Letter

 

With the support of Unite the Union, on Tuesday, 5 November I will join many London Bus Drivers in a march and demonstration at TfL Headquarters to hold Sadiq Khan to account for the 'Safety Scandal'  that has resulted in the deaths of at least 86 people from Bus Safety Incidents and 76 London Bus Drivers from Covid-19 while he has served as TfL Chair and Mayor of London. 


We are demanding that TfL and the Mayor immediately accept a London Bus Drivers' 'Bill of Rights' that I've attached for your information and review. 


While I still await your direct response my 26 June Open Letter, if you study the Bill of Rights and what I have requested the Transport Committee to investigate, i.e.—

  • The Contradiction between TfL's Bus Contract Timeliness Incentives and Speed Limits;
  • TfL's Refusal to Require Independent Bus Crash Investigations;
  • TfL's Failure to conduct Risk and/or Human Factors Assessments of Bus Driver Working Conditions that are known to have a direct impact upon Safety Performance.

—you might appreciate that Bus Drivers are not going to wait months or years until the Transport Committee deigns to get around to scrutinising TfL and the Mayor for creating and maintaining working conditions where we cannot operate our vehicles safely and with duty of care.  

 

I am pleased Unite the Union is supporting this entirely London Bus Workers'-initiated Direct Action next week. If you lead the Transport Committee to investigate the issues I raised in my 26 June Open Letter, you will discover why our grassroots protest is so necessary.

 

I await your direct reply to my 26 June Open Letter.

 

 

Yours sincerely,

 

Lorraine Robertson


 

 

Attachment: London Bus Drivers' Bill of Rights

London Bus Drivers' Bill of Rights

 

1. The Right to a safe work schedule without any forced overtime or loss of pay

2. The Right to a decent and proper rest break in the working day

3. The Right to drive a safe and well-maintained vehicle

4. The Right to clean, serviced toilet and rest facilities on all bus routes

5. The Right to report safety concerns without fear of retribution from TfL or employers

6. The Right, when seriously ill and covered by a doctor's note, to not be harassed into coming into work until fit to do so

7. The Right to relevant and timely safety training

8. The Right to drive without being forced to answer radio messages and texts from Controllers whilst in motion

9. ⁠The Right to have all company rules in writing and clearly displayed

10. ⁠The Right to be treated with dignity and respect by our employers, TfL and the public

11. The Right to Working Air Cooling in our cabs in the summer heat 

12. The Right to Working Heaters in our cabs in the cold of winter

29-Oct-24

By email and blog post

29 October 2024

Sadiq Khan, Mayor of London and TfL Chair
City Hall
Kamal Chunchie Way
London E16 1ZE 

cc: Transport Commissioner; Deputy Mayor for Transport; Deputy Mayor for Social Justice and Communities, London Victims' Commissioner; Walking and Cycling Commissioner; TfL Board Secretariat; TfL SSHR Panel Secretariat; London Assembly Transport Committee Members; Tom Kearney (@comadad)


Dear Mr. Mayor,

With the support of Unite the Union, at 1100 on Tuesday, 5 November I will be leading London Bus Drivers in a march from Unite the Union's Regional London Office in Islington down to TfL Headquarters on Blackfriars. When we arrive at Palestra House, we will demonstrate to hold you and TfL to account for the 'Safety Scandal' that has resulted in the deaths of at least 86 people from Bus Safety Incidents and 76 London Bus Drivers from Covid-19 while you have served as TfL Chair and Mayor of London. 

I woke up to your 'Safety Scandal' in Spring 2020, while I was working as a Bus Driver Driver for a Singapore-based London Bus Contractor. While my colleagues across London fell ill and died from Covid-19, I couldn't help but notice that Company Managers and TfL officials, had effectively, vanished.  

I've since learned that, in April 2020, while—

TfL was telling Unite the Union "masks not necessary". I've also learned TfL never requested copies of Covid-19 Risk Assessments from its Bus Contractors. 

Like many other Bus Drivers, I am convinced that my colleagues had the highest rate of deaths from Covid-19 in the United Kingdom in April 2020 because of your and TfL's well-evidenced failures to use the powers you had—and had already exercised to protect TfL employees—to save London's Bus Drivers. 

Since that traumatic time, I've had the opportunity to—

  • to speak with TfL officials in person about their failure to protect Bus Drivers during Covid;
  • exchange letters with your Deputy Mayor about the "Culture of Fear" TfL permits on its contracted Bus Operation which prevents Bus Drivers reporting their well-founded concerns about safety problems to their managers or TfL; 
  • be gaslighted by you about Poor Bus Driver Working Conditions on James O'Brien's "Speak to Sadiq",

Like you, I've also had the opportunity to read—

—and I 'm convinced that your and TfL's constant refrain that, for Buses, "Safety is TfL's first priority"  is just a lie you've made for media consumption.

Why? 

Because TfL's latest Framework Contract for Bus Services in London—dated 1 January 2016—has zero requirements for safety performance—

  • TfL Bus Contracts contain nothing about 'world leading' Bus Safety Programmes
  • TfL Bus Contracts contain nothing about Vision Zero

But TfL Bus Contracts contain everything about the absolute requirement for London Buses to run On Time, Frequently and Efficiently for the convenience of London's Bus Users and for the benefit of Bus Operator Shareholders. 

Perhaps that explains why— 

  • the number of people killed and injured by Buses is higher now than when you took in May 2016;
  • so many of my colleagues fell ill snf died from Covid-19;
  • TfL chooses to mislead Londoners about the actual number of people killed and injured in preventable Bus Safety Incidents;
  • Bus Drivers report that Driver Fatigue, Lack of Toilet Dignity and Unsafe Bus Cab Temperatures are more prevalent today than ever before;
  • Bus Drivers today must demand the basic human rights shown in the London Bus Drivers' Bill of Rights I've attached for your information and immediate approval

Please look closely at the Rights London Bus Drivers require today so that they can drive safely and with duty of care on London's increasingly congested-roads.  

As TfL Chair since May 2016, aren't you the least bit ashamed that Bus Drivers even feel compelled to march to TfL Headquarters on 5 November to demand these Human Rights to work safely on a contracted Bus Operation that reports to you?  

If you continue to refuse London Bus Drivers this Bill of Rights, TfL's Safety Scandal will be your Legacy. 

Yours sincerely,


Kevin Mustafa


Attachment: London Bus Drivers' Bill of Rights



 


London Bus Drivers' Bill of Rights


1. The Right to a safe work schedule without any forced overtime or loss of pay

2. The Right to a decent and proper rest break in the working day

3. The Right to drive a safe and well-maintained vehicle

4. The Right to clean, serviced toilet and rest facilities on all bus routes

5. The Right to report safety concerns without fear of retribution from TfL or employers

6. The Right, when seriously ill and covered by a doctor's note, to not be harassed into coming into work until fit to do so

7. The Right to relevant and timely safety training

8. The Right to drive without being forced to answer radio messages and texts from Controllers whilst in motion

9. ⁠The Right to have all company rules in writing and clearly displayed

10. ⁠The Right to be treated with dignity and respect by our employers, TfL and the public

11. The Right to Working Air Cooling in our cabs in the summer heat 

12. The Right to Working Heaters in our cabs in the cold of winter


 

23-Sep-24
By Email and Blogpost
Elly Baker, ChairLondon Assembly Transport CommitteeCity HallKamal Chunchie WayLondon E16 1ZE23 September 2024
cc: London Assembly Transport Committee, Members and Staff
Good Morning Elly Baker,
I received the attached letter from you as Transport Committee Chair "responding to your email from 26 June 2024"  on 19 July via a Committee Staffer. 
As you know, my 26 June email to you and the Committee simply contained a link to an Open Letter from former TfL Bus Driver Lorraine Robertson: acting on Lorraine's express instructions, I was pleased to post her letter on my blog and email the link to you and the Committee on 26 June. 
Although I intend to respond publicly to your 19 July letter to me in due course, kindly note it's been over two months and Lorraine Robertson still awaits your response to the issues she requested the Transport Committee to investigate, namely—and quoting directly from her 26 June Open Letter—
  • The Contradiction between TfL's Bus Contract Timeliness Incentives and Speed Limits;
  • TfL's Refusal to Require Independent Bus Crash Investigations;
  • TfL's Failure to conduct Risk and/or Human Factors Assessments of Bus Driver Working Conditions that are known to have a direct impact upon Safety Performance.
If you have a chance to listen to my recent podcast or read Sunday's report from My London "Whistleblower London bus drivers 'exhausted' and 'use faulty vehicles' in 'dangerous' conditions" , you might understand why I'm surprised that you—a Labour Party Member and well-regarded union activist—seemingly chose to deny a London Bus Driver any agency to express her valid concerns to the Transport Committee about well-evidenced TfL policies that affect Bus Driver Safety Performance.  Like my 26 June email to the Committee, Lorraine Robertson is also copied to this email and awaits the Committee's thoughtful response to her urgent request.  In the interest of transparency and to encourage public scrutiny of the Transport Committee's important work holding the Mayor of London to account, kindly note that I have posted your 19 July Letter and this email correspondence on my blog.
Yours sincerely,
Tom Kearney#LondonBusWatch T: ddddddddddddddE: comadad1812@gmail.comTwitter: @comadad Blog:  www.saferoxfordstreet.blogspot.co.uk 2018 Winner, Community Hero Award — The Johns Hopkins University Alumni Association2016 Winner, Transport - Sheila McKechnie Foundation SMK Campaigners Award





26-Jun-24
Elly Baker, Chair
London Assembly Transport Committee
City Hall
Kamal Chunchie Way
London E16 1ZE
cc: London Assembly Transport Committee, Members and Staff

Dear Elly Baker,
RE: Open Letter - Assisting the Inevitable Independent Inquiry about the Safety of the London Contracted 'Bus Market' Model
Congratulations on your re-election to the London Assembly and your selection to serve as Chair of the Transport Committee. You may recall that we had a chance to meet on 14 December 2021 when I gave evidence as a veteran TfL Bus Driver for the Transport Committee's Investigation of the Mayor's Vision Zero Programme.  
While you're busy considering your Committee's plan-of-work for the coming four years, I'd like to call your attention to some Transport Committee scrutiny that I believe that might be required in the nearest future, specifically to assist that requested in Resolution 6 carried unanimously by the RMT National Industrial Organising Conference of Bus Workers on 28 April 2023:  
Resolution 6: Independent Inquiry about the Safety of the London Contracted 'Bus Market' Model 
"That this RMT National Bus Workers Industrial Organising Conference calls upon the RMT N.E.C. to support and campaign for an independent inquiry about the safety of the London Contracted Bus Market Model that is being adopted by other UK cities. This conference notes that, while London's Contracted Bus Market Model is being adopted by other cities and regions throughout the UK, the London Assembly and independent campaigners have published well evidenced reports showing that TTL's contracted bus operation is as described by a former TfL board member and safety panel chair in evidence submitted to the London Assembly in 2020, "Institutionally unsafe". 
Over the 5 year period from 2016-2021, from collisions involving a TfL bus, an average of two people per day have been sent to hospital and 1 person has been killed every four to six weeks, an egregious bus safety performance record that places London in the lowest quartile for bus safety performance when independently benchmarked to its world city peers. Added to this appalling bus safety performance record is the fact that during the COVID pandemic, drivers died at twice the rate as expected based on age, ethnicity and home post code. 
Based on the London Model's well evidenced poor safety performance record, this conference calls upon the RMT N.E.C. to ask the House of Commons to launch an independent Inquiry of the systematic safety problems associated with TfL's Contracted Bus Market Model." 
Although your colleague on the Transport Committee, Keith Prince AM, brought this important Resolution to the Mayor's attention in May 2023, Sadiq Khan's non-committal response coupled with the lack of news from Westminster or City Hall about any Independent Inquiry suggests that what RMT's Bus Workers requested in 2023 remains unconsidered by the public officials vested with the powers to do it.
However, with the Labour Party's imminent national election victory and its Manifesto committing a Labour Government to 'build on the work of Labour mayors' to give 'new powers for local leaders to franchise local bus services'—I believe that the Safety Performance of London's Bus Franchise Model will become the focus of a lot of scrutiny, if not from City Hall, certainly from Westminster and the national press.   
Why?
Because, as you most certainly already know— 
  • London is home to the largest franchised Bus Operation in the United Kingdom: TfL Bus Franchise Contracts account for 50 percent of UK Bus Journeys conveyed by 25 percent of the country's Bus Fleet;
  • On 11 April 2024, Labour's shadow transport secretary, Louise Haigh MP set out the party's plans for a better bus network across England, with a promise— "to allow every community across the country to take back control of local bus services"—and specifically cited London as a model;
  • In the words of former TfL Board Director and Safety Panel Chair Michael Liebreich, TfL's Bus Franchise Model is "Institutionally Unsafe";
  • Since 2007, TfL's own published data shows that—year-on-year—London buses have accounted for 10% of all of London's road fatalities and about 10% of all pedestrian fatalities in London despite Buses' presence on the road over this period having declined from constituting about 3% to about 1% of all vehicles on the road at any given time;
  • TfL's sole measure of bus contract performance is a time-based "Excess Waiting Time" calculation which Independent benchmarking shows London—
    • in the highest tercile of its 'world city' peers for Bus Punctuality and Profitability per Bus;
    • in lowest tercile of its 'world city' peers for safety (collisions per km): based on this published independent annual benchmark data, London appears to have the least safe bus system of any major European city;
  • TfL has never conducted a safety risk assessment of the Bus Franchise Model or its Bus Contract Financial Incentives;
  • 1 in 5 of the London Bus Drivers surveyed by Loughborough University (2017) indicated that they had to fight sleepiness at least 2-3 times a week, and about 1 in 4 had a 'close call' due to fatigue in the past 12 months;
  • For decades, TfL's contracted Bus Operation has averaged over 26,000 Bus collisions annually—in 2023, TfL recorded over 28,000—from which
    • about 1200 people are injured every year;
    • 1 person is killed about every six weeks; 
    • 80 to 100 people are sent to hospital every month from Preventable Bus Safety Incidents (80% Collisions, 20% Onboard Trips & Falls), over 20 of these victims with serious and/or life-changing injuries;
  • Over one quarter of London Bus Routes don't have a toilet for Bus Drivers at one end of the route;
  • TfL has agreed with Bus Operators and Unite the Union that Bus Drivers don't need a toilet on any route round trip that lasts up to 150 minutes — this 'criteria' was agreed without a Human Factors or Risk Assessment;
  • TfL has evidence of (at least) 12 million (est.) Annual Bus Speeding incidents on file that it does not share with the Police;
  • Since January 2016, more than 1 pedestrian per month has been injured by a TfL Bus hitting them in a zebra or pelican crossing; 
  • Since 1 April 2015, an average of 6 people per month (2022-23: 8 per month- getting worse) have been injured after being struck by a Bus Wing Mirror;
  • TfL received the highest Health & Safety Fine ever in July 2023 for HSE Failures on the Croydon Tram, a contracted surface transport operation that was founded, managed and monitored by TfL's Bus executives;
  • Transport for London (TfL) does not require the bus operating companies to share copies of their risk assessments covering activities within their garage environments. This includes any that were created or updated as a result of Covid-19.
  • despite the facts that—
    • the total number of bus miles in London has declined;
    • the total number of bus users in London has declined;
    • the total number of buses in London's contracted bus fleet has declined;
    • the total number of Bus Drivers in London has declined, and, 
    • since 2016, the Mayor of London has announced 3 'world leading' Bus Safety Programmes and a Vision Zero Programme;
—the number of people killed and seriously injured from Bus Safety Incidents are now higher than 2016
 
To get ahead of the national press and Westminster, I would strongly advise you urgently to lead the Transport Committee to build upon the evidence and conclusions found in the London Assembly's March 2024 "Bus, Tram and Tube Safety" Investigation and perhaps focus on three specific areas highlighted in Appendix 1 of that investigation— 
  • The Contradiction between TfL's Bus Contract Timeliness Incentives and Speed Limits;
  • TfL's Refusal to Require Independent Bus Crash Investigations;
  • TfL's Failure to conduct Risk and/or Human Factors Assessments of Bus Driver Working Conditions that are known to have a direct impact upon Safety Performance;
—which will no doubt be the focus of national press and Westminster scrutiny in the coming weeks after the new Government's promised "Better Buses" Bill is submitted to Parliament for consideration. 
If you choose to lead such an urgent investigation as Chair of the London Assembly Transport Committee, kindly note that I will, once again, be pleased to contribute evidence as a veteran London Bus Driver.  If you choose not to lead such an investigation, then those who inevitably will do so can find my open letter on the public record.
Yours sincerely,
Lorraine RoberstonLondon Bus Driver (Retired)

19-Apr-24



I am grateful for the opportunity to once again address the RMT's Bus Worker National Industrial Organising Conference. I congratulate its organisers and RMT Union on celebrating this important conference's 81st year. 
Since this is the third National Conference in which I've been honoured to share my transport research with members since 2018, I'd like to follow up with you all on a resolution that was put forward last year by the Nottinghamshire & Derbyshire Branch and passed by members which called upon "the House of Commons Transport Committee to launch an Independent Inquiry of the Systemic Safety Problems associated with Transport for London's 'Contracted Bus Market' Model."

What progress has the union made on putting this Resolution into effect? 

If the answer is "none", I'd like to underscore why such an Independent Inquiry is critical today and to provide you with some encouragement—and perhaps some useful data—to ensure that such an Independent Inquiry is conducted, if not by the Commons Transport Committee, then perhaps by the RMT or the broader UK Trade Union movement.

The 2017 Bus Services Act gave devolved regional authorities the right to contract public Bus Services from private Bus Operators under terms and conditions written, negotiated and enforced by these local authorities, something London's Mayor has been doing through TfL since 2000.   As you know, the London Bus Franchise Model was recently adopted by Manchester's Mayor Andy Burnham, much to the acclaim of the national press, the Labour Party and its supporters

In fact, yesterday's Labour Party "Better Buses" announcement by its Shadow Transport Secretary reaffirms its support for the London Bus Franchise Model, e.g. —

"Where bus franchising is in place, in London and Greater Manchester, buses have thrived."

— and further promises—"to allow every community to take back control of their buses by removing barriers that currently limit bus franchising powers only to metro mayors."

As I have concluded from investigating London's long experience of having Mayoral control over Bus Services, buses "thriving" really means that the politicians who oversee London's public bus network put Bus Passengers' convenience ahead of everyone else's safety, including Bus Drivers' and other Road Users', pedestrians' especially. 

The London Bus Franchise Model is "Institutionally Unsafe"

London's quarter-century experience with Mayoral control of the bus public network has shown that, essentially, Bus Passengers only care if their Bus is Cheap, Convenient and Timely

For decades, that 'Holy Trinity' has served as TfL's overwhelming priority in its contracting of Bus Services in London, a city which accounts for about 50% of UK Bus Journeys and 25% of the country's Bus Fleet.

The fact that these cheap, convenient and timely London Buses—

  • share the roads with growing numbers of other road users—increasingly on two wheels and their feet —who have a right to consider their journey just as important as Bus Users'; 

  • impose negative externalities like pollution, particularly from the majority of London Buses running on diesel: a whopping 77 percent of TfL's Contracted Bus Fleet run solely on diesel (45 percent) or are diesel hybrids (32 percent), which will continue to pollute for decades; 

  • because of their size and mass, carry a much higher risk of death and serious injury from crashes, which is borne out by the fact that TfL buses—about 2% of total traffic—have been involved in 1 in about every 10 of all London road fatalities since 2007.  Note: in June 2016, TfL's (now Chief Safety Officer) told the Parliamentary Advisory Council for Transport Safety "Buses are four times more likely to be involved in a KSI collision with a pedestrian than would be expected for their share of traffic"—and TfL's published data reveals that people killed or seriously injured (KSI) from Bus Collisions have increased since 2016. 

— rarely register on most Bus Users', TfL and Bus Company Bosses' and London politicians' radar screens. 

As a result of the London Bus Franchise Model's contract priorities, the Bus System's Operational Safety Performance and Driver Working Conditions have suffered because if London's Mayors and local politicians actually made these a priority, they'd find themselves in direct conflict with a longstanding systemic principle that "Time is Money" which has long served as the only public bus service performance metric in London that matters. TfL's sole measure of public Bus Contract Performance is for its Bus Contractors to stick to the costs based on  running times they've contractually agreed with TfL.

Remember: 60% of the cost of running a public Bus is the Driver, so there is a systemically-reinforced disincentive for TfL and its contractors to add any extra bus drivers to routes where any new or emerging reality conflicts with (a) costs and (b) profits directly tied to already-contracted Bus Service Performance levels.  Instead, TfL and its Bus Operators  choose to put pressure on Bus Drivers to compensate for what former TfL Board Director and Safety Panel Chair Michael Liebreich has evidenced is an "Institutionally Unsafe" contractual arrangement. And this pressure means Bus Drivers work while fatigued, distracted by System Controllers and frequently exceed the legal speed limit just so that their Bus Operator employer can meet TfL's contracted timeliness and availability targets. 

Under the London Bus Franchise Model, making Bus Drivers pay for TfL's and Bus Operators' lethal contract priorities is called "efficiency". And any Mayor who claims to be contracting a public bus operation from for-profit Bus Companies more 'efficiently' for passengers who, at the time same, is not increasing fares or local taxes to fund this 'improvement', means that all this new efficiency is being funded by reductions to your pay and through degrading working conditions which have a direct impact on your safety performance.  

From my own experience underpinned by over a decade of research (all in the public domain), I know that the London Bus Franchise Model is both big business for Bus Operators and lethal for both Bus Workers and the general public. Since I began my research after recovering from critical injuries sustained in a Bus Crash in 2009, TfL's published data reveals that over 150 people have been killed and thousands have been seriously injured from preventable Bus Safety Incidents, the vast majority of these casualties generated from collisions. Since the current Mayor was elected in May 2016, at least 77 people have been killed from preventable Bus Safety Incidents, over three quarters of which were from collisions.

A recently issued cross-party London Assembly Transport Committee Investigationits third since 2017—continued to highlight the same problems with the London Bus Franchise Model evidenced in the Assembly's previous investigations, i.e, Driver Fatigue, Lack of Toilet Dignity,  and Pressure to meet TfL's contracted timeliness and availability targets. Despite the London Mayor's announcement of 3 'world leading' Bus Safety Programmes and a Vision Zero Programme since 2016, the number of people killed and injured in Bus Safety Incidents in London is higher today than when the first of these Safety Programmes was announced on 1 February 2016.  Seeing that London's total Bus Fleet Size, Bus Mileage, and the actual number of both Bus Users and Bus Drivers have all shrunk since 2016, London Buses' negative safety trend is especially alarming. By all metrics of systemic safety, the London Bus Franchise Model is a manifest failure.   

Since I'm limited for time, please allow me to detail only a few of these systemic failures:

  • Bus Collisions: despite the fact that London has fewer Buses, Bus Drivers and fewer Bus Miles run, Bus Collisions are now higher today than they were than when the present Mayor was elected in 2016. In 2023, TfL recorded over 70 Bus Crashes per day. TfL's annual tally for Bus Crashes now exceeds the number of London Bus Drivers: that's more than 1 recorded crash per London bus driver per year.  Since 2018, when London's Bus System Performance has been compared to its global 'world city peers', the city regularly appears in the quartile having the highest bus "collisions per km". I would wager London is the only European city to occupy this dubious place in the international benchmarking tables year-after-year.  
  • Preventable Bus Safety Incident Injuries: Total Injuries generated from Preventable Bus Safety Incidents—the vast majority from collisions, but increasing numbers of passenger trips and falls onboard—are now higher than they were than when the present Mayor was elected.  Since 2016, an average of 3 people a day are sent to hospital from Preventable Bus Safety Incidents and, about every 6 weeks, someone has been sent to the morgue.  Remember: London has fewer Buses, Bus Drivers and fewer Bus Miles run than when the present Mayor was elected, so every bus, every bus mile, and every public bus journey is now more dangerous today than it was when the current "Vision Zero" Mayor was elected. 
  • Bus Collision Investigations: in sharp contrast to the Rail, Air, and Maritime Sectors, Transport for London entrusts its Bus Contractors to carry out their own crash investigations. In fact, the Mayor has rejected all recommendations by London Assembly Members to establish an  Independent Bus Crash Investigation Branch for London.  The peculiar fact that TfL allows its Bus Contractors to investigate their own crashes was recently raised in the House of Lords by Lord Hampton. I hope that this scrutiny by Lord Hampton is a leading indicator that Westminster might take a greater interest in the known safety failings of the London Bus Franchise Model. 
  • Bus Driver Fatigue: even though there is plenty of published evidence proving Bus Driver fatigue is chronic problem throughout the London Bus Operation and the Mayor has full authority to act to take meaningful and immediate action to mitigate it, the Mayor has refused to compel TfL to redesign London Bus Contracts to ensure that Bus Operators aren't financially-incentivised to enforce Fatigue-Inducing Rosters, Rotas and Working Practices. 

In fact, it is quite telling that, despite (a) the Mayor's announcements of 3 'world leading' Bus Safety Programmes, Vision Zero and (b) TfL incurring the largest Health and Safety Fine ever for Surface Transport Safety failings in July 2023, TfL's Framework Bus Contract has not changed since it was last updated in January 2016. 

The 2017 Loughborough Bus Driver Fatigue Report found that "stress and mental overload whilst driving" and "time pressure" from, inter alia, "headway" contributed to a working environment where 1 in 5 of the London Bus Drivers surveyed by Loughborough indicated that they had to fight sleepiness at least 2-3 times a week, and about 1 in 4 had a 'close call' due to fatigue in the past 12 months.

    • Yet, in response to a question about the relationship between "Rest Day Working and Bus Safety Incidents" from London Assembly Member Neil Garratt in February 2023, the Mayor confirmed:

"The type of shift being worked at the time of an incident is not information that is routinely captured as part of the bus operator's initial incident reporting to Transport for London (TfL)." 

    • In a response to a question about TfL's 'Bus Fatigue Management Working Group' from London Assembly Member Keith Prince in October 2023, the Mayor confirmed that this group meets in secret, has no published minutes or agendas and does not include any representatives of bus drivers or the public. 
    • University College London's March 2021 Phase 2 Consulting Report about London Bus Driver Deaths from Covid-19 concluded and recommended—"Fatigue is a pre-existing issue for some bus drivers, with some evidence that COVID-19 infection and lockdown has contributed to this. Action, already being taken following previous research into factors contributing to tiredness, should be enhanced to address any new issues arising from the pandemic, following a short-term review of shift lengths, patterns and rotas"—Yet, despite repeated questioning from Keith Prince AM since 2021, the Mayor recently confirmed that TfL has yet failed to conduct a ""short term review of shift lengths, patterns and rotas" over three years after this recommendation was made. 

If "True ignorance is not the absence of knowledge, but the refusal to acquire it" then the Mayor's and TfL's apparent witting ignorance about the causes and effects of Fatigue among London Bus Drivers is, in my honest opinion, grossly negligent
  • Hot Cabs: even though he has full powers to act, the Mayor refuses to ensure that TfL Bus Contractors' will not force London Bus drivers "to drive - and will also suffer no consequences from their employer for refusing to drive - any London bus with a cab temperature that exceeds that for safe transport of livestock in the UK."  Last summer, Bus Drivers were regularly recording 40c in their cabs yet the Mayor refuses to inform the public what happened to the Bus Driver that newspapers reported had passed out in the bus cab from the heat and subsequently crashed. 
  • Lack of Corporate Governance on Safety (1): the Mayor refuses to invite representatives of the public and Bus Workers to attend the Safety Bus Meetings TfL convenes every quarter with its Bus Contractors. If Bus Drivers aren't in the room where TfL decides safety policy with its contractors, then London Bus Safety Policy's happening without them. If Labour's going to give all local authorities the right to franchise Bus Services, Bus Workers need to be in the room where safety policies are negotiated, agreed, implemented and monitored. In London's Bus Franchise Model, the Mayor ensures they aren't.
  • Lack of Corporate Governance on Safety (2): despite TfL being responsible for 100% of their revenue, the Mayor refuses to mandate that each Bus Contractor that supplies Bus Services to TfL appoint a Bus Worker Representative to the board.  If Labour's going to give all local authorities the right to franchise Bus Services, Bus Workers need to be in the board rooms where those contracts are negotiated, agreed, implemented and monitored.  Again, in London's Bus Franchise Model, the Mayor ensures they aren't. 
  • Failure to Conduct Covid-19 Risk Assessments: In December 2021, the Mayor confirmed "Transport for London (TfL) does not require the bus operating companies to share copies of their risk assessments covering activities within their garage environments. This includes any that were created or updated as a result of Covid-19."  The Mayor admits that TfL chooses to be wittingly ignorant about its Bus Contractors' Safety Practices? In my view, that Mayor's response captures the essence of the manifest safety failure of the London Bus Franchise Model in a nutshell

Making "Better Buses" Better for Bus Workers and Public Safety

Taking advantage of the Freedom of Information rights we all have in the UK, I have voluntarily generated a vast amount of detailed evidence about the safety failings of the London Bus Franchise Model which is all available in the public record, i.e.,—

  • Dozens of FOI Requests
  • Hours of recorded public testimony by London Bus Drivers, Politicians and Experts
  • Hundreds of Mayors's Questions
  • Thousands of Pages of Evidence
  • Hundreds of Thousands of Bus Safety Data Points

All this data evidences how lethal the London Bus Franchise Model has been for Bus Drivers and the public, especially pedestrians young and old, male and female.  Perhaps the Labour Party will be gratified to know that the London Bus Franchise Model is an 'equal opportunity killer'? 

With the near certainty of a crushing Labour Party victory in the impending National Election and that Party's promise to devolve bus contracting to local authorities, I can assure you that—warts and all—the London Bus Franchise Model will be coming to a local authority near you. 

If TfL's quarter-century experience contracting out Bus Services to Bus Contractors is any guide, when Labour does roll out the London Bus Franchise Model nationwide, then RMT Bus Workers should be prepared to combat—

  • Contracted Punctuality, Availability and Convenience Targets taking priority over Bus Safety Performance
  • Excluding Bus Workers from Decision-making about Bus System Safety 
  • Excluding Bus Workers from Decision-making about Bus System Contract Priorities 
  • Lower Wages and Longer Hours
  • Shorter Rest Breaks
  • Lack of Toilet Dignity
  • Dangerously Hot Bus Cabs 
  • Absence of Transparent Decision-making about Safety Policies that affect directly affect Bus Driver Working Conditions
  • Lack of Transparency about Bus Contract Incentives, Bus Safety Performance and Local Government relationships with Bus Contractors
  • Pressure to meet contracted bus timetables that prioritise passenger convenience over operational safety
  • Public Authorities failing to collect key Bus Safety Performance Data
  • Public Authorities hiding Bus Safety Performance Data from public scrutiny
  • And lots more people killed and seriously injured from preventable Bus Safety Incidents

When I started looking for London's Public Bus Safety Performance Data from my hospital bed in February 2010, there was absolutely none to found anywhere in the public domain. Today, London is probably globally unique for the sheer volume of Bus Safety Data Performance Data TfL publishes: that transparency is entirely due to my voluntary campaign and the support my relentless efforts have received in London from (a) Conservative, Liberal Democrat and Green Assembly Members, (b) scores of Bus Drivers and (c) the Battersea and Wandsworth TUC  and, nationally, from the RMT and GMB unions.  You'll note that I've not mentioned either the Labour Party nor its largest funder Unite the Union in my 'shout-out' because, aside from some thoughtful outreach from Labour MP Matt Western 5 years ago, I've not heard anything from either in the 14 years I've been researching Bus Safety Performance in London.  

Lee Odams, RMT Vice Secretary Nottinghamshire & Derbyshire Bus Branch and Secretary of RMT National Industrial Organising Conference of Bus Workers discovered the value of having publicly-available data ready-to-hand when Manchester announced it was 'taking back control' of its Bus Network last year. Shortly after the October 2023 announcement, 2 pedestrians were killed in Bus Collisions about which Transport for Greater Manchester (TfGM)'s Director of Bus Stephen Rhodes had this to say: 

"We are concerned by the unusually high number of incidents involving buses over recent days, which is far above what we might normally see on any given week".  

But Lee knew that statement didn't ring true because in 2019 he sent Freedom of Information Requests to every council in the United Kingdom asking each to provide him with exactly the same Bus Safety Performance Data that TfL has published every quarter since 2014. And just like 90% of UK Councils that sent Lee a response, TfGM didn't have any Bus Safety Incident Data. And because Lee had a signed May 2019 letter from TfGM in hand stating explicitly—"...bus services in Greater Manchester are run by commercial services and they do not share this information with TfGM"— Lee was able to send Mayor Andy Burnham a copy of this evidence in an open letter asking if the Mayor of Manchester would compel TfGM commit to the publishing the same Bus Safety Data TfL publishes.   

In December 2023, Lee received a response to his open letter where TfGM indeed committed to publishing Manchester's Bus Safety Performance Data "in the future", but until we see anything in print, these are still only fine words. To be honest, I'm not reassured that TfGM decided that publishing Bus Timeliness Data took priority over its being transparent about its buses' operational safety performance, but it would appear that, just as in London, bus punctuality is the only metric Bus Passengers care about.   I wonder if any Bus Workers (or their unions) were in the room when TfGM's new contracted Bus Punctuality metrics were decided? 

I am pleased that this Conference has a Resolution encouraging Mayor Andy Burnham to force TfGM to keep its promise to make Manchester's Bus Safety Performance Data public. However, without (a) London being forced to publish Bus Safety Performance data after years of voluntary campaigning by me and (b) Lee Odams embarrassing Mayor Burnham and TfGM publicly by publishing its 2019 FOI response to him, I'd wager neither of the UK's two leading cities where the Mayors oversee Bus Contracts would have done anything.  Manchester still hasn't.

Meanwhile, Labour has promised to put forward a 'Better Buses Bill' as soon as it gets into power. We will need a lot of "Lee Odamses" in many local and regional authorities throughout the UK to ensure that all the new authorities contracting bus services will, at a minimum, be as transparent about Bus Safety Performance as London and—at some point in the future—Manchester.  Will Labour's 'Better Buses Bill' compel Regional Mayors and Local Authorities who contract public Bus Services through franchises collect and publish their contracted Bus Operations' Safety Performance Data for public scrutiny on a regular basis? 

Now that the London Bus Franchise Model is no longer a question of "if" but "when" it will be implemented by a local authority near you, it is imperative that the RMT Union fully appreciates how its adoption by Regional and Local Political Leaders vested with the same executive authority enjoyed by London's Mayor will impact upon its members' working conditions, wages, general well-being and public safety.  It's useful to note that the English words for "politics" and "policies" share the same root.  And since we live in a democracy and have Freedom of Information rights, as RMT members and Bus Drivers Paul McDonnell, Lee Odams, Theresa Emerson, Lorraine Robertson, and Kevin Mustafa have known for years, there's no reason why RMT Bus Workers need to wait to receive permission from anyone before launching 'independent inquiries' of their own. So that Labour's "Better Buses" politics stands a chance of producing Bus Franchise polices that are actually better for Bus Workers and public safety,  labour unions urgently need to launch more of those Independent Inquiries. And I'll be pleased to assist them if they do. 

Thank you for your time.

Tom Kearney

#LondonBusWatch

E: comadad1812@gmail.com

Twitter: @comadad



 

24-Jan-24

via Email and Blog Post

From: kevin mustafa Subject: Wake up BBC! TfL's still putting "Miles" ahead of "Lives"! An Open Letter to Tom Edwards, BBC Transport CorrespondentDate: 24 January 2024 at 11:24:31 GMTTo: tom edwards
Tom Edwards, Transport CorrespondentBBC London NewsBBC Broadcasting HousePortland PlaceLondon W1A 1AA
Dear Tom Edwards,
By way of introduction, I am the London Bus Driver you interviewed anonymously in January 2021 about the high death rate of TfL Bus Drivers from Covid-19 ("Bus Drivers say they feel "miles" being put ahead of "lives"). 
I studied your report from 21 January 2024 ("Passengers frustrated by bus that does not stop") about your BBC Colleague Paul Moss's unsatisfactory experiences with Route 18 Buses with great interest.  Because your news report was entirely based upon (a) Mr. Moss's anecdotal evidence (b) Mr. Moss's recollections from speaking at some point with 'one inspector', and (c) some boilerplate comments made by a unprepared functionary in Transport for London's PR department, I thought it might be helpful for you to have a Bus Driver's perspective on the obvious systemic safety issues evoked by your report. 
Since three statements you chose to publish— 
  • "Mr Moss says he spoke to one inspector who said it was because the bus drivers are under pressure to make up time on the route, so they skip stops."
  • "The ticket inspector said the schedule is too tight," he says."
  • "And the drivers have been told, 'if you're late , if you don't have time', and these were the inspector's words, 'then just go go go'."

—confirm to me (at least) that the 'Institutionally Unsafe' foundations of TfL's contracted Bus Operation are in plain sight (at least to that TfL inspector and the BBC)please permit me to help you to connect the dots your report manifestly failed to do.
With 20mph, Intelligent Speed Adaptation and Increasing Congestion, TfL's Contracted Bus Schedules aren't fit-for purpose. 
On 14 December 2021, in response to a question about speed limits and Bus Time Tables from Siân Berry AM, Bus Driver Lorraine Robertson told the London Assembly Transport Committee 
"The problem that we have with speed limits as a bus driver is that we drive to a timetable, what is called a headway. Now that we are coming across roads that have the 20mph speed limit, our timetables have not been changed to take into consideration that we are going 10mph less, doing 20mph as opposed to 30mph. That is a problem that we are having."

Following Lorraine's comments, a review of Mayor's Questions since February 2022 will show that Neil Garratt AM has been valiantly trying to compel the Mayor and TfL to admit that there's an obvious disconnect between 'too tight' schedules and the pressure these put on Bus Drivers "to make up time on the route" in a city with much more traffic where the Mayor and the Boroughs have widely extended 20mph limits since 2020.  For example, this exchange between Neil and Mayor Khan from 12 October 2023 nicely captures the Mayor's utter failure to comprehend the consequences of these trends, some of which TfL's catalysed
With Vision Zero, having Timeliness serve as TfL's only Bus Contract Performance Metric is not safe for Drivers, Passengers or other Road Users
Because London Bus Users like the BBC's Mr. Moss consistently tell TfL and its political supporters that the only issue that matters to them is that London Buses run on time and fast, the only performance metric TfL and its Bus Contractors use—regardless of increasing congestion and numbers of vulnerable road users in London—is Bus Timeliness measured by Excess Waiting Time ("Headway") that Bus Operators and TfL have maintained "almost like a religion" since the summer of 2001. 
Since TfL's contracted Bus Operation is entirely focused on Bus Drivers keeping to time, anything that takes time out of that operation—like Rest Breaks, Toilet Breaks, Meal Breaks, Congestion, Road Works, Driving Safely to Road Conditions, not Speeding, Paying Heed to Vulnerable Road Users, Ensuring passengers with special needs can board and get into place safely—puts additional pressure on Bus Drivers to, as you stated in your report, 'make up time on the route.'  To avoid harassment and punishment by Bus Operators, Bus Drivers are incentivised to cut corners on safety to meet contracted timetable targets and they are regularly disciplined if they don't.  That is not a safe working culture and exactly what Bus Drivers feel complelled to do to "make up time on the route" is precisely what the BBC should have been investigating for the past couple of decades.  
In my half-decade as a Bus Driver, Bus Users were only happy when I arrived and left on time and drove them to where they wanted to go quickly.  Bus Users didn't care if I was forced to drive while fatigued, or sick, or distracted or stressed: in fact, they never asked.  The mantra of London's Bus Users is clear: as long as their Bus is on time and gets them to the place where and when they want it, that's the only thing that matters.  And Safety? Look at the Bus Contract Incentives and TfL's published Bus Casualty Data: Safe Operating Conditions for London Bus Drivers are simply not on Bus Passengers', TfL's or Bus Operators' radar screen. It's always been "Go! Go! Go"! So why has the BBC never investigated TfL's Dangerous Bus Contract Incentives
After experiencing years of conditions getting worse for me as a London Bus Driver and then surviving the unique hell of Covid, my only meeting with TfL's Safety and Bus Bosses convinced me that—with bureaucrats like that in chargethings could only get worse.  And they have.  Fatigue, Stress, Poor Working Conditions, Lack of Toilet Dignity, Lack of Air Conditioning and Heat in Bus Cabs, Low Wages—just ask any honest London Bus Driver—everything's been getting worse.  For decades, it appears that Bus Drivers and Londoners are and have been—literally, dying—just so London's public buses don't inconvenience the "Mr. Mosses" of this city.  The Times has published a number of articles about the dangerous time-based incentives embedded into DPD Drivers' contracts: perhaps your next report might investigate TfL's
Please listen to my January 2021 Interview again: What has changed? 
During our January 2021 interview, you'll hear me say "it's miles over lives.  A lot of the time you feel that all TfL and the Operators want to do is keep the buses moving at whatever cost".  A few months after our anonymous interview, after 5 years as a proud London Bus Driver I decided to quit after I had a Teams Meeting on 10 June 2021 with TfL's Chief Safety Officer and TfL's Head of Bus Business organised by Keith Prince AM with help from volunteer Bus Safety Campaigner Tom Kearney. Frankly, after witnessing all the deaths and experiencing the sickness that resulted from TfL's, the Bus Operators' and Unite the Union's, in my view,—incompetence—during the Pandemicthat Teams Meeting confirmed to me how out-of-touch TfL's officers were about London Bus Drivers' dangerous working conditions. So, after that meeting I made up my mind to quit the Buses and go public in order to draw attention to TfL's "Institutionally Unsafe" contracted Bus Operation.  On that note: why has the BBC never investigated why TfL was handing out PPE to its own driver employees on the same day (9 April 2020) TfL was telling Unite the Union 'masks were not needed' for London Bus Drivers?  
I came to London Buses from a profession where I already had acquired extensive professional safety training: in fact, carrying out Risk Assessments was part of my previous job.  To be honest, even with what I saw on the Buses before Covid—e.g, Drivers falling asleep at the wheel, Engineers telling Bus Drivers to "carry on" after calling in while Hazard Lights were flashing and major systems were failing, being rushed while carrying out first-use checks by garage bosses, Bus Drivers being harassed or sacked because they complained about known-but-unresolved safety problems—the most unsafe experience I ever had as a London Bus Driver is when we started to get sick and die from Covid-19 in Spring 2020.   In January 2021, I told you "miles" were more important than "lives" on TfL Buses.  Since our last discussion, TfL's own published data reveals that Bus Mileage has decreased while total Bus Casualties have increased to a higher level than they were in 2016.  Will the BBC ever investigate why, after the announcement of Vision Zero and three 'world leading' Bus Safety Programmes since 1 February 2016, Bus Safety Performance in London has declined?
I hope you'll refer this note the next time you decide to publish a story about TfL Bus Performance.  Or better yet—it's been over three years—just give me call! You won't have to make me anonymous and at least you'll have interviewed one London Bus Driver.  For transparency, public interest and information for my fellow Bus Workers (including those driving on Route 18 whom I'm certain are enduring some extra pain as a result of your—in my experienced view—ill-informed BBC story), kindly note that I've already published this email as an Open Letter on Tom Kearney's blog.
Yours sincerely,

Kevin Mustafa
Former London Bus Driver, volunteer Bus Workers' Activist
26-Oct-23
By email and blogpost
 
Mr. Andy Burnham, Mayor of Greater Manchester
Greater Manchester Combined Authority
Tootal Buildings
56 Oxford Street
Manchester M1 6EU
E: the.mayor@greatermanchester-ca.gov.uk
 
Cc: Stephen Rhodes, Director of Bus, stephen.rhodes@tfgm.com; Martin Shier, Bus Network Performance Manager martin.shier@tfgm.com

26 October 2023 
Dear Mayor Burnham,
 
RE: When will Transport for Greater Manchester (TfGM) publish Bus Safety Performance Data? 
 
As a veteran Bus Driver and Vice Secretary of RMT's Nottinghamshire and Derbyshire Branch, I applaud your success in making Greater Manchester the first public bus operation to be brought under local council control using its powers granted under by the Bus Services Act 2017.  As someone who has long campaigned on for improving Working Conditions for Bus Drivers and Bus Safety, I am encouraged by the 'world class safety standards' that TfGM's Bee Network promises 'will be delivered across bus' under your leadership. 
 
Your historic achievement is obviously being closely watched (and applauded) by the UK Labour Party whose Shadow Transport Secretary Louise Haigh recently told the Guardian:  "Labour would offer all local areas the chance to franchise bus services, in a similar way to Transport for London, which would give them the power to set routes and fares and remove poor providers." 
 
However, imagine my surprise to read a recent Manchester Evening News headline "Shock after week of carnage on the buses as bosses share concern over 'unusually high number' of crashes" which described how two pedestrians had been killed in one week by Public Buses in Greater Manchester. In that same article, a quote from TfGM's Director of Bus Stephen Rhodes (copied) caught my eye—
 
"We are concerned by the unusually high number of incidents involving buses over recent days, which is far above what we might normally see on any given week".  
 
Your successful acquisition of "Transport for London" powers and the substance of Mr. Rhodes's public statement have inspired me to post this Open Letter today.
 
Inspired by London Businessman and Bus Crash Survivor Tom Kearney's keynote address to the 76th Annual RMT Union National Busworkers Conference ("Transparency, Accountability and Leadership can fix the UK's Poor Bus Safety Culture"), on 3 May 2019 I sent this Freedom of Information Request to Transport for Greater Manchester (TfGM):
"Since 2014, Transport for London (TfL) has published Bus Safety Incident Data on its website every quarter (https://tfl.gov.uk/corporate/publications-and- reports/bus-safety-data). The data publishes shows injuries by Bus Route, Operator and Borough supported by a dataset containing all this information made available for public scrutiny. Accordingly, I would like to make a Freedom of Information Request for Transport for Greater Manchester to provide me with a spreadsheet displaying the Bus Safety Incident Data for the period 1 January -30 March 2019 showing: 
 
1.     Date of Incident 2.     Bus Route3.     Local Name of Operator

4.     Operator Group Name (if applicable)

5.     Bus Garage/Depot

6.     Injury Description (Fatality, Serious/Minor Injury - Taken to Hospital, MinorTreated at Scene)7.     Victim's Sex

8.     Victim's Age

9.     Incident Event Type (Collision, Fall, Assault, other)

10.  Victim Category (Passenger, Pedestrian, Cyclists, 3rd Party Vehicle, Bus Driver, other)" 
 
The disappointing response I received five days later from TfGM stated:
 
"We do not hold any recorded information in relation to your request.  Since bus deregulation in 1986, bus services in Greater Manchester are run by commercial services and they do not share this information with TfGM.  Bus services in London were never affected by deregulation. TfL runs a franchising system which allows them to collate and publish this data." 
Since you now have the "TfL" powers and—at least as far as Greater Manchester's Bus Safety Performance is concerned—Mr. Rhodes obviously knows what a "normal" week looks like, when can the public expect to see the information I requested in May 2019 published at least every quarter on TfGM's Website? 
I look forward to your reply.
 
Yours sincerely,
 
 
Lee Odams
Vice secretary Nottinghamshire & Derbyshire Bus Branch and Secretary of RMT National Industrial Organising Conference of Busworkers

28-Sep-23

At a meeting of the London Assembly Transport Committee on 27 September 2023, Keith Prince AM asked TfL to 'come clean' about what decisions it took about a Safety Audit that TfL was finalising at the time Sandilands occurred to be (a) cancelled (b) kept from the RAIB Investigation and (c) removed from the public record.  

Here is my annotated informal transcript of Keith Prince's statement (a formal record of which will no doubt be published on the London Assembly site in due course)—

"From evidence TfL has provided through numerous Mayor's Questions and FOIs, when the Sandilands Tragedy occurred on 9 November 2019, these facts are known—

  • TfL was putting the final touches on Internal Audit 16767 ("Trams Management of Operational Risk") which had already concluded First Group "Adequately Controlled" Operational Risk on the Croydon Tram." 

  • "Hours after the crash, one of the Auditors sent an email to the Head of Audit which stated 
    • "As soon as I heard the news this morning my thoughts were, my audit is going to be more high profile"  
    • "Incidentally, the Derailment RA [Risk Assessment] was last reviewed on November 2013, so is one overdue for review"


  • "Despite being asked for this Audit twice by the RAIB Investigators (on 24 November 2016 and 24 January 2017), Internal Audit 16767 was never provided by TfL to the RAIB and IA 16767 is nowhere to be found in TfL's Audit and Assurance Committee Records." 

"In the evidence TfL's provided to the Assembly, I have possession of a completely blacked-out letter which I believe explains why TfL a) decided to not provide IA 16767 to the RAIB and b) remove IA 16767 from the public record." (NB: the Blacked-Out Correspondence relates to the 24 January 2017 Request for IA 16767 from the RAIB Investigator).  

"Since (a) TfL and First Group have already received the largest Health and Safety fine in history and (b) the Sandilands families may seek to overturn the Inquest Verdict of "Accidental Death" will TfL:
1) Publish the Contents of the Blacked-Out Letter that TfL released in its much-delayed response to Question 2019/17340?

2) Publish a link to the evidence TfL made available in its response to Question 2019/17340 on the GLA Mayor's Question Time Site? I know for a fact that this evidence has been published online by a concerned member of the public — why not publish the Question 2019/17340 evidence on the GLA site and stop giving the impression TfL's trying to hide something?"



"I am determined to lead the most transparent, engaged & accessible administration London has ever seen"

—Sadiq Khan, Mayor of London, 7 May 2016



13-Sep-23


"Transport for London leads the way on bus safety" exclaimed the headline of an Opinion piece penned by Tom Cunnington, TfL's Director of Bus Business Development that recently appeared in the news site and publication Route One ("Number One for Coach, Bus & Minibus"). While Tom Cunnington's PR placement highlighted all of TfL's good intentions surrounding its two decades-long 'roll-out' of Intelligent Speed Assistance (ISA) to its contracted Bus Fleet, when you think about, the TfL executive merely parrots the words TfL has been using for many years while conveniently forgetting that New York City did lots of the same stuff TfL claim as "a first" twenty-odd years ago. 

But let's not get bogged down in the details, there's plenty of time for that!

Though, before we start, let me introduce myself: I've had over thirty years experience in the bus industry, top-to-bottom, and while I will try not to befuddle you with tech and bus lingo, ask virtually any Bus Driver the same questions and—with only a few months in the industry—he or she will give you the same sort of feedback, if not with the same level of detail.

If there is anything that needs clarifying I will endeavour to help out, but I'll also try to keep this as simple as I possibly can. 

So without further ado, let's get going.

Let's look at Tom Cunnington's published remarks:

"We welcome the work on improving bus safety by Stagecoach East on the Cambridgeshire Guided Busway, but its use of the retarder with Intelligent Speed Assistance (ISA) in the UK is not a "first"."

Sounds impressive doesn't it? But how do you think this system works?

"Bus Safety" is the buzzword here—you'd imagine that using this would mean that buses were "safer" because "every journey matters"—but how exactly have buses been made "safer"? 

Because I do hope Tom Cunnington will explain how...

"Transport for London's Bus Safety Development team has been working with London Bus Operators, manufacturers, and suppliers like Actia for several years, and led the way with trials of the technology on urban buses."

Again, lots of big words designed to make you think that Safety's a huge priority! An entire team dedicated to bus safety development, working with operators, manufacturers and suppliers...for several years even!

Let's conveniently disregard the recent London Assembly discussion about the long-standing problem of Lack of Air Conditioning (A/C) in Bus Drivers' cabs—and how TfL will need to commission a complete redesign of the bus to make A/C work. Bus Drivers working in unsafe hot conditions in Bus Cabs has been an an issue since at least 2006 when TfL mandated that all buses must have Bus Cab A/C fitted to its contractors' vehicles.  Today A/C is fitted, it just doesn't work in most cases because TfL didn't insert the word 'working' next to 'installed' in its requirement!  We'll leave the long sad story of Bus Cab A/C for another thread, but please keep this in mind: the difference between TfL announcing that some new 'safety' technology will be 'installed' but not insisting—contractually—that the technology is actually 'working' suggests that TfL's ability to monitor implementation of 'safer' technologies like ISA (and A/C!) is compromised from the start. I do wonder if that systemic fault is intentional

But I digress...let's get back to the to the blog!

How many Bus Operators was Tom Cunnington talking about? Where do TfL and they have these "discussions"? Behind closed doors would be a good guess and certainly appears to be true.   

But when you realise that the ISA trials were done by Volvo on their buses, it doesn't sound as impressive does it?

"ISA formed part of our 2019 Bus Safety Standard, and has been mandatory on all new buses in London since then. Through a combination of retrofit and new, Stagecoach in London has over 500 buses fitted with Actia systems that limit the bus' speed through the retarder, with a further 1800 at the other London operators."

OK.  Let's assume the Mayor is correct and that a total of 3280 buses in TfL's total fleet (about 36% of the total) do have ISA fitted by now.  Let me tell you this fact though: this may reflect the situation on paper, but the reality is far from that.

Let's first take this "2019 Bus Safety Standard" (that, in fact, TfL announced in October 2018): one of the things it includes is a pedal camera in the Driver's footwell, because there were too many instances of 'pedal confusion'—again, on paper—that led to many crashes, some of them fatal. Nothing to do with runaway buses where there was a fault, oh no, the "blame the Driver for everything" mantra is strong here. 

Let's also look at that repeated word "retarder". The retarder is the electromagnet that's in the "gearbox" to help slow the bus down when the brakes are applied, to give a smoother braking feel to the passengers rather than to rely solely on the foundation brakes where you have the brakes working on their own. When the retarder fails, you can't use the bus as it takes so much more stopping that you can literally put your foot through the floor and it still doesn't stop. So the use of the word retarder here is not just incorrect, it's for something altogether completely different.

The actual method of the ISA is explained in his next paragraph, which, again, sounds great, but we'll take a closer look at it.

"This system uses a digital speed map which can be regularly updated as speed limits are changed, and because it does not rely on mapping the individual routes, it also works when the buses change garages, run out of service, and even on rail replacement."

The system TfL describes sounds wonderful, but dig a little deeper and it soon starts to fall apart.

  • The digital speed map is designed by the Bus Operator.
  • It is updated by the Bus Operator.
  • The limits are changed by the Bus Operator.
And guess who decides if the Bus Operator wants to turn ISA on or off? 

You guessed it! the Bus Operator.

You may be asking "But why would TfL fit such a system and then not use it as it is designed to be used?"

And here is the rub that neither Tom Cunnington nor TfL will be rushing to write to Route One about.

TfL pay to have the ISA system fitted and then let the Bus Operator run it. And as the recent Sandilands tram investigation showed us, this kind of "hands-off" contractual arrangement is—quite literally—'an accident waiting to happen'.

Imagine—if you will—the very basics of how TfL operates: TfL pay a Bus Operator a set sum of money to operate a bus service—based on contract targets such as service intervals, i.e., how often a bus is going to turn up.  These contracted time targets have historically meant that the same numbers of buses will run at the same frequency. 

But we already know that buses are running around faster than they should because the Drivers are late (or they need to use the facilities, or there are too many passengers, or someone has parked in a bus lane, or it's raining, or there's a Y in the day etc....).  So when 20mph speed limits are imposed across the board, the bus time tables don't change and the Drivers are expected to make those same bus journeys at the same frequency and—get this—at the same speed.  And if there is an accident—"e.g, the Driver was driving too fast to meet the contracted timetable, we have held a meeting and he's been sacked, that's the end of that" (assuming you ever find out this is what's happened because, as we all know, these meetings are held behind closed doors and not independently reviewed or scrutinised, so anything could happen and it all gets brushed under the carpet and the public knows nothing).

Now imagine TfL's limited the buses' speed, and—all of a sudden—those contracted buses can't get to where they need to go in time and the Bus Drivers can't make any of that time up by speeding because ISA means they can't:  TfL will have to add more buses to the system—which costs money. So it would appear that TfL are more than happy to turn a blind eye to the ISA systems not being switched on by the Bus Operators: it's a win-win...except for Safety, of course.

And because there is no one there from TfL to monitor if the technology is actually 'working', TfL does nothing when Bus Operators disable ISA—so their Bus Drivers can speed to meet TfL's contracted Timeliness and Availability targets.

Officially though, TfL have now incorporated speed checking into the ticket machine since TfL went "module-less" a few years ago, so much so that TfL has the capacity to identify every single Bus that's broken the speed limit—by Operator, by Depot, by Route, by Bus and even by the Driver. Moreover, TfL now sells access to this Speed Data to the Bus Operators, with the knowledge that the Bus Operators are required to show at least 3 months of continuous late running before TfL will consider altering any contract's route timings. And despite seeing all that evidence of unsafe speeding by Bus Drivers who are incentivised by TfL to meet the route timings embedded in these contracts, TfL may still decide it doesn't want to adjust those contracted route timings to reflect reality/improve safety. 

So you got this, right? 

  • The Bus Driver speeds to make up time and keep to the Bus Operators' contracted Timeliness and Availability targets;  
  • Despite the obvious disconnect between the contracted targets and the reality of driving conditions the route, TfL doesn't change the route timing;
  • if the Driver has an accident, the Bus Operator disciplines the Driver for speeding;
  • Bus accidents 'happen', people are killed and seriously-injured, Bus Drivers are disciplined (or fired).....and nothing changes.
Welcome to "Vision Zero" on the Buses!
Meanwhile, Tom Cunnington prattles on:

"We have also introduced ISA that stops the bus from accelerating beyond the speed limit on 1150 Euro VI Volvo hybrid buses, using the less agile route-based mapping and geofencing for each route the buses will travel on - as described by Paul Halford."

Remember a little way back when TfL were citing the Bus Safety Standard it introduced in October 2018?

Well, even before that, there's a set limit to how fast buses can accelerate from a standing start, and it's been getting lower and lower over the years.

This is fine from a passenger safety point of view—no one wants granny to fall over and break her hip—but it's not at all helpful when you are crawling along in traffic, pulling out at a roundabout, pulling away from the lights—ie., all the things a Bus Driver needs to do during the course of a normal working day behind the wheel. 

And from a Bus Driver's perspective, it's a stress-inducing madness—

  • you lose more time than you would (time that you can't afford to lose because you'll be dropping back later and later)
  • the newer bus in front of you, which is even slower (but 'safer'), is also running late, and backing up the route—
  • and then the iBus Controller is on every Bus Driver's case complaining to each how they're ruining the service.

Can you see how the "real life" experience of a London Bus Driver is so far removed from the computer-generated perfect world of sound bites and "look at how great we are!" propaganda proffered to the public from TfL's  'higher-uppers' like Tom Cunnington?

That's before you discover that Volvo set up the ISA system in, I think, 2016 and it took years for that tech to be incorporated into the other types of buses.

I could complicate things by explaining how wide a variety of vehicles are deployed by Contractors on the London Bus Fleet. I could confuse you even further by explaining how the mechanicals of the bus can be made by one manufacturer and the body by another—this is why there was no standard Covid Screen 'protection' that TfL claimed was fitted: some companies used sellotape, while others used shower screens!  Here again, the difference between 'installed' and 'working' probably made a huge difference to human lives and livelihoods.

As you can see, there's a 'reality gap' that separates Mr. Cunnington's few simple 'pats-on-the-back' paragraphs from what ISA really means for London's Bus Drivers and the public. 

I could have expanded this Guest Blog to tens times the length, so, please bear with me while I continue to expose how far out of touch TfL and its Bus Operators remain with those of us here working on the coal face every day.

Stay safe.  See you soon!

—Bus Driver V0


19-Aug-23

From: Members Correspondence <MembersCorrespondence@tfl.gov.uk>

Sent: Thursday, July 27, 2023 1:01:52 PM
To: Members Correspondence <MembersCorrespondence@tfl.gov.uk>
Subject: Update from Transport for London  

Good afternoon

 

I'm writing to let you know that the sentencing hearing of TfL and Tram Operations Limited (TOL) by the Office of Rail and Road (ORR) concluded today in connection with the 2016 Sandilands tragedy. The ORR prosecuted TfL and TOL for an offence under the Health and Safety at Work, etc Act 1974. TfL and TOL pleaded guilty at the earliest opportunity. TfL and TOL were ordered to pay fines. 

 

TfL Commissioner, Andy Lord, Lilli Matson, Chief Safety Health and Environment Officer, Glynn Barton, Chief Operating Officer and Mark Davis, General Manager for London Trams were present throughout the three day hearing and were deeply moved and saddened hearing the devastating impact of the tragedy on those who were injured and the families of those who lost their lives. 

 

On behalf of TfL we apologise for this tragedy and for the pain, distress and suffering that all those affected have endured and continue to endure. None of us can begin to appreciate the enormity of the loss suffered by the families and friends of Dane Chinnery, Donald Collett, Robert Huxley, Philip Logan, Dorota Rynkiewicz, Philip Seary and Mark Smith or the impact on the lives of the many who suffered injury. Every passenger on the tram that morning entrusted their safety to us but we failed them and for that we are truly sorry. We remain committed to providing support to anyone who needs it.

 

We accepted responsibility promptly and we did everything possible to ensure the right support was quickly in place to help all those affected. Since 2016, we have delivered an extensive programme of major industry-leading safety improvements to the tram network. We have worked closely with the independent Rail Accident Investigation Branch (RAIB) and the ORR to introduce a new safety regime and implement all measures that were applicable to our tram network. Alongside TOL, we have been at the forefront of implementing innovative technology on the Croydon tram network to address the RAIB's recommendations and to improve safety for customers and staff. This includes implementing speed restrictions, additional signage for drivers, measures to improve visibility, measures to combat driver fatigue and distraction, an automated braking system, and improved emergency evacuation procedures and risk assessments.  

 

We continually review our network and work with the wider tram industry to ensure we are running the safest possible service for our customers - and to ensure that such a tragedy can never happen again. 

 

Kind regards

Kirsten

 

Kirsten

Government Relations

Transport for London

 
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