NSW Parliamentary Inquiry into driver education, training and road safety

CPSA welcomes the opportunity to comment on the NSW Parliamentary Committee on Community Services inquiry into access to transport for seniors and disadvantaged people in rural and regional NSW.

Introduction

Despite data stretching back ten years saying otherwise, in 2016 the then NSW Roads Minister and the current NSW Police Assistant-Commissioner in charge of road traffic claimed that the risk of serious injury and death for older drivers is increasing. The truth is that the number of people over seventy in NSW is growing steadily, but that in proportion to that growth serious crash injuries have flatlined while road deaths are trending down.

The entirely fictional increasing risk of serious injury and death among older drivers is used as an argument in the defence of older driver road testing. NSW is the only jurisdiction in Australia where older drivers must periodically submit to a road test and risk losing their licence. In fact, NSW and the state of Illinois (USA) are the only jurisdictions left in the developed world where road testing of older drivers is still practised, despite overwhelming academic evidence that it does nothing for road safety.

a) Trends in road safety research and crash statistics

In January 2016, the Daily Telegraph ran a story in which both the NSW Police Assistant-Commissioner for Road Traffic John Hartley and the then NSW Roads Minister Duncan Gay exhorted older drivers to review their need to drive. Both based themselves loosely on published statistics and appeared to define 'older driver' as someone over 70 (John Hartley) or over 65 (Duncan Gay) [1].

The Road Traffic Casualty Crashes in New South Wales - Statistical Statement for the year ended 31 December 2015 published by Transport for NSW' Centre for Road Traffic presents information on the basis of which some might draw the conclusion that the trend for serious injuries among older drivers is steadily up [2]. While the final column (below) showing the total serious injuries among road users aged 70 and over, is not part of the Statement, the calculation is a simple and obvious one.

 

Year

Serious injuries 70-79

Serious Injuries 80+

Serious Injuries All Ages

% of Serious Injuries 70+

2005

566

444

11767

8.6%

2006

600

465

12459

8.5%

2007

648

500

11750

9.8%

2008

606

496

11372

9.7%

2009

570

534

11402

9.7%

2010

644

539

11449

10.3%

2011

666

558

11671

10.5%

2012

686

591

12252

10.4%

2013

714

655

12666

10.8%

2014

783

654

12420

11.6%

2015

773

642

12121

11.7%

 

As the table above shows, serious casualties among road users as a proportion of the total number of casualties were 8.6 per cent in 2005 increasing to 11.7 per cent in 2015, a significant increase.

However, viewing these numbers in the perspective of NSW population data, a different picture emerges. As the table below shows, the proportion of serious injuries among those aged 70-and-over of the over-70s population cohort in any given year has been roughly the same over ten years.

 

Year

NSW population 70+

Serious Injuries 70+

% of Serious Injuries 70+

2005

644446

1010

0.16%

2006

652509

1065

0.16%

2007

667718

1148

0.17%

2008

681214

1102

0.16%

2009

695768

1104

0.16%

2010

713412

1183

0.17%

2011

731555

1224

0.17%

2012

749036

1277

0.17%

2013

768653

1369

0.18%

2014

793558

1437

0.18%

2015

818194

1415

0.17%

 

In fact, the injury rate calculated in this way is roughly the same as for those aged 70-and-under, as the table below shows.

 

Year

NSW population UNDER

70

Serious Injuries UNDER 70

% of Serious Injuries UNDER 70

2005

6129754

10757

0.18%

2006

6163591

11394

0.18%

2007

6220282

10602

0.17%

2008

6333686

10270

0.16%

2009

6438632

10298

0.16%

2010

6431588

10266

0.16%

2011

6479945

10447

0.16%

2012

6558064

10975

0.17%

2013

6640747

11297

0.17%

2014

6719842

10983

0.16%

2015

6802006

10706

0.16%

 

A similar picture emerges when road deaths are examined (see table below). After 2005, the 16.3 per cent rate of road deaths among over-70s over all-ages road deaths appears to be seesawing before rising strongly in 2014 to 19.5 per cent. However, when road deaths for the over-70s are calculated as a percentage of the NSW population aged 70 and over, it becomes apparent that road deaths in this age group have been in a pronounced downtrend for a decade.

 

Year

Road deaths OVER 70

Road Deaths ALL AGES

OVER 70 Road deaths as % of ALL AGES Road deaths

NSW population OVER 70

OVER 70 Road deaths as % of OVER 70 NSW Population

2005

83

508

16.3%

644446

0.013%

2006

64

496

12.9%

652509

0.010%

2007

76

435

17.5%

667718

0.011%

2008

59

374

15.8%

681214

0.009%

2009

63

453

13.9%

695768

0.009%

2010

61

405

15.1%

713412

0.009%

2011

62

364

17.0%

731555

0.008%

2012

64

369

17.3%

749036

0.009%

2013

54

333

16.2%

768653

0.007%

2014

60

307

19.5%

793558

0.008%

 

Clearly, declaring that older drivers are inherently unsafe drivers is no different from declaring that women drivers are unsafe. It is blatantly discriminatory.

  • Recommendation 1: That the NSW Government acknowledges that long term the proportion of crashes and road deaths involving older drivers is no cause for alarm.

 

c)    The needs of any particular driver groups

Older drivers are needlessly discriminated against through mandatory on-road tests. As regional residents are largely car-dependent due to a shortage of alternative transport options, NSW’s older driver licensing system constitutes a significant barrier to accessing transport. This system must be dismantled. NSW is one of the few jurisdictions worldwide that has a mandatory test for older drivers.  A practical driving test must be undertaken every two years from 85 onwards in order to retain an unrestricted license, with annual medical testing beginning from the age of 75. If a practical driving test is not undertaken a restricted or modified license is issued in which older NSW drivers are confined to driving within their local area. This typically imposes a 10 kilometre radius restriction from the driver’s home. However, there is little to no evidence that more restrictive licensing policies have any impact on older driver crash involvement or casualty outcomes[4]. Following formal reviews, Queensland, Tasmania, Victoria and Western Australia have dismantled age-based licence restrictions, recognising that older drivers do not pose a major road safety threat and that compulsory testing does not improve road safety.

NSW’s older driver licensing system is inherently contradictory. Medical testing from age 75 assumes that a medical diagnosis will detect unacceptable loss of driving ability, but that from age 85, when typically a person’s health is less than when they were 75, the medical diagnosis apparently loses some of its power and needs to be supplemented with a road test. This is clearly not logical. The kindest interpretation of this policy is that the road test serves as a proxy medical test for cognitive disease, notably dementia. This approach appears to be testimony to the undying and deeply seated prejudice held by the NSW licensing authority and NSW Police that people over 85 have no business driving cars.

The NSW Government justifies retaining the older driver licencing system on the basis that older people are disproportionately represented in crash statistics. However, this is a shallow interpretation of crash statistics, which does not account for the role of frailty bias and, as noted above, for the increase in the number of people over 70 living in NSW. Langford and Koppel state ‘older adults’ biomechanical tolerances to injury are lower than those of younger persons […], primarily due to reductions in bone strength and fracture tolerance’. This means that age-related frailty increases the chance of serious injury or death following a car accident.

Older drivers tend to drive less annual kilometres compared with other age groups as they increasingly self-regulate[7]. Self-regulation involves the gradual reduction in driving distances, limiting driving at night, sticking to familiar routes and driving more slowly. Further, international research has shown that older driver crash involvement is primarily restricted to certain subgroups of older people (those with dementia, epilepsy or insulin treated diabetes, for example) rather than encompassing all older drivers[8]. This evidence suggests that health/medical-based assessments of driving capacity are likely to be more effective in reducing accidents than age-based assessments, as a person’s health has a more tangible and direct impact on their driving skills.

With the proportion of the population over the age of 85 being projected to increase by 60% between 2010 and 2030, the number of older drivers is growing significantly. Thanks in large part to developments in medical science and public health policy, this new generation of older drivers is healthier, more active and more mobile than previous generations. Nonetheless, NSW’s changing demography will have a significant effect on the cost of administering the older driver licensing system, which is yet to be proven effective. Accordingly, CPSA calls on the NSW Government to immediately dismantle this unfair and ineffective system.

It should also be noted that the NSW driver licensing authority has two mechanisms at its disposal to temporarily or permanently revoke a person’s driver licence regardless of age. The first mechanism is based on the authority being notified by a qualified medical professional of a person’s unfitness to drive due to a proscribed medical condition, including cognitive disease. The second mechanism is based on demerit points.

Finally, driver licence revocation is a deeply traumatic experience for older drivers and is associated with a loss of independence and a diminished sense of identity[9]. As a result, the OECD has strongly recommended against age-based mandatory assessment programs such as that used in NSW citing that these programs have no demonstrable road safety benefits and contribute directly to a range of mobility, public health, and economic disadvantages[10].

  • Recommendation 2: That the NSW Government dismantle the older driver licensing system in line with international and national evidence showing it produces no improvements in road safety in general or specifically for older drivers.
 
e) The needs of metropolitan, rural and regional drivers

In 2015 CPSA surveyed members about their transport habits, with 59% of respondents living in a rural area or a major regional town and 72% reporting the Age Pension as their primary source of income[11]. 71% of respondents indicated that they would like to use more public transport, but cited significant physical barriers to doing so, including the accessibility of stations and public infrastructure surrounding stations plus the infrequency of services and timetable coordination. The Transport for NSW Disability Action Plan 2012-2017 indicates that in 2012, around 40% of TrainLink stations were wheelchair accessible, with a further 45% of stations providing assisted access[12]. However, it is difficult to find more detailed station-specific information. The accessibility of rural and regional bus stops is harder to gauge as proper accessibility depends on road and kerbside treatments, which come under the jurisdiction of local councils. Not only do accessible public transport stations support people with disability to use public transport, but also older people with mobility difficulties, parents with prams, and people with luggage or shopping bags. It is critical that public transport users are able to access information about the accessibility of public transport infrastructure so that they can plan their journeys.

People living in regional areas are significantly more reliant on private car-based transport than their metropolitan counterparts due to a lack of alternatives in the form of public or community transport. At the same time, roads in regional NSW tend to vary in quality with a greater prevalence of unsealed and dirt roads, as well as hazardous roads and roadsides. Regional NSW residents are more likely to have to drive long distances, which increases the risk of driver fatigue. As a result, people living outside major cities are twice as likely to experience a serious road-related injury compared to city-dwellers[13]. Regional residents are at least three times more likely to die as the result of a transport accident[14]. On top of this, low income regional residents are more likely to be driving an older model car and less likely to prioritise repairs and maintenance, further increasing their risk of an accident[15].

The significantly higher prevalence of injury and death on regional roads warrants immediate intervention from the NSW Government. In 2010, the Australian Rural Roads Group made a number of recommendations for cost-effective investments in rural road infrastructure that have been proven to improve safety outcomes for regional drivers:

  • ‘Treatments for roadside hazards in rural settings have been found to reduce pole and other fixed roadside casualty crashes by 68%
  • ‘Clearer road markings (which ‘channel’ vehicles safely at rural intersections) have been found to reduce casualty crash frequency by 36%
  • ‘Crash rates can be reduced by 20% for every one metre increase in bitumen seal width (‘shoulder sealing’) of an existing road
  • ‘Roundabouts at rural intersections can reduce casualty crash risks at intersections by 70-80%; when such crashes occur, the roundabout reduces the cost of accidents by around 90%.'[16]

As regional drivers rely on private car-based transport, CPSA welcomes the NSW Government’s 2016-17 Budget allocation of $50 million towards the Fixing Country Roads project and allocations for upgrades to major regional highways. CPSA calls on the NSW Government to continue this work through the allocation of funding in upcoming budgets.

  • Recommendation 3: That the NSW Government allocates significant funding to improve the safety and drivability of roads in regional NSW.

 

h) Experience of other jurisdictions, and interstate cross-border issues

Periodic road testing of older drivers is a rarity in the developed world. In the USA, the state of Illinois is the only state that still road tests seniors. Japan, Korea, Canada and Western-European countries (including the UK) do not road-test on the basis of age.

In Australia, all states and territories except New South Wales have accepted the evidence that the road testing (and licence cancellation upon failing the test) of seniors has no positive or negative effect on road safety.

 

References

[1] http://www.dailytelegraph.com.au/news/nsw/top-traffic-cop-urges-seniors-to-get-off-the-roads/news-story/5f0fec7239a965732b612aea76f9fd8f

[2] Table 2: Serious [crash] injuries (all hospitalisations), year, age

[3] Population data sourced from:  3101.0 - Australian Demographic Statistics, June 2016, Australian Bureau of Statistics.

[4] Please see: Koppel, S. (2013) ‘Effectiveness of age-based mandatory licensing assessments in reducing older driver crash risk’ Available: http://www.abc.net.au/cm/lb/5137342/data/effectiveness-of-age-based-mandatory-licensing-assessments-in-r-data.pdf

[5] O’Rourke, J. ‘Top traffic cop urges seniors to get off the roads’ The Daily Telegraph [Sydney] 6 January 2016. Available: http://www.dailytelegraph.com.au/news/nsw/top-traffic-cop-urges-seniors-to-get-off-the-roads/news-story/5f0fec7239a965732b612aea76f9fd8f [Accessed 21/07/2016]

[6] P358: Langford, J. Koppel, S. (2006) ‘The case for and against mandatory age-based assessment of older drivers’ Transportation Research Part F: Traffic Psychology and Behaviour,  9(5), pp353-362

[7]Molnar, L. Eby, D. (2006) ‘The Relationship between Self-Regulation and Driving-Related Abilities in Older Drivers: An Exploratory Study’ Traffic Injury Prevention, 9(4), pp314-319

Wong, I (2014) ‘Sustaining safety and mobility amongst older adults: The Multilevel Older Person’s Transportation and Road Safety Model’ PhD thesis. Available: https://eprints.qut.edu.au/70007/ [accessed 6 July 2016]

[8] Howell 1997 ‘Forward, perspectives and prospectives’ in Handbook of the human factors and the older adult pp. 1-6, San Diego; Janke1994 Age-related disabilities that may impair driving and their assessment: Literature Review, Sacramento

[9] Whitehead, B. Howie, L. Lovell, R. (2006) ‘Older people’s experience of driver license cancellation: a phenomenological study’. Australian Occupational Therapy Journal, 53(3), pp173-180

[10] OECD (2001) ‘Ageing and Transport: Mobility Needs and Safety Issues’. Available at http://www.oecd-ilibrary.org/transport/ageing-and-transport_9789264195851-en [accessed 11/07/2016]

[11] CPSA (2015) ‘Transport Survey 2015’ Available: http://www.cpsa.org.au/files/Transport_Survey_2015.pdf

[12] Transport for NSW ‘Disability Action Plan 2012-2017’ Available: http://www.transport.nsw.gov.au/content/transport-nsw-disability-action-plan-2012-2017 [accessed 15 July 2016]

[13] P24: Henley, G. Harrison, J. (2012) ‘Trends in serious injury due to land transport accidents, Australia 2000-01 to 2008-09’ Injury research and statistics series no. 66. Cat. No. INJCAT 142. Canberra: AIHW. Available: http://www.aihw.gov.au/WorkArea/DownloadAsset.aspx?id=10737421990

[14] ABS (2011) ‘Health outside major cities’ Catalogue number 4102.0. Available:  http://www.abs.gov.au/AUSSTATS/abs@.nsf/Lookup/4102.0Main+Features30Mar+2011

[15] National Rural Health Alliance (2015) ‘Submission to the Rural and Regional Affairs and Transport References Committee Inquiry into Aspects of Road Safety in Australia’ Available: http://www.ruralhealth.org.au/document/submission-rural-and-regional-affairs-and-transport-references-committee-inquiry-aspects

[16] P16: Australian Rural Roads Group (2010) ‘Going Nowhere: the rural local road crisis, its national significance and proposed reforms’ Prepared by Juturna Consulting on behalf of Australian Rural Roads Group. Available: http://infrastructureaustralia.gov.au/policy-publications/publications/files/Australian_Rural_Roads_Group_Report.pdf