Request ID: FOI-4783-2324 Date published: 26 April 2024
You asked
Dear Transport for London,
1 -
The Traffic Signs Manual - CHAPTER 3 Regulatory Signs – published in 2019 sets out the requirements made of highway authorities when imposing traffic regulations in terms of signs required.
Does TFL have a policy of compliance with this official government document?
Please provide a copy of that policy statement, and how it is to be implemented.
2 -
Paragraph 8.10.3 of the Manual states:
“Speed enforcement should be highly visible, with drivers made fully aware of the presence of cameras and of the prevailing speed limit. The camera and speed limit signs should always be clearly visible to drivers, and not obscured by other street furniture or vegetation. The minimum clear visibility distance for the signs should be at least that shown in Table 8-4. Speed limit repeaters and camera signs should be co‑located where permitted and practicable. For fixed cameras, the speed limit and camera signs should normally be visible to the driver in the same view as the camera. This might require speed limit repeater signs to be spaced at different intervals to those recommended in Table 8-4 where the signs would not otherwise coincide with camera locations.”
Did TFL have regard to this paragraph when installing its average speed camera enforcement along the A20 eastbound from the flyover above the A224 roundabout?
Please document how this was done.
Does this camera installation, being the start of the average speed check enforcement, comply with the Manual?
Where s the 40mph repeater, with the Average speed check sign?
http://pjm2.net/QXAD.NET_220914/TRAFFIC_240101/A20-NORTH%20OF%20BYPASS%20-%20SPEED%20CAMERA%20%231%20-%20240322.jpg
Does this camera installation, being the end of the average speed check enforcement, comply with the Manual?
http://pjm2.net/QXAD.NET_220914/TRAFFIC_240101/A20-NORTH%20OF%20BYPASS%20-%20SPEED%20CAMERA%20%232%20-%20240322.jpg
What steps did TFL take, post installation, before commencing operation, to ensure these two camera poles met the requirements of the Manual?
3 -
Paragraph 8.10.1 of the Manual states:
“Signs prescribed by the Regulations for indicating speed cameras are diagrams 878, 880 and 880.1 (S11‑2‑63, 64 and 65 respectively, see Figures 8-16, 8-17 and 8-18). The sign to diagram 878, with the legend “Speed cameras”, is used to indicate the boundary of an area where camera enforcement is taking place. When placed within such an area to act as a reminder to drivers that cameras are being used, the legend may be omitted, with the sign often co‑located with a speed limit repeater sign (see Figure 8-19). Where camera enforcement utilises two or more cameras to measure the average speed of a vehicle over a set distance, the legend on diagram 878 is varied to “Average speed check”.”
8.10.3: “a repeater sign to diagram 670 may be co-located with the camera sign to diagram 878 without any legend as shown in Figure 8-19, especially on the approach to an enforcement camera.”
What steps did TFL take to ensure that signs to diagram 878 varied to “Average speed check” were co-located with 40mph speed limit repeaters, for example as per diagram 8.19, “especially on the approach to an enforcement camera”?
4 –
At the southbound exit to the A20 from the A224 roundabout there is a sign saying: “Speed reduction due to skid risk” – see photo.
The road surface along the A20 from the point to beyond the BP petrol station is in good condition.
What “skid risk” does this sign relate to, and how would any driver be able to understand this?
What steps were taken to indicate where to expect to find this “skid risk” – for example by placing a suitable sign where significant flooding has been observed.
What does “Speed reduction” mean – does it mean “Speed limit reduced to 40mph” – if so, why does it not say that – which would be far more meaningful and informative?
Was a similar sign placed on the flyover to inform faster-moving traffic - please explain?
http://pjm2.net/QXAD.NET_220914/TRAFFIC_240101/A20_A224_A223%20-%20A20%20SOUTHBOUND%20EXIT%20SLIP%20-%2020240320_103546.jpg
5 -
Paragraph 8.3.1 states “to ensure that drivers are fully aware of the speed limit in force it is recommended that repeater signs are provided at the intervals shown in Table 8-4”.
Paragraph 8.3.4 states:
“Sizes, recommended maximum spacing and minimum clear visibility distances (CVD) for repeater signs are shown in Table 8-4. Repeater signs should normally be staggered on alternate sides of a single carriageway road, or on alternate sides of each carriageway of a dual carriageway road. However, where site constraints preclude this, adjacent signs may be placed on the same side of the road.”
Did TFL have regard to this paragraph when installing its reduced 40mph-speed limit along the A20 eastbound from the flyover above the A224 roundabout?
What checks were made to ensure repeaters were installed as per the Manual?
Please document how this was done.
6 –
For a 40mph limit, the first repeater should be no more than 250m from the start of the limit.
Subsequent repeaters should be no more than 350m from the previous one.
They should all be clearly visible for at least 40m.
As the A20 is dual carriageway here, the repeaters should alternate between the side and central reservation.
What steps did TFL take to ensure this was complied with?
Please provide a plan showing where each 40mph sign and repeater are located, with the distances apart, and explain any failure to comply with the Manual.
7 -
This warning sign is placed a short distance before the end of the new 40mph speed limit.
What was the reasoning that led to it being placed here, where it is too late to do any good, rather than placing it before the first speed enforcement camera, where it would assist drivers to be aware of the change, and avoid being caught speeding?
Where is the speed camera warning sign co-located with the 40mph repeater on the second speed camera pole?
http://pjm2.net/QXAD.NET_220914/TRAFFIC_240101/A20_TFL_40MPH%20-%20NEW%20LIMIT%20WARNING%20SIGN%20-%20240322.jpg
8 –
Why is there a sign saying REDUCE SPEED NOW” alongside the main carriageway approaching the BP petrol station offslip?
There is no reason for traffic going ahead to slow down here.
http://pjm2.net/QXAD.NET_220914/TRAFFIC_240101/A20_TFL_40MPH%20-%20REDUCE%20SPEED%20WARNING%20SIGN%20-%20240323.jpg
9 –
TFL claim that safety is a top priority.
Why is there the word SLOW painted on the BP petrol station offslip right at the entry to the station – see photo for Qu 7?
This is much too late to be of any use.
Why is the word SLOW not painted on the BP petrol station offslip at two suitable locations in the photo below, so as to warn drivers of the need to slow to near walking speed at the end of the straight in view?
Why no chevron bend sign above the crash barrier?
http://pjm2.net/QXAD.NET_220914/TRAFFIC_240101/A20_TFL_40MPH%20-%20BP%20OFFSLIKP%20-%20NO%20SLOW%20SIGNS%20-%20Clipboard-2-240325.jpg
Since any risk of flooding has passed by the area shown in the photo, why does the 40mph speed limit not end at the grass at the end of the chevrons on the road?
10 –
The photo shows extensive intrusion of vegetation into the sight lines beside the road, and even creates a risk to passing vehicles including anyone on bike
What process does TFL employ to ensure that intruding vegetation does not create risk to road users, as here?
Please provide a dated and timed copy of the two most recent inspection reports that addressed this issue at this location.
http://pjm2.net/QXAD.NET_220914/TRAFFIC_240101/A20_TFL_40MPH%20-%20OBSTRUCTIVE%20VEGETATION%20-%2020240320_111040.jpg
We answered
TfL Ref: EIR-4783-2324
Thank you for your request received by Transport for London (TfL) on 25th March 2024 asking for information about the speed limit on the A20.
Your request has been considered in accordance with the requirements of the Environmental Information Regulations (EIR) and our information access policy.
Please note that TfL has answered a number of previous requests about this issue, the answers to which can all be found on our website here:
In regard to your specific requests, I can confirm that we hold some of the information you require. Your questions are answered in turn below:
1 - The Traffic Signs Manual - CHAPTER 3 Regulatory Signs – published in 2019 sets out the requirements made of highway authorities when imposing traffic regulations in terms of signs required.
Does TFL have a policy of compliance with this official government document? Please provide a copy of that policy statement, and how it is to be implemented.
Answer: The Traffic Signs Manual (the Manual) offers advice to traffic authorities and their contractors, designers and managing agents in the United Kingdom, on the use of traffic signs and road markings on the highway network. Mandatory requirements are set out in the Traffic Signs Regulations and General Directions 2016 (as amended) (TSRGD). Whilst the Manual can assist with complying with the mandatory requirements, it cannot provide a definitive legal interpretation, nor can it override them. This remains the prerogative of the courts or parking adjudicators in relation to the appearance and use of specific traffic signs, road markings etc. at specific locations. While TfL has no official policy, we endeavour to comply with the TSRGD regulations. The advice is given to assist authorities in the discharge of their duties under section 122 of the Road Traffic Regulation Act 1984 and Part 2 of the Traffic Management Act 2004. Subject to compliance with the Directions, which are mandatory, it is for traffic authorities (including TfL) to determine what signing is necessary to meet those duties.
2 - Paragraph 8.10.3 of the Manual states:
“Speed enforcement should be highly visible, with drivers made fully aware of the presence of cameras and of the prevailing speed limit. The camera and speed limit signs should always be clearly visible to drivers, and not obscured by other street furniture or vegetation. The minimum clear visibility distance for the signs should be at least that shown in Table 8-4. Speed limit repeaters and camera signs should be co‑located where permitted and practicable. For fixed cameras, the speed limit and camera signs should normally be visible to the driver in the same view as the camera. This might require speed limit repeater signs to be spaced at different intervals to those recommended in Table 8-4 where the signs would not otherwise coincide with camera locations.”
Did TFL have regard to this paragraph when installing its average speed camera enforcement along the A20 eastbound from the flyover above the A224 roundabout? Please document how this was done.
Answer: The signage design referred to Traffic Signs Manual guidance and this design was forwarded to the Metropolitan Police to confirm their acceptance in terms of enforceability.
Does this camera installation, being the start of the average speed check enforcement, comply with the Manual?
Answer: Yes, it does comply with Traffic Signs Manual guidance.
Where s the 40mph repeater, with the Average speed check sign?
Answer: There are signs to TSRGD diag. no. 879 installed prior to the entry camera post and there are multiple speed repeaters along the monitored stretch. The co-location of repeater signs with the average Speed Check sign is not a requirement.
What steps did TFL take, post installation, before commencing operation, to ensure these two camera poles met the requirements of the Manual?
Answer: The Metropolitan Police attended site prior to enforcement operation.
3 - Paragraph 8.10.1 of the Manual states:
“Signs prescribed by the Regulations for indicating speed cameras are diagrams 878, 880 and 880.1 (S11‑2‑63, 64 and 65 respectively, see Figures 8-16, 8-17 and 8-18). The sign to diagram 878, with the legend “Speed cameras”, is used to indicate the boundary of an area where camera enforcement is taking place. When placed within such an area to act as a reminder to drivers that cameras are being used, the legend may be omitted, with the sign often co‑located with a speed limit repeater sign (see Figure 8-19). Where camera enforcement utilises two or more cameras to measure the average speed of a vehicle over a set distance, the legend on diagram 878 is varied to “Average speed check”.”
8.10.3: “a repeater sign to diagram 670 may be co-located with the camera sign to diagram 878 without any legend as shown in Figure 8-19, especially on the approach to an enforcement camera.”
What steps did TFL take to ensure that signs to diagram 878 varied to “Average speed check” were co-located with 40mph speed limit repeaters, for example as per diagram 8.19, “especially on the approach to an enforcement camera”?
Answer: There are signs to TSRGD diag. no. 879 installed prior to the entry camera post and there are multiple speed repeaters along the monitored stretch. The co-location of repeater signs with the average Speed Check sign is not a requirement.
4 – At the southbound exit to the A20 from the A224 roundabout there is a sign saying: “Speed reduction due to skid risk” – see photo.
The road surface along the A20 from the point to beyond the BP petrol station is in good condition. What “skid risk” does this sign relate to, and how would any driver be able to understand this? What steps were taken to indicate where to expect to find this “skid risk” – for example by placing a suitable sign where significant flooding has been observed. What does “Speed reduction” mean – does it mean “Speed limit reduced to 40mph” – if so, why does it not say that – which would be far more meaningful and informative? Was a similar sign placed on the flyover to inform faster-moving traffic - please explain?
Answer: The speed limit was reduced in response to a number of incidents caused by ongoing flooding issues that have caused vehicles to skid and lose control (see document attached). The signs were provided to convey temporary information to explain to road users why the speed limit had been reduced. The signs were provided at the entry points to the reduced speed limit to highlight the change to road users.
5 - Paragraph 8.3.1 states “to ensure that drivers are fully aware of the speed limit in force it is recommended that repeater signs are provided at the intervals shown in Table 8-4”.
Paragraph 8.3.4 states: “Sizes, recommended maximum spacing and minimum clear visibility distances (CVD) for repeater signs are shown in Table 8-4. Repeater signs should normally be staggered on alternate sides of a single carriageway road, or on alternate sides of each carriageway of a dual carriageway road. However, where site constraints preclude this, adjacent signs may be placed on the same side of the road.”
Did TFL have regard to this paragraph when installing its reduced 40mph-speed limit along the A20 eastbound from the flyover above the A224 roundabout?
Answer: Yes.
What checks were made to ensure repeaters were installed as per the Manual? Please document how this was done.
Answer: The signage design referred to Traffic Signs Manual guidance and this design was forwarded to the Metropolitan Police to confirm their acceptance.
6 – For a 40mph limit, the first repeater should be no more than 250m from the start of the limit. Subsequent repeaters should be no more than 350m from the previous one. They should all be clearly visible for at least 40m. As the A20 is dual carriageway here, the repeaters should alternate between the side and central reservation.
What steps did TFL take to ensure this was complied with?
Answer: The signage design referred to Traffic Signs Manual guidance and this design was forwarded to the Metropolitan Police to confirm their acceptance. Owing to site constraints, signs were placed on the same side of the road rather than alternate between central reservation and verge.
Please provide a plan showing where each 40mph sign and repeater are located, with the distances apart, and explain any failure to comply with the Manual.
Answer: Please see the attached plan.
7 - This warning sign is placed a short distance before the end of the new 40mph speed limit. What was the reasoning that led to it being placed here, where it is too late to do any good, rather than placing it before the first speed enforcement camera, where it would assist drivers to be aware of the change, and avoid being caught speeding? Where is the speed camera warning sign co-located with the 40mph repeater on the second speed camera pole?
Answer: The photo is of a temporary sign on the verge outside the BP station. The signage installed was in addition to the regulatory signage - a number of these temporary signs were installed by the contractor along the route to highlight the change in speed.
8 – Why is there a sign saying REDUCE SPEED NOW” alongside the main carriageway approaching the BP petrol station offslip? There is no reason for traffic going ahead to slow down here.
Answer: The photo is of a cantilever Variable Message Sign. The back of the sign is shown highlighted in the photo. This sign was not provided as part of this scheme
9 – TFL claim that safety is a top priority. Why is there the word SLOW painted on the BP petrol station offslip right at the entry to the station – see photo for Qu 7? This is much too late to be of any use. Why is the word SLOW not painted on the BP petrol station offslip at two suitable locations in the photo below, so as to warn drivers of the need to slow to near walking speed at the end of the straight in view? Why no chevron bend sign above the crash barrier?
Since any risk of flooding has passed by the area shown in the photo, why does the 40mph speed limit not end at the grass at the end of the chevrons on the road?
Answer: Neither the SLOW marking or vehicle restraint system referred to on the nose of the off slip are assets maintained by TfL.
The speed limit ends at the end of the on slip from the service area to minimise the number of national speed limit signs required.
10 – The photo shows extensive intrusion of vegetation into the sight lines beside the road, and even creates a risk to passing vehicles including anyone on bike. What process does TFL employ to ensure that intruding vegetation does not create risk to road users, as here? Please provide a dated and timed copy of the two most recent inspection reports that addressed this issue at this location.
Answer: The maintenance of vegetation alongside the carriageway as defined in our maintenance contract (1.8m edge of Carriageway Cutting) is carried out once per annum and at this location is completed under our A20 block closures. There are no “inspection reports” as such. The safety inspections are carried out on the back of works orders. From this the safety inspectors record any defects meeting the intervention levels as separate instances, each of which get their own orders on which to carry out repairs based on the risk. If the inspector did not record any defects relating to the vegetation, it can be assumed that there was no defect to record. The spreadsheet attached shows the recent defects picked up on the section of carriageway.
If this is not the information you are looking for, or if you are unable to access it for any reason, please do not hesitate to contact me.
Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed.
Yours sincerely,
David Wells FOI Case Officer FOI Case Management Team General Counsel Transport for London
