PACTS Submission to the Motorcycle Safety Group

8th August 2025 (updated 4.9.25)

1. Safe vehicles

• Are current vehicle regulations, as applied to motorcycles, sufficient?

1. ABS should be compulsory on A1 motorcycles too. These are what most riders learn on, and young riders use, so carry the highest at risk riders.

2. Automatic closing of throttle, either a thumb throttle or split throttle tube could save up to 1 second in reaction time, and achieve a 15 mph or more reduction in impact speed. Richard Cuerdon has the design concept for the split throttle.

3. There is a problem with ground clearance, particularly with cruisers, when banked. All PTWs should ideally be able to be banked at 45 degrees when fully loaded, without grounding. Lack of ground clearance will contribute to crashes on corners. (I’ve previously trained the St Ledger Harley Chapter – we had problems).

4. There is a problem with some ABS systems when the rear brake sets off the system for the front brake as well. This could increase braking distances and can be unsettling to riders. The Yamaha R9s we use have a setting where you can disable ABS on the rear brake, so it’s an industry known problem. It may be better to have linked brakes (rear brake operates front brake as well) or even to restrict ABS to just the front wheel. Testing needed.

5. There probably should be a maximum life for tyres – say 10 years? Tyres get noticeably harder as they get older and provide less grip. (I’ve just had a blow out on a 14 year old tyre on my motorhome. The regulations only cover minibuses).

6. Electric PTWs and those with automatic gearboxes, should have systems where the throttle closes automatically when the brakes are applied, and does not operate until the throttle is closed and reopened. This to compensate for the lack of a clutch. Needs testing and confirming.

2. Safe road users

• the training and testing regime for motorcyclists, both pre-test training and advanced training

2.1 Pre-test Training

1. 40% of young rider fatalities <19 years are underage. Unknown additional number have no licence, which could be circa 30% for all ages based on other country’s data. Public awareness program needed, on the dangers of riding without any training. 

2. Riders should be compelled to retake their CBT before upgrading to a 125 cc. See jump from 16-17 years old in casualty rates, and 50cc vs 125cc.

3. Emergency Braking advice from the DVSA is wrong. Apply the rear brake immediately.

4. ‘Thinking Distance’ is wrong. It’s not 0.7 seconds, it’s 1.5 seconds or more, based on TRL past research. 

5. Separation distance should be 3 seconds for PTWs, as Norway and NSW. PTWs are limited to 0.9g (they tip up), cars are now stopping at 1.2 g or more.

6. There should be a separate licence category for automatics as with cars etc.

2. Licence Testing

1. Hazard awareness is stressed, and tested – but there is no advice as how to react. This needs to be included in training and demonstrated on test. Slow, revise road position, cover brakes, use horn, plan escape route, accelerate smartly away when safe. (Always assume you are invisible).

2. Braking from high speed (58 mph?) to be included in training and testing. Use datalogging unit (or phone App). 

I’ve recently been working with Benjamin Smith from Bikeability. They will now be teaching braking’s ‘Square Law’ – twice the speed = 4 x the stopping distance to young cyclists. This is important to them (downhill) and to prepare young riders for PTW’s.

3. Bikeability also teaches smooth brake application (no snatch) and ‘covering the brakes’ which are skills transferrable to PTW’s. Young enough, and this should become ‘hard-wired’. Covering the brakes is currently not advised nor taught for PTWs, which I believe it should be. It just needs carrying over to PTWs, and to include the foot brake. As a minimum in response to hazards, if not as a routine.

4. Banking in corners (minimum 35 degrees?) to be included in training and testing. Use same datalogging unit (or phone App).

3. Post-Test 

1. Many riders > 50 years old will not have had any training at all. This still needs addressing – hence the higher collision rates. (see DVSA ERS data).

2. Official ‘DVSA Post Test Workshops’ should be considered in addition to Enhanced Rider Scheme assessments. I have one called ‘SharpRider ™‘ which was designed with Derbys CC and has been delivered since 2012 across most of the East Midlands and South Yorkshire. It is available to anyone FOC.

3. Positioning to see and be seen. Once riders have a basic level of control and competence, then they need to consider altering the way they ride to increase their safety. Riders are taught to ride mid lane or to the left, as this is safer when you are learning. However, using the full width of the lane, with training, provides better visibility and potential escape routes. Good advice in Police Motorcycle Roadcraft, but the concept of ‘buffering’ from NSW should also be considered to be taught.

4. DVSA post-test data. Data acquired recently via FOI. We now have data on common riding faults with which to review pre and post test training.

The Importance of the Enhanced Rider Scheme for Motorcyclists – British Superbike School

That it appears to take 24 years for 80% of riders to become competent, needs addressing. As do young rider fatalities. We now have data on what is not taught effectively, to accelerate this. (Data acquired from 5,000 professional rider assessments, from probably over 100 trainers, covering all ages).

On the plus side, the data seems to show the success of introducing CBT’s and a pursuit riding test in 1990. A fixed shift down in fatalities which should now move forward every year.

5. Braking is the main issue, in an emergency. This is identified by riders themselves as a training requirement, but not trainers, as riders aren’t tested within the ERS scheme (it’s an assessment). Most riders can’t stop effectively from high speed in an emergency. Very easy to test and confirm, but no one is interested. Many skid and fall, or lack confidence to brake hard, or panic and don’t brake at all (YouTube).

I’ve presented and lobbied on braking at RSGB conferences, but been ignored by those who could act. Missed for >50 years?

I’ve been working on ‘Braking’ including reaction times, which are of similar importance to speeding. This is where I am so far:-

Ultimate Guide Emergency Motorcycle Braking

6. >50% of fatalities are thought to be on rural bends. There is now no official advice on cornering lines, (there was in the 1970’s Roadcraft) and worryingly the ‘Wall of Death’ method, going around the outside of every corner, appears in an old DVSA video, and is taught by some trainers.

This is our advice on cornering for post-test riders, which we consider to be ‘best practise’ from a variety of sources. I believe it should be standard official DVSA or Roadcraft advice, or changed and issued.

Mastering Safe Cornering on the Road, with ‘Slow In Fast Out’ Technique

4. Advanced Training 

1. We now know there is no evidence that advanced training (non DVSA post-test training) is effective. See National Highway’s Agilisys report. Behaviour can be changed, as found, but currently is not for the better. The DVSA Enhanced Rider Scheme was not evaluated – which is very odd as data was available (see above).

2. The proposal is to enforce commercial advanced trainers to be DVSA licenced, for which I believe legislation is already in place. The Law says commercial ‘driver’ not ‘rider’ training requires licensed trainers, so has been seen as a loophole. The CPS definition of ‘driver’, is whoever is steering. The RPMT infrastructure and delivery has been in place for nearly 20 years. It just needs enforcing.

3. For the voluntary sector – mainly the IAM and RoSPA – the proposal is that they distance themselves from the police, who continually pass on hazardous ’emergency response’ behaviours. RoSPA uses current and ex-police examiners, who therefore set the riding standards. They should adhere to DVSA and Police Roadcraft Riding Standards. (Emergency Braking advice needs addressing).

4. Riders should adhere to the Highway Code ‘should nots’, and overtake only when necessary, or when at low risk. Riders should never be in a hurry. ‘Making good progress’ can conflict with safety. 

5. I am also now concerned that these ‘emergency response’ practices are being passed on via some police force’s BikeSafe courses, from recent feedback from riders. This should be addressed. I was a civilian assessor for Lincs BikeSafe, which I thought was a very effective initiative. This needs to be addressed or BikeSafe withdrawn, in the interests of public safety. 

The Potential Problems with ‘Advanced Motorcycle Training’

6. I am sure the police have better things to do. Road policing is nearly non-existent. They were involved in training before WW2, as there was nothing else at the time. There are now DVSA riding manuals and DVSA licenced trainers for the general public. Police Motorcycle Roadcraft is good, (apart from emergency braking advice) but it should be relabelled as the DVSA post test riding manual, and the emergency response chapter removed.

7. National Highways via Bikertek are currently encouraging front wheel trail braking into every corner, from an ex-police rider, including when turning at junctions. It is obviously hazardous, makes no sense, and conflicts with both DVSA and Roadcraft advice – for all vehicles. Probably again from unwritten police emergency response or pursuit training. If nothing else, riders will be entering corners faster than otherwise, putting themselves at higher risk. I have asked them to remove the video, but they have refused. They have stated that they are trying to make PTW training ‘exciting’. I also pointed out the rider on their landing page is riding with his visor open. They have now pixelated the top of the picture in response to hide this. I believe they simply do not have the required competency in-house. The DVSA has, within the Dft. This is now with my MP to take to the Ombudsman.

3. Collision Investigation

1. Crash data is currently based in the Criminal Justice System. Prosecution, not collision prevention. Black box data from bikes and cameras is being ignored, I believe. Crashes are poorly investigated (despite long road closures) and there is a lack of coroner reports. I was told by a recently retired crash investigator that data protection meant that they could not acquire and use black box or video data (which can include accelerometer data). I believe this to be untrue, as it would potentially be criminal evidence.

2. The data would record response time and road position, speed, braking effectiveness, and changes in direction or swerving. And the force of the impact. Whether the rider tried to brake, or swerve, or both. Or tried to bank the bike. Or did nothing.

3. In addition, marks on the road would show if and where a rider had skidded and/or fallen. Sweeping everything into ‘Loss of Control’ is not helpful. The recent condensing of the categories into RSF’s, will probably make matters even worse.

4. This inappropriate and poor accident reporting system is hiding the root causes of most fatal crashes, which according to Bruce Wilson a forensic crash investigator from NZ, is mainly about braking, with half of riders skidding and falling (which should reduce as ABS becomes more common) or simply lacking the confidence to fully apply the brakes, or at all (panic).

5. Advanced and post-test training needs to include actual braking practice from speed. A new App is required (which could also be used for licence testing). The iAccel brake testing app is only now available on Iphone. An app with a faster sampling rate would be better for training. See KurvX datalogging as an example.

6. Circa 80% of crashes appear to be either at junctions or on rural corners, although again the system only reports ‘not within 20 metres of a junction’, so mainly on a bend has to be assumed. I confirmed this with the Lincs police over a decade ago. 

7. The prime problems of both braking and cornering have been hidden by poor crash reporting.

Mike Abbott MBA, RoADAR (Dip), DVSA RPMT 800699, ACU Coach #62210

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