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Occupational safety has ranked responses to hazards for decades, in a hierarchy of controls. Removing a hazard works best. Protecting the individual exposed to it works least.
Applied to passive mobility:
- avoid: trips that are not needed, through short distances and good local services
- replace: walking, cycling and public transport instead of the private cardesign
- streets and vehicles built so that a mistake does not cost a life and cause only harm as little as possible
- rules and training: speed limits, driving tests
- personal protection: helmets and high-visibility clothing for those at risk
The last two levels have been relied on longest and have delivered least, especially as speed limits are very limited enfored, illegal parking rarely results in being towed away. Vulnerable road users, including kids, are asked to be very careful, all the time.
At the design level there are two ways to reduce the harm of the motor traffic that remains:
- street design
- vehicle design
Vehicles that bypass European safety law
A growing problem is vehicles that reach European roads without meeting European safety requirements at all. Large pickups built for the US market enter the EU through individual vehicle approval, a procedure originally intended for genuine one-off vehicles such as those adapted for people with reduced mobility or for the emergency services. Vehicles approved this way do not have to comply with the General Safety Regulation of 2019, with on-road testing for air pollution, or with the EU CO₂ standards for cars and vans. Among the requirements they avoid are energy-absorbing bonnets and front bumpers, automated emergency braking, intelligent speed assistance and reversing detection.
The scale is no longer marginal. Nearly 5 000 Dodge RAM pickups were registered in Europe in 2023, 20 % more than in 2022 and 2,7 times the 2019 figure, and more than 20 000 are now on European roads. Dodge RAMs make up about 60 % of individual approval imports, and 86 % of these vehicles enter the EU through certification bodies based in Germany. With a typical bonnet height of about 126 cm, compared with 70 cm or less for a small car, they are also among the most dangerous vehicles for pedestrians, and above all for children.
A city cannot change how these vehicles are approved. It can, however, make compliance with the EU safety requirements that every type-approved vehicle has to meet a condition of entering its streets.
Sources: Letter from T\&E, ETSC, the European Cyclists’ Federation, BEUC, Clean Cities, Eurocities, POLIS and the International Federation of Pedestrians to the European Commission on individual vehicle approval, 4 July 2024; ETSC, Sales of dangerous US pickup trucks up 20 % in Europe, 5 July 2024. In July 2024 the Commission stated its intention to strengthen the rules on individual vehicle approval to a level of protection comparable with EU type approval.
safe vehicle standard proposal
Protection for the people inside a vehicle is well regulated. UNECE regulations and EU type approval have required crash tests for occupants for decades, and Euro NCAP has rated them since 1997. Seat belts, airbags, crumple zones and electronic stability control have made vehicles far safer for those inside them. Protection for the people outside has not kept pace. Crash tests for pedestrian protection exist only for cars and light vans, and only since the 2000s. Between 2014 and 2024, deaths of car and other vehicle occupants in the EU fell by 19 %. In urban areas, people walking, cycling already make up 70 % of everyone killed on the roads (European Commission 2026). This standard is drafted therefore to protect vulnerable road users and above all children and older people. The safe vehicle standard is also for the drivers. Drivers causing a fatal collision carry that burden for the rest of their lives.
general requirements
Vehicles which do not fully comply with all EU regulations are regarded as unsafe vehicles which shall not be permitted on European streets, but at least banned from entering cities! A growing number of vehicles reach European roads without meeting European safety law at all. Large pickups built for the US market enter through individual vehicle approval, a procedure intended for genuine one-off vehicles.
Vehicles class (G) must have a permit for entering urban aereas, for the site they serve.
vehicle body design
1. direct vision
The driver needs to see a child standing close to the front and the kerb side of the vehicle directly, without mirrors or cameras. The Direct Vision Standard developed for London by Loughborough University measures how much of the space around a vehicle the driver can see directly from the driver’s seat. Until a dedicated rating exists for each vehicle class, the Direct Vision Standard method shall apply to every vehicle covered by this standard:
- new vehicles: 5 stars
- vehicles already in use: at least 3 stars
The star thresholds were set for trucks over 12 t. For lighter trucks, vans and cars, they shall be calibrated to the same protective aim: seeing a child close to the vehicle. Cameras and sensors can support the driver. They do not replace direct vision, because a person seen directly is noticed faster than one on a screen.
2. bonnet height
The bonnet hight must be below 1,00 m. Measured on the centreline of the vehicle, at the point where the line of the bonnet, extended forward at its own angle, meets the front of the vehicle. This criterion does not apply to cab-over vehicles.
3. underrunprotection
Every safe vehicle needs an all-around full-surface underrunprotetion which needs to get as low as the aproach and breakover angle allows.
Class 1
vehicles over 3,5 t. The sharpest change in slope they meet is at raised crossings, with ramps of typically 10 %. A change from 10 % to 0 % corresponds to 5,7°; with the margin, about 9° for the approach, departure and breakover angle.
Class 2
vehicles up to 3,5 t, which must be able to use garages. Garages have usuallly a slope of at most 15 %. Between the street and a ramp steeper than 10 %, a transition area of at least 3 m with a slope of at most 5 % is required.foot of the ramp, 15 % to 0 %: 8,5°; with the margin, about 11,5° for the approach and departure angletop of the ramp, 15 % to 5 %: 5,7°; with the margin, about 9° for the breakover angle
Class G
to be difined
4. outer shell of the vehicle
Front
no rigid steel bumpers and no bull bars
No front attachments. Mounting plates for front attachments such as snow ploughs or sweepers are permitted only on municipal vehicles. When no attachment is fitted, the mounting plate must be covered with an energy-absorbing pad.
Rear
No sharp-edged rear attachments such as spoilers. Towhocks and tail lifts shall be integrated into the rear underrun protection as far as technically possible, so that they do not protrude beyond it.
Side.
No running boards that extend sideways beyond the front of the vehicle.
The whole outer shell:
no protruding or spiked wheel nuts and hub coversedges and corners rounded, at least to the level already required for cars under UN Regulation No 26 on external projections, extended to all vehicles
mirrors and camera arms need to easaly fold away on impact
Attachments only with a safety certificate. Every attachment to the outer shell must have a safety certificate confirming that people walking and cycling are not put at greater risk than by the vehicle without it. The existing EU type approval for frontal protection systems is the model. Vehicles whose operation strictly requires specific attachments, such as winter service or construction vehicles, are exempt for those attachments, but not from the certificate for all others.
acceleration
at most 1,5 m/s² at least within the urban area. Verified through a certified, tamper-proof driving mode. It can be delivered in software, without building new vehicles. Intelligent speed assistance, already required in new vehicles, can be switched off by the driver and does not meet this criterion.
This standard is written to become a UNECE regulation, or at least the basis of EU vehicle type approval. Until then, it shall be applied jointly by an alliance of cities, as a condition for entering their streets.
standards still to be develop
The main development work for Euro NCAP, research partners and the UNECE World Forum for Harmonization of Vehicle Regulations (WP.29) shall be:
- a Euro NCAP score for the protection of people walking and cycling as part of the vehicle certification approval
- Collision protection for vehicles larger than cars. Crash tests for the protection of people walking and cycling exist for cars and light vans. For heavy vans, trucks and buses, no such test exists. Their flat, upright fronts tend to knock a person down and run over them instead of deflecting them. A standard is needed for front shape and energy absorption on heavy vehicles. Euro NCAP intends to begin crash testing trucks from 2030, which is a starting point.
- Direct vision for vehicles under 12 t. For trucks from 3,5 to 12 t, the Direct Vision Standard method can most likely be applied as it is: the cab design and the driver’s position are similar. For vans and cars, the principle carries over, but the star thresholds need calibrating. The driver sits much lower, and the critical area is the space directly in front of the bonnet and at the near side, at the height of a child. Loughborough University has indicated willingness to extend the method to all motor vehicles above a speed threshold of around 30–50 km/h.
- A certified urban driving mode, tamper-proof, limiting speed and acceleration within defined zones.
- A safety certificate for attachments, confirming that an attachment does not increase the risk to people walking and cycling.
- Tyre abrasion limits, being developed at EU and UNECE level. Until they apply, a measurable interim criterion is needed, for example based on tyre width and vehicle mass.
A low cab gives the driver a direct view of the street, and spares them climbing in and out dozens of times a day.