Responding to road safety audit recommendations

A road safety audit recommendation is not an instruction. The audit team identifies a safety problem and suggests a measure, and the design organisation then has to answer each one in a designer's response, either accepting it or setting out a reasoned exception for the overseeing organisation to approve. Getting that document right is what keeps a section 278 agreement moving, and the usual failure is treating the audit report as a snag list to be worked through silently rather than as a set of propositions that need an answer in writing.

The process sits in the National Highways standard GG 119, which applies on the strategic road network and is adopted in substance by most local highway authorities for development-led works.

What the audit team can and cannot require

The audit team looks at road safety and nothing else. That boundary matters when a recommendation strays into territory the team has no remit over.

An audit may identify problems arising from the design that could affect the safety of road users, and recommend measures to address them. It may not redesign the scheme, specify a solution in detail, comment on whether the design complies with standards, raise capacity or delay issues, or opine on maintenance liability, drainage adequacy as an engineering matter, or appearance. Where a recommendation does cross that line, say so politely in the response and answer the safety point that sits underneath it.

The team must also be independent of the designer, with no prior involvement in the scheme. If the audit has been carried out by someone who worked on the layout, the authority can refuse to accept it, and the audit has to be redone.

The structure of a designer's response

Keep the format mechanical. One row or one numbered entry per audit problem, in the audit report's own numbering, with nothing omitted and nothing merged.

Answer every problem, including the ones where the answer is that the issue falls away because the element has been removed from the scheme. An audit problem with no corresponding entry is the single quickest way to have the response bounced back.

Date it, name the responding organisation and the individual, and reference the audit report by its version. Where the design has moved on since the audit, say which revision the audit saw and which revision the response relates to.

Accepting a recommendation and changing the design

Accepting usually costs less than arguing, provided the change stays inside the land you control and does not unpick anything already approved.

Check three things before accepting. Whether the change sits within the application red line or the land in the section 278 agreement, because a widened splay or a relocated crossing can need land outside both. Whether it alters anything shown on an approved planning drawing, which may need a non-material amendment under section 96A of the Town and Country Planning Act 1990 or a minor material amendment under section 73. And whether it affects a geometric check already carried out, since moving a kerb line changes the visibility splay and stopping sight distance calculations you submitted.

A change to a junction radius or a forward visibility envelope ripples. It can alter swept path analysis, the turning area for a refuse vehicle, the gradient at the tie-in and the position of gullies, which brings the highway drainage arrangements back into play.

Writing an exception report that holds up

Where a recommendation is not accepted, the standard requires the reasons to be recorded and a decision taken by the overseeing organisation. An exception report that simply says the measure is not required will be rejected. One that works gives, in order:

1. The problem as the audit team described it, accepted as a problem.
2. Why the recommended measure is not appropriate here, on evidence rather than preference.
3. An alternative measure, if one exists, and why it addresses the same problem.
4. The residual safety risk, describing who is exposed and in what circumstances.
5. Any monitoring or review proposed, and the stage at which the issue will be revisited.

The strongest reasons are physical and verifiable: the land needed is in third party ownership, the measure conflicts with a statutory undertaker's apparatus, the geometry cannot be achieved within the adopted boundary, the measure would introduce a worse hazard. The weakest is cost, which rarely carries an exception on its own.

Accepting the problem while declining the measure is the posture that works. An exception report that disputes whether there is a safety problem at all invites the authority to side with its auditor.

Who signs off a departure

The designer does not approve its own exception. Approval rests with the overseeing organisation: on the strategic road network that is the project sponsor within National Highways, and on a local road it is the highway authority officer managing the section 278 or section 38 agreement, usually with reference to their own road safety team.

Build that into the programme. The sign-off is a separate decision by a separate person, often needing a committee of one more layer up where the residual risk is material, and nobody will agree it over the phone. Get the exception report in early and in a form that can be signed without amendment.

Keep the signed exception on file for the life of the scheme. At Stage 3, before the works open to traffic, the audit team will be given the earlier reports and responses, and an unsigned exception from Stage 1 reappears as a fresh problem.

Carrying problems forward between stages

Audits run in stages: broadly at preliminary design, at detailed design, after construction and before opening, and then in monitoring after opening. Each stage team receives the previous reports and the responses, so nothing dies quietly.

Where a Stage 1 problem cannot be resolved at preliminary design, record it as carried forward with the reason, rather than closing it out with a holding answer. The Stage 2 team will test whether the detailed design resolved it. Where an element has changed so much that the earlier problem no longer arises, say which drawing revision removed it.

Monitoring stages look at recorded collisions after opening. Those are rarely a developer's liability once the works are adopted, but on a scheme where the exception rested on a monitoring commitment, somebody has to own it, and the section 278 agreement should say who.

When a late recommendation hits the programme

The expensive case is a Stage 2 recommendation that requires more land. By detailed design the planning permission is granted, the land deal is done and the contractor is mobilising. A recommendation to extend a splay across a neighbour's frontage then becomes a land negotiation, a section 73 application and a programme delay measured in months.

Reduce the exposure by auditing earlier. An interim audit at the point the access strategy is fixed, before the planning application is submitted, catches geometric problems while the layout can still be changed at little cost, and the findings can be reflected in the access drawings that sit behind the transport assessment. It costs a few thousand pounds against a redesign that costs far more.

An illustrative example. A developer takes a Stage 1 audit on a 60-dwelling access at preliminary design, accepts a recommendation to relocate the pedestrian crossing 15 metres west, and carries the change into the submitted drawings. The same recommendation arriving at Stage 2, after the carriageway levels were agreed, would have required a revised drainage design and a fresh swept path check, and the construction traffic routing in the construction traffic management plan would have needed reissuing.

This is general guidance, not legal advice; check the position with your local planning authority, the relevant highway authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.