A police force posted a photo (shown above) of one of its officers who stopped a speeding vehicle at an undisclosed location outside of Toronto, Ontario. The officer is seen standing in a live lane while at the driver’s window of the offender’s vehicle. The scenario depicted here is very dangerous as it provides no protection to the officer should a vehicle travel at highway speed in that live lane. While Ontario has enacted a “slow down and move over” law that should, theoretically, prevent drivers from driving in a lane next to a police traffic stop, the practical reality is that there are many instances where slowing and moving over cannot be achieved, especially where large transport trucks block the vehicle ahead. In emergency situations there are instances where police cannot always clear a live lane and that dangers exists. However in the case of traffic stops a driver of a vehicle that has been pulled over can be instructed by an officer to drive further away from a live lane before commencing discussions on a traffic infraction. The officer must also be instructed in using his/her vehicle as a blocking vehicle, positioning it at a proper distance, off-set and angle that it will give the officer the greatest opportunity to avoid major consequences. Also, where possible, an officer should stand on the right side of a stopped vehicle, not on the driver’s side, on high speed roadways and expressways.
Many safety scenarios can be demonstrated to officers at training facilities such as the Ontario Police College near Aylmer Ontario, where sufficient grounds have been available for decades. In the 1980’s I was instructing at the Ontario Police College at courses such as Advanced Accident Investigation. During my many encounters with the College’s traffic instructors Rick Fruin and Murray Turner I was provided with glimpses of how police were trained at the college. I observed some of the testing taking police on the old airport runways that were part of the College’s grounds. I also had an opportunity to conduct some of my own tests using the College’s vehicles and grounds as shown below.
As the police community is close-knit and somewhat closed it is unclear what training is being conducted in the present day to keep officers safety in their traffic duties. But constant reminders need to be given to officers and their actions need to be monitored for their own safety.
The inefficiency of documentation and distribution of collision data in the Province of Ontario is revealing when compared to what is done in the U.S.
Just five months after the end of 2021 the U.S. National Highway Traffic Safety Administration is able to provide an estimate of the numbers of traffic deaths in the county that has a population almost 10 times the size of Canada. Yet the Province of Ontario still stumbles along with attempts to reveal final data from the year 2019.
An important notice from NHTSA is that fatalities increased substantially in 2021 as noted in their newly released documentation:
“NHTSA projects that an estimated 42,915 people died in motor vehicle traffic crashes last year, a 10.5% increase from the 38,824 fatalities in 2020. The projection is the highest number of fatalities since 2005 and the largest annual percentage increase in the Fatality Analysis Reporting System’s history.
Preliminary data reported by the Federal Highway Administration show that vehicle miles traveled in 2021 increased by about 325 billion miles, or about 11.2%, as compared to 2020.”
Why are these increases occurring despite the fact that many new safety features are coming into the modern vehicle fleet? Are they related to higher usage of the road system? Can the increases be blamed on the Covid pandemic? Are other factors at play?
In Ontario there is no current information about basic road safety trends. Even those data that are revealed in Ontario’s Road Safety Annual Report (ORSAR) provide no useful information about what causes injuries and deaths. ORSAR data is based on police reports written up mostly by officers who have limited time, training and understanding to explore the complexity that exists in typical collision causes. But more importantly, there is no expertise in understanding what has caused an injury or death, and when certain results should involve further investigation. And the Ontario Ministry of Transportation has no real interest in documenting causes of injury and death.
In many instances relatively minor collisions result in fatalities yet there is not special interest in understanding why these occur. In Ontario the focus of police investigations is in laying charges against motor vehicle drivers, not in documenting how and why someone was injured or died. The police logic is that identifying injury mechanisms is not police work. This means that identifying ways to improve road user safety becomes inefficient.
Trends in collision causes have existed for decades without much official awareness. Loss-of-control events on two-lane highways that result in rollovers, tree/pole impacts or erroneously-described “head-on” impacts all have similar sources that are never discussed. Fatal, rear-end impacts on high-speed expressways are similarly ignored in terms of their possible related sources. This results in the existence of many unsafe, uncorrected conditions that continue to exist over many years.
Ultimately what is needed is high-quality, unbiased data. If this must come solely from police reports then improvements need to be made in the quality of that data including safe-guards against typical police-reporting bias. In this modern age where costs of producing photos and video are minute, collision data should be supplemented with these very cheap methods of providing objective support for what has been officially accepted into a large-scale database. When reliable data is created and analysed, and the findings are distributed in a timely fashion, an efficient system of detecting newly-emerging, road-safety trends becomes a useful tool for all of society’s benefit.
Much like vehicle fires, rolling over into shallow water is something that appears of minimal importance when the incident results in minor or no injury. Yet too often it results in a drowning death.
An intersection collision reported by Dufferin OPP today, May 12, 2022, highlights the role that luck can play in either taking a life or saving it. The OPP provided two photos on its Twitter account showing the results of a collision that occurred on County Road 10 at its intersection with Mon Amaranth Townline, north-east of Toronto, Ontario. One photo, shown below, appears to show a Jeep that landed upside down in a small creek. The OPP noted: “Thankfully an off-duty OPP officer was first on scene and freed the driver and passenger who were trapped in the water”.
In the second photo, below, we see that the other vehicle narrowly missed entering the water and also stayed upright. This is how luck can make such a difference when a danger lurks.
Very little importance is given to small streams or ponds near roadways, particularly if they appear to be shallow. The logic continues to be that “if I drive into it, it can’t hurt me when it is only one foot deep”. How little we understand that in many loss-of-control events a vehicle does not stay on its wheels but rolls over. When a vehicle stops upside down the body part of an occupant that is closest to the ground is the head. And if the occupant cannot escape that position it can be extremely dangerous. Even a water depth of one foot can be extremely dangerous if you are entrapped in your seated position and your head is in that water. You might fight by lifting your head, over and over again, but eventually you will tire out. And if no help arrives you will slowly drown.
That is why proper roadside barriers are crucial in areas where there is water near a roadway. Such barriers need to be of proper strength and design, including a proper length so that a wayward vehicle cannot by-pass the barrier and enter the water. Unfortunately when near-drownings occur no mention is made of the status of the barriers that should have prevented a vehicle entering an area of water.
A spokesperson for the Canadian Armed forces was reportedly quoted as saying “no further detail can be provided at this time” with respect to the death of four cadets at the Royal Military College in Kingston, Ontario. Detail? Are we kidding. What detail was provided? No a single piece of information was disclosed except that four cadets died, and that a green vehicle was removed from the water at Point Fredrick. How enlightening.
Who was responsible for monitoring the activities of the cadets on this date and time? How did the “green vehicle” enter the water and was it equipped to protect its occupants in such an occurrence? What roadside safety devices were installed at the site to prevent a military vehicle from accidentally entering the water. The unanswered questions could go on and on.
In many instances there is little information that can be disclosed in the early hours of a death investigation. On the other hand there have been numerous instances where weeks, months and years have passed and no information of any substance has ever been released in certain deaths. It makes for situations where certain individuals can claim immunity from prosecution for their negligence, or worst, because they are members of select clubs of influence. Where will the current “incident” stand in this meandering approach to justice?
It is easy to get information on the effectiveness of high-tension cables barriers especially from those organizations who either sell them or use them on their highway systems. But what about information that demonstrates their in-service performance and whether the barriers are being repaired in a timely fashion? Silence.
Equally, it is possible to obtain information about the number of collisions occurring on Ontario’s Highway 401 if one has an infinite amount of timee to follow collision reporting provided across the whole Province of Ontario on its 511 system. But monitoring what is happening on specific problem areas such as the infamous “Carnage Alley” between London and Tilbury is virtually impossible because only the most minimal information is provided to the public.
A recent travel through Carnage Alley by Gorski Consulting in early April, 2022, revealed several locations where the cable barrier was damaged from unknown collisions, as shown in the photos below.
What kind of collisions resulted in this damage is unknown. And how long the damaged barriers have remained damaged is unknown.
A long-time proponent of concrete barrier installation on Highway 401 in her Chatham, Ontario area, Alysson Storey, recently noted in a response on Twitter that “I have found it much more difficult to track collisions in Carnage Alley the last 2-3 years. But even keeping a basic running list is better than nothing.”
It is not clear why this greater difficulty has come about. Are police and official news agencies being helpful in providing information about these collisions? How would anyone know? Are the newly installed cable barriers performing as expected? How would the public know when there is no information about the issue?
What we can say from our own observation is that certain collision repairs along Highway 401 are not being made in a timely fashion. For example, on December 3, 2021 we observed the damage to an ET-Plus guardrail terminal on the north side of the westbound lanes of Highway 401 just west of Highbury Ave in London, as shown in the photo below.
This terminal was not repaired until the afternoon of May 2, 2022, as shown in our photo below.
This delay of five months means that, anyone who might strike the terminal would be exposed to an unknown level of performance, most probably a degraded level of performance. But who would know of this delay unless someone was actually monitoring it?
So what about those damaged sections of cable barrier on Highway 401 in Carnage Alley? How long have they remained damaged after they were struck? In Alysson Storey’s experience the repairs should be performed much sooner (and she is right):
“I know in certain states there is a specific time frame (eg 2 weeks) that damaged cables must be repaired by. I don’t know if ON has the same standards, although I sincerely hope so. Once a cable is damaged, the entire segment is useless. So we’re back to square one.”
What may happen when a vehicle strikes a damaged cable barrier is unpredictable. It depends on the characteristics of the vehicle, its speed, the angle of approach, and so on. But clearly we should not be using the public as guinea pigs in such experiments.
News media have reported that shortly before 2320 hours on April 4th, 2022, the rider of an e-bike was struck by a hit-&-run motor vehicle in the area of Toro Road and Keele Street in Toronto, Ontario. The rider reportedly sustained life-threatening injuries. Understandably no information was provided about how the collision occurred because the investigation is in its early stages. However, as noted in almost all previous occasions, no information will ever be revealed including how the rider sustained his/her injuries.
Unfortunately this is the sign of the times and an indication of what is to come in the not too distant future. E-bikes or E-cycles are becoming more common. E-cyclists not only ride on city streets but also on sidewalks. Ontario’s Ministry of Transportation has made it illegal for cyclists to ride on sidewalks because of the dangers they say exist including the fact that cyclist speeds are substantially higher than the walking speeds of pedestrians. Yet observations by Gorski Consulting indicate that at least 50 percent of cyclists continue to ride on sidewalks, regardless of the law. This suggests that, despite what the Ministry is saying, cycling on the sidewalk may be safer for cyclists than sharing a lane with motor vehicle traffic. But there is likely to be an added complication to this discussion.
Observations by Gorski Consulting indicate that those who ride e-cycles travel at substantially higher speeds than the average cyclist using pedal power. E-cycles are also substantially heavier, especially if they are also carrying cargo. This combination of higher speed and higher mass means that travelling on the sidewalk, or roadside, will present new safety challenges that few appreciate. If motorists found it difficult to react to a pedal-powered cyclist on the sidewalk travelling at 10 km/h, the problem will be exacerbated when an e-cyclist’s speed is 25 or 30 km/h. That higher speed and mass will also come into effect if collisions should occur with pedestrians, particularly the elderly or children.
There is a large impetus for various jurisdictions in North America to increase cycling volumes, partially due to climate change issues. Cycling groups are also highlighting the benefits of cycling versus motor vehicles. But little is being done to recognize that the environment in which cyclists will be travelling is not compatible, and that cyclist collisions, as poorly documented as they already are, will become more prevalent and more severe in the not too distant future.
Recently Gorski Consulting attempted to convey an important safety message to cyclists with a short Twitt. This was based on the results of real-life collisions that were reconstructed by Gorski Consulting. What resulted was an angry response from many who decided the message was blaming cyclists for the existence of the safety problem.
This is just another example, of many, where the internet has created new armies of radical and intolerant beings who can no longer assess matters calmly and objectively. It represents a new development of our time where persons become indoctrinated within their village of fellow believers, unwilling and incapable of understanding an alternative viewpoint. These are psychological matters that need the intervention of specialists in human behavior who can explain what is taking place. Yet the word of specialists on many important issues, whether from the medical, engineering or general scientific communities has been suppressed by the general noise of the internet. It is just as easy for some village shaman to use seductive messaging that pleases what the crowd wants to hear rather than the dry logic of science that is often too complex for the average person to understand. This is an evolving development and its resolution is uncertain. But mass hysteria is a dangerous thing.
After two years of silence the Red Hill Valley Parkway (RHVP) Inquiry has recommenced with an attempt by the City of Hamilton to keep back certain documents. No one will know what those documents are because the decision to withhold will be made “in camera” or behind closed doors, as noted on the Commission’s website below:
“Update March 30, 2022
The City of Hamilton has delivered a notice of motion for directions. The motion asks the Commissioner to appoint a designate to determine whether or not certain documents are protected by a form of legal privilege and, therefore, the City need not produce them to the Inquiry. The City is also asking the Commissioner to direct the designate to hear the motion in camera and that any motion materials be filed with redactions to protect information that may be privileged.
If any members of the media or public wish to make submissions to the Commissioner about the motion for directions, please contact lead Commission Counsel Robert A. Centa at [email protected] no later than noon on April 6, 2022.”
How would anyone know whether to object to this proceeding without knowing something about what documents are to be held secret? How would anyone know whether to object if there is no information about who the “designate” will be? It can be noted that the City of Hamilton created the Commission in the first place and they placed limits/controls on how it would operate. Yet the City of Hamilton could be one of the entities held at fault for concealing engineering reports about the possible sub-standard conditions of the RHVP. By this time almost all Hamilton citizens will have gone off to “more interesting” topics of the day, guaranteeing that no public outcry would occur even if there is something nefarious occurring.
Why do so many cyclists chose to ride on a sidewalk rather than on the road where they are legally required? That is one of the questions we need to answer if we are to improve cycling efficiency and safety in the Province of Ontario.
Gorski Consulting has been gathering observations of cyclists in London, Ontario for many years. These observations are permanent since they were made with video or still photos. This allows for review of the observations to extract information that was not needed at the time of the documentation. As Ontario, Canada and other nations work toward increasing cycling as a mode of travel observations of cyclist characteristics and actions become vital to understanding how to accomplish these increases in cycling volume while also improving efficiency and safety.
In recent years London Ontario, like many Canadian cities, has been building various cycling facilities. Data from several in-street sensors also suggest that cycling volumes are rising. At face value these developments appear to be good news. Yet the vast percentage of roads in London still remain geared for automotive travel. This means that the increased numbers of cyclists are riding on roadways not built to accommodate cyclists. This leads to the likelihood that increased cyclist injuries and deaths can be expected in the future.
London and Ontario have never provided a detailed and public accounting of the number of cyclist collisions that occur in their jurisdictions. One reason for this is that revealing these numbers could place responsibility on these entities for those incidents where the infrastructure has been substandard. It cannot be ignored that both London and Ontario are the defendants in many civil suits and thus they have a reason to hide safety-related problems if those problems become the source of those civil suits. Yet, if these entities cannot be relied upon to detect and correct safety problems, who is left to do that essential work?
At no cost to the taxpayer, Gorski Consulting has been providing data to the public about a variety of road safety issues, including cycling safety, for many years. As we have no interest in the outcome of civil suits we are able to provide an independent and reliable assessment of what is occurring on our roads.
While Gorski Consulting cannot provide any information about cyclist collisions, we are able to provide a detailed study of the characteristics and actions of cyclists on London’s streets. This can help to unravel what causes may be involved in those cyclist collisions.
The table below is an example of two factors that are being tracked in our cyclist observations: cyclist gender and cyclist riding location. For a number years we have been noticing the small number of female cyclists that exist an London’s roads or adjacent to them. Similarly we have also observed that a large number of cyclists use the sidewalks of roadways rather than riding on the right edge of a lane shared with motor vehicles. The table below summarizes the status of these two factors over a nine-year period commencing in 2013.
Looking in the first column of the table we see the data referring to the years 2013 and 2021. It can be seen that there were a total of 1574 observations of male cyclists and only 277 observations of females, resulting in a total of 1851 observations.
Next we note how many cyclists were observed to be travelling on the sidewalk rather than on the road. There were 761 males and 160 females observed on the sidewalk. A limitation in this analysis is that there was no distinction made between cyclists who were walking their cycle versus riding on it, although the vast majority of cyclists were riding. Also cyclists who were observed within a pedestrian crossing were also coded as riding on the sidewalk regardless of whether they were walking or riding. We may update the analysis on some future date to distinguish between walking and riding cyclists.
Next we have a row of the table labelled “% Female”. This is the percentage of all observed cyclists who were judged to be female, over the total number of observed cyclists, so 160/1851 = 14.96 %. All the data in the table excludes cyclists whose gender could not be identified. There were 130 cyclists in the years 2013 through 2021 whose gender could not be identified.
Next we have percentages for the males and females observed on the sidewalk. As an example the number of observed males on the sidewalk, 761 was divided by the total number of male cyclists, or 761/1574 = 48.35 %. The same method revealed that 57.76% of females were observed on the sidewalk.
It was noted that a larger than normal number of observations were made in the year 2021 (564) compared to the nine-year total of 1851. In 2021 there also appeared to be a higher number of cyclists observed riding on sidewalks. Thus we made a column of data for the years 2013 through 2020 and a separate column for the year 2021, to show the differences. It is not clear whether the differences are genuine however it appears that the percentage of males (64.89) and females (64.94) riding on a sidewalk were higher in 2021 than the previous eight years where the males percentage was only 40.94 % and the female was 55.00 %. Differences could exist in the way that we made our observations in the earlier years such that we may not have focused as much on cyclists existing off the road surface. Never-the-less the difference is intriguing. We cannot see an obvious reason why cyclists should be using the sidewalk more often but this may be resolved with further studies.
We also created a separate column for data from the first quarter of the year 2022. Since there were only 83 observations made in this period the calculated values have likely been affected by small cell volumes. For example only 10 female cyclists were observed and 9 of them were observed on the sidewalk leading to a calculated percentage of females on the sidewalk of 90%. Clearly this value does not appear to be accurate. But we will see what develops once further data is obtained for the year 2022.
Cyclist observation data collected by Gorski Consulting between the years 2013 and 2021 indicates that approximately 50 percent of cyclists ride on sidewalks adjacent to the streets of London, Ontario. On higher hazard roads this percentage rises dramatically. For example, from observations obtained between 2018 and 2021, along the busy, 4-lane, segment of Dundas Street between Highbury Ave and Clarke Road the percentage of sidewalk riders was noted to be 82.6 percent.
It is peculiar that the City of London’s by-law prohibits cyclists from riding on a sidewalk unless the rider is under the age of 14. Presumably this is because it is deemed safer for children to ride on the sidewalk. Yet arguments presented by Ontario’s Ministry of Transportation in various publications emphasize the dangers of riding on the sidewalk. For example, in Ontario’s Book 18 of the Traffic Manual the following dangers of riding on sidewalks are noted.
“Myth #1: Cycling on Sidewalks is Desirable
Cycling should almost never be mixed with pedestrian traffic on sidewalks. The only exception is for children (typically under the age of 11) who may lack the necessary skills and cognitive abilities to operate a bike on a roadway with motor vehicle traffic. Cycling on a sidewalk is strongly discouraged because of the mobility constraints and varying abilities of pedestrians and cyclists. Cyclists travel at much higher speeds than pedestrians, yet they cannot change their direction or speed as quickly as a pedestrian can. There are also numerous fixed objects on or adjacent to a sidewalk around which cyclists must navigate. These include parking meters, utility poles, sign posts, transit shelters, benches, trees, fire hydrants and mail boxes. In general, cyclists should have access to dedicated or bicycle-friendly facilities. Other conflicts that cyclists encounter while riding on a sidewalk include pedestrians alighting from buses, exiting stores and emerging from parked cars. Such situations do not allow enough time for cyclists to avoid a collision. Pedestrians, on the other hand, can find it difficult to predict the intended direction of an oncoming or overtaking cyclist. When cyclists use sidewalks to travel in the opposite direction to the adjacent motor vehicle flow, conflicts occur more frequently at driveways or intersecting streets. This is because drivers who exit these areas are not looking for cyclists, who travel at higher speeds than pedestrians. The risks to cyclists are similar to those for raised cycle tracks, in-boulevard facilities and separated bike lanes described in section 126.96.36.199. However, they are amplified since the lack of a formal cycling facility and associated signing makes drivers less likely to expect cyclists to be crossing. Finally, sidewalks are typically 1.5 metres wide which is the minimum width of an on-street bicycle lane. Thus, any manoeuvring by the cyclist to avoid pedestrians, fixed objects or oncoming cyclists would require them to either stop or leave the sidewalk. In residential areas, it is common for children to ride their bicycles on sidewalks. This type of cycling is appropriate, however these sidewalks should not be signed as bicycle paths or routes.
If cycling on the sidewalk is so truly dangerous why does the Ministry of Transportation and many municipalities allow children to ride on sidewalks? Do children’s cognitive skills really become better than adults when it comes to dealing with the dangers of riding on sidewalks? Or is it that riding on the road is more dangerous than officials wish to admit.
Ontario’s Ministry of Transportation and Ontario’s municipalities downplay the hazards of cyclist travel on roadways. The two photos below show an example of a typical hazard. As shown in the first photo a cycling lane comes to an end on Hale Street just south of Brydges Street in London, Ontario. The southbound cyclist must now approach a parked vehicle with no alternative but to steer left, further into the southbound lane.
In other instances not all cycles are of the same width, especially when the cyclist is carrying cargo, as shown in the example below. Veering further into a traffic lane means that a potential is created whereby an unsuspecting motorist must steer away from the cyclist when that opportunity does not always exist.
There are other examples of the lack of practical understanding of how cyclists ride that results in the creation of cycling infrastructure that attempts to force riders to perform according to official dictates. In the example below the City of London created a one-way cycling track on Dundas Street in east London presumably in the belief that cyclists would follow the dictates of the signage and only travel in the direction indicated by that signage. The result, as shown in the two photos below is that cyclists just ride the “wrong” way in accordance to the way cyclists have always travelled despite what the signs say.
Those who design cycling infrastructure must understand how cyclists behave, naturally, in the roadway environment rather than dictating that their behaviours must change. Unreasonable theoretical dictates mean that there will be conflicts and a constant need for costly enforcement to subdue cyclists to confirm with those dictates. Many of these problems can be reduced by observing how cyclists behave in their natural state. Detailed documentations using video and still photos are objective ways of providing data of cyclist characteristics and motions. Gorski Consulting continues to provide this vital behavioral data.
There is always a need to emphasize the importance of wearing a seat-belt because in the vast majority of cases seat-belt usage can save an occupant’s life or reduce the severity of injury. However there are instances where seat-belt use can be a problem. Those instances are when a vehicle is submerged in water or a vehicle becomes engulfed in a fire and the occupant becomes entrapped by the seat-belt. No safety device is 100% fool-proof and the public needs to have a realistic appreciation of that. And when dangers exist that could lessen the effectiveness of safety systems those dangers need to be clearly spelt out.
The OPP failed in its obligation to warn the public about the danger of a recent near-drowning when it posted the above photo along with the following comment on its Twitter account:
“A #SaturdayShoutOut to a driver in Norfolk County, whose seat belt use and quick thinking saved his girlfriend’s life. His pickup left the road, rolled into a watery ditch that submerged the vehicle. He managed to cut their seat belts and escape”
The emphasis of this story should not have been about the success of the driver who was able to cut seat-belts and allow him and his passenger to escape his submerged pick-up truck. In many instances such a success is pure luck. In many instances of such rollover even glancing blows to the head can cause an occupant to become disoriented. When a vehicle tumbles and then comes to rest upside down such an occupant can become even more disoriented and not even understand which way is up. Darkness only magnifies the problem. Water coming into the interior of an upside down vehicle can be variable in its volume depending on factors such as the status of the windows and whether they have been broken before the landing in water. Al these complications make success unpredictable and often unsuccessful. Suggesting to vehicle occupants that they can successfully escape such a vehicle with the use seat-belt cutters is not helpful. Seat-belt cutters can help but do guarantee a successful result.
A far more important point that should have been made is that standing water near any roadway can be a real danger. Therefore where ever such water exists is it essential that roads personnel, police and others who have control over the characteristics of a site, ensure that the site contains sufficient roadside safe guards to prevent or minimize that chance that an loss-of-control vehicle could exit the roadway and enter the water. In the present case the OPP should have notified the public that they had examined the site where the pick-up fell into the water and made a determination whether the site contained properly functioning roadside protection from such an occurrence. It is not helpful that the OPP Twitter post did not even mention the specific location where the pick-up truck entered the water. So no one else would capable, independent of the OPP, to inspect the site and determine if an unwarranted danger existed.
This is just another example of numerous past instances where police, who are often the only ones entrusted to investigate and reconstruct collisions, fail to document those instances where roadway problems pose an unreasonable danger to the public. There exists in the police culture that they are there primarily to charge drivers with offenses related to the Highway Traffic Act or Criminal Code and that they should have no responsibility to document roadway safety problems. This is one of the factors that prevents many safety problems from being corrected.