If Bus Reform Is Serious About Safety, Here’s What the Contracts Should Actually Say

Bus reform is moving quickly.

Franchising pilots are underway. Authorities are securing funding. Operating models are being drafted. Delivery plans are being published.

But one question still isn’t being asked clearly enough:

Where is the safety governance architecture written into the contracts?

Not strategy statements.

Not vision documents.

Not high-level commitments to “safe and reliable services”.

I mean the enforceable clauses.

Because once contracts are signed, that’s what governs behaviour.

Reform Is Structural — But Safety Must Be Structural Too

Across several rural and urban areas, early franchising documentation focuses heavily on:

- Delivery structures

- Procurement models

- Commercial frameworks

- Organisational design

All important.

But safety governance cannot sit outside that framework. It must be embedded within it.

If it isn’t written into the contract schedule, it becomes discretionary.

And discretionary safety is fragile safety.

What Already Exists — We Don’t Need to Reinvent It

London has demonstrated for years that structured safety governance is possible.

- Quarterly bus safety publication

- Categorised incident reporting

- Trend analysis

- Vehicle safety standards

- Defined learning mechanisms

The Bus Safety Standard (BSS) was designed to be reusable beyond London.

There is no reason Combined Authorities cannot align with it.

This isn’t about copying London.

It’s about adopting proven structures.

Five Things That Should Be Written Into Every Franchising Contract

1. Quarterly Safety Data Publication

Contracts should require:

- Monthly submission of standardised Safety Performance Data

- Quarterly public dashboards

- Categories including collisions, passenger falls, assaults, near misses

- Rolling trend analysis

- Normalised metrics (per million km / passenger journeys)

If the public is funding services, the public should see the safety performance.

2. Confidential Reporting With No Retaliation

Rail has structured confidential reporting.

Bus does not have a national equivalent.

Contracts should require:

- Membership of an independent confidential reporting scheme

- Just culture protection

- Published anonymised summaries

- No detriment for raising safety concerns

Safety intelligence must be protected.

3. Driver Welfare Written As A Safety Control

Fatigue, thermal stress, lack of facilities and in-motion distraction are not HR issues.

They are collision risk factors.

Contracts should define:

- Maximum driving blocks

- Minimum recovery windows

- Guaranteed toilet access at both ends of routes

- Cab temperature thresholds

- No controller contact while in motion except emergencies

If we say safety is a priority, welfare must be written into the schedule.

4. Bus Safety Standard Alignment

New vehicles entering service should meet the latest relevant BSS elements:

- Advanced Emergency Braking

- Intelligent Speed Assistance

- Direct Vision standards

- Slip and fall mitigations

Operators should submit annual fleet safety gap analyses.

This creates a roadmap instead of vague ambition.

5. Independent Learning Loops

When serious incidents occur:

- Reviews should focus on learning, not blame

- Independent expertise should be involved

- Findings should inform contract performance measures

Rail has structured learning architecture.

Bus should not lag behind.

Why This Matters Now

Franchising is expanding across England.

Different authorities are developing different models.

If safety governance is not standardised at contract level, we risk:

- Inconsistent reporting categories

- Patchwork transparency

- Difficulty identifying national patterns

- Fragmented learning

Most bus services across the country are operated by a small number of major groups.

Without common reporting frameworks, systemic risks become harder to detect.

This is not an accusation.

It is a design warning.

The Opportunity

Authorities are not starting from scratch.

The tools already exist:

- London’s published data model

- The Bus Safety Standard

- Parliamentary evidence from frontline drivers

- Independent academic research

- Existing confidential reporting systems

The opportunity is simple:

Embed safety governance before contracts become entrenched.

It is far easier to design architecture at the beginning than retrofit it later.

Final Thought

Bus reform is structural change.

Safety must be structural too.

If we embed transparency, reporting consistency and welfare-as-risk-control into the operating model now, we build a system that is resilient, accountable and trusted.

If we do not, we will spend the next decade correcting what we failed to write down at the start.