From: kevin mustafa < >
Subject: Re: Toilets on bus routes and Bus Drivers Bill of Rights
Date: 8 July 2026 at 11:03:37 BST
To: Lorraine Robertson < >
Cc: Caroline Russell <[email protected]>
Dear Caroline,
Thank you for sharing the follow-up letter from Transport Commissioner Andy Lord regarding the 25 March 2026 meeting. While he uses polished, regulatory language, a close reading of his response actually provides concrete proof of the systemic failures we have been campaigning against.
I want to break down his admissions on the three core areas so the Transport Committee can hold TfL firmly to account:
1. Toilet Facilities: The Failed Promise of "Resolution"
Andy Lord’s letter confirms that TfL's current framework agreement is failing to protect drivers. Relying on operators to "self-regulate" or react to point-deductions on an index does not keep cabs cool or provide dignity at work.
Now that the Commissioner has put these numbers in writing, will you and the Transport Committee haul TfL back in to explain why a nearly 30% AC defect rate and zero-toilet routes are deemed acceptable in 2026?
As mentioned previously, I am pushing for an urgent Roundtable with Lorna Murphy, and Andy Lord. Your support in forcing them to face the frontline reality—rather than hiding behind a list of 30-year-old laws—is vital.
Yours sincerely,
Founding Member Bus Driver Bill of Rights Campaign
Mob
From:
Sent: 08 July 2026 10:47
To: kevin mustafa < >; Lorraine Robertson < >
Subject: Toilets on bus routes and Bus Drivers Bill of Rights
Hello Kevin and Lorraine,
As Chair of the Transport Committee, Caroline has just received a letter from Andy Lord following up on various issues raised with him the meeting on 25 March 2026.
Within it were three topics that you have been campaigning on:
Details of numbers of toilet facilities across the three bus route priority categories, including how many priority one category routes have no toilet facilities at all
Our policy is to provide a toilet at both ends of a bus route where the round-trip time exceeds 150 minutes. For routes with a round-trip time of less than 150 minutes, a toilet must be available at least at one end of the route.
We prioritise investment in new toilet facilities, working with bus operators and trade unions, based on agreed criteria. Routes are categorised into three priority groups:
• Priority one routes: no toilet provision at either end of the route
• Priority two routes: toilet provision available, but not for all hours of the operating day
• Priority three routes: round trip time greater than 150 minutes, with toilet provision at only one end of the route
There are currently five priority one routes, 15 priority two routes, and 43 priority three routes.
While we had previously resolved all priority one routes, access arrangements have since changed. A detailed review has identified these gaps, which we are now addressing. For priority one routes, additional time is included in the schedule to allow for a comfort break for bus drivers.
Information on whether TfL is using dip sampling to record how many buses have working air conditioning
We do not use dip sampling to record whether buses have working air conditioning on a pass/fail basis. Instead, we use our Engineering Quality Monitoring (EQM) process, which is designed to identify a range of defects rather than to assign a pass/fail score to a vehicle.
EQM inspections covering Heating, Ventilation and Air Conditioning/Cooling (HVAC) were introduced last year. Prior to this, we carried out targeted spot checks based on intelligence relating to localised issues. The introduction of HVAC inspections has formalised and strengthened this approach. From 12 October 2025, the inspection focus switched to heating systems to cover the winter period before HVAC inspections recommenced in the spring.
The identification of a defect does not necessarily mean that the air conditioning system is not operational, but that performance is somewhat degraded in at least one vent position. Where defects are identified, operators are allocated points contributing to their overall Safety Performance Index and are provided with an inspection report. Responsibility for rectifying defects rests with the operator. The purpose of the inspections is to encourage a more proactive approach to maintenance, rather than to indicate that vehicles are falling below a minimum standard.
As the HVAC inspection regime is relatively new, the available dataset is currently limited. During the two-month period in which inspections took place between August and October 2025, 290 vehicles were inspected and 86 defects relating to driver cab air conditioning were identified. These findings do not indicate that vehicles were not in working order, and operators were expected to take corrective action following inspection.
Inspections of bus air conditioning systems recommenced on 4 May 2026 and will continue until 17 October 2026, after which inspections will transition to heating systems. This allows us to build a more robust evidence base over time. 7
Confirmation of whether TfL will begin to recognise the Bus Drivers’ Bill of Rights
Many aspects of the proposed Bus Drivers’ Bill of Rights are already covered by existing agreements, actions or legislation.
Relevant legislation includes, but is not limited to, the Safety at Work Act (1974), the Workplace (Health, Safety and Welfare) Regulations (1992), Working Time Regulations (1998), Management of Health and Safety at Work Regulations (1999), and the Equality Act (2010).
Further regulation is provided by the requirement for all bus operating companies to hold a valid Public Service Vehicle Operator Licence, and to comply with requirements set by the Traffic Commissioner, with enforcement administered by the Driver and Vehicle Standards Agency.
Our framework agreement sets out further contractual obligations that must be met by the bus operating companies, including compliance with vehicle specifications that incorporate the latest Bus Safety Standard. We undertake audits to ensure compliance, including through EQM, which also provides maintenance assurance for heating and cooling systems, as mentioned in more detail above.
In addition, all operators have their own policies, procedures and agreements, which cover all aspects relating to their employees at work.
All bus drivers are required to undertake training as part of their Certificate of Professional Competence and participate in ongoing training to support their development. We also provide clear guidance to drivers on what is expected of them through the Big Red Book.
We encourage any London bus driver who feels their rights are being infringed to raise their concerns with their employer, their union, or us directly. This can also be done via an anonymous reporting system, The Confidential Incident Reporting & Analysis Service (CIRAS), which is available to all drivers.
Kind regards,
Officer I City Hall Greens
LONDONASSEMBLY
City Hall, Kamal Chunchie Way
LONDON E16 1ZE
london.gov.uk
Source: https://saferoxfordstreet.blogspot.com/2026/07/kevin-mustafa-responds-to-andy-lords.html
Auto-imported from Tom Kearney’s blog.
Subject: Re: Toilets on bus routes and Bus Drivers Bill of Rights
Date: 8 July 2026 at 11:03:37 BST
To: Lorraine Robertson < >
Cc: Caroline Russell <[email protected]>
Dear Caroline,
Thank you for sharing the follow-up letter from Transport Commissioner Andy Lord regarding the 25 March 2026 meeting. While he uses polished, regulatory language, a close reading of his response actually provides concrete proof of the systemic failures we have been campaigning against.
I want to break down his admissions on the three core areas so the Transport Committee can hold TfL firmly to account:
1. Toilet Facilities: The Failed Promise of "Resolution"
- The Admission: Andy Lord admits there are currently 5 "Priority One" routes with absolutely zero toilet provision at either end of the route, alongside 15 Priority Two and 43 Priority Three routes with severe deficiencies.
- The Contradiction: He claims TfL had "previously resolved all priority one routes" but that "access arrangements have since changed." This proves TfL's strategy is fragile and reactive.
- The Frontline Reality: His "solution" for Priority One routes is to pad the timetable for a comfort break. A longer schedule is not a toilet. Forcing a driver to hunt for a public restroom mid-route wastes time, increases stress, and fails basic workplace welfare standards.
- The Admission: Between August and October 2025, TfL inspected 290 vehicles and found 86 defects relating directly to driver cab air conditioning.
- The Reality: That is an immediate 29.6% failure rate in the small sample they took.
- The Evasion: He tries to soften this by saying a defect just means performance is "somewhat degraded" rather than broken. To a driver sitting in a glass box in summer, "degraded" cooling means cab temperatures spiking past 40C. Furthermore, shifting focus entirely to heating in October means they have no data on how many AC units seized up or failed over the winter before spring restarted.
- The Admission: TfL is flatly refusing to recognize the Bus Drivers' Bill of Rights, passing the buck by listing decades-old legislation (like the Health and Safety at Work Act 1974) and operator licenses.
- The Counter-Argument: If the Health and Safety at Work Act 1974 or the Workplace Regulations 1992 were actually working on the London bus network, we would not have 28,000 people signing a petition, 5 routes without a single toilet, and a 30% failure rate on cab climate control.
- The Buck-Passing: He states that responsibility for rectifying defects "rests with the operator" and tells drivers to just complain to their employers or use CIRAS. This ignores the fact that TfL owns and controls the network. TfL sets the contracts; they cannot subcontract out their moral and legal duty of care.
Andy Lord’s letter confirms that TfL's current framework agreement is failing to protect drivers. Relying on operators to "self-regulate" or react to point-deductions on an index does not keep cabs cool or provide dignity at work.
Now that the Commissioner has put these numbers in writing, will you and the Transport Committee haul TfL back in to explain why a nearly 30% AC defect rate and zero-toilet routes are deemed acceptable in 2026?
As mentioned previously, I am pushing for an urgent Roundtable with Lorna Murphy, and Andy Lord. Your support in forcing them to face the frontline reality—rather than hiding behind a list of 30-year-old laws—is vital.
Yours sincerely,
Kevin Mustafa
London Bus Safety CampaignerFounding Member Bus Driver Bill of Rights Campaign
Mob
From:
Sent: 08 July 2026 10:47
To: kevin mustafa < >; Lorraine Robertson < >
Subject: Toilets on bus routes and Bus Drivers Bill of Rights
Hello Kevin and Lorraine,
As Chair of the Transport Committee, Caroline has just received a letter from Andy Lord following up on various issues raised with him the meeting on 25 March 2026.
Within it were three topics that you have been campaigning on:
Details of numbers of toilet facilities across the three bus route priority categories, including how many priority one category routes have no toilet facilities at all
Our policy is to provide a toilet at both ends of a bus route where the round-trip time exceeds 150 minutes. For routes with a round-trip time of less than 150 minutes, a toilet must be available at least at one end of the route.
We prioritise investment in new toilet facilities, working with bus operators and trade unions, based on agreed criteria. Routes are categorised into three priority groups:
• Priority one routes: no toilet provision at either end of the route
• Priority two routes: toilet provision available, but not for all hours of the operating day
• Priority three routes: round trip time greater than 150 minutes, with toilet provision at only one end of the route
There are currently five priority one routes, 15 priority two routes, and 43 priority three routes.
While we had previously resolved all priority one routes, access arrangements have since changed. A detailed review has identified these gaps, which we are now addressing. For priority one routes, additional time is included in the schedule to allow for a comfort break for bus drivers.
Information on whether TfL is using dip sampling to record how many buses have working air conditioning
We do not use dip sampling to record whether buses have working air conditioning on a pass/fail basis. Instead, we use our Engineering Quality Monitoring (EQM) process, which is designed to identify a range of defects rather than to assign a pass/fail score to a vehicle.
EQM inspections covering Heating, Ventilation and Air Conditioning/Cooling (HVAC) were introduced last year. Prior to this, we carried out targeted spot checks based on intelligence relating to localised issues. The introduction of HVAC inspections has formalised and strengthened this approach. From 12 October 2025, the inspection focus switched to heating systems to cover the winter period before HVAC inspections recommenced in the spring.
The identification of a defect does not necessarily mean that the air conditioning system is not operational, but that performance is somewhat degraded in at least one vent position. Where defects are identified, operators are allocated points contributing to their overall Safety Performance Index and are provided with an inspection report. Responsibility for rectifying defects rests with the operator. The purpose of the inspections is to encourage a more proactive approach to maintenance, rather than to indicate that vehicles are falling below a minimum standard.
As the HVAC inspection regime is relatively new, the available dataset is currently limited. During the two-month period in which inspections took place between August and October 2025, 290 vehicles were inspected and 86 defects relating to driver cab air conditioning were identified. These findings do not indicate that vehicles were not in working order, and operators were expected to take corrective action following inspection.
Inspections of bus air conditioning systems recommenced on 4 May 2026 and will continue until 17 October 2026, after which inspections will transition to heating systems. This allows us to build a more robust evidence base over time. 7
Confirmation of whether TfL will begin to recognise the Bus Drivers’ Bill of Rights
Many aspects of the proposed Bus Drivers’ Bill of Rights are already covered by existing agreements, actions or legislation.
Relevant legislation includes, but is not limited to, the Safety at Work Act (1974), the Workplace (Health, Safety and Welfare) Regulations (1992), Working Time Regulations (1998), Management of Health and Safety at Work Regulations (1999), and the Equality Act (2010).
Further regulation is provided by the requirement for all bus operating companies to hold a valid Public Service Vehicle Operator Licence, and to comply with requirements set by the Traffic Commissioner, with enforcement administered by the Driver and Vehicle Standards Agency.
Our framework agreement sets out further contractual obligations that must be met by the bus operating companies, including compliance with vehicle specifications that incorporate the latest Bus Safety Standard. We undertake audits to ensure compliance, including through EQM, which also provides maintenance assurance for heating and cooling systems, as mentioned in more detail above.
In addition, all operators have their own policies, procedures and agreements, which cover all aspects relating to their employees at work.
All bus drivers are required to undertake training as part of their Certificate of Professional Competence and participate in ongoing training to support their development. We also provide clear guidance to drivers on what is expected of them through the Big Red Book.
We encourage any London bus driver who feels their rights are being infringed to raise their concerns with their employer, their union, or us directly. This can also be done via an anonymous reporting system, The Confidential Incident Reporting & Analysis Service (CIRAS), which is available to all drivers.
Kind regards,
Officer I City Hall Greens
LONDONASSEMBLY
City Hall, Kamal Chunchie Way
LONDON E16 1ZE
london.gov.uk
Source: https://saferoxfordstreet.blogspot.com/2026/07/kevin-mustafa-responds-to-andy-lords.html
Auto-imported from Tom Kearney’s blog.