Open Letter #VisionZero: Why is TfL allowed to ghost people who've been killed or seriously injured "on or by a bus" in its annual official Road Casualty reportin

By email and blogpost

Sir Sadiq Khan
Mayor of London
City Hall
Kamal Chunchie Way
London E16 1ZE

cc: Transport Commissioner; Deputy Mayor for Transport; Deputy Mayor for Social Justice and Communities, London Victims' Commissioner; TfL Walking and Cycling Commissioner; TfL Board Secretariat; TfL SSHR Panel Secretariat; TfL Chief Safety Officer; TfL Director of Bus; TfL Head of Insights and Direction; TfL Chief Operations Officer; London Assembly Transport Committee Members

2 December 2025​

Dear Sir Sadiq,

Your refusal to respond—or even acknowledge—my Open Letter of 12 September 2025—Will TfL's 'Safety Scandal' serve as your only Legacy?—suggests that you and your TfL appointees reckon that a longstanding policy of contemptuously ghosting me will dissuade me from going public about my volunteer research about TfL's "Institutionally Unsafe" Surface Transport Operation.

Noting that one of your ghosting appointees recently virtue-signalled about a World Remembrance Day for Road Traffic Victims event, I thought it was timely to ask you—as TfL Chair—Why is TfL allowed to ghost people who've been killed or seriously injured "on or by a bus" in its annual official Road Casualty reporting?

Here's the Problem—

A. TfL is Misleading the Public on Bus KSI Data: Despite TfL claiming since March 2018 that it measures Bus KSIs to include everyone "killed or seriously injured on or by a bus", TfL consistently applies a STATS19 definition to this metric, which allows TfL to exclude people —​

"killed on on by a Bus", inter alia, by "collisions on private land, noncollisions (e.g. death due to medical episodes or slips, trips and falls on a bus), incidents outside the Greater London boundary and death occurring after 30 days". ​

The most recent example of TfL publishing this misleading KSI metric can be found on page 30 of TfL's "Travel in London 2025" Annual Overview that will be presented tomorrow to the TfL Board. ​

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Are TfL Board Members aware that Figure 17 is Misleading? ​

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B. TfL excludes 20% of Bus Fatalities from its Annual Road Casualty Reporting.

After years of downloading and reviewing the Bus and Road Casualty data that TfL publishes on its website, it's obvious that Figure 17 must be constructed from STATS19 datasets that TfL knows have excluded about 20% of the preventable fatalities "on or by a bus" that have occurred over the period.​

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Does the TfL Board know that TfL's Bus Casualty Data excludes 1 in 5 Victims?​

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Accordingly, Figure 17 cannot possibly include the total number of deaths "on or by a bus"—including—among the dozens of other fatal incidents TfL's official Annual Road Casualty Reports similarly ignore—the preventable deaths of:​

Ezarhul Islam (73), who fell after a Go Ahead 191 Bus moved suddenly without warning in October 2015, but died while still in hospital in December 2015. Because Mr. Islam died 30 days after his death—which resulted in the Coroner issuing a "Prevention of Future Deaths" Order in June 2016—TfL recorded his death as a "Medical" in origin and didn't include the incident in any official Road Casualty reporting, including Figure 17. Since 1 January 2014, TfL has recorded 69 Fatalities with "Medical" serving as the cause. How many of these "Medical" deaths represent Bus Injury Victims like Mr. Islam, who died 30 days after the incident?

Saba Mirza (31), who was critically injured on a Zebra Crossing by a Metroline Route 46 in November 2016 but, I understand, died while still in hospital in January 2021 (i.e., after 30 days). By the way, the collision incident that eventually killed Saba Mirza is not recorded in any of TfL's published Bus Safety Performance records, including "TfL Bus Drivers critically injuring pedestrians on Zebra Crossings".

A Male Pedestrian (41) hit by a speeding Go Ahead Route 191 Bus at Edmonton Bus Green Station in February 2020.

Melissa Burr (32) hit by a Go Ahead Route 507 Bus at Victoria Bus Station in August 2021.

Stephen Mitchell (60), killed while trying to board a Go Ahead Route 363 Bus in Peckham in November 2022. Until London Assembly Member Keith Prince reported the fact that the Bus Driver was convicted for "causing death by driving without due care and attention" in 2025, on its website TfL previously recorded the incident as a non-fatal "Collision" Incident where the victim required "No Treatment". Since 1 January 2014, TfL has recorded 3053 Bus Collision Incidents where the victim required "No Treatment". How many of these incidents resulted in the death of the victim where the Bus Driver was convicted?

Grace Mecaley (74) hit by Go Ahead Route 212 Bus at Walthamstow Bus Station in December 2023. ​

Note: The Bus Stations where the unknown Male Pedestrian, Melissa Burr and Grace Mecaley were killed by TfL Buses, are—in principle—held to a much higher Health and Safety standard than public roads. Given the Mayor's Vision Zero 'ambition', how can TfL justify failing to report any preventable incident where someone has been killed "on or by a bus" at a Bus Station?
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C. TfL excludes 80-85% of Serious Injuries from Buses from its Annual Road Casualty Reporting

The KSI data TfL shown in Figure 17 is based on Serious Injury data that is substantially lower than the annual data which can be extracted from the Bus Casualty Data that TfL publishes on its website every quarter. Using "Taken to Hospital" as the only reasonable proxy for Seriously Injured, and given that the Mayor admitted to Neil Garratt (AM) that—

'TfL does not receive ongoing updates on the status and health outcomes of people who were previously involved in bus incidents and has no information about the health status of members of the public up to eight years after an incident'

—the vast difference between TfL's published annual Serious Injury figures and TfL's published "Taken to Hospital" data suggests that TfL's official Serious Injury data has to be a number that TfL executives simply invent. This chilling discrepancy demands a clear and evidence-based explanation that neither you nor TfL seem capable of delivering. ​

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Does the TfL Board know that TfL's Serious Injury from Buses data only reflects about 20% of those Reported Injured who've been Taken to Hospital?​

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D. Lack of Data Integrity results in TfL and the Mayor misleading the public about the Real Danger of its Contracted Public Bus Operation.

Building upon a recent press statement by former TfL Board Director and Safety Panel Chair, Michael Liebreich, 'the way TfL spins the data on bus safety in London is reprehensible. Despite the Mayor’s Vision Zero target targeting “no deaths in or by a bus by 2030”, TfL knowingly uses a defective STATS19 dataset to (a) design bus safety policies (b) measure Bus Safety Performance against Vision Zero targets (c) determine management bonuses that excludes around 20% of bus deaths, such as those that occur in private bus stations.

Whenever deaths go down, TfL talk about reductions in deaths (2023), but when they go up they talk about KSIs (2024), and the numbers for serious injuries are (a) internal figures that are never independently audited (b) inexplicably lower than the number of people Bus Operators report to TfL are sent to hospital after being injured in recorded and reported preventable bus safety incidents.

Despite a Vision Zero Programme being in place since July 2018, the reality is TfL buses killed 16 people in 2024—the highest annual figure since 2009, despite a 20% reduction in bus journeys since then. The reality is that London has the least safe bus system of any major European city, and TfL and the Mayor are manipulating data so that Londoners didn’t know it.'​

Here's the—start of a— Solution:

E. "Radical Transparency" and Vision Zero

On 21 December 2023, Neil Garratt AM asked you a question:

"On 11 September 2019, a former TfL Board Director and Safety Panel Chair told the London Assembly Transport Committee and your Deputy Mayor for Transport: “We owe it to the victims of that accident [Sandilands] and we owe it to victims of accidents on the buses and on other parts of the network to get to the bottom of exactly how this organisation is run. How does it deal with this sort of situation? What happened? Why did it happen? How did they do that audit? What lessons can we learn about how to do audits? How can we make sure that we are delivering the radical transparency that is the only way to deliver Vision Zero? I am not trying to be difficult or unpleasant or cause problems, but I can tell you now that if you do not deal with that culture and if you do not have robust audit processes, you will get nowhere near to Vision Zero. Nowhere near to Vision Zero.” Since (a) bus collisions remain at the same level (about 80 per day) as when you announced your Vision Zero Programme in July 2018 and (b) casualties from buses are now higher than when you took office, will you commit to a policy of “radical transparency” on bus safety?"​

In your response, you stated —​

"Transport for London (TfL) has no higher priority than the safety of its customers, staff, and those affected by its operations, and continues to strive to reach the ambitious Vision Zero targets."​

I need not remind you that,​

• since you've been Mayor, your Vision Zero Target for Buses that "no one to be killed on or by a bus by 2030" has been going the other way.

• on 3 July 2025, your own Transport Commissioner admitted to the London Assembly that—

"until this year...the Bus Companies would still be penalised if they curtailed or did not meet their performance requirements because of the hot weather or because they were taking action to support Driver Welfare"​

• you will get nowhere near Vision Zero unless you compel TfL to deliver 'radical transparency' on Londons' failing Bus Safety Performance and unsafe Bus Driver Working Conditions.

As TfL chair, you can begin to reverse your failing Bus Safety record around today by immediately—

1) Issuing a Formal Apology to each of the families of Saba Mirza, Stephen Mitchell, Melissa Lamb and Grace Mecaley—all killed "on or by a bus" under your watch as Mayor and TfL Chair—with a full explanation as to why—since their loved ones' deaths "do not meet STATS19 criteria"—TfL did not include their incidents as part of (a) "the underpinning data source for all road safety policy and from which Transport for London (TfL) built its evidence base for the Bus Safety Standard (BSS)" (b) "TfL’s road safety targets and baseline" (c) in the determination of executives' bonuses for achieving safety targets in, respectively, 2016, 2021, 2022 and 2023, (d) Figure 17.



2) Publishing a Consolidated Annual Figure for people "killed on or by a bus" in London.



Your explanation as why you refuse to order TfL to perform the simple task of publishing a consolidated annual figure that shows all the people "killed on or by a bus" is, frankly, contemptuous of the families of the over 100 victims who—while you have served as Mayor and TfL chair—have been killed "on or by a bus", as well as of the at least 9698 victims who've been sent to hospital from preventable Bus-related injuries over the same period. A truly just Vision Zero Policy would not impose on the families of victims—or on victims themselves—the obligation to interrogate TfL's dubious datasets in order to discern the actual number of how many people have been killed "on or by a bus" in London. Both you and TfL are wittingly adding insult to injury: have you no shame?

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3) Instructing TfL to conduct a Independent Data Integrity Audit of all TfL's published Bus Safety Datasets



Since at least 2022, Keith Prince has been asking you instruct TfL to conduct an Independent Audit of the Integrity of TfL's published Bus Safety Performance Data.

March 2025 - Vision Zero: Bus Safety Data Integrity Audit​

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November 2024- Vision Zero: Independent Data Integrity Audit of TfL Bus Safety Data​

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March 2022 - Independent Audit of TfL’s Quarterly Bus Safety Data​

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Given the obvious problems associated with TfL Bus Safety Data reporting—I've only described a few above—your repeated refusal to even countenance Keith Prince AM's reasonable 'ask' brings to mind a statement that

Lord Hampton​

—"who recently sponsored five, ultimately unsuccessful, safety-related amendments to the​

Better Buses Bill​

in the House of Lords"—made to the press about your refusal to inscribe the London Bus Drivers Bill of Rights into TfL's Framework Bus Contract.​

“TfL will probably say ‘we don’t recognise this because nobody’s brought this to our attention’.

“But if it has been brought to their attention and they’re not doing anything about it, that’s a very different thing.”​

Under your watch as Mayor and TfL Chair, you've presided over a Surface Transport Operation that has produced—

• at least 100 deaths from preventable Bus Safety Incidents;
• 76 deaths of Bus Drivers from Covid-19; and,
• 7 deaths from the 2016 Croydon Tram Crash at Sandilands.

While Bus Safety's obviously been a 'very different thing' at TfL since at least 2001, and despite all your virtue-signally about Vision Zero, you've done nothing to rid TfL of its "Institutionally Unsafe" Culture. In fact, even TfL's dubious datasets evidence that you've made it worse.

TfL's 'Safety Scandal' will be your Legacy.
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Yours sincerely,

Tom Kearney
#LondonBusWatch

E: [email protected]
Twitter: @comadad
Bluesky: @comadad.bsky.social

Blog: www.saferoxfordstreet.blogspot.co.uk
Bus Services [No. 2] Bill Evidence Submission [July 2025]: https://bills.parliament.uk/publications/61937/documents/6837
London Assembly Transport Committee Investigation [April 2024]: https://www.london.gov.uk/about-us/...rom Tom Kearney received 15 December 2023.pdf
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2018 Winner, Community Hero Award — The Johns Hopkins University Alumni Association
2016 Winner, Transport – Sheila McKechnie Foundation SMK Campaigners Award
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Source: https://saferoxfordstreet.blogspot.com/2025/12/visionzero-why-is-tfl-allowed-to-ghost.html
Auto-imported from Tom Kearney’s blog.