PFD report

Lisa Marie Bowen · Prevention of Future Deaths report

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Issued 20 Nov 2025•Surrey

Report record

Published report and response evidence

This page connects the concerns raised in this report with statements found in recipients’ published responses. A link shows a clear evidence connection; it does not assign responsibility.

View original report
Concerns
5

Raised in this report

Recipients
6

Named on the report

Responses found
4

Of 6 recipients

Stated actions
9

Described in responses

Source document

Full report text

This is the full text from the original published report.

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Concerns and recipient responses

Select any concern, action or position to view the source wording.

Report evidence summary

Concerns raised5

  1. Failure of anti-locking braking systems to reliably recognise tyre detachment
  2. Lack of regulatory requirements for under-run protection device strength
  3. Lack of industry testing and data collection on braking following tyre detachment
Responses linked to these concerns

Each statement is shown once, even when linked to more than one concern.

Actions described in response An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.5

  1. Action

    Continue regularly reviewing ABS design with specialist suppliers to identify appropriate safety updates.

    Stated by Toyota (GB) PLC and Toyota Motor Corporation and Toyota Motor Europe NV/SAStated in progressThe respondent said that this action was in progress when they made their response on 21 November 2025.
  2. Action

    Implement ABS design changes that can help detect tyre detachment while driving.

    Stated by Toyota (GB) PLC and Toyota Motor Corporation and Toyota Motor Europe NV/SAStated completedThe respondent said that this action was complete when they made their response on 21 November 2025.
  3. Action

    Examine the possibility of introducing further amendments to UNECE regulations addressing the identified concerns.

    Stated by Department for TransportStated plannedThe respondent said that this action was planned when they made their response on 21 November 2025.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.3

  1. Position

    Total tyre detachment is highly unusual and rare, with only one known case affecting ABS performance and producing a fatal outcome.

    Stated by Toyota (GB) PLC and Toyota Motor Corporation and Toyota Motor Europe NV/SADisputes the concernThe respondent disagreed with part of the concern or the basis for it.

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure of anti-locking braking systems to reliably recognise tyre detachment

Wider context from the report

“Concern 1 As stated above, the brakes on the Deceased’s Toyota Corolla did not work effectively because, when the brake pedal was pressed, the vehicle’s anti-locking braking system was activated, and it operated to reduce the braking effect almost entirely. At the inquest I heard evidence that: (i) Following the tyre detachment, the speed of the wheel with a detached tyre was much higher than the speed of the three other wheels with undamaged tyres. (ii) The anti-locking braking system recognised this differential in speed, but perceived that the problem lay with the three slower wheels and assumed that they had locked or were at risk of doing so. (iii) Consequently, each time the brake was applied, the anti-locking braking system immediately released the braking pressure to the three slower wheels in order to avoid them locking, thereby prioritising the preservation stability and steerability over braking. (iv) In this way, the anti-locking braking system was working in accordance with its design. (v) The system was unable to recognise that the problem in fact lay with the fourth wheel which was rotating much more quickly than the other wheels because its tyre had detached. (vi) The outcome was an unintended effect of the system’s design which arose because the specific scenario, of tyre detachment occurring whilst the vehicle was being driven, which was thought to be a rare occurrence, had not been taken into account in the design process. (vii) Testing of anti-locking braking systems and braking performance, following a tyre detachment, is not undertaken by the industry as a whole and, therefore, relevant data is not collated. At the inquest and PFD hearing I was informed that – (i) A large number Toyota Corolla motor cars continue to be driven on the roads of the UK with the same anti-locking braking system as was in Ms Bowen’s vehicle. (ii) Anti-locking braking systems are developed by a small number of specialist companies and it may well be that other vehicles currently on the roads of the UK have systems similar to that in Ms Bowen’s car. (iii) The company which developed the anti-locking braking system used in Ms Bowen’s car (Advics) has since developed and improved its system so that it is better able to recognise if one wheel speed is so different from the others that the data from that wheel should be ignored as unreliable. However, the improvements are not foolproof, not least because acceleration or deceleration of the vehicle affects this function. (iv) The anti-locking braking system now used in Toyota Corolla motor cars has been developed by a different company (Bosch) and it is not known by Toyota precisely how it would respond following a tyre detachment whilst the vehicle is being driven. (v) It seems that relevant regulations concerning anti-locking braking systems do not address or specify requirements relating to the scenario faced by Ms Bowen. Although the detachment of a tyre whilst a vehicle is being driven is thought to be a rare occurrence, I am concerned that that may not be the case and that if it were to happen again, in the same or similar circumstances, the risk of future death continues. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of regulatory requirements for under-run protection device strength

Wider context from the report

“Concern 2 This concern relates to the catastrophic failure of the under-run protection bar (“the Device”) that was in place on the piece of the lorry with which Ms Bowen collided. At the inquest I heard and accepted expert evidence which established that: (i) The Device was compliant with all relevant regulations and legal requirements, save only that fixing bolts of an incorrect strength had been used to attach it to the lorry’s chassis. (ii) The strength of the Device was grossly insufficient, either to have prevented any underrun, or even to have reduced the extent of the Toyota’s under-run. (iii) The Device would not have been strong enough to do so even if the correct fixing bolts had been used. One expert stated that he was aware that some under-run protection devices are capable of providing protection against much greater forces than is currently required under the law and he expressed disappointment that the relevant legislation and regulations are not more robustly framed, so as to require the use of these much stronger devices. I am concerned that, in the absence of more stringent requirements in relation to the degree of force that an under-run protection device should be capable of withstanding, a risk of future death arises. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of industry testing and data collection on braking following tyre detachment

Wider context from the report

“Concern 1 As stated above, the brakes on the Deceased’s Toyota Corolla did not work effectively because, when the brake pedal was pressed, the vehicle’s anti-locking braking system was activated, and it operated to reduce the braking effect almost entirely. At the inquest I heard evidence that: (i) Following the tyre detachment, the speed of the wheel with a detached tyre was much higher than the speed of the three other wheels with undamaged tyres. (ii) The anti-locking braking system recognised this differential in speed, but perceived that the problem lay with the three slower wheels and assumed that they had locked or were at risk of doing so. (iii) Consequently, each time the brake was applied, the anti-locking braking system immediately released the braking pressure to the three slower wheels in order to avoid them locking, thereby prioritising the preservation stability and steerability over braking. (iv) In this way, the anti-locking braking system was working in accordance with its design. (v) The system was unable to recognise that the problem in fact lay with the fourth wheel which was rotating much more quickly than the other wheels because its tyre had detached. (vi) The outcome was an unintended effect of the system’s design which arose because the specific scenario, of tyre detachment occurring whilst the vehicle was being driven, which was thought to be a rare occurrence, had not been taken into account in the design process. (vii) Testing of anti-locking braking systems and braking performance, following a tyre detachment, is not undertaken by the industry as a whole and, therefore, relevant data is not collated. At the inquest and PFD hearing I was informed that – (i) A large number Toyota Corolla motor cars continue to be driven on the roads of the UK with the same anti-locking braking system as was in Ms Bowen’s vehicle. (ii) Anti-locking braking systems are developed by a small number of specialist companies and it may well be that other vehicles currently on the roads of the UK have systems similar to that in Ms Bowen’s car. (iii) The company which developed the anti-locking braking system used in Ms Bowen’s car (Advics) has since developed and improved its system so that it is better able to recognise if one wheel speed is so different from the others that the data from that wheel should be ignored as unreliable. However, the improvements are not foolproof, not least because acceleration or deceleration of the vehicle affects this function. (iv) The anti-locking braking system now used in Toyota Corolla motor cars has been developed by a different company (Bosch) and it is not known by Toyota precisely how it would respond following a tyre detachment whilst the vehicle is being driven. (v) It seems that relevant regulations concerning anti-locking braking systems do not address or specify requirements relating to the scenario faced by Ms Bowen. Although the detachment of a tyre whilst a vehicle is being driven is thought to be a rare occurrence, I am concerned that that may not be the case and that if it were to happen again, in the same or similar circumstances, the risk of future death continues. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Insufficient strength of under-run protection devices

Wider context from the report

“Concern 2 This concern relates to the catastrophic failure of the under-run protection bar (“the Device”) that was in place on the piece of the lorry with which Ms Bowen collided. At the inquest I heard and accepted expert evidence which established that: (i) The Device was compliant with all relevant regulations and legal requirements, save only that fixing bolts of an incorrect strength had been used to attach it to the lorry’s chassis. (ii) The strength of the Device was grossly insufficient, either to have prevented any underrun, or even to have reduced the extent of the Toyota’s under-run. (iii) The Device would not have been strong enough to do so even if the correct fixing bolts had been used. One expert stated that he was aware that some under-run protection devices are capable of providing protection against much greater forces than is currently required under the law and he expressed disappointment that the relevant legislation and regulations are not more robustly framed, so as to require the use of these much stronger devices. I am concerned that, in the absence of more stringent requirements in relation to the degree of force that an under-run protection device should be capable of withstanding, a risk of future death arises. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure of anti-locking braking regulations to specify requirements for tyre detachment

Wider context from the report

“Concern 1 As stated above, the brakes on the Deceased’s Toyota Corolla did not work effectively because, when the brake pedal was pressed, the vehicle’s anti-locking braking system was activated, and it operated to reduce the braking effect almost entirely. At the inquest I heard evidence that: (i) Following the tyre detachment, the speed of the wheel with a detached tyre was much higher than the speed of the three other wheels with undamaged tyres. (ii) The anti-locking braking system recognised this differential in speed, but perceived that the problem lay with the three slower wheels and assumed that they had locked or were at risk of doing so. (iii) Consequently, each time the brake was applied, the anti-locking braking system immediately released the braking pressure to the three slower wheels in order to avoid them locking, thereby prioritising the preservation stability and steerability over braking. (iv) In this way, the anti-locking braking system was working in accordance with its design. (v) The system was unable to recognise that the problem in fact lay with the fourth wheel which was rotating much more quickly than the other wheels because its tyre had detached. (vi) The outcome was an unintended effect of the system’s design which arose because the specific scenario, of tyre detachment occurring whilst the vehicle was being driven, which was thought to be a rare occurrence, had not been taken into account in the design process. (vii) Testing of anti-locking braking systems and braking performance, following a tyre detachment, is not undertaken by the industry as a whole and, therefore, relevant data is not collated. At the inquest and PFD hearing I was informed that – (i) A large number Toyota Corolla motor cars continue to be driven on the roads of the UK with the same anti-locking braking system as was in Ms Bowen’s vehicle. (ii) Anti-locking braking systems are developed by a small number of specialist companies and it may well be that other vehicles currently on the roads of the UK have systems similar to that in Ms Bowen’s car. (iii) The company which developed the anti-locking braking system used in Ms Bowen’s car (Advics) has since developed and improved its system so that it is better able to recognise if one wheel speed is so different from the others that the data from that wheel should be ignored as unreliable. However, the improvements are not foolproof, not least because acceleration or deceleration of the vehicle affects this function. (iv) The anti-locking braking system now used in Toyota Corolla motor cars has been developed by a different company (Bosch) and it is not known by Toyota precisely how it would respond following a tyre detachment whilst the vehicle is being driven. (v) It seems that relevant regulations concerning anti-locking braking systems do not address or specify requirements relating to the scenario faced by Ms Bowen. Although the detachment of a tyre whilst a vehicle is being driven is thought to be a rare occurrence, I am concerned that that may not be the case and that if it were to happen again, in the same or similar circumstances, the risk of future death continues. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Continue regularly reviewing ABS design with specialist suppliers to identify appropriate safety updates.

Verbatim wording from the response

“As in all areas of car design changes, Toyota is committed to the continued evolution of ABS. The design is therefore regularly reviewed and, if appropriate, updated in conjunction with specialist suppliers, with changes gradually introduced starting from new models. Although total tyre detachment (as in this incident) is very rare, some of the ABS design changes already implemented can help detect tyre detachment while driving.”

Source location

Response from Toyota GB PLC
Page 2 · response
Published 21 November 2025

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Implement ABS design changes that can help detect tyre detachment while driving.

Verbatim wording from the response

“As in all areas of car design changes, Toyota is committed to the continued evolution of ABS. The design is therefore regularly reviewed and, if appropriate, updated in conjunction with specialist suppliers, with changes gradually introduced starting from new models. Although total tyre detachment (as in this incident) is very rare, some of the ABS design changes already implemented can help detect tyre detachment while driving.”

Source location

Response from Toyota GB PLC
Page 2 · response
Published 21 November 2025

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Examine the possibility of introducing further amendments to UNECE regulations addressing the identified concerns.

Verbatim wording from the response

“Having reviewed your report, and considered the current provisions in UNECE Regulations, I have instructed my officials to examine the possibility of introducing further amendments to these regulations to address the concerns raised. The Vehicle Certification Agency (VCA) confirmed that the braking system of the car involved in the collision was approved to R13H. Recent amendments have been made to the provisions of R13H to allow approval authorities more scrutiny over the functioning of brake systems in non-fault conditions, but these are applied at the discretion of the issuing authority.”

Source location

Response from Department for Transport
Page 1 · response
Published 21 November 2025

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Gather information over the coming months to better understand risks to existing vehicles on the road.

Verbatim wording from the response

“The above measures will only resolve the risk in new vehicles. Since there is considerable uncertainty over the potential risk to existing vehicles on the road, I have asked my officials to gather what relevant information they can over the coming months to better understand the situation. From this my department will consider whether any retrospective action should be taken.”

Source location

Response from Department for Transport
Page 2 · response
Published 21 November 2025

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Present the case at the relevant UNECE forum and collaborate on whether specific R13H provisions are necessary.

Verbatim wording from the response

“My officials will therefore highlight the particulars of this case at the relevant UNECE forum in May and collaborate with members of that forum on whether specific provisions are necessary for R13H.”

Source location

Response from Department for Transport
Page 2 · response
Published 21 November 2025

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Total tyre detachment is highly unusual and rare, with only one known case affecting ABS performance and producing a fatal outcome.

Verbatim wording from the response

“The total detachment of a tyre from a wheel of a passenger vehicle is highly unusual. You heard evidence from an expert automotive engineering consultant who described the specific scenario that preceded this collision – namely total tyre detachment - as “very unusual and rare”. This is consistent with Toyota’s experience.”

Source location

Response from Toyota GB PLC
Page 2 · response
Published 21 November 2025

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Accurate detection of complete tyre detachment is not currently technologically possible, and no industry solution yet exists.

Verbatim wording from the response

“The experts at the inquest agreed that, unfortunately, the technology does not yet exist to detect accurately when a tyre has completely detached from a car. According to one of those experts, work is being done to understand how anti-lock braking systems could be designed to detect complete tyre detachment – but no one in the industry yet has the answer.”

Source location

Response from Toyota GB PLC
Page 2 · response
Published 21 November 2025

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Uncertainty about risks to existing vehicles prevents immediate decisions on retrospective safety action.

Verbatim wording from the response

“The above measures will only resolve the risk in new vehicles. Since there is considerable uncertainty over the potential risk to existing vehicles on the road, I have asked my officials to gather what relevant information they can over the coming months to better understand the situation. From this my department will consider whether any retrospective action should be taken.”

Source location

Response from Department for Transport
Page 2 · response
Published 21 November 2025

Open published response

Other statements in published responses

These actions and other statements could not be clearly connected to one concern in this report.

Recipient-stated actions An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.4

  1. 1

    Gradually implement enhanced TPMS messages and buzzer alerts to inform drivers of tyre-pressure loss and discourage driving in dangerous conditions.

    Stated by Toyota (GB) PLC and Toyota Motor Corporation and Toyota Motor Europe NV/SAStated in progressThe respondent said that this action was in progress when they made their response on 21 November 2025.
  2. 2

    Review and enhance customer guidance and retailer training materials on vehicle safety, including wheel and tyre checks.

    Stated by Toyota (GB) PLC and Toyota Motor Corporation and Toyota Motor Europe NV/SAStated completedThe respondent said that this action was complete when they made their response on 21 November 2025.
  3. 3

    Communicate tyre safety, warning indicators and essential safety-check procedures through customer and public information channels.

    Stated by Toyota (GB) PLC and Toyota Motor Corporation and Toyota Motor Europe NV/SAStated in progressThe respondent said that this action was in progress when they made their response on 21 November 2025.
  4. 4

    Consider whether retrospective action should be taken regarding existing vehicles.

    Stated by Department for TransportStated plannedThe respondent said that this action was planned when they made their response on 21 November 2025.

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Gradually implement enhanced TPMS messages and buzzer alerts to inform drivers of tyre-pressure loss and discourage driving in dangerous conditions.

Verbatim wording from the response

“In addition, Toyota has been gradually implementing changes in the design of its new cars that will ensure that drivers are provided with more information about any reduction in tyre air pressure and are”

Source location

Response from Toyota GB PLC
Page 2 · response
Published 21 November 2025

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Review and enhance customer guidance and retailer training materials on vehicle safety, including wheel and tyre checks.

Verbatim wording from the response

“TGB also continually reviews and enhances the guidance provided to customers, and training materials provided to its retailer network, to support safe and responsible vehicle use. For example, its review and enhancement of its Service Advisor training materials have increased awareness of key customer vehicle safety considerations (including but not limited to the importance of wheel & tyre checks).”

Source location

Response from Toyota GB PLC
Page 2 · response
Published 21 November 2025

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Communicate tyre safety, warning indicators and essential safety-check procedures through customer and public information channels.

Verbatim wording from the response

“In addition to the information included in the owner’s manual/user guide, TGB regularly communicates through its social media, customer communications and website channels to promote safe driving, awareness of vehicle warning indicators and essential safety-check procedures. This has included articles on the importance of tyre maintenance, tread depth, labelling, tyre pressure warning lights and more.”

Source location

Response from Toyota GB PLC
Page 2 · response
Published 21 November 2025

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Consider whether retrospective action should be taken regarding existing vehicles.

Verbatim wording from the response

“The above measures will only resolve the risk in new vehicles. Since there is considerable uncertainty over the potential risk to existing vehicles on the road, I have asked my officials to gather what relevant information they can over the coming months to better understand the situation. From this my department will consider whether any retrospective action should be taken.”

Source location

Response from Department for Transport
Page 2 · response
Published 21 November 2025

Open published response
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Information checked against the published report and official responses · Data reviewed 7 Sep 2026 · About data quality and limitations

Official responses located
4/6

Data last updated 7 September 2026