I have today received an email from them with a pdf attachment of their new advice ie dated Nov 2010. The relevant bit of advice is:
The only case of exemption from regulations is for cycles when being used between sunrise and sunset, lights or reflectors are not required on cycles used at these times. However it is advisable to fit and use lights and reflectors if cycling in the daytime when visibility is poor, e.g. fog.
The first sentence is an accurate statement of the law as I understood it, and was the reason for my query. (The previous advice treated pedal cycles as motor vehicles.) The second sentence is purely advice, presumably based on common sense. While I'm obviously pleased that they have corrected their advice to conform with the law, I'm not too happy about official advice being smuggled in like this, when it has not been subject to the same consultation processes as the Highway Code - the normal source of road safety advice.
Am I just being picky?
The email I have just received is brief so I'm not clear about the status of the document. I've only posted the relevant bit because the rest appears to be the same as before, but in what is probably a clearer format.