Keeping commercial vehicles safe to drive (roadworthy)
How to keep heavy goods vehicles (HGVs) safe to drive, including daily checks, inspections, maintenance and record keeping.
All drivers must carry out a daily vehicle inspection and complete a driver’s defect report for each vehicle before commencement of driving.
A company should operate a ‘nil defect’ reporting system, which means that a defect report must be submitted each day irrespective of whether there are any defects to report. If there are no defects, then a driver should state ‘nil defects’ on his report.
The ‘nil defect’ reporting system is a requirement of the Traffic Commissioner and failure to adhere to this requirement could jeopardise holding an Operator’s Licence.
Defect sheets must be properly completed and include a driver’s name, vehicle registration number, odometer reading as well as the date and time of the check. Any rectification or repair must be noted on the driver’s defect report.
The defect sheets will form part of the maintenance record for the vehicle and must be maintained for a minimum of 15 months.
You must carry out a daily walkaround check to see if your HGV is safe to drive, and record the results of the check.
You must carry out at least one walkaround check of the whole vehicle every 24 hours, usually before you drive it.
Daily walkaround checks are part of having an effective vehicle maintenance system.
The Driver and Vehicle Standards Agency (DVSA) has produced this guide to explain the responsibilities and systems involved in maintaining vehicles in a roadworthy condition, regardless of operating conditions, fleet size or vehicle type. The procedures and systems explained in this guide are useful for operators, drivers and all those who are responsible for operating, maintaining or providing commercial goods and passenger carrying vehicles. The general principles apply equally to light goods and passenger vehicles below the operator licensing thresholds and for vehicles that are otherwise exempt.
It is not enough to rely on a maintenance system alone, because this cannot ensure that vehicles are roadworthy. To ensure best practice, you will need to combine good quality maintenance practices and skills with supervision and effective management of the system.
New vehicle operators
If you are a new operator, you will find practical advice on how to devise, install and monitor a system for ensuring roadworthiness. If you follow the advice given in this guide, you can make sure you are complying with the law and that your compliance can be monitored and controlled.
Experienced vehicle operators
If you are an established or experienced vehicle operator, you will be able to use this guide as a benchmark to assess whether your systems are sufficiently comprehensive or should be reviewed and improved in order to maintain compliance. This guidance applies to you whether you carry out your own maintenance, contract out maintenance or do a combination of both. DVSA do not specifically define a new or experienced vehicle operator because what constitutes an experienced operator could vary.
However, we do make suggestions as to what could make an experienced operator:
- If you have been trading under this licence or a previous licence for more than three years
- If you have been trading under this licence for more than 1 year, and you have been visited by a DVSA inspector and been approved as satisfactory
- If your company has been trading under this licence for a length of time such that you can prove that your roadworthiness process is effective and fully established
- If you can demonstrate suitable evidence proving your experience when questioned by DVSA or the Traffic Commissioner. This could be a combination of staff experience and skills, maintenance procedure experience and substantial defect reports/data
We recognise that there are different methods and systems from those that are described within this guide that can result in vehicles being maintained in a roadworthy condition. If you are an operator who wishes to adopt different systems, you must still satisfy Traffic Commissioners that the system you use is effective. Traffic Commissioners will only agree to variations that will not reduce the control necessary to ensure satisfactory maintenance.
There must be a firm management commitment to review and improve maintenance systems where defects are found on vehicles or when the fleet size or the nature of the business is changing. As a licensed operator, you can also be assured that the maintenance systems described in this guide will be accepted by the Traffic Commissioners, provided that the resulting condition of your vehicles remain satisfactory. If this is not the case, however, Traffic Commissioners reserve the right to require more stringent arrangements from you (eg shorter periods between inspections), and the competence of the persons who carry out safety checks may be challenged. The ultimate test will be whether a vehicle is, in fact, roadworthy.
The procedures and systems described in this guide relate to responsibilities for roadworthiness, the different types of inspections, inspection intervals, data storage, inspection facilities, planner updates and essential reviews. This guide includes many references to written maintenance records; however, using an electronic vehicle maintenance system can provide effective management of all relevant data including safety inspections, maintenance scheduling and driver defect reporting. Keep in mind that as a general principle computer records are acceptable, provided that they contain the essential information that can be made available for examination.
Getting it right
DVSA recognises that operators of heavy goods will not get everything right all the time. However, we do want you to be vigilant and responsible. The penalties for and consequences of non-compliance to you the operator and/or driver – and to the general public – can range from the inconvenient to the very serious and, sometimes, to the catastrophic. You and your staff may be fined or prosecuted, and your vehicles may be prohibited. At worst, you may cause serious injury or fatalities because of badly maintained vehicles.
Key points of a good maintenance system
Use these important key points as a guide to help you plan and set up a compliant and effective maintenance system for your vehicles.
- A driver or responsible person must undertake a daily walkaround check, preferably immediately before a vehicle is used.
- First use inspections are essential for operators who lease, hire or borrow vehicles. These are especially important where vehicles and trailers have been off the road for some time.
- Drivers must report promptly any defects or symptoms of defects that could adversely affect the safe operation of vehicles. Reports must be recorded and provision should be made to record details of any rectification work done.
- Drivers’ defect reports used to record any faults and rectification work must be kept for at least 15 months.
- Operators must ensure that safety inspections are carried out at the stated frequency.
- Safety inspections must include those items covered by the appropriate statutory annual test.
- Safety inspections should be pre-planned, preferably using a time-based programme.
- The system of safety inspections must be regularly monitored, especially in the early stages.
- Any remedial work carried out as a result of safety inspections must be recorded.
- The safety inspection record must include:
- name of owner/operator
- date of inspection
- vehicle identity (registration mark/trailer number)
- make and model
- odometer (mileage recorder) reading, if appropriate
- a list of all the manual items to be inspected
- details of any defects
- name of inspector
- full details of any repair work and who did it
- a signed declaration that any defects have been repaired satisfactorily and the vehicle is now in a safe roadworthy condition.
- On certain types of vehicles and for some operations, intermediate safety checks may be necessary.
- Records of safety inspections must be kept for at least 15 months for all vehicles, including vehicle/s that have been removed from the operator licence.
- Staff carrying out safety inspections must be competent to assess the significance of defects. Assistance must be available to support the safety inspection process.
- There must be an internal system to ensure that unroadworthy vehicles are removed from service, with someone responsible for taking vehicles off the road.
- Operators who undertake their own safety inspections must have the correct tools and facilities for the size of the fleet and type of vehicle operated.
- All operators should have access to a means of measuring brake efficiency and setting headlamp aim. For vehicles showing signs of visible exhaust smoke, a diesel smoke meter should be used to ensure that the level of smoke emission is within the legal requirements.
- Operators are responsible for the condition of vehicles and trailers that are inspected and/or maintained for them by agents, contractors or hire companies.
- Operators who have contracted out their safety inspections must draw up a formal written contract with an inspection agency or garage, and this must be retained on file. Such operators should view inspection records and have a means of regularly monitoring the quality of work produced for them.
- The dates when safety inspections are due must be the subject of forward-planning.
- A maintenance scheduling system, planner or wall chart should be used to identify inspection dates at least six months for manual systems or can be dynamic for electronic systems.
- Any system of maintaining roadworthiness of vehicles should be effectively and continually monitored.
- Any changes by licensed operators to arrangements for safety inspections must be updated on the vehicle operator licensing system (VOL).
- Drivers must be adequately trained and given clear written instructions about their responsibilities.
Responsibilities for roadworthiness
This section gives best practice advice on the responsibilities that an operator or driver will have to undertake to ensure the roadworthiness of their vehicle. It covers what you are legally required to do according to the law.
As a user of vehicles, it is your responsibility to ensure that the vehicles you use are roadworthy. It is an offence to use an unroadworthy vehicle on the road. The term ‘user’ of a vehicle applies to the driver and the person paying the driver to act for them.
If you are an operator of heavy goods vehicles (HGVs), you must meet the governing legislation that the Traffic Commissioners have outlined in their Statutory Guidance Document. This is now in legislation, so if you operate within the UK or outside of the UK, you should ensure vehicles are roadworthy.
Operators must comply with the declaration they give to the relevant traffic commissioner that they will ensure that their vehicles are operated in a fit and serviceable condition. If operators intend making any change to their maintenance arrangements, they must update the details on the vehicle operator licensing system.
Hire, loan or lease vehicles
The vehicle itself may either belong to the user or be in their possession under any agreement for hire, hire purchase, loan or lease. The user of a towing vehicle is responsible for the roadworthiness of a trailer even if it does not belong to them
If foreign trailers are used then the user is responsible for the roadworthiness in terms of condition but also in terms of the technical design of the trailer.
Traffic commissioners require that all vehicles be maintained in a fit and serviceable condition when operated under an operator’s licence. DVSA’s examiners support traffic commissioners by providing assessments of the effectiveness of operator’s systems in meeting this requirement. We will, therefore, focus on the levels of compliance and standards of roadworthiness rather than how operators achieve the high standards expected. This provides operators with considerable freedom to tailor their systems to the needs of their business.
When it comes to ensuring the roadworthiness of a vehicle, there are two types of essential inspections – which differ in scope and depth. Each type is used for a different purpose and requires different levels of skill to be carried out effectively.
The two types of inspection are:
- daily walkaround checks
- first use inspections/regular safety inspections.
An inspection should not be confused with a service. A service contains items requiring routine maintenance, usually determined in scope and frequency by the vehicle’s usage and the recommendations of the vehicle’s manufacturer.
Daily walkaround checks
This section looks at the daily walkaround check. It offers best practice advice on setting up a system for reporting faults and looks at defect reports, while clearly stating your legal position.
A driver or responsible person must undertake a daily walkaround check before a vehicle is used. As a driver, DVSA recommend this check is carried out before you first drive the vehicle on the road each day.
Where more than one driver will use the vehicle during the day's running, the driver taking charge of a vehicle should make sure it is roadworthy and safe to drive by carrying out their own walkaround check; however, due to health and safety implications this may not be practical on all occasions.
An example of a system for managing in-service driver changes is where a walkaround check is carried out by a responsible person, and the drivers monitor the vehicle during the day's running. When there is a change in driver during the day, it is sometimes unsafe to carry out a walkaround check, for example at a stop. This will be considered acceptable where there is a robust driver defect reporting system in place, which details the initial walkaround check and any defects or ‘nil’ defects reported during the day for the various drivers of that particular vehicle.
The driver is always legally responsible for the condition of the vehicle while in use. Therefore, conducting a daily walkaround check is a vital part of a driver’s core role. Operators can delegate the walkaround check to a responsible person, who must carry out a minimum of one check in 24 hours.
The check should cover the whole vehicle or combination. On multi-trailer operations, a check should be made on each trailer being used. The check should cover interior and exterior items that can be safely assessed without necessarily the use of a workshop [see Annex 8 for walkaround check items].
Assistance may be required at some time during the check, for example, to see that lights are working. Alternatively, a brake pedal application tool may be used as an effective way of making sure stop lamps are working, and that the braking system is free of leaks. In addition, a torch, panel lock key or other equipment may be needed.
It could be beneficial to incorporate a post use check, to save downtime.
It is important that drivers are aware of the overall vehicle dimensions, including trailer and load. High vehicles should display an in-cab overall height indicator. It is also important to consider route planning before starting your journey if low bridges need to be avoided.
A system of reporting and recording defects
There must be a system of reporting and recording defects that may affect the roadworthiness of the vehicle. This must include how they were rectified before the vehicle is used. Daily defect checks are vital, and the results of such checks must be recorded as part of the maintenance system. It is important that enough time is allowed for the completion of walkaround checks and that staff are trained to carry them out thoroughly. Drivers should be made aware that daily defect reporting is one of the critical elements of any effective vehicle roadworthiness system.
Examples of how to perform a walkaround check can be found on YouTube under DVSA HGV or PSV driver’s daily walkaround checks.
Drivers’ defect reports
As the driver, you are legally responsible for the condition of your vehicle when in use on the road.
Drivers must report any defects, or symptoms of defects, that could prevent the safe operation of the vehicles. In addition to daily walkaround checks, you must monitor the roadworthiness of your vehicle when being driven, and be alert to any indication that the vehicle is developing a fault eg warning lights, vibrations or other symptoms. When a vehicle is on site work, you should walk around the vehicle before leaving the site to identify any faults. If any safety defects are found, you must not use the vehicle on the road until it is repaired.
Providing a written report
Any defects found during the daily walkaround check, while the vehicle is in use or on its return to base, must be the subject of a written report by the driver or some other person responsible for recording defects.
The details recorded should include:
- vehicle registration or identification mark
- details of the defects or symptoms
- the reporter’s name
- who the defect was reported to
- assessment of the defect
- rectification work
- date rectification work was completed.
It is also common practice to use a composite form that includes a list of the items checked each day. Where practicable the system should incorporate ‘nil’ reporting when each driver makes out a report sheet - or confirms by another means that a daily check has been carried out and no defects found. Electronic records of reported defects are acceptable and must be available for 15 months, along with any record of repair.
All drivers’ defect reports must be given to a responsible person with sufficient authority to ensure that any appropriate action is taken. This might include taking the vehicle out of service. Any report listing defects is part of the vehicle’s maintenance record and must be kept for at least 15 months, together with details of the rectification work and repairer.
It is good practice to have ‘nil’ defect reports as they are a useful means of checking that drivers are carrying out their duties and these forms can be used for audit purposes.
A ‘nil’ defect reporting system demonstrates a check has been conducted and is a positive report that the vehicle is free from defects.
If you are an owner-driver, you will probably not have anyone to report defects to, except your transport manager (if you have one). In these cases, defects and the remedial action taken can simply be recorded and held for at least 15 months.
Drivers must be made aware of their legal responsibilities regarding vehicle condition and the procedures for reporting defects. Operators must ensure that all drivers are adequately trained to perform this function, and this may be part of their driver’s certificate of professional competence training. Driver’s responsibilities should be detailed in writing, describing defect reporting systems as well as any other duties they are expected to perform. The driver should sign to confirm they have received their responsibilities in writing and understand what is required. A copy of the document should be kept on file. Drivers share the responsibility for the vehicle’s roadworthiness with the operator. They may be fined or prosecuted for roadworthiness offences found on vehicles if they are considered partly or wholly responsible.
Minor repairs by drivers
If you are an operator, you should bear in mind that drivers who are expected to repair minor defects in service would need appropriate training.
Traffic commissioners can take action against a driver who fails to complete an adequate walkaround check. This could lead to a driver conduct hearing, which may result in the loss of the vocational driving licence.
Traction services and third party trailers
Operators can provide a traction-only service to customers who wish to own their own trailers for branding and loading purposes but do not wish to operate vehicles to pull them. It is also common practice for an operator who may own trailers but is also contracted to tow third party trailers not owned or maintained by them.
Ensuring third party trailer roadworthiness can be problematic for the traction service operator. Usually for short-term use the trailer owner would be responsible for the routine maintenance of the trailer, including the safety inspection (SI). Under these circumstances, traction operators are reliant on the trailer owner to correctly carry out their own safety inspections within their stated frequency and complete any necessary repairs.
The traction operator is responsible for ensuring a thorough walkaround check of the tractor/trailer combination is carried out to establish it is safe prior to use. If defects are identified during the walkaround check, these should be rectified prior to use.
Traction operators would be expected to work with the trailer owners to ensure any trailers operated fall within the owner's agreed SI frequency and that they are roadworthy. It is best practice for the trailer owner to provide evidence for the operator that first use checks and safety inspections have been undertaken and demonstrate there are no outstanding defects reported for the trailer. There must also be a robust system in place to ensure defects identified during the walkaround check, or develop during use, are recorded and rectified before the tractor/trailer combination is operated in an unroadworthy condition.
The driver/operator bears the full responsibility for the safe operation and roadworthiness of the tractor/trailer combination at the time it is being driven.
If a PG9 (roadworthiness prohibition) is issued to the trailer for a defect which would not have been apparent to the driver - either during the walkaround check or because of faults which would not be evident by the performance, handling or warning systems of the vehicle during use - there is a potential issue associated with the trailer owner’s maintenance regime.
Operators are responsible for ensuring any prohibitions issued to vehicles/trailers used by the operator are cleared or they have notified the vehicle/trailer owner a prohibition has been issued. Clearance inspection results are normally recorded against the operator who received the prohibition notice. Failure to take appropriate action when a prohibition is issued could associate the operator with the offence of using the vehicle/trailer in contravention of a prohibition notice. Operators are also urged to proactively follow up potential issues with the vehicle/trailer owner and third-party maintenance provider with the aim to addressing any shortfall within the maintenance systems.
Although the operator does not own the trailer, they are ultimately responsible for using the combination in an unroadworthy condition, and the traction operator’s compliance risk score will be affected [see Section 6]. It is, therefore, strongly recommend that hauliers obtain from the trailer owner or customer the safety inspection interval for the trailer/s concerned and a copy of the current relevant inspection reports to ensure the trailer has been correctly inspected within the stated frequency.
A good practice guide for third party trailer operators has been produced by IRTE. This details some more useful information on how to operate third party trailers safely and legally.
Regular safety inspections and first use inspection
This section describes why regular safety inspections and the first use inspection are essential to an effective roadworthiness maintenance system.
Inspection scope and content
A safety inspection can be a freestanding inspection of just those items affecting road safety and certain environmental issues. Or it can be part of a more comprehensive inspection that, in addition, takes into account items relating to the vehicle’s work, performance and economic operation. Regular safety inspections are essential to an effective roadworthiness maintenance system. Although a part of the overall vehicle maintenance plan, the inspections should ideally be undertaken as a separate, albeit often sequential, operation to routine servicing and repair.
This provides the maintenance programme with the flexibility to intensify or otherwise change frequency of inspections. It also allows the introduction of ad-hoc inspections, should they be required, without affecting frequency of servicing and other routine work (eg when the operating conditions call for more regular checks or when first use inspections are required). In addition, freestanding inspection reports can be produced which provide the operator with the means of determining not only the roadworthiness of individual vehicles in service but also the overall effectiveness of their vehicle maintenance system, thus enabling the instigation of any changes that may be necessary.
Being cost effective
Although primarily undertaken in the interest of safe vehicle operations, safety inspections– together with prompt remedial action– are also cost effective. The early indication of wear, damage or maladjustment may prevent sudden failure of components resulting in unscheduled downtime or prevent wear becoming so advanced that premature replacement becomes necessary.
The driver is always legally responsible for the condition of the vehicle while in use; therefore, conducting a daily walkaround check is a vital part of a driver’s core role. Operators can delegate the walkaround check to a responsible person, who must carry out a minimum of one check in 24 hours.
First use inspection
Vehicles brought into use
When a vehicle or trailer is first brought into use with an operator it should have undergone a first use inspection, which is essentially the first safety inspection. New vehicles entering service that have undergone a recorded pre-delivery inspection (PDI) that is as comprehensive as a safety inspection will not require a further inspection. Used vehicles, not previously operated should be given a full safety inspection.
Vehicles being returned to use
If a vehicle has been off the road for a period longer than the planned maintenance inspections, it should be given a full safety inspection prior to being brought back into use. A note must be placed on the vehicle maintenance file to show the vehicle has been off the road. Hire, loan or lease vehicles If you are the user of the vehicle, it is your responsibility to ensure that any hired, leased or borrowed vehicle is in a roadworthy condition and has all the necessary certification when used on the road. Therefore it is essential that you do a daily walkaround check (as described in Section 3) before any such vehicle is used. It is your responsibility to be able to provide maintenance records covering the period of use.
Hired vehicles should be inspected by a member of staff from the rental company prior to being made available for each rental. This pre-rental inspection should include all major mechanical parts, exterior and interior condition and electronic equipment, fluids, tyre condition and pressure. The operator should keep a copy of this checklist as proof that the rental company has carried out a pre-rental inspection. This inspection, along with a walkaround check by the operator, will help ensure that the vehicle being used is roadworthy. If the operator has any doubt that the rental company has carried out a comprehensive pre-rental inspection of the vehicle/trailer, then a first use inspection should be carried out.
Rental and leasing companies who are members of the British Vehicle Rental and Leasing Association are regularly inspected under the BVRLA’s Quality Assurance Programme, where the maintenance records, branches and vehicles are inspected by an independent UKAS accredited inspector. This inspection can be used as part of your regular monitoring of the rental and leasing companies who provide vehicles for you.
A safety inspection must include all the items covered by the statutory annual test. Examples of Safety Inspection forms can be found in Annex 4A(HGV) and 4B(PSV), the safety inspection form can be any format as long as the mandatory items listed in Section 1 of this guide are included on the form.
Standards to be applied
Reference should be made to manufacturers’ recommended tolerances to ensure that each item covered by the safety inspection is inspected properly and limits of wear and tolerance are adhered to.
In addition, DVSA produces annual test inspection manuals, which give details of inspection methods and pass/fail criteria. Copies of the annual test inspection manuals can be downloaded free of charge by visiting the GOV.UK website.
It must be emphasised that the standards for the annual test are the minimum legal standards and should be used as guidance for the safety inspection. The inspector will need to consider the frequency of inspection, the age of the vehicle, expected mileage and type of work undertaken to assess whether a component would remain in a serviceable condition before the next inspection is due.
Safety inspection intervals
Operational needs must not override safety considerations. Safety inspections should, where it is practicable, be programmed to follow a time-based pattern. The frequency at which inspections are undertaken should be determined by assessing the level of mechanical degradation likely to be incurred over a period as a result of the vehicle’s usage. This will depend on such factors as:
- the age and type of vehicle operated
- the recommendations of the vehicle manufacturer
- the nature of its load, the equipment and fittings it carries or supports
- the type and range of operations on which it is likely to be engaged
- the type of terrain and the nature of the environment in which it operates or is likely to operate
- the distance and speeds at which it travels and the journey times.
Assessing the above factors for each vehicle will, in the majority of cases, enable a time-based programme of inspections to be formulated. Some operations, however, are subject to continuous change, or vehicles can frequently be reassigned alternative tasks or routes, making the adoption of a strictly time-based inspection programme impracticable.
Mileage-based inspection programmes may be more suitable for some operators but will need to be linked to time.
Older vehicles and trailers
National statistics show that as vehicles and trailers age, the average annual MOT failure rate increases and they are more likely to experience in-service roadworthiness defects than newer vehicles. Therefore, the guidance has reflected that older vehicles and trailers will need more frequent maintenance, and has indicated a minimum safety inspection frequency of six weeks requirement for vehicles and trailers aged 12 years and older. However, depending on usage, ie low mileage and light conditions, the frequency may be extended.
New vehicle operators
If you are a new vehicle operator, you will not have the benefit of experience or vehicle maintenance records to call upon.
Setting the inspection frequency will need to take into account the type of work undertaken, the operating conditions, the age of vehicle and mileage covered. Whatever the safety inspection interval is, its effectiveness in ensuring that the vehicle is safe for use on the road must be regularly monitored.
Monitoring is especially important in the early stages.
A guide to safety inspection intervals
An inspection frequency would normally range between 4 to 13 weeks. See table below for examples of operating conditions.
|A.||Lightly loaded vehicles– easy operating conditions||13-6 weeks|
|B.||General haulage– trunking||10-5 weeks|
|C.||Arduous work– constant heavy loads||8-4 weeks|
|D.||Off road– difficult conditions||4 weeks|
|E.||Vehicle 12 years or older||6 weeks|
Experienced vehicle operators
If you are an experienced operator, you are free to tailor these inspections to suit the nature of your operations and vehicle characteristics. You may even deploy more than one system across a fleet, where vehicles and the nature of their work vary, even where one particular aspect of vehicles’ operations require a greater inspection frequency than the whole vehicle fleet (see case study 2). Systems will be judged primarily on their effectiveness in maintaining roadworthiness.
It follows, therefore, that in order to maintain an inspection regime that is sufficiently flexible to accommodate these changing criteria, it might be more appropriate to adopt an inspection frequency determined by, for instance, the vehicle’s mileage. However, if you modify your inspection schedule, it is sensible to monitor the effect on roadworthiness on a monthly basis. If an unacceptable increase in defects were seen then a change back to the original schedule would be necessary.
The Vehicle Operator Licensing system (VOL) records a time based frequency for both vehicles and trailers. Therefore, if a mileage-based frequency is adopted, the expected maximum equivalent time-frequency should be entered into the system (up to 13 weeks). Then ensure the mixed frequency box is ticked on VOL to record that a varied inspection frequency is being used. This same process should be used if a mixed time frequency is being used for different vehicles or trailers on the fleet.
Leasing companies may be able to assist operators with determining the frequency of inspections.
Whichever safety inspection interval is decided upon, the inspection frequency should not be extended without updating the Vehicle Operator Licensing system. The following safety inspection should be carried out within the specified weekly or mileage-based time scale, and not beyond. To allow some flexibility in planning safety inspections it is recommended that the International Organisation for Standardisation (ISO) week numbering system is used. With this system the safety inspection should be completed within the relevant ISO week it falls. ISO defines the week as always starting with Monday through to Sunday. See Annex 6 for an example of a maintenance planner.
Example of a six weekly SI interval has been decided using the ISO week planner. For this example, the vehicle came into service and had a first use inspection in week 10 of the ISO calendar. The following safety inspections should then be completed within ISO week 16, 22, 28, 34, 40, 46……etc. If a safety inspection was completed outside the planned schedule, for example because of a breakdown, a new schedule may need to be created. For the example given above it would not be permissible to carry out an early SI in week 20 and then have an eight-week interval to week 28. The operator would need to either carry out another SI at week 22 - and continue with the originally planned schedule - or reschedule 6-week intervals from week 20 to 26, 32 ….etc. Vehicles that are only used for part of the year, or that have been out of service for some time, should be inspected before they are brought back into service.
When they are being used, the subsequent safety inspection intervals should be determined in accordance with the table above, conditions of use and the equivalent annual mileage (eg 20,000 miles covered over a six month period represents an equivalent annual mileage of 40,000).
Trailers not permanently coupled, but in regular use, need to be assessed on their conditions of work and anticipated mileage.
Where there are doubts about what interval to choose, new operators are advised to be cautious and make more, rather than less, checks.
Where vehicles operating in difficult conditions - eg in quarry work or on building or land reclamation sites, and vehicles carrying corrosive substances where conditions result in accelerated component wear and vehicle damage - the operator is advised to increase the number of safety inspection checks above the guidance in the table shown.
Case study 1 – N E Hall
N E Hall are a new haulage company who need to implement a maintenance schedule. They estimate an annual mileage of 100,000 miles and will be carrying out arduous work. Based on DVSA’s graph they selected an initial time interval of four weeks for their inspections.
Case study 2 – Bob’s Construction
Bob’s Construction are an experienced operator and have two 7.5 t trucks which operate on the road and also on building sites. They found that 75% of defects identified during the four weekly inspections were suspension related due to the terrain.
They decided to modify their maintenance schedule such that the suspension was inspected every three weeks and the whole vehicle was inspected every six weeks. After trialing this for six months they noticed an improvement in the suspension condition but did not see any deterioration in other parts of the vehicle due to the reduced frequency. VOL would need to be updated to show the new six week frequency but also tick the mixed frequency to cover the three weekly suspension check.
Case study 3 – CJS Couriers Plc
CJS Couriers Plc are a courier company that normally operate within the Bristol area but occasionally carry out national or continental deliveries. CJS found that, during normal operations, the four weekly system was too frequent as very few defects were ever found. However, when there is an increase in national or continental deliveries they were seeing a spike in defects during that period. Generally, during a local delivery period, they will drive 50 miles a day on each vehicle. A national delivery could result in a daily mileage of 360 miles depending on location, and a continental delivery would be significantly more. They decided to switch the policy so that the vehicles are inspected every 2000 miles or six weekly, whichever comes first.
Case study 4 – Pronto Bus Plc
Pronto Bus Plc are a large operator with great experience. They use two different models of buses: the Speedliner and the Retro. Because of the age difference between the two models, they found they had significantly different levels of reliability. The Speedliner vehicles, which were over 12 years old, were very unreliable and so they needed to inspect them every four weeks to maintain safety. The Retro, which is a newer vehicle, was much more reliable and so the inspection frequency was reduced to six weekly. After monitoring this for 12 months, they found no change in roadworthiness for the Retro model. An update on the Vehicle Operator License System (VOL) will be required due to the change in the inspection frequency. The maximum frequency will need to be recorded on VOL. In this case, six weeks and the mixed frequency box ticked.
Case study 5 – MacDonald Bus Ltd
MacDonald Bus Ltd are an experienced operator who run 152 buses around the Edinburgh area. They operated a strict 28 day inspection frequency but felt this was excessive because 75% of the fleet was relatively new. They decided to reduce the frequency to 42 days for the 114 buses, which are under six years old, and keep the remaining, older, buses, as they are. This was seen to have no negative effect on roadworthiness over a 12 month monitoring period.
They were able to reduce their yearly inspections by 300, thus freeing up buses and staff for other jobs. In this case, the Vehicle Operator License system (VOL) will need to be updated with the maximum frequency. The mixed frequency will also need to be ticked.
Case study 6 – Move4U
Move4U are a removal company with a fleet of vans and trucks of various sizes. They initially used a four weekly inspection as recommended by DVSA but felt this was too often. They increased this to 12 weekly, but after a six month monitoring period, they saw a large rise in defects resulting in more prohibitions from DVSA at the roadside. They then decided to reduce this to six weekly as a more realistic frequency.
After 12 months of monitoring, the defect level has matched what it was at four weeks, and so Move4U have decided to use this schedule permanently.
Please note: The case studies are based on fictional examples and not related to current operators.
Safety inspection report forms
A safety inspection report must be completed for each safety inspection for both vehicles and trailers. If the safety inspection report is to be stored electronically, then the paper version does not need to be retained. This does not rule out the use of electronic devices (eg tablets) in place of paper safety inspection reports.
Each report must show at least the following:
- name of owner/operator
- date of inspection
- vehicle identity (registration/trailer number)
- make and model
- odometer (mileage recorder) reading (if appropriate)
- a list of all items to be inspected
- an indication of the condition of each item inspected
- details of any defects found
- name of inspector
- details of any remedial/rectification or repair work and who carried out the work
- a signed statement that any defects have been repaired satisfactorily and the vehicle is now in a safe and roadworthy condition.
Examples of suitable safety inspection report forms are given in Annex 4A and 4B.
The report may contain details of any work to be carried forward. In particular, further checks may be needed on certain items deemed likely to deteriorate during service and make the vehicle unroadworthy before the next scheduled inspection or routine service.
Intermediate safety checks
With some types of vehicle and operation, it may be necessary to check some components more often than at full safety inspections. For example, a vehicle used in urban areas such as a public service vehicle or a local delivery vehicle, or vehicles used in hilly areas, may require a weekly brake component and adjustment check together with a steering and suspension inspection. It is sometimes necessary to check components following repair work.
Ad hoc safety inspection intervals
Safety inspections may be needed at times outside the scheduled programme. Examples include when the vehicle is used for harder work or covers greater distances than usual (eg vehicles used on site).
Electronic capture and storage of safety inspection data
Safety inspection and repair work records, whether undertaken by operators or contracted out, must be kept for at least 15 months as part of a vehicle’s maintenance history.
Operators must, however, ensure that the electronic records are complete and available, or can be made available on request for inspection at the operating centre. If you hire, lease or borrow a vehicle you are responsible for its roadworthiness and must have available, if required, copies of any inspections that have been carried out while the vehicle is in your possession.
The right digital solution can add benefits to any maintenance system by providing ease of access to all relevant data in one place, including:
- safety inspections
- unplanned maintenance
- inspection reports
- driver defect reporting system
- fleet management.
Linking to related data - such as technical information - means that it can be obtained quickly, as well as giving you the ability to create maintenance schedules, which are both planned and dynamic.
Systems can be linked to those run by maintenance providers, giving shared data on:
- maintenance history
- scheduled repairs
The automated processes that can be created help to organise and manage an efficient and well planned system.
What the maintenance system needs to do
It’s ultimately the roadworthiness of the vehicles operated that will demonstrate if the system is well designed and meets the required standards.
Operators, as well as drivers, are responsible for the condition of their vehicles. Operators need to satisfy themselves that any systems/devices used do not undermine the running of a safe and efficient fleet.
Software/hardware providers should make sure that any system they design takes into account the requirements of this guide.
Important features of a computerised system:
- the availability of hard copies of records to be produced on request
- it must be tamper proof (eg records can’t be changed at a later date)
- it must be clear what’s been checked and by whom
- there must be a clear end-to-end audit trail
- data file which covers all maintenance records for the fleet
- fully electronic inspection records
- collaborative digital planners
- drivers walkaround check and defect reporting application
- compliance dashboard
- meet data protection requirements (including the general data protection regulation)
- data back-up and disaster recovery system.
Any maintenance software should be developed in line with the maintenance schedule agreed as part of the operator’s licence requirements, and in consultation with this guide.
Making sure your vehicle maintenance system is secure
To make certain that your system is secure you should consider:
- digital authentication – eg a login or PIN
- date and time stamping
- an audit trail on both the part of the maintenance provider and the operator.
Whilst enforcement action for non-compliance rests with the operator, it is their responsibility to make sure that the system provider can guarantee the reliability of the data.
Recording the maintenance of hired or temporary vehicles
Digital systems must take account of such vehicles as defined within this guide.
Keeping old data
Where vehicles or trailers change ownership, the records relating to these - even in digital format - must still be available to the original operator in accordance with this guide.
Managing the system
Regular administration and backup of electronic data should be undertaken. It is ultimately the responsibility of the operator to ensure the safekeeping of such data, along with an effective management process.
Easy access to the data - for management and enforcement purposes - must also be available. Data security and integrity must exist with any system used - this may include some form of clear audit trail.
DVSA do not ‘approve’ any software systems or hardware devices. It is ultimately the operator’s responsibility to make sure that the maintenance system used meets the requirements of their operator licence. However, for the DVSA Earned Recognition scheme, IT systems have been validated to ensure correct reporting of key performance indicators.
Conducting the daily walkaround check
The daily walkaround check can be done using a handheld device, and the results stored digitally.
These can include devices like tablets or smartphones, which can be given to the driver or allocated to the vehicle. The system must provide:
- a suitable method of digital signature
- secure data input and storage
- confirmation that the vehicle is in a roadworthy condition at the start of the journey.
Forms can also be completed by hand and then scanned and saved digitally. Images must be easily accessible by date and vehicle.
It should always be possible to produce a minimum of the current day’s record at the roadside. Systems must include effective date and time stamping to make sure data is reliable, including nil defect reporting where it is included.
Nothing in this guide prevents the operator from using systems with additional functions.
Recording in-service defects
The same systems can record defects which happen whilst a vehicle is in use. This can be an extension of the same process, with the ability for the driver to ‘add’ a record for that day including information about the action taken. Such systems should reflect the requirements as shown above.
In all cases, there must be confirmation that the vehicle is safe to use.
Creating a safety inspection programme
Planning safety inspections
Safety inspections must ideally be planned six months in advance. Vehicles that are subject to a statutory annual test can plan their year’s programme - such as cleaning and major servicing - to avoid duplication of work associated with the test.
A simple method of drawing up a programme is to use a year round planner or flowchart. Digital systems are equally fine, and electronic record management and storage systems will often include a planning feature.
Please use the guidance set out in this guide when using a digital system. Such systems must:
- be capable of providing records in ‘real time’ to the operator
- include an audit process that shows date and time stamping.
Regular safety inspections
You can collect and store safety inspection information using an electronic device. The records must show a clear audit trail from inspection to sign-off after repair (if one is needed). It is very important that it includes a declaration that the vehicle is fit for service or not.
Completing safety inspection report forms
A separate record must be completed for each safety inspection of a vehicle or trailer. Where the record of the safety inspection is to be stored digitally, then the checklist used for the inspection does not need to be kept. You can use an electronic device (eg a tablet) in place of a checklist.
Capturing and storing safety inspection data electronically
Barcoding or scanning of defects found or work done is acceptable providing that a means of interpreting each code is available. See important features of a computerised system.
Safety inspection records stored digitally must be:
- capable of producing hard copy information if required.
Computer records must contain the same information as any comparable manual form.
A person undertaking safety inspections must be technically competent and operationally aware of the safety standards that apply to the vehicles they examine. They should have been trained in the techniques of vehicle examination, diagnosis and reporting, and possess a sound working knowledge of the relevant inspection manuals produced by DVSA. A safety inspector could prove technical competence by solely time served experience. However, with modern vehicle systems and working practices, it is strongly recommended that inspectors obtain relevant technical qualifications and achieve an automotive technical accreditation such as IRTEC (Inspection Technician Accreditation) or similar - meeting a recognised quality standard for the vehicles they inspect.
A safety inspector should not be expected to carry out repair or servicing work during the course of the examination.
Use of assistants
There may be times during the course of an inspection when the inspector will require the assistance of someone to operate certain vehicle controls. The operator must ensure that this assistance is available when required. The vehicle’s driver can often provide such assistance.
Authority to remove or reinstate a vehicle
If you are the operator, you must ensure that someone within your organisation has the authority to decide whether a vehicle is fit for service at all times.
That person must be available to decide whether a vehicle can be allowed back into service after repairs. This responsibility may be delegated, in writing (ie in the form of a standard agreement) provided that it is made clear what their responsibilities are.
The transport manager retains legal responsibility for vehicle roadworthiness, regardless of whether his or her activities are delegated.
Vehicles should be cleaned regularly on top, inside and underneath. This will make it easier to spot defects at scheduled safety inspections and during the daily walkaround checks.
4.13 Duties of staff
It is important that all staff with an involvement either directly (eg drivers and workshop staff) or indirectly (eg transport management) are made fully aware of the company’s legal and moral responsibilities as an operator of road vehicles. They should also be made aware of the subsequent importance of ensuring the effective operation of the vehicle maintenance programme.
Drivers, workshop staff and those otherwise responsible for the condition of vehicles should be individually informed in writing of their specific duties and responsibilities – particularly regarding safe vehicle operation.
Emphasis should be placed on the importance of maintaining an effective safety inspection programme and the role they play in promoting and sustaining its integrity.
One method might be to write to each relevant employee in duplicate, thus permitting a returned signed copy to be retained by the company.
Safety inspection and repair facilities
This section covers the facilities needed to undertake safety inspections and the arrangements needed if you do not undertake your own inspections. The same guidance applies to the repair of any defects found during safety checks.
If you are an operator, you must decide whether to undertake your own safety inspection and maintenance work in-house or to contract all or part of the work to someone else.
If you decide to provide your own safety inspection facilities, you must ensure that they are adequate for the job, even if the inspection is contracted out.
It is strongly recommended that the maintenance facility demonstrates their competence by achieving a recognised accreditation for workshop standards. This can be gained through manufacturers’ franchised workshop quality standards or by an independent assessment, like the IRTE National Workshop Accreditation scheme.
Safety inspection facilities
Facilities should include:
- undercover accommodation for the largest vehicle in the fleet. This is required to ensure that safety checks can be conducted satisfactorily in all weathers (depending on fleet size the building may need room for more than one vehicle at a time)
- tools and equipment appropriate to the size and nature of the fleet
- an adequate under-vehicle inspection facility
- adequate lighting
- access to brake test equipment (eg a roller brake tester, decelerometer)
- access to headlamp test equipment
- access to emissions testing equipment
- access to steam or pressure under-vehicle washing facilities
- a safe working environment.
If an operator fails to maintain vehicles in a safe and roadworthy condition with the facilities provided the Traffic Commissioner may take regulatory action.
For guidance on the DVSA approved equipment relating annual test: www.gov.uk/become-an-mot-station/approved-testing-equipment
As part of promoting good practice and improving safety standards, the Society of Operations Engineers (SOE) has produced a series of technical guides. Most are free to download and include the best practice for wheel security and safe working practices.
The SOE technical guides can be found using this link: www.soe.org.uk/resources/technical-guides
Wheels and tyres
The code of practice for the selection and care of tyres and wheels for commercial vehicles (developed jointly by the Department for Transport, the British Standards Institute and industry and trade associations) recommends that following road wheel removal and refitting, the wheel nut torque should be checked – after the vehicle has been standing for 30 minutes or after having travelled for between 40 km and 80 km (25 to 50 miles). All re-torque checks must be recorded and retained on file.
Tyre management system
A robust tyre management system is essential for any professional vehicle operator and should ensure:
- that tyres in service are appropriate to the vehicle and operating conditions
- that tyre age is monitored and that tyres aged more than 10 years old should not be used except on a rear axle as part of a twin wheel arrangement. Where tyres more than 10 years old are used, their age should be recorded and a specific risk assessment, that considers the speed and loading conditions that the vehicle will operate under (for example, operating only in urban areas) is done
- tyre pressures are maintained and monitored
- that vehicle tyres are regularly and closely examined for damage and wear with mechanisms in place to address any identified issues
- that processes exist to distribute best practice in tyre management throughout the fleet
- that staff dealing with tyre management are properly trained and empowered to act with sufficient authority
- that any technician dealing with tyre inspections or repairs is properly trained and qualified
- that any on-site tyres are properly stored
- that drivers are properly trained and equipped to recognise and report tyre issues.
Braking performance assessment
As per the annual test, every safety inspection must assess the braking performance of the vehicle or trailer. It is strongly advised that a calibrated roller brake tester (RBT) is used at each safety inspection to measure individual brake performance and overall braking efficiencies for the vehicle or trailer to the annual test standards. However, it is also acceptable to use an approved and calibrated decelerometer to measure overall brake efficiency values for vehicles without trailers.
In the case of trailers, an Electronic Braking Performance Monitoring System (EBPMS) may be used as a means to assess trailer-braking performance and provide a brake performance value while the vehicle is in service (for further details see EBPMS section).
Brake testing should be undertaken with the vehicle or trailer in a laden condition in order to achieve the most meaningful results; however, due to basic design limitations or restriction caused by the type of cargo normally carried, this is sometimes not possible.
A printout of the brake efficiency test from either the RBT or decelerometer should be attached to the safety inspection record. If the brake test equipment cannot produce a printout, efficiency results must be recorded by the inspector on the safety inspection report.
To help operators arrange a brake performance assessment with safety inspections, it is acceptable for a satisfactory brake performance assessment to be carried out within the same week of the planned safety inspection. Brake efficiency testing can be carried out by either an approved RBT or decelerometer test. Measured braking performance assessment can be carried out by means of EBPMS.
Where it is impractical to obtain a brake efficiency test or a measured performance assessment on a safety inspection, the braking performance must still be checked by means of a road test carried out under controlled and safe conditions.
The use of brake temperature measurement can improve the effectiveness of a road test and is an established method to assess if individual brakes are operational. Brake disc/drum temperature readings should be compared across an axle after a laden road test or by in-service monitoring, using a brake temperature sensor, which can be a simple handheld device or using a more sophisticated remote monitoring system.
Brake temperature readings would need to be well above ambient temperature with relatively consistent readings taken for each brake across an axle. Brakes which are cold (ambient temperature) or showing an inconsistent reading from the brake on the opposite side on the same axle, should be investigated further.
The safety inspection record must be annotated how the braking performance was assessed. However, a road test to check the braking performance for all planned safety inspections will usually be inadequate. It is therefore normally expected that the vehicle or trailer should complete at least three successful brake efficiency tests spread throughout the year in addition to the annual MOT test.
If deficiencies in brake performance have been identified either during the use of the vehicle or trailer or at the safety inspection appropriate remedial action must be taken to address the issue. Where braking system rectification is not obvious, a laden measured brake efficiency test must also be carried out confirm the brakes are performing satisfactorily before the vehicle or trailer can be considered as roadworthy. The results of this brake test must be kept as evidence of repair with the operator’s maintenance documentation and can be included as one of the brake tests required to meet the minimum requirement.
Electronic braking performance monitoring system (EBPMS)
Braking performance of the vehicle and/or trailers can be monitored and assessed using EBPMS. Braking performance must be monitored and compared against the statutory requirements for the type of vehicle or trailer fitted with EBPMS.
To enable EBPMS to be used as evidence for the operators’ preventative maintenance system, ideally, the system would identify the position of a defective brake. It must, however, be capable of at least identifying overall vehicle braking performance value.
DVSA does not ‘approve’ software systems or hardware devices but does acknowledge an industry standard specification for EBPMS (see below) which may be used to supplement the operators’ maintenance arrangements. Ultimately, it is the operators’ responsibility to ensure their vehicles are operated in a safe condition at all times, and that the maintenance system used is fit for their particular set of circumstances and meets the undertakings of the operator licence.
Manufacturers of EBPMS will need to demonstrate how their system adequately monitors and reports braking performance and that it conforms to the industry standard specification.
In-service braking performance defects
The system must be capable of alerting the operator to under-performing service brakes.
Safety inspection brake performance evidence
It is essential that the system provides braking performance evidence where this is to be used for the safety inspection braking performance report. Evidence can either be stored electronically or as a printout, which should be retained in-line with the Guide to Maintaining Roadworthiness.
Reports must be in a format that clearly identifies:
- the vehicle or trailer
- assessment date and the monitoring period
- a value for the service braking performance for the assessment period.
The monitoring period shall be the period between the scheduled safety inspection intervals.
Operators who use EBPMS as service braking performance evidence, are expected to include a braking performance report on every safety inspection record, unless either a suitable roller brake test, decelerometer test, or brake temperature measurement was conducted.
If EBPMS provides insufficient data to deliver a service braking performance value an alternative method shall be used to assess service braking performance and records retained.
Parking brake performance
Where EBPMS is unable to assess parking brake performance, but the service brake performance is reported to be performing satisfactorily by an EBPMS, a visual inspection of the parking brake components and check of system operation would be accepted as the minimum requirement for a parking brake safety inspection. If there is any doubt over the parking brake performance, further tests must be conducted.
Electronic Braking Performance Monitoring System Industry Standard Specification
Where operators experience problems with braking performance either at annual test, roadworthiness inspections or through operational performance and fail to meet the standards outlined above, the Traffic Commissioner may take regulatory action.
Furthermore, if an operator demonstrates an adverse compliance history whilst meeting the requirements outlined above it will be necessary to introduce further measures.
Emissions and air quality
For vehicles showing signs of visible exhaust smoke, a diesel smoke meter should be used to ensure that the level of smoke emission is within the legal requirements. Information on the levels of permitted exhaust smoke is contained in DVSA‘s annual test inspection manuals.
Vehicles fitted with emission control systems (ECS) need to be maintained in line with manufacturers' recommendations. Drivers and operators are required to monitor the ECS warning lamps, and ensure the diesel exhaust fluid level (AdBlue®) is maintained correctly.
Any emission control system faults need to be rectified as soon as possible and repaired in line with manufacturer’s standards.
It should be noted that a person who fails to maintain an emission control system, or modifies or removes it, could be found guilty of an offence. This would put your operators’ licence at risk, and the potential penalties are unlimited fines.
Contracted out arrangements
If you decide to use a contractor, you are still responsible for the condition of vehicles that are inspected and/or maintained for you by your agents or contractors.
Care must be taken to ensure that the facilities used by the contractor areadequate and that the staff are competent. The list of facilities can be used to check a contractor. You should also ascertain that the contractor is in possession of an inspection manual and has suitable inspection sheets.
Drawing up a contract
It is essential to have a written contract that sets out precise details of vehicles covered and frequency and type of check, along with a repair policy. Such a contract must be kept on the operator's maintenance file and produced on request. You must also make sure the maintenance provider details are up-to-date on the Vehicle Operator Licensing system (VOL).
Even when a maintenance contract exists between you (the operator) and a contractor, you remain legally responsible for the condition of the vehicle, the authorisation of any repair work undertaken and the retention of records. You need to be satisfied at all times that the level of maintenance agreed matches the demands placed upon vehicles and that the standards achieved by the contractor are kept at a sufficiently high level. You should, therefore, talk regularly with the contractor to ensure that they are familiar with the operational needs of the vehicles they are required to inspect and repair. This knowledge is important if the contractor is to be called upon to advise on a particular course of action – particularly when your technical know-how is limited.
Even when you get on well with a contractor, you should have a system for regularly monitoring the quality of work done.
Obtaining first time pass rate annual test data from the contractor is one way of checking that their performance is satisfactory, but this should be supplemented by other checks.
Any sign of unreliability, incompetence or other shortcomings causing a reduction in the standards achieved should receive prompt attention. Here again a good working relationship can help, but if problems persist you may well consider a change of contractor.
As an operator, you may employ a visiting agent to undertake safety inspections, repairs and routine maintenance. However, you should ensure that the agent is qualified to work on the type of vehicles you operate and that adequate facilities and tools are used. As is the case for contracted-out maintenance, you are responsible for vehicle condition and upkeep of records.
Roadside safety inspections
Only emergency repairs may be done at the roadside. Routine maintenance, including safety inspections and repairs, may not be carried out on the public highway.
Planning a safety inspection programme
Safety inspections must be planned in advance. Vehicles that are subject to a statutory annual test may have their year’s programme planned around the anticipated test date to avoid duplication of work associated with the test, such as cleaning and major servicing. An electronic scheduling system can be used to effectively plan maintenance activities for the fleet. Or, a simple method of drawing up a programme is to use a year planner or flow chart. An example can be found in Annex 6.
Electronic vehicle maintenance management and storage systems often incorporate a dynamic electronic planning feature which automatically schedules the next inspection. The information should be kept in the simplest form possible and displayed prominently. This will serve as a reminder of programmed inspections or of any changes that have been necessary.
All vehicles subject to programmed attention should be included. Ideally, planning systems should set safety inspection dates at least six months in advance. Vehicles’ test dates should be included, as should servicing and other ancillary equipment or calibration dates, eg tachograph, lifting equipment, etc.
Any planning system should be updated regularly, indicating the progress of the programme and recording any extra work carried out. Vehicles that have been taken off the operator’s licence - or other vehicles temporarily off-road - should have their period of non use identified, and a note should be made when vehicles have been disposed of.
The planning system may be used to record other items in the vehicle maintenance programme, such as servicing, unscheduled work and refurbishing. Each activity should be clearly identified.
This section examines why the continuous reviewing and monitoring of the quality of safety inspections is essential for all systems in maintaining a vehicle’s roadworthiness.
Continuous reviewing and monitoring of the quality of the systems in place is essential to ensure that they are sufficiently comprehensive to do the job.
One method of monitoring is to invite a technically competent third party to periodically re-inspect or undertake a safety inspection, irrespective of whether inspections are done in-house or are contracted out.
The content of completed inspection reports can also be analysed. Checks should reveal any incomplete records and may also show patterns of faults. If many faults are reported regularly, this could indicate that:
- there are not enough safety inspections
- daily walkaround inspections are not being completed correctly
- defects are not being corrected promptly or effectively.
If no defects or few defects are reported regularly, safety inspection intervals may be too short or the quality of the inspection may not be good enough.
Effective monitoring will enable you, the operator, to adjust the intervals between safety inspections to suit the operation of vehicles. In this respect, there is considerable flexibility provided within the framework of this guide.
Monitoring of drivers’ daily checks
The daily walkaround check is a vital part of any maintenance system, and so requires continuous monitoring to ensure the checks are being performed correctly. Electronic driver defect reporting systems can be effectively used to manage drivers' walkaround inspections. Operators can also use tachograph analysis to monitor the time taken to carry out a walkaround check.
A way of monitoring the quality of the daily check is to have a visiting agent or competent in-house member of staff re-examine the vehicle as it leaves or enters the operating centre. The inspection result can be checked against the driver's defect reports to ensure the driver's check is of sufficient quality.
Another approach could be to use the safety inspection. The person carrying out the safety inspection could note which defects found should have been detected during the driver’s daily walkaround check. A review of the driver defect reports could be performed and appropriate action taken to establish why the defects were not detected during the walkaround check.
Continuous monitoring is essential to ensure effective management control of the maintenance system. A risk-based approach should be adopted. Where issues are identified more frequent checks should be carried out and measures put in place to address any problems found.
Annual test results
Attention should also be paid to annual test results, the issue of prohibitions and inspection notices. Regular monitoring of all available information will enable you to check the effectiveness of your system in keeping your vehicles roadworthy.
What does the annual test for commercial vehicles involve?
Full details of what is tested can be found in the Heavy Goods Vehicle Inspection Manual and the Public Service Vehicle Inspection Manual.
What happens at the end of the test?
If the vehicle passed the test, you will be given the annual test certificate, which you need to keep safe. If the vehicle failed the test, you will be given a copy of the test card, which lists where the vehicle failed the test. You can also ask for copies of the smoke test report and the brake test report.
What happens if faults are found?
During the test, the inspector may find minor defects, which you can ask to repair. If the inspector thinks that these repairs can be carried out quickly and safely, you may be given permission to do so.
Sometimes the test shows up defects that are so serious that the vehicle cannot be moved on the public highway and a prohibition may be issued.
If your vehicle fails the annual test
If defects on your vehicle cannot be repaired at the time of the test, you will need to rectify the defects and resubmit your vehicle for retest.
Operator compliance risk score
DVSA uses the Operator Compliance Risk Score (OCRS) system to decide which vehicles should be inspected during roadside checks. OCRS is used to calculate the risk of an operator not following the rules on roadworthiness (the condition of its vehicles) and traffic (eg drivers’ hours, weighing checks).It is more likely that your vehicles will be inspected if your OCRS is high.
Operators who have a high score are more likely to be targeted than those with a low score. However, this does not mean that operators with a low score will never be subject to checks. It does mean, though, that these operators are unlikely to be targeted on the basis of their OCRS score.
Operators who are accredited for Earned Recognition (see below) have a ‘Blue’ OCRS status, which is the lowest possible score.
Therefore, operators that achieve and maintain good standards are likely to be stopped less often.
As an operator, you get points when a test or inspection finds a defect or infringement of the rules. The more serious the defect or infringement, the more points you attract.
Further information and guidance about OCRS, test histories and roadside check reports are available on GOV.UK.
British Standard BS EN ISO 9001 is a standard for quality management systems. If you are an operator who has been awarded this standard, you must observe systems of working set out in a quality manual. Such a manual would contain details of the organisation of the business, responsibilities of staff and methods of operation.
Those businesses aiming for BS EN ISO 9001 accreditation would need to consider the training, documentation recording, planning, standards and monitoring aspects of their organisation.
Vehicle safety recalls
If you receive notification of a safety recall for your vehicle(s) from a manufacturer, it is important that you act promptly to ensure the rectification work is undertaken. This will remove the risk that your vehicle may become unroadworthy due to the potential defect identified by the manufacturer.
DVSA earned recognition scheme
DVSA Earned Recognition is a voluntary scheme run by DVSA with an aim to reduce the burden of enforcement on operators with a strong track record of compliance and adherence to standards.
Operators must be able to demonstrate that they have robust systems and processes that promote effective and proactive transport management. By maintaining audited compliance systems, operators will ‘earn recognition’.
Key performance indicators will provide an effective means of monitoring the level of compliance, which may avoid the need to carry out a roadside inspection or operator visit and provide DVSA with the assurance and confidence that the operator is effectively managing the transport operation and functioning in a compliant manner.
The main benefits for an operator in DVSA Earned recognition are:
- you’ll be provided with a DVSA marque to use on your website and other publicity materials
- you’ll be recognised as a DVSA approved operator through a published list on GOV.UK
- your OCRS will show a ‘Blue’ Earned Recognition status, which is the lowest risk score
- your vehicles are less likely to be stopped at the roadside for inspections
- DVSA enforcement staff are less likely to visit your premises
- you’ll have direct access to a DVSA Earned Recognition team
Operators can find out more about DVSA Earned Recognition, and how to apply, by going to the GOV.UK website.
DVSA Earned Recognition status will recognise ‘exemplar’ operators and their investment made in compliance.
Enforcement of the operator licensing scheme
- The Goods Vehicles (Licensing of Operators) Act 1995 requires that any person who uses (ie ‘operates’) a goods vehicle or vehicles with a maximum gross weight over 3,500 kg in the course of a business must have an operator’s licence (generally referred to as an ‘O’ licence). Operators of public service vehicles also require a PSV operator licence issued under the Public Passenger Vehicles Act 1981 (as amended). A separate ‘O’ licence is required for each Traffic Area in which the user has an operating centre, but one ‘O’ licence will cover any number of operating centres within the same Traffic Area.
- When considering an application for an ‘O’ licence, the Traffic Commissioners must consider, amongst other matters, whether there will be satisfactory facilities or arrangements for keeping authorised vehicles in a fit and serviceable condition. They will seek assurances that the applicant will conduct regular safety checks and inspections of the vehicles at specified intervals and keep records of those checks and inspections and their results. These details are ‘undertakings’ (formerly known as ‘statements of intent’) made for the purposes of obtaining a licence. Operators must ensure their listed inspection provider is up to date on the Vehicle and Operator Licensing service
- At any time after a licence has been granted the Traffic Commissioners may direct that it be revoked or suspended, or that its scope be reduced on several grounds, including:
- that the holder of the licence gave for the purpose of procuring a licence an ‘undertaking’ that has not been fulfilled
- convictions relating to the maintenance of vehicles in a fit and serviceable condition
- the issue of a prohibition on the use of a vehicle (see 8 below).
- Examiners (employed by DVSA) provide the Traffic Commissioners with a technical assessment of a licensed operator’s maintenance arrangements. This assessment is normally made:
- shortly after the grant of a licence
- when advice might be needed because of a request by the operator for a variation to the licence or because evidence of maintenance problems has come to light; following the issue of prohibition notices, poor annual test results or similar evidence following complaints about smoky vehicles where no satisfactory response has been received from the operator; and if the licence is being reviewed for other reasons not related to maintenance.
- In the course of a maintenance assessment, vehicle examiners may wish to examine vehicles from the operator’s fleet, examine records of vehicle safety inspections kept by the operator, and inspect maintenance facilities. The extent to which records are inspected will depend on vehicle condition and the operator’s history. Failure to keep records of safety inspections is in itself a regulatory matter. The vehicle examiner may discuss with the operator appropriate safety inspection procedures and will report whether they consider the maintenance arrangements to be satisfactory; any deficiency may result in an unsatisfactory report, leading to possible regulatory action by the relevant Traffic Commissioner. In certain circumstances, eg where facilities at the operating centre do not allow adequate inspection, the operator may be asked to bring their vehicles and records into a suitable location for inspection.
- Examiners may at any time:
- enter and inspect a goods or public service vehicle and for that purpose detain the vehicle during such time as is required for inspection
- enter any premises on which they have reason to believe a goods vehicle or public service vehicle is kept
- divert vehicles that are stationary at the roadside to another location for inspection within five miles.
DVSA also employ Enforcement Support Officers who have the power to stop a moving vehicle for the purpose of examining vehicles. These activities may be carried out by an officer in uniform standing by the roadside directing vehicles into a check site or by the use of a marked vehicle displaying a matrix sign giving directions to the driver.
- Examiners may make visits to operating centres to examine vehicles or to check drivers’ records. They also conduct spot checks at the roadside. Examiners’ activities may extend beyond a visual inspection. Examiners have a range of equipment that operators may encounter, including mobile roller brake testers, exhaust smoke meters, and equipment to check the function and setting of the speed limiter.
- When vehicle examiners encounter a defective vehicle at the roadside, on an operator’s premises or at an approved testing facility, they may issue a prohibition notice (form PG9) or a vehicle inspection notice, depending on the severity of the fault(s). A prohibition is a ban on the further use of the vehicle on a road. Prohibitions may take effect immediately or may be delayed for up to ten days, depending on whether there is an immediate danger to public safety. Exemptions may be issued, eg to allow a vehicle to be towed away for repair. A prohibition will not be removed until a vehicle examiner is satisfied that the vehicle is fit for service. As a minimum, this will entail an examination of the components and systems affected by the defects. However, at the examiner’s discretion it may be extended to include as much of the vehicle as needs to be inspected for the examiner to be satisfied it is roadworthy.
- Other sanctions available to DVSA Examiners at the roadside include the issue of a Fixed Penalty Notice in relation to roadworthiness defects. Defects that relate to brakes, steering and tyres may also be endorsable and attract penalty points on the driver's licence. In certain circumstances, your vehicle could be immobilised until the defects are rectified. If your vehicle is immobilised you will be required to pay a release fee before you are allowed to use your vehicle.
Prohibition Notices Endorsed
Against each defect, it is necessary to categorise its significance in roadworthiness compliance and maintenance:
- ‘S’ for significant failure of roadworthiness compliance
- ‘-‘ (Blank) for defects which may or may not be attributable to poor maintenance
- ‘X’ where the defect is no reflection on the maintenance system.
Roadworthiness prohibitions both immediate and delayed, will be endorsed ‘S’ if, in the Examiner’s opinion, any of the defects which led to the prohibition were an indicator that there is significant failure of roadworthiness compliance. These are defects that the operator and/or driver should have been aware of through any or all of the following:
- Long standing defect that should have been detected and repaired at the last safety check.
- The defect or issue should have been detected at the first use/daily walk round check.
- Performance, handling and/or warning systems would have made the defect obvious to the driver.
- Poor workmanship should have been apparent to repairer.
- The nature of the defect(s) observed at annual test were such that they should have been found before the vehicle was presented for test.
- The number and nature of defects present on this notice indicates a significant failure in maintenance.
Defects(s) NOT considered to be maintenance related – ‘X’
Appropriate for defects of an entirely random failure nature such as a lighting bulb failure or a new fracture in a road spring leaf, where it is also apparent that it would not have been noticed by the driver.
Unable to determine whether a defect is attributable to poor maintenance:
If it is not possible to determine whether or not the operator, driver or the maintenance arrangements are culpable, then the defect is not endorsed.
NOTE: If a person obstructs an authorised examiner acting in the course of their duty, they are guilty of an offence.
Where to get additional help
2.1 Technical support
The Traffic Commissioners and DVSA provide advice and assistance to operators to help improve professional standards in the industry. Examiners can advise on safety inspections and can help operators set up acceptable record-keeping systems or maintenance facilities. Together with the Traffic Commissioners, we view this part of our duties as an effective and important means of improving road safety.
The vehicle manufacturer is an important source of advice on the characteristics and technical requirements of the vehicles that the operator is using. Such advice is published in the vehicle handbook and other publications. Further advice can be obtained from the local specialist dealer and/or direct from the manufacturer.
The trade associations such as the Confederation of Passenger Transport, the Guild of British Coach Operators, the Freight Transport Association (FTA), the Road Haulage Association (RHA) and the British Vehicle Rental and Leasing Association (BVRLA) are important sources of advice for operators.
The trade associations provide a national inspection service that can range from a regular programme of safety inspection checks to monitoring those undertaken by an outside garage or by the operator themselves. They also provide operator compliance audits, which help ensure continuous and effective management of maintenance and operator and licensing systems. The trade associations also represent the road haulage and bus industry when talking to the Department for Transport. Operators will find it beneficial to participate in their work in order to understand better the importance of effective vehicle maintenance.
The trade associations, individual colleges, training organisations such as Go Skills, and vehicle manufacturers offer courses and seminars covering operator licensing and maintenance systems. Further advice and information regarding training can be obtained from the relevant sector skills councils (ie Go Skills for public service vehicles and Skills for Logistics for heavy goods vehicles) and trade associations
Saving fuel and protecting the environment
There are a number of government recognised organisations that offer help and assistance when considering fuel consumption and protection of the environment.
The Energy Saving Trust works to cut greenhouse gases and air pollution from the road transport sector. It promotes cleaner, lower carbon vehicles and fuels, eco-friendly driving techniques and low carbon transport alternatives.
SAFED (Safe and Fuel Efficient Driving) is the DfT-approved programme, which has demonstrated average fuel savings of more than 10%, a corresponding saving in fuel and reduction in carbon and CO2 emissions, and a reduction in gear changes of 37%. SAFED can qualify as a training module under the EU Training Directive Driver CPC requirements.
Many Authorised Testing Facilities (ATFs) and other private sector sites are now suitably equipped to offer brake performance and other roadworthiness checks.
The following publications are available to download free of charge.
Manual Inspection procedures and minimum roadworthiness standards for the statutory testing of heavy goods vehicles
PSV Inspection Manual
Inspection procedures and minimum roadworthiness standards for the statutory testing of public service vehicles
Categorisation of Defects
Standards (primarily for use by DVSA enforcement staff) on the issue of prohibitions for roadworthiness defects on all classes of vehicles
Enforcement Sanctions Policy
Sanctions and procedures DVSA officers will take for road traffic and construction and use offences w