By Jared Dunbar, Director of Transport Services
In the course of preparing for a Public Inquiry, I’ve come across many different types of mistakes that licence holders make.
In almost all cases, this is simply down to a lack of knowledge or experience, rather than a reckless approach to compliance.
I’ve broken down the most common mistakes, so you don’t find yourself in the same situation:
- An Operator may hire a vehicle, perhaps on a long-term contract, but the maintenance of that vehicle is undertaken by the owner of the vehicle. (However, the Operator does not specify the new maintenance provider by informing the Traffic Commissioner that this 3rd party is also undertaking the maintenance).
- Operators inadvertently stretch their PMI intervals over Christmas by assuming it means 6 weeks of being driven and that the 2 weeks ‘shut down’ doesn’t count. The next inspection is due 6 calendar weeks after the last inspection (unless of course there has been a proper VOR period).
- An Operator receives a prohibition and investigates the root cause but does not document that process. Likewise, there’s often a failure to document MOT failure investigations.
- An Operator may look at their 6 weekly inspection sheets to check that defects have been signed off as rectified, but they don’t interrogate the driver detectable faults on the PMI sheet and take appropriate action.
- If a fault is recorded by the driver on a daily defect sheet, then ensure the rectification work is recorded on the daily defect sheet. Make sure that it is also signed and dated. If an external contractor completes the repair, then it can be helpful to staple a copy of the invoice to the daily defect sheet.
- Operators may apply to the Traffic Commissioner for an increase in their licence without first checking that their operation is being run compliantly. The application often triggers a DVSA visit and so operators should make sure they are compliant, perhaps through the use of an independent audit, before submitting the application.
- Operators shouldn’t rely on their external maintenance contractor to do their job properly. Operators should be permanently monitoring them to make sure paperwork is completed on time and correctly. PMI sheets should be returned with the vehicles.
- If a vehicle is off the road, then place a VOR sign in the cab and ensure the keys are locked away in a safe place. Drivers may unknowingly use the vehicle because no one has told him the vehicle is VOR and there is no sign in the cab.
- Transport managers simply get drivers to countersign the infringement reports and there is no evidence of the discussions that took place during the infringement meeting or, worse still, no actual meeting took place.
- Operators book their vehicles for rolling road brake test but then don’t ensure it is completed in a laden condition, or they fail to look at the other information on the printout, such as the imbalance figures.
Keeping up-to-date with any changes that impact your obligations is crucial for avoiding accidental mistakes.