Recent cases have flagged up many of the same old compliance issues: Transport Managers and Directors not being inquisitive enough about compliance and their records. This is also a criticism that I have heard Traffic Commissioners make in many Public Inquiries and has predominantly been directed at the company directors.
In one case, a director asked the Transport Manager whether compliance was ok and was satisfied when he was told “yeah – it’s fine”. Had he taken the time to look at the records he’d have realised there were a multitude of issues, such as no infringement meetings, vehicles being driven long distances without cards inserted, and missing maintenance records.
What could the director have done differently?
They had various options. One solution is to look at a sample of the records yourself regularly. This would have flagged up the problems to even the untrained eye.
An alternative option would be to bring in an independent auditor to review the records and prepare a report telling you what’s good and what’s bad. You could even retain their services to help fix the problems, if need be.
Other cases can have more nuanced problems which a director might not pick up on.
Here are just a sample of issues found in recent paperwork:
- PMI sheets made reference to a second document containing all the rectification work. None of these documents were on file – why had no one obtained them? Usually, the rectification sheet would be recorded on the PMI itself – why wasn’t this raised with the maintenance provider?
- There was no documented analysis of the PMI sheets and investigations of the driver detectable faults recorded on them.
- For instance, why was there an ABS fault, indicator out, and a cut tyre showing on a PMI sheet when the daily defect sheet for the day before said there were no issues? Of course the issues could have occurred that day but, given similar problems existed every PMI, the likelihood of that disappears.
- Secondly, how did the vehicle get to the maintenance providers? As it was driver by the Operator’s staff, why was there no walkaround sheet completed for that day? Why hadn’t this been spotted?
- Why were the PMI sheets signed off as roadworthy when the brakes weren’t tested until 3 days later? Why did nobody notice?
- Why had no brake tests been completed on some PMIs?
- Why weren’t tyre ages being recorded on PMI sheets?
Many directors or transport managers worry that they have no mechanical knowledge and so aren’t qualified to check a PMI sheet. Yes, mechanical knowledge can help in some things but analysing paperwork often requires limited or no technical expertise, simply a probing mind.
If you would like support staying compliant, reach out to our transport law experts today. Jared Dunbar can provide the guidance you need.