Richard Pelly of Pellys Transport and Regulatory Law reviews the Driver and Vehicle Standards Agency’s (DVSA) newly updated Guide to Maintaining Roadworthiness and advises on what the changes means for heavy goods vehicle (HGV) operators.
At the time of issue of the most recent Traffic Commissioners’ Annual Report in December 2017, there were reported to be 73,458 goods vehicle operator’s licences in circulation. What this should mean is that over 70,000 copies of the newly updated Guide to Maintaining Roadworthiness ought to have been downloaded by goods vehicle operators. As previous editions of the guide made clear, and as the latest edition emphasises, it is the operator’s responsibility to ensure that its vehicles and trailers are safe on the road.
The importance of the guide
The purpose of the guide is unchanged. It is published to offer guidance to operators on the steps that they ought to take in order to ensure that their vehicles are safe on the road.
The guide is endorsed by the Traffic Commissioners and is frequently referred to in public inquiries. When DVSA vehicle examiner officers visit operators to carry out maintenance assessments, they make specific reference to the guide (and to the DVSA’s Categorisation of Vehicle Defects, if they find anything wrong with vehicles or trailers).
Knowing what the guide says will not only help operators keep their vehicles and trailers safe, but it will also mean that they are more likely to satisfy the DVSA at any assessment (and so avoid the issue of prohibitions or the threat of being called to public inquiry).
So what’s new?
The good news for operators is that the guide is not a complete rewrite (and it would be odd if it was, because many of the fundamentals set out in previous editions are just that). Much of the material will therefore be familiar and for operators who were already following the 2014 edition of the guide, this update ought to help not hinder.
That being said, it is worth operators noting the following:
More detailed guidance relating to IT for Vehicle Maintenance Systems
This guidance had previously been published as a separate standalone document, but it has now been incorporated into the guide. The guidance provides details on what a good IT maintenance system should do including some of the key features of a computerised system (for example, the capability to print hard copies of maintenance records upon request) and advice on how to keep electronic maintenance systems secure.
Guidance is also provided on what is becoming an increasingly common method of using electronic handheld devices for the completion of walkaround checks.
Maintenance facilities — adequacy and accreditation
While the general list of what a maintenance facility should include is largely the same (with reference now being made to emissions testing equipment), the new guide adds an advisory note that for operators who do their own maintenance, it is important that they ensure that their own in-house facilities are adequate for the job.
To this is added the strong recommendation that workshops and fitters are accredited.
Given that, according to the DVSA, tyre defects are among the most common safety-related problems that they come across, it is no great surprise that there is the addition of a new section on a Tyre Management System, which includes advice on checking a tyre’s age, the appropriateness for the vehicle, the importance of making sure that staff dealing with tyres are properly trained, and that drivers are equipped to recognise and report tyre issues.
This is another section which has been substantially extended with the inclusion of guidance which had previously been published elsewhere — this time, in relation to Electronic Braking Performance Monitoring Systems (EBPMS) which the DVSA acknowledges can be effective in supplementing maintenance arrangements, including recommending the use of an EBPMS for trailer brake testing.
More generally, the guide now includes a strong recommendation that a laden brake test is carried out at every regular safety inspection, preferably using a calibrated roller brake tester, and it provides more detailed technical guidance on the various measurements which should be taken when completing brake tests, including temperature measurements of brake discs and drums following road testing.
Perhaps most importantly, the guide states that it is “essential” that whichever system is used for brake testing, at regular safety inspections, it must be capable of providing evidence of the performance results which can be included in, or appended to, the safety inspection sheet.
Operators should expect to mark down if the DVSA finds that the brake test results are missing, and they should not assume that an entry “Road Test — brakes ok” will be sufficient.
Predictably, given the widespread press coverage on emissions and emulator “cheat devices”, the guide includes a new section providing guidance on the maintenance of vehicles’ emissions control systems — with specific reference to operators and drivers ensuring that AdBlue levels are correctly maintained.
Updated sample defect report sheet and safety inspection sheet
In line with some of the new recommendations discussed above, the sample walkaround check sheet has been amended to include a check for AdBlue (as well as a check for vehicle height), while the sample regular safety inspection sheet now includes a section to record road test brake temperatures.
More is also made of the importance of operators monitoring the work that is done to check their vehicles and trailers, and as the guide states: “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.” The daily vehicle and trailer checks (frequently carried out by drivers immediately before they drive) are highlighted as being especially important, as is the importance of effectively monitoring these checks and the way in which they are recorded.
Monitoring — Earned Recognition
There is a new section in the guide explaining how the DVSA’s new “Earned Recognition” scheme works and what operators are required to demonstrate to be eligible.
Goodbye to Annex 4
The graph which had previously been recommended for assessing the suitable safety inspection frequency interval has been disposed of and replaced with a table setting out a range of operating conditions which it is recommended are used as the new basis for the right interval to use.
Operators wishing to change the inspection intervals need to ensure that any changes are recorded using the Vehicle Operator Licensing (VOL) system online. Usefully, the guide includes a number of case studies setting out how inspection intervals can be set and explaining what updates to VOL are required.
What should operators do?
Download and read the new guide, transport managers and those working for them in the traffic office ought to know what the guide says.
Review the systems and records already in place and consider what changes, if any, need to be made.
Ensure that all maintenance providers whether internal or external, have access to, and have read the new guide.
Make a note of the changes and take action — few, if any operators, will have nothing to do to ensure that the new guide’s updated recommendations are followed.