DVSA compliance — how do you measure up?

During this financially difficult and strangely quiet period in the bus and coach industry, not everything is standing still. The way compliance is monitored by the DVSA continues to develop and our Consultant Editor has taken a look at some of these methods and asks the question “How do you measure up?”

Long gone are the days when your friendly vehicle inspector would pop in for a coffee, check a couple of vehicles and proffer some wise words of advice. The modern DVSA inspectorate has developed a number of data systems that provide them with a measure of an operator’s compliance, often using data available to or provided by the operator themselves. It is therefore important that an operator who already has this data within their own control can manage their operation to ensure successful compliance with the wide array of performance indicators that they are measured against.

Encounters with the DVSA

DVSA inspectors record every time they come into contact with one of your vehicles, which is termed an encounter. This could be an MOT test, a roadside check or a depot visit. Data from these encounters is used to produce your:

  • MOT Test History

  • Vehicle Encounters Report

  • OCRS Score.

From these reports, you can benchmark your MOT first time pass rate (National Average of 87.76%) and MOT final pass rate (National Average of 91.99%). This data also determines your OCRS score, further details of which can be found in Employer Factsheet: Operator Compliance Risk Score (OCRS).

The accuracy of the data used to create these reports is vital, for example, only vehicles declared on the Vehicle Operator Licencing (VOL) system will be credited with an MOT pass. However, all failures are recorded, whether the vehicle is declared or not, potentially resulting in your MOT pass rate dropping simply because you are not being credited with the passes.

These MOT Test History and Vehicle Encounter reports are produced monthly and are available on the first Monday following the first Friday of each month and can provide data over the last three years of operation. OCRS Scores are updated weekly. You are strongly recommended to monitor these reports regularly depending on the number of vehicles you operate.

You can register for these reports at GOV.UK.

Bus Open Data Service

The Bus Open Data Service (BODS) was introduced under the Bus Services Act 2017. BODS requires operators running registered bus services, including school services, to upload three pieces of data for each service to the BODS portal, which are:

  • the current registered timetable in TransXchange format

  • the current fares

  • a live Siri data feed from your vehicle tracking system.

All this information is available from Ticketer ticket machines and although this is more problematic if you are using older Wayfarer or similar products, the DfT has produced some tools to help.

The legal requirement came into force on 31 December 2020 and although the DfT has deemed this as a trial year, the data will be used to check punctuality from the end of March 2021. The justification for BODS is that it allows passengers to have real time information on their local bus services which overcomes a key barrier to the use of the bus as a primary mode of travel — what time will my bus turn up?

While this should be great news for operators, with hopefully more passengers and fewer complaints, the data will also allow both the operator and the DfT to monitor the performance of bus services against the Transport Commissioner’s guidelines on reliability and punctuality. The DfT has played down the use of this data to monitor bus service performance but all operators will be able to monitor the performance of their own services, a key requirement of the Transport Commissioner when determining compliance.

Earned Recognition

The DVSA launched their Earned Recognition scheme in 2018, which enables the provision of a suite of compliance information directly to the DVSA. This information is provided directly from the operators own in-house electronic systems every four weeks and includes data on driving activities such as drivers’ hours compliance and vehicle maintenance.

The reporting data for drivers’ hours include statistics on:

  • repeat infringement offenders

  • kilometres driven without a drivers’ card inserted

  • driving and working time infringements.

Most operators use external tachograph analysis companies and many of these are accredited for Earned Recognition and can usually switch this module on so you can check your performance, even if you are not sending reports.

The reporting of maintenance data includes statistics on:

  • completion of the safety inspection regime

  • defect reports and rectification

  • MOT pass rates.

Operators can check data before it is sent, which enables the operator to demonstrate their compliance and, more crucially, to demonstrate that they are able to manage non-compliance and are in control of their operation.

DVSA Manuals

In February 2021, the DVSA updated the Guide to Maintaining Roadworthiness, which is essential reading for those wanting to be compliant. The DVSA also produce downloadable versions of the PSV Inspection Manual and Categorisation of Defects, which have also been recently updated and these should be made available to your maintenance staff.

For those operators who are already working hard to achieve compliance, you should take heart that the increasing use of performance management by the regulatory authorities is much more likely to bring an end to non-compliant operators or those simply not in control of their operation.

While the more cynical may think that Big Brother is watching you, the data being used to track your compliance is available to you and most importantly enables you to manage your operation compliantly. The key is knowing how and where to access this data before someone else asks you the question “How do you measure up?”