We employ a number of warehouse staff who possess LGV licences. We sometimes ask them to drive goods vehicles, operating under the EU Drivers’ Hours Regulations, to cover for staff sickness and holidays. It has come to our attention that we need to monitor the number of times these employees work as drivers, during a “reference period”, so as not to contravene the requirements of the Road Transport (Working Time) Regulations 2005 (RTWTR). Please explain the rules in connection with the use of employees who only drive goods vehicles on occasions.

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