Records must be kept as evidence of this and should include any defect reporting systems that you have in place. Safety inspection intervals must also be complied with as agreed with the Traffic Commissioner, which would include any undertakings in relation to the operator licence.
Senior Traffic Commissioner Statutory Document No. 3 is the statutory guidance a transport manager is required to follow. When it comes to vehicle maintenance the following MUST be adhered to.
VEHICLE – MANAGEMENT
• To ensure that vehicles and trailers are kept in a fit and roadworthy condition.
• To ensure that reported defects are either recorded in writing or in a format which is readily accessible and repaired promptly.
• To ensure that vehicles and trailers that are not roadworthy are taken out of service.
• To ensure that vehicles and towed equipment are made available for safety inspections, service, repair and statutory testing.
• To ensure that safety inspections and other statutory testing are carried out within the notified O-licence maintenance intervals (ISO weeks).
• To liaise with maintenance contractors, manufacturers, hire companies and dealers, as might be appropriate and to make certain vehicles and trailers are serviced in accordance with manufacturer recommendations.
THIRD-PARTY MAINTENANCE PROVIDERS
Where an operator uses a third-party maintenance provider there should be an agreement in place between both parties. When using the online Vehicle Operator Licensing portal there is no longer a requirement to send a hard copy to the Office of the Traffic Commissioner (OTC). However, this could be requested and must be made available if required.
IN-HOUSE MAINTENANCE
If carrying out your own maintenance, there should be enough under cover facilities to accommodate the largest vehicle in your fleet. This should include an adequate under-vehicle inspection facility ie, pit, ramp etc. The facility should be a well-lit, safe working environment and there should be appropriate tools and equipment in relation to the size and nature of the fleet. Where an operator does not have all the required equipment, ie, roller brake tester, there should be evidence available of access (local truck dealer). Guidance can be found in the Guide to maintaining roadworthiness (Section 5.1).
Any staff employed to carry out safety inspections should be competent and experienced in vehicle inspection techniques. This could be through experience, technical qualifications or both. The IRTEC (Inspection Technician Accreditation) qualification is now one of the most common forms of recognised qualification for vehicle technicians.
PLANNED MAINTENANCE
Safety inspections and general maintenance must be planned. There should be a minimum of six months of forward planning available at any one time. However, most operators will have 12 months of forward planning, which will include servicing, MOT and tachograph calibration dates. Operators using vehicles fitted with ancillary equipment such as cranes, tail lifts etc, can also use this system to include planned inspections for the equipment. Electronic systems are the most common form of maintenance planner, although a wall chart is still acceptable and a good form of back up.
DRIVER DEFECT REPORTING SYSTEMS
Using a ‘nil’ defect reporting system is good practice. Any defects found by the driver are known as positive defect reports. These should be kept for the minimum 15 months and filed in the vehicle history file as they form part of your maintenance system. They must show who the defect was reported to and any rectification action carried out. Nil defect reports should be kept for as long as they are useful, for example keeping a rolling safety inspection cycle – 6, 8 or 10 weeks of reports would show the Driver and Vehicle Standards Agency (DVSA) that you have a system in place. This would also allow an operator to quality monitor any driver reportable defects there were evident on a safety inspection report when the previous day the driver had submitted a nil defect report.
SAFETY INSPECTION REPORTS
Safety inspection reports must meet a basic format and conform with the criteria laid out in the Guide to maintaining roadworthiness. These include the name of the inspector who carried out the inspection and a list of items to be checked, including the relevant inspection manual numbers for the inspector’s cross reference. The most frequently monitored and criticised section of the inspection report when audits are carried out is the brake performance section, usually IM 71 service brake performance being left blank. These should always be annotated with how the brake performance was carried out – roller brake tester, Tapley meter or basic road test.
In the case of trailers, an Electronic Braking Performance Monitoring System (EBPMS) may be used as a means to assess trailer-braking performance and provide a brake performance value while the vehicle is in service.
There is a statement at the end of the safety inspection document stating that any defects have been repaired satisfactorily and the vehicle is now in a safe and roadworthy condition. This final declaration must be signed by someone who has the authority to put the vehicle in or out of service. The transport manager retains legal responsibility for vehicle roadworthiness, regardless of whether his or her activities are delegated. The Office of the Traffic Commissioner can request information remotely at the time of operator licence renewal. DVSA can also do this when carrying out records audits if they feel there is no need for an actual visit in person, although remote audits may also ‘trigger’ a visit if records are not satisfactory.
ELECTRONIC RECORDS
More and more operators are turning to fully electronic systems, which includes driver daily walkaround checks and safety inspections. This allows all parts of the maintenance system to be linked for instant updated information. A driver can use their hand-held devices to record the checks. FTA’s Drivers’ Walkaround Check system is as simple as scan, inspect, transmit and track. Quick Reference (QR) bar codes are placed on the vehicle at key inspection points. These weather-resistant label tags contain information about the:
• Driver
• Vehicle
• Vehicle Inspection Point
• Components to be inspected
• Pre-defined list of defects and advisories
Using a mobile device such as a smart phone, iPhone or tablet, the driver scans in a unique QR bar code identifying the driver carrying out the safety check. It should always be possible to produce a minimum of the current day’s record at the roadside.
Some maintenance providers are also recording and transmitting completed electronic safety inspection reports directly to the operator. The operator should retain these for the minimum 15 months and be able to provide a printed version at the request of a DVSA officer. The records can be stored on a central database but must still be made available at each operating centre.
QUALITY MONITORING
There should also be evidence of a quality-monitoring system in place. This could include safety exit inspections (inspecting a vehicle directly after its planned safety inspection) and gate checks on vehicles leaving the depot after a daily walkaround check has been carried out.
CONCLUSION
Where record keeping is concerned, whatever method is used, whether electronic or paper based, all records must be fully completed, easy to follow and be retained for the minimum 15 months. Even where a vehicle or trailer has been sold, the maintenance records for them remain part of an operator’s maintenance system for 15 months from date of sale.
