Part of our Operator Questions series. Why consistent analysis is the evidence DVSA asks for, how it catches pattern infringements early, and where unknown driving and overspeeds fit in.
This is one of the questions we're regularly asked by transport managers and operators - so here's the straight answer from our analysts.
Regular analysis of driver and vehicle tachograph data provides operators with a clear and current picture of active transport operations. Frequent driver debriefings focusing on infringements and knowledge gaps, patterns of events and faults highlighting maintenance issues and lead in infringement percentages identifying worst offenders must be actioned and rectified to clearly evidence effective management.
Identifying and applying time sensitive corrective actions to pattern infringements, systemic issues and high-risk drivers dramatically reduce the risk of prohibitions related to tachograph non-compliance.
Operators are required under s.13C(4) of the Goods Vehicles (Licensing of Operators) Act 1995 to maintain satisfactory facilities and arrangements for keeping vehicles in a fit and serviceable condition; failure to demonstrate this through evidenced analysis is itself grounds for licence action at public inquiry under s.26(1) of the same Act.
Consistent regular analysis acts as an early warning indicator as well as an evidential source. Consistency is key to maintaining the required levels of compliance, assisted heavily through transparent understanding of driver actions and vehicle movement. The ‘Traffic Examiner Visit Report’ asks the direct question of ‘Is there an effective system for checking of records and downloaded data in place?’ This standard is set against the Guide to Maintaining Roadworthiness which the Upper Tribunal has approved as the benchmark for whether maintenance and compliance arrangements are satisfactory, and which states at section 6.3 that operators should monitor their OCRS score and use it as a compliance management tool. DVSA may exercise discretion to those who demonstrate historic consistent compliance, proactive analysis becomes a mitigating factor in these scenarios.
Detailed regular analysis identifies the compliance boundary for more than just Drivers Hours and Working Time management. Operators should concentrate on all key performance indicators and maintenance flags. Overspeeds must be noted and enforced to reduce the likelihood of enforcement action on the road. Drivers who consistently trigger overspeeds across multiple months risk a systems and processes audit along with enforcement action against their vocational licence. All aspects of Unknown Driving must be scrutinised and evidenced as this is a key focal point for DVSA. Every Unknown Driving event must be reasoned with evidence supporting the action. Maintenance exemptions, test drives and yard shunts must all sit within the data parameters (distance travelled in the period of time) for signoff. Failure to evidence these issues is cause for further investigation and potential referral to the Traffic Commissioner. Events and faults must be checked and acted upon to eradicate maintenance issues. Failure to action these lends to a lackadaisical approach to maintenance through tachograph data, often leading to further maintenance shortfalls and issues that attract OCRS points during roadside stops. A proactive approach with clear understanding of the compliance requirement to these scenarios as well as all other areas of an analysis report, and reduction of ongoing infringements is the best way to reduce prohibition risks. OCRS is the risk based management system that DVSA use to track operator compliance; it calculates the risk of an operator not following the rules on roadworthiness and traffic, including drivers’ hours, a higher score increases the likelihood of roadside inspection.
Goods Vehicles (Licensing of Operators) Act 1995
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