The construction sector has been ramping up activity and men and materials are flooding back onto the roads. Andy Miles, a fleet transport specialist from AS Miles Consulting with 35 years’ experience, is calling on contractors, distributors and product manufacturers to make sure that their drivers and vehicles are fully compliant when they return to work.
As the COVID-19 crisis evolved many businesses were thrown into disarray. However, with firms restarting their transport fleet, it is important to ensure that everything is being done in accordance with the legislation – now and in the future.
The Government and the Office of the Traffic Commissioner (OTC) have made a number of announcements and changes to help firms operating transport fleets since the crisis began. Below are the some of the key points that firms operating commercial vehicles need to be aware of.
- PMI – Safety Inspections
There may be occasions where your Preventative Maintenance Inspection(PMI) provider cannot comply with the current agreement that you have due to access issues, staff availability and any other government measures.
In these circumstances it has been agreed that:
- You can extend your PMI schedule to a MAXIMUM of 50% of your normal pattern or 17 weeks, whichever is less. So, a six week period can be extended to a Maximum of 9 weeks
- The vehicles MUST remain in a roadworthy condition at all times.
We would also recommend, as with all of these situations, a record of every action and reasons for PMI extensions are recorded for your own records too.
Before vehicles are used ensure that they are checked over. The drivers need to pay extra attention to the Daily Walkaround checks. A major Tyre manufacture recently warned that tyres left for an extended period with tyre pressures around 14% below recommended pressures could face unseen damage.
Due to the current situation the DVSA are not able to conduct many of the MOT tests, in these circumstances an extension has been granted, initially for 3 months. The conditions imposed are that:
- The vehicle must remain in roadworthy condition at all times
- It should receive a PMI as it would normally
- An exemption certificate is applied for to extend the MOT
We would also recommend, as with all of these situations, a record of every action and reasons for MOT extensions are recorded for your own records too.
- Our Transport Manager has been furloughed
The whole issue of furloughing Transport Managers must be taken very carefully, especially if the Operator wishes to continue using any of the fleet. Certainly, as soon as operations begin to require the use of O licence vehicles the Transport Manager (s) should be brought back to work to prepare ready for operation.
- Driving Licence Medicals (LGV / PCV) – D4
Some drivers have been unable to obtain Medicals for Driving Licence renewals. As a result on Friday 17 April it was announced that any driver who’s licence expires from I January 2020 can apply for a 1 year extension using the new process. However, on the 12 month extension expiry a driver will then have to make a full application and supply a complete D4 Medical.
- Extension to Drivers Hours rules relaxation
Where this does apply the rules, which were due to expire on 23 April, have now been extended until 23:59 on 31 May 2020.
Any use of these regulations must be documented by the driver, and the company to ensure the evidence is available should any Police or DVSA enforcement stops take place, or any subsequent enquires in the future are made.
There is various advice on the Traffic Commissioners web site, or if you have further questions please feel free to contact A S Miles Consulting on the number at the bottom of this article.
- Driver CPC training – DVSA Observations and comments
There has been an agreed period of grace for Drivers whose Driver Certificate of Professional Competence (CPC) expires between 1 March and 30 September 2020. However, it has been noted by the DVSA that there are a significant number of drivers across the industry who are currently either furloughed or on short time working.
Some Training companies, such as ourselves, subject to various agreements have been allowed to carry out Driver CPC, as well as Operator Licence Awareness Course (OLAC) and Transport Manager refresher training, via Webinars.
The questions are already being asked of drivers that if they have either been furloughed or are on short time working, could they not taken advantage of the time to bring their CPC up to date?
This might be one to watch and even discuss with your agency suppliers.
- Auditing – Public Inquiry requirement
During this period, the OTC have issued guidance as to how organisations can have a remote / virtual audit carried out. Having completed around half a dozen or so, these appear to be working well. They can also be used for organisations that want to be proactive to ensure that their systems have been followed correctly during the Covid-19 outbreak.
- Financial Standing
Even in the current situation a business is still expected to be able to maintain its Financial Standing. If not, the Transport Manager and/or Directors must request a period of grace to get themselves back in line. This is not an automatic right, but experience has shown that if you are open, honest and straight with the Traffic commissioner they will be with you too, so write and ask – they understand the strange times we are in.
These are very strange time for everyone but safety is a top priority. Even though there have been some concessions please make sure that you, your employees and your vehicles, remain compliant. If you still have any questions or need to speak in confidence on any Operator Licence matter, please feel free to contact me.
AS Miles Consulting
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