1. Testing and enforcement
Phil Jowitt
Senior Customer & Stakeholder Engagement Manager
DVSA
27 October 2016 ● Park Royal, Warrington

2. FTA Fleet Engineer Seminar 27th October 2016
Phil Jowitt
Senior Customer & Stakeholder Engagement Manager
DVSA
Helping you stay safe on Britain's roads

3. Disruptive even for a compliant check
Compliance Today
Check driver records
Operator records
Tachograph checks
Disruptive even for a compliant check
Check vehicle condition & load
Prohibit unsafe vehicles
Immobilise dangerous vehicles
Issue fixed penalties
Operator follow-up investigations
Currently DVSA enforcement activities mainly uses front line resources to physically stop vehicles and check compliance standards at the roadside and operating centres. These activities use a large amount of DVSA enforcement resource and are also disruptive for the operator, even if the encounter is clear.
DVSA frontline enforcement -
Check driver records
Check vehicle condition & load
Prohibit unsafe vehicles
Issue fixed penalties to drivers
Immoblise dangerous vehicles that cannot be quickly rectified
Instigate follow-up action for serious infringements
DVSA want to use our enforcement resource in a more effective way by allowing front line enforcement to focus on the non compliant.
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4. Serially non- compliant
Compliance Vision
To introduce more efficient & effective interventions without compromising standards or outcomes
Compliant
Mostly
Satisfactory
Non- compliant
Serially non- compliant
Exemplar
Continued disruptive targeting
Remote
compliance
Remote
Compliance
Inspections & visits
DVSA recongnises the transport industry is segmented, ranging from exemplar operators who are industry leaders in compliance standards to serially or intentionally non-compliant.
DVSA wants to adopt appropriate strategies to manage each segment of the industry, We want to recognise operators who adopt a culture of compliance and treat them differently to operators who are willfully or serially non-compliant.
DVSA wants to develop remote compliance products to enable a more efficient and pragmatic approach for monitoring compliance for the operators who have a good track record, which will free off front-line resource to target and disrupt the non-complaint
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5. Remote Compliance Remote Compliance
DVSA remote compliance products
REO – Using remote monitoring and desk based assessments to check compliance or manage low level offending. Unobtrusive but effective methods which can efficiently check compliance to actively manage, support and encourage operators to be compliant.
STMO – Used for effective resource deployment (right place, right time) to encounter the non-compliant, supports focused disruptive targeting campaigns, makes effective use of technology systems (ANPR, WIMS, OCRS, Intel) to focus front-line DVSA enforcement activities.
Earned Recognition concept – To accredit operators who demonstrate a high level of compliance standards and to adopt a light-touch remote monitoring regime. Operators will not be targeted for front line enforcement and have access to a business network manager who will adopt a top down management approach to deal with any potential issues with the operator.
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6. Earned Recognition Concept
Identifying the “exemplar operators”
Earned Recognition Concept
Exemplar Operator
Earned Recognition is about accrediting operators investment in compliance. This means we will reduce the burden on the compliant and enable our front-line enforcement to focus on the serially or serious non compliant.
Considerations
Agree KPIs
Define Standards and T&Cs
Monitoring dashboards/ IT solutions
Network Business Manager - Role
data orientated
compliance
working with industry
remote
monitoring
Develop a model for 3rd Party Audits
Next Steps
Feasibility study to test the earned recognition concept
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7. Earned Recognition Concept
What we want
What you get
Recognised ER status published on
Treated differently at roadside
ER status for OCRS & ANPR
Light touch monitoring
Access to DVSA Business Network Manager
Operators with an excellent track record of compliance
Provide DVSA with a remote monitoring
Demonstrate continuous and effective management control
Adopt a culture of compliance and proactive management regime
Once accredited DVSA will:-
Publish a list of operators who are accredited
Change roadside instructions to treat ER vehicles differently
Update ANPR & OCRS to show an ER status.
Adopt a light-touch remote monitoring regime including exception reporting of check KPIs.
Assign a Business Network Manager to the operator
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8. Earned Recognition Approach
Application with T&Cs
Application Review
Monitor
Assessment Audit
Voluntary application with published T&Cs and standards
DVSA will carry out application review with validation checks and performance assessment against KPIs for compliance standards
There will be an audit to ensure the operator has appropriate systems in place to enable effective management control of the transport operation.
Once accredited DVSA will carry out light-touch remote monitoring of KPIs to ensure standards are maintained.
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9. ER Concept - Application Criteria
Established operator (min 2 yrs) with good compliance history
Electronic transport management systems with DVSA remote monitoring
Annual test final pass rate at least 95% (under consultation)
Drivers hours infringement KPIs (under consultation)
No TC regulatory action for at least 2 years (under consultation)
Electronic monitoring by exception to KPIs rather than any type of access.
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10. ER Concept - Progress
Blind Trial (October 2015) to develop the earned recognition concept
150 operator licenses have undergone pre-audit checks
10 trial assessment visits have been carried out at operator premises
Pre-audit criteria has been developed
The assessment scope and standards have been developed
Product development has increased momentum
Feasibilty study carried out through September and October
Feasibility study – Audits of 7 Operators across industry sectors to check standards and process
Survey has been carried out to gauge industry interest in the scheme
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11. Data & Access Requirements
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12. What will we need? We require electronic remote monitoring system
Monitoring for both tachograph analysis and maintenance documentation
Explore how vehicle telematics can be utilised in the future
We require electronic operators systems using dashboards to measure KPIs. This will involve exception reporting to DVSA
2. Effectively we require access to two systems, tachograph analysis and maintenance, again we will go into more detail during the presentation.
Although vehicle telematics are available we generally wouldn’t need access to those systems unless they were being used to evidence problems found. But it is accepted that telematics do hold a lot of information so we would like to work with this industry to explore how this information could be accessed and used in the future.
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13. Tachograph Data Current analysis situation
We would require exception reporting from all relevant databases and reports
Dashboard giving DVSA and the operator an overview of KPIs
Whether using analogue or digital records the majority of operators use external analysis companies. A vehicle would have to be over 10 years old to be fitted with an analogue tachograph instrument.
The dash board will be a quick method of displaying KPI data using probably an automated trigger.
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14. Tachograph Infringement Bands
Overall infringement rate
Fixed Penalty bands as specified in current legislation
Band 1: Currently £50
Band 2: Currently £100
Band 3: Currently £200
Band 4: Currently £300
KPI’s are broken down into 4 bands;
This would need to be an industry wide standard for consistency.
Road Traffic Offenders Act 1988
Road Traffic Act 1988
Road Safety Act 2006
Relevant Secondary Legislation
The Road Safety (Financial Penalty Deposit) (Appropriate Amount) Order 2009
The Road Safety (Financial Penalty Deposit) (Appropriate Amount) (Amendment) Order 2013
The Road Safety (Financial Penalty Deposit) Order 2009
The Road Safety (Financial Penalty Deposit) (Interest) Order 2009
The Fixed Penalty (Procedure) (Vehicle Examiners) Regulations 2009
The Fixed Penalty Offences Order 2009
The Fixed Penalty Order 2000, as amended by the Fixed Penalty (Amendment) Order 2009
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15. KPIs The KPIs are based on number of tachograph days Band Percentage
1.30%
Band 2
1.20%
Band 3
0.80%
Band 4
0.70%
Overall
4.00%
W / T
These are the tolerances for offence rates for ER concept
Working Time
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16. How Trigger Points Work
All KPIs are measured over a monthly period
Any KPI that is not met will result in a trigger being initiated
Action will only be taken when
Any KPI is exceeded by 2% or more
Any KPI is exceeded more than 1% but less than 2% twice in a three month rolling period
Any KPI is exceeded by less than 1% three times in a three month rolling period
Any KPI is exceeded more than four times in a twelve month rolling period
Managed monthly
Each case on it’s merits
Explanation to action plan for example.
Systems audit, etc
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17. Other Tachograph Measures
Working time A key performance indicator will be used to capture all working time infringements. This is a measure for all working time infringements and follows the same principle for initiating triggers as described for the drivers hours Repeat Offenders Drivers who have infringements on regular occasions .
A single figure will be used for all working time infringements
Unexplained missing mileage will require recording, what is the best way of doing this?
Repeat individuals will be weeded out, as any consitent offender will be identified, even if masekd
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18. Other Tachograph Measures
Missing mileage All missing mileage will have to be accounted for. The reasons for missing mileage should be explained within the analysis. Unexplained missing mileage will result in further action. The operator will be expected to declare that all missing mileage has been accounted for within 8 weeks. Details will be inspected during the normal operator audits. MSI Any MSI will result in a trigger
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19. Alerting DVSA
When a KPI has been triggered an alert will be sent to DVSA
The alert will contain a link to the trigger
DVSA will then decide what course of action is required
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20. Infringement Scoring Each band will be measured individually
Failure to meet one or more key performance indicators may result in further action
Bands set at an achievable level
Any MSI infringements will result in further action
Further action could be informal talks, formal conversation, additional audits, reporting for offences, reporting to Traffic Commissioner, start of proceedings to remove from the scheme
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21. Manual Records & Electronic Data
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22. Maintenance Information Systems
Currently may be captured by;
fully electronic maintenance systems
fully manual, part manual & part electronic
System access
Automated reporting KPI breaches.
Many operators still run fully manual systems where data is held at individual premises. Often where electronic systems are used these are used in conjunction with manual systems or there are a number of different systems employed for example a mixed manufacturer fleet.
It is not our expectation at this stage to have all aspects of the maintenance procedure to be fully electronic
What we do want is the ability for the Operator system to be able to provide automated s or notification of breaches of KPIs
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23. Manual Systems
Unless the data could be adapted to produce a dashboard systems where documentation is scanned may not be suitable
All safety inspection sheets and any driver defect reports that have items on them where action should have been taken.
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24. Electronic Systems
For a fully electronic system where all details are captured our expectation is this would include an automated notification of KPI breaches.
Safety Inspection records
Safety Inspection frequency monitoring
Walk around checks
Driver Defect Reporting & action taken
Electronic forward planning
Tachograph calibration dates
MOT pass rates
This is a wish list of what we would like to see, are all of these possible?
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25. Maintenance Dashboard
Dashboard giving DVSA and the operator an overview of KPIs
Bands will be included for the following
1. Complete set of safety inspection records - 100%
2. Safety Inspection sheets are completed correctly including all relevant sections and signed off as being roadworthy - 100%
3. Safety Inspections are within the stated frequency %
4. Driver defect reports are checked to ensure where road safety related items have been reported action has been taken %
5. Vehicle & trailer MOT pass rates - 95%
Ideally we would want to see an exception report of the dashboard giving us an overview of KPIs to enable us to focus on any areas of concern
The KPI trigger points are the same for drivers ours and maintenance.
Any KPI is exceeded by 2% or more
Any KPI is exceeded more than 1% but less than 2% twice in a three month rolling period
Any KPI is exceeded by less than 1% three times in a three month rolling period
Any KPI is exceeded more than four times in a twelve month rolling period
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26. Further Information
MSI details can be found in the Enforcement Sanctions Policy
Maintenance guidance can be found in the Guide to Maintaining Roadworthiness
‘Use IT for a vehicle maintenance system’, linked from the above guide
Under Regulation (EC) 1071/2009, there is a requirement that the repute of licensed transport operators and transport managers is reviewed whenever these have been penalised for offences in relation to certain vehicle defects, of a severity defined as ‘Most Serious Infringements’ (MSI) in the Annex to that Regulation.
Most Serious Infringements are detailed in the Enforcement Sanctions Policy, this can be accessed either through .GOV or using the QR code.
Guidance can be found in the Guide to Maintaining Roadworthiness which also includes a link to Use IT for a vehicle maintenance system. This can be downloaded from .GOV or by using the QR code.
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27. Guide to Maintaining Roadworthiness review – brake testing
To provide operators with greater flexibility, where it is impracticable to obtain a brake efficiency result on a safety inspection the brake performance must still be assessed by means of a road test carried out under controlled and safe conditions, the safety inspection record must be annotated that the brake performance was assessed by a road test.
However, a road test method to assess the brake performance for all planned safety inspections will usually be inadequate. Therefore it is normally expected that the vehicle or trailer should complete at least three successful brake efficiency tests spread throughout year in addition to the annual MOT test.
The methods which can be used for assessing braking performance for a safety inspection are:-
Road Test – Minimum requirement
Roller Brake Tester (RBT)
Decelerometer
Electronic Braking Performance Monitoring System (EBPMS) – Now accepted for trailers for safety inspection evidence.
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28. Guide to Maintaining Roadworthiness review – brake testing
It is also best practice to test the vehicle or trailer in a laden condition and to obtain a printout of the brake efficiency test from either the RBT or Decelerometer, which should be attached to the safety inspection record.
If the brake test equipment cannot produce a printout, efficiency results must be recorded by the inspector on the safety inspection report.
To help operators arrange brake tests with safety inspections it is acceptable for a satisfactory brake test to be carried out within the same week of the planned safety inspection.
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29. Guide to Maintaining Roadworthiness review – brake testing
If deficiencies in brake performance have been identified either during the use of the vehicle or trailer or at the safety inspection a measured brake efficiency test must be carried out. This efficiency test must confirm the brakes are performing satisfactorily before the vehicle or trailer can be considered as roadworthy.
The results of this brake test must be kept as evidence of
repair with the operator’s maintenance documentation and can be included as one of the brake tests required to meet the minimum requirement.
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30. Guide to Maintaining Roadworthiness review – brake testing
Where operators experience problems with braking performance either at annual test, roadworthiness inspections or through operational performance and fail to meet the standards outlined above, the Traffic Commissioner may take regulatory action.
If an operator demonstrates an adverse compliance history whilst meeting the requirements outlined in the Guide to Maintaining Roadworthiness it will be necessary to introduce further measures.
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31. Laden Brake Testing Helping you staf safe on Britain's roads
As you know where required, vehicles must be presented laden for the brake test (65% +)
We now publish advice, in one document, ‘Heavy Vehicle Brake Test Best Practice’
Failure to present laden may lead to a refusal to test or a reduced brake test result
It is our aim to conduct an effective check of the performance of vehicle and trailer brakes in all cases
Balanced with this we also aim to inconvenience presenters and operators as little as possible
It is in all of our interests to ensure that vehicles that are required to be presented for test laden are presented in that condition & gain an effective brake test
As you know, in order to achieve a laden state ATF’s may rent a load or loaded trailer to presenters or they can use a ‘dummy’ load
There are a few exceptions either by design or the type of load they carry, that are not suitable to be loaded e.g. refuse vehicles, vehicles with restricted access
Momo’s 13 & 14 of 2016 gives more information on laden testing.
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32. View to the front Current Position Review complete
Proposal for heavy vehicles
Will consist of a crucial zone 400 mm square section centred on steering wheel
No obstructions within this area
Remainder of screen any obstruction that materially affects the drivers view from the drivers seat
Informal review with stakeholders planned for mid November
View to the front
Proposals to be circulated for review in November:
 To permit single elements of damage that can be contained within a 20mm
diameter circle.
 To permit single cracks, that do not penetrate both glass layers of a laminated
windscreen, of any length provided they do not connect two edges of the
windscreen.
 Where a combination of minor damage areas exist, their impact on the driver’s view
should be assessed by the tester. Where the tester deems the extent of damage to
materially affect the driver’s view a fail would be recorded.
It is our view that this would not pose an issue for road
safety.
As to the remainder of the windscreen outside of the crucial zone we propose the
following:
 Assessment of any obstruction or damage outside of the crucial zone from the
driver’s seat and only fail any item that materially affects the drivers view.
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33. Helping you stay safe on Britain's roads
We are the useful link
If you require any further information please contact us
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