1. DVSA Guide To Maintaining Roadworthiness
2014 revision

2. DVSA Guide to Maintaining Roadworthiness
Main changes to guidance on:
Safety inspection intervals
Brake testing
Inspection facilities
Older vehicles and trailers
Established operators
Third party traction
The Driver and Vehicle Standards Agency (DVSA) launched a revised 2014 version of the Guide to Maintaining Roadworthiness at the CV show in April, a critical industry document which provides guidance in the practices operators are recommended to undertake in the maintenance and inspection of their fleet.
The document, which is widely considered to be the industry benchmark on good practice for keeping vehicles fit and safe. FTA has worked closely with DVSA in the revision process and believes the 2014 version seeks to strike a balance between providing guidance on best practice, particularly for those who have less industry experience, while allowing experienced and professional operators to make decisions about effective maintenance regimes for their own fleet
In this presentation I will go through the main changes in the revised 2014 version of the guide which include;
Safety inspection intervals
Brake testing
Inspection facilities
Older vehicles and trailers
Established operators
Third party traction

3. Context…. It is a guide ‘Nothing in the guide is mandatory,
but operating as outlined in the guide will
ensure the relevant conditions and
undertakings of an operator licence are met’
Undertakings -
GV79
TM1
During the drafting of the guide, FTA became increasingly concerned that it was being reframed as an instructional document applying additional regulatory burdens to industry without the usual impact assessments being conducted but, following discussions with DVSA and Traffic Commissioner Kevin Rooney, FTA is confident that the context of the document has been clarified with far greater emphasis on allowing experienced operators to determine how to achieve compliance.
The revised foreword from Traffic Commissioners Sarah Bell and Kevin Rooney makes it clear that nothing in the guide is mandatory, but operating as outlined in the guide will ensure the relevant conditions and undertakings of an operator licence are met.
A reminder then of what those undertakings are in relation to vehicle maintenance:
GV79 undertakings:
I understand that by signing the application I am accepting the undertakings below;
Vehicles and trailers, including hired vehicles and trailers, are kept in a fit and serviceable condition;
Drivers report promptly any defects or symptoms of defects that could prevent the safe operation of vehicles and/or trailers, and that any defects are recorded in writing;
records are kept (for 15 months) of all driver reports which record defects, all safety inspections, routine maintenance and repairs to vehicles, and that these are made available on request;
TM1 declaration:
I understand that my responsibilities include:
The making of arrangements to ensure that the vehicles are maintained properly, including the inspection of vehicles at the appropriate time and the action taken to remedy defects found;
The reporting and recording of vehicle defects by drivers;
The method of compilation and the accuracy of all records, which must be kept for a period of not less than 15 months;

4. Inspection intervals Clarifies previous ambiguity Formally recognises
6 weeks or 42 days?
Formally recognises
Within the week it is due
ISO week
Monday to Sunday
The guide clarifies a previous ambiguity relating to inspection intervals and now formally recognises that an inspection can be carried out during the week it is due to fall, and the guide recommends that an International Organisation for Standardisation (ISO) planning system week (starting with Monday through to Sunday) is used to allow some flexibility when planning safety inspections.

5. Older vehicles & trailers
Vehicles over 12 years old
max 6 weeks
Rationale - DVSA stats
HGV initial fail rates*
2 year old – 8.1%
12 year old – 40.6%
*DVSA Effectiveness Report 2012/13
The guide makes new recommendations for a minimum inspection frequency of no more than six weeks for vehicles and trailers which are over 12 years old. The rationale for this is based on DVSA statistics showing that as vehicles and trailers age, the average annual test failure rate increases and they are more likely to experience in-service roadworthiness defects than newer vehicles.

6. Brake testing Dedicated section ‘Strongly advises’
roller brake tests at each inspection
Calibrated decelerometer
acceptable
Road test method
‘usually inadequate for all inspections’
‘Normally expected’
At least 3 brake efficiency tests per year plus annual test
Guidance on the brake testing element of safety inspections has been significantly revised and, for the first time, given a dedicated
section rather than being referred to in other parts of the guide, demonstrating the focus that DVSA and Traffic Commissioners
want to place on this area.
The guide ‘strongly advises’ that a calibrated roller brake tester is used at each safety inspection, or the use of a calibrated decelerometer to test vehicles without trailers is recognised as an acceptable alternative.
While this ‘strongly advises’ statement was always there in previous versions, there is now greater emphasis on managing brake
efficiency testing where access to roller brake testing equipment might be limited.
To provide operators with greater flexibility, where it is impractical to obtain brake efficiency results on every safety inspection,
the guide states that brake performance can be assessed by means of a road test with he safety inspection report being annotated
accordingly. However, it suggests that a road test method to assess brake performance for all planned safety inspections will usually
be inadequate and it is normally expected that the vehicle or trailer should complete at least three successful brake efficiency tests
spread throughout the year in addition to the annual test.

7. Brake testing Best practice Essential Flexibility Laden Print out
Results of test recorded
on inspection report
Flexibility
Within the same week of
the planned inspection
Where possible, the guide states 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.

8. Brake testing Brake performance issues: and
Annual test
Roadworthiness inspections
Operational performance
and
Failure to meet guidance standards
then
Traffic Commissioner may take regulatory action
While it is worth reiterating that nothing in the guide is mandatory, the guide notes: ‘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.’
This means that operators who have a good compliance record with brake performance need not gold-plate what they are already doing, but operators with poor brake performance compliance need to take heed of the guidance, otherwise if they do find themselves at Public Inquiry they can expect that they have already fallen below the Traffic Commissioners’ expectations for maintenance standards.

9. Inspection & repair facilities
Lists facilities which should be in place
Originally drafted wording
Traffic Commissioner approval required
for deviation from the listed facilities
Final document
‘If an operator fails to maintain vehicles in a safe and roadworthy condition with the facilities provided the Traffic Commissioner may take regulatory action.’
The initial re-drafting of the guide raised concerns with a number of members regarding a change surrounding the facilities needed to conduct one’s own safety inspections, with the requirements being tightened and a requirement to seek approval from the Traffic Commissioner to deviate from these parameters. The final document now mirrors other sections of the guide in allowing a degree of flexibility but stating: ‘If an operator fails to maintain vehicles in a safe and roadworthy condition with the facilities provided the Traffic Commissioner may take regulatory action.’
Facilities should include:
undercover accommodation for the largest vehicle in the fleet. This is required to ensure that safety checks can be conducted satisfactorily in all weathers (depending on fleet size the building may need room for more than one vehicle at a time);
tools and equipment appropriate to the size and nature of the fleet;
an adequate under-vehicle inspection facility:
adequate lighting;
access to brake test equipment (e.g. a roller brake tester, decelerometer);
access to headlamp test equipment;
access to steam or pressure under-vehicle washing facilities; and
a safe working environment.
‘If an operator fails to maintain vehicles in a safe and roadworthy condition with the facilities provided the Traffic Commissioner may take regulatory action.’

10. Experienced operators
Inspection interval graph
Aimed at new operators
Revised guide
Additional information
Flexibility for inspections
Case study scenarios
Modifications
Close monitoring of roadworthiness
The guide has always featured a graph which recommends minimum inspection intervals for vehicles and trailers aimed at new operators setting up an inspection programme for the first time.
The new guide includes additional information for experienced operators with regard to flexibility in tailoring inspections to suit the nature of operations and vehicle characteristics. It acknowledges that modern vehicle systems now have the ability to indicate maintenance requirements, and that operators may deploy more than one system across a fleet, where vehicles and the nature of their work vary.
It recommends that where modifications to inspection schedules are undertaken, then monitoring the effect on roadworthiness on a monthly basis should be carried out. DVSA and Traffic Commissioners will judge systems primarily on their effectiveness in maintaining roadworthiness.

11. Third party traction New guidance for third party traction
Operators responsibilities
Trailers are roadworthy
Owner’s inspection interval adherence
Best practice
Evidence of first use / safety inspection
Evidence no defects are present
There is now additional guidance for operators providing a traction only service to customers who wish to own their own trailers, stating that it would be expected that operators would need to work with the trailer owners to ensure any trailers operated fall within the owners’ agreed safety inspection frequency and that they are roadworthy.
It suggests it is best practice for the trailer owner to provide evidence for the operator that first use checks and safety inspections have been undertaken and there are no defects reported for the trailer.

12. Example inspection reports
The safety inspection record must include certain information
Example report forms revised
Tyre tread depths & pressures
Indication defects are driver reportable
Stronger declaration
‘any defects have been repaired satisfactorily and the
vehicle is now in a safe roadworthy condition’
The safety inspection record must include:
name of owner/operator
date of inspection
vehicle identity
odometer (mileage recorder) reading, if appropriate
a list of all the inspection manual items to be inspected
details of any defects
name of inspector
details of any remedial/rectification or repair work and by whom it was done
A signed declaration that any defects have been repaired satisfactorily and the vehicle is now in a safe roadworthy condition
Changes to the example safety inspection reports provided in the guide include the addition of tyre tread depth and pressure entries, an indication that defects are driver reportable and a stronger declaration statement that any defects have been rectified satisfactorily and the vehicle is now in a safe and roadworthy condition.

13. Other minor changes More emphasis on competence Quality monitoring
Driver walk round checks
First use inspections
Much more emphasis on quality monitoring & competence of staff involved in maintenance & with responsibility for roadworthiness
Annual test results
OCRS
Driver daily checks
Maintenance providers
Third party quality monitoring
More emphasis on first use inspections – has moved from being in the driver walk round check section to safety inspection

14. Summary & advice GTMR remains guidance Focus is on
Level of compliance
Standards of roadworthiness
Not how it is achieved
Ultimate test – are vehicles roadworthy?
DVSA recognise that there are different methods and systems from those that are described within this Guide that can result in vehicles being maintained in a roadworthy condition.
Operators who wish to adopt a different system, must still satisfy Traffic Commissioners that the system you use is effective. Traffic Commissioners will only agree to variations that will not reduce the control necessary to ensure satisfactory maintenance.
DVSA and Traffic Commissioner focus is on the levels of compliance and standards of roadworthiness rather than how operators achieve the high standards expected
The ultimate test will be whether or not a vehicle is, in fact, roadworthy.

15. Summary & advice
Continual review & monitoring of vehicles & maintenance systems
Inform Traffic Commissioners of changes
Regular audits
Continuous reviewing and monitoring of the quality of the systems in place is essential to ensure that they are sufficiently comprehensive to ensure roadworthiness.
Monitor vehicle inspection reports
Rectification of defects
Are driver reportable defects present indicating poor walk round checks?
Are they completed correctly with signed declaration?
Monitor annual test results & OCRS score
Review & monitor systems & effectiveness, inform Traffic Commissioners of changes
Carry out audits – FTA VIS audits benchmark systems against the GTMR. YOU CAN WIN A FREE AUDIT TODAY BY BUSINESS CARD DROP AT THE FTA STAND.