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Goods & Passenger Vehicle Operator Licence Compliance

London Borough of Barking and Dagenham

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    Vehicle Operator Licence Compliance

    Licence Compliance – Case study synopsis

    Operators of commercial vehicles have many important responsibilities under the Goods Vehicles (Licensing of Operators) Act 1995 and Public Passenger Vehicles Act 1981. Licence Compliance is essential to keep on top of.

    An operator’s licence is required for vehicles over 3,500kg and it is a Transport Manager’s responsibility to ensure operator licence undertakings and conditions are adhered to.

    The London Borough of Barking and Dagenham commissioned an audit of the compliance systems and procedures, following up on recommendations through the engagement of a team of Transport Consultants.

    The Challenge

    Due to a number of staffing changes within the transport department, over an extended period of time, it had become difficult to establish if transport administration systems were fully compliant with legislation. The challenge was to confirm whether correct systems, procedures, and records were in place to ensure:

    • Vehicles were insured, taxed, and always operated in a roadworthy condition with valid MOT.
    • Drivers had the correct licence for the category of the vehicle and licences were being checked on a regular and sufficient basis.
    • Vehicles were not operated while overloaded.
    • Drivers were obeying the driver hours regulations and recording them correctly via the tachograph or logbooks if required.
    • Drivers were checking that the vehicles were in a roadworthy condition before driving and that the checks were documented correctly.
    • Maintenance records were being kept for at least 15 months.
    • HGV vehicles were being operated within the operator licence conditions.
    • Vehicles were operating from the registered operating centre.
    • Prompt communication with the Traffic Commission regarding notifiable changes.

    One of the key issues identified was the absence of a suitably qualified Transport Manager on the operator’s licence and the Traffic Commissioner’s expressed concerns at this, consequently requesting immediate remedial action to adhere to their licence compliance.

    Further points included:

    • The quality of driver pre-use vehicle checks needed improvement.
    • The documentation of driver licence checks being carried out in an untimely manner.
    •   There was a lack of driver health declarations obtained, particularly driver’s eyesight which is required to be checked and documented.
    • Compliance documents related to hiring vehicles was incomplete and hire companies with regular vehicle inspections needed improvement, often conducted outside of the agreed schedule.
    • The driver handbook was not updated for a number of years and required revision.
    • The driver hours monitoring required revision and improvements and the introduction of a more robust system.
    • The vehicle maintenance planner required revision, with systems updates better able to reflect frequent vehicle fleet changes.
    • Documenting flow within the transport department appeared to be very labour intensive causing delays in document processing and record keeping.  

    The Solution to Licence Compliance

    An external, independent audit of compliance systems was conducted by DVSA Earned Recognition Approved Auditors – GVL Management Limited. This was followed up with consultancy support to deliver on the audit recommendations until a fully compliant transport management system was introduced.

    The improvements included the appointment of an external Transport Manager taking the responsibility for the operator’s licence, supported by a team of specialist Transport Consultants, who were able to lead the improvement project in line with audit recommendations.

    The team was able to successfully implement maintenance planning – with both internal and external providers, establish a driver licence check procedure, produce quality monitoring of driver pre-use checks and ensure driver health declarations and eyesight check procedures followed. Necessary document revisions were completed and further recommendations including staff training were made in relation to day to day management of the fleet department.

    The Impact

    Appropriate levels of transport licence compliance were achieved, and operator licence undertakings were maintained.  The Council benefitted from cost-savings from external maintenance and vehicle rentals being better managed, along with better utilisation of people and time resources.

    How is the new approach being sustained?

    Following the appointment of a permanent Transport Manager, the compliance systems are being maintained, and regular internal auditing continues to take place.

    Lessons Learned in Licence Compliance

    It is important to review existing compliance systems on a regular basis and maintain robust contingency plans in case of absence with key members of the team. If you have compliance questions, feel free to get in touch.

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