An effective and worthwhile maintenance regime?
As an operator, are you confident that your maintenance standards are to an acceptable level that would satisfy DVSA if any of your vehicles were stopped at the roadside? If not, why not?
Far more importantly, are your standards to a level that demonstrates to the Traffic Commissioner that you are complying with the obligations entered into when the licence was granted? If not, why not?
Have all your relevant staff been trained to understand and follow the required maintenance procedures that every operator must have in place? If not, why not?
Does every driver assigned to your specified vehicles follow a clear walk-round check and defect reporting procedure that he/she fully understands? Is there a list of the main items to check kept within the cabs of all your specified vehicles to assist the driver in their duty? If not, why not?
While there is not a legal obligation and requirement to keep ‘nil’ defect reports, do you have in place clear documented evidence that all drivers assigned to your vehicles follow a procedure that you have ensured they understand to carry out walk-round checks as required? If not, why not? see our own simple procedure demonstrated below.
Defect reporting procedure
Is there an appropriate person or persons (it doesn’t have to be the transport manager) that is always available to your drivers when they detect a defect or symptoms of a defect, whether that be during a standard working day or when they start in the middle of the night ? If so, do all drivers assigned to your specified vehicles (whether they be full-time/casual/agency) know who this person or persons is and how they can contact them? If not, why not?
Is every detection of a defect or symptom of a defect notified to an appropriate person as soon as possible and is a written record of the defect report made and dealt with as required to comply with the obligations of the operator licence? If not, why not?
Once a defect or symptom of a defect is detected by a driver and reported to the appropriate person is the action decided upon by the appropriate person evidenced by completing a written report that is stored within the vehicle file and made available on request for the next fifteen months? If not, why not?
Is the defect or symptom of a defect reported always investigated and the appropriate action taken and a written record made and stored within the maintenance file for that vehicle and made available on request for the next fifteen months? If not, why not?
Is a written record of any rectification actions taken relating to each and every defect generated and completed in the required way and stored within the vehicle maintenance file and made available on request for at least the next fifteen months? If not, why not?
Once any defect or symptom of a defect has been detected by a driver and reported and dealt with appropriately, does someone within the operation cross reference with the most recent safety inspection sheet provided immediately following a safety inspection, to see if there is any advisory or monitor note that relates to the defect or symptom of defect reported? If not, why not?
An area of compliance that we find many operators falling down on when we carry out independent maintenance audits is ensuring that daily walk-round checks and defect reporting are given the importance they deserve, not forgetting to ensure that the intervals between safety inspections are not compromised.
While adequate procedures are often found to be in place it is their satisfactory implementation that seems to be the problem.
Regular safety inspection /preventative maintenance inspection (PMI)
Operators must not only introduce procedures, they must make sure that they are both understood and also followed by every member of the staff, if the compliance needs are to be adhered to. What’s more, if you are an operator that uses third party maintenance contractors to carry out safety inspections, you must make sure that you leave them in no doubt that you will never accept any changes to your forward plan of safety inspection dates. If you have submitted a licence application stating you would like the Traffic Commissioner to grant six weekly safety inspections for your vehicles you cannot ever afford to be fobbed off by a workshop that would rather you waited to send your trucks in until it suits them.
An agreed six weekly interval period means a MAXIMUM interval between safety inspections of 6 weeks and no more. So, never be in any doubt that if you let your agreed interval over-run more than the 6 week or whatever interval you have agreed with the Traffic Commissioner you will be failing to keep one of the obligations you entered into with the Traffic Commissioner when the licence was granted. The interpretation of the safety interval accepted by the Traffic Commissioners is what is referred to as the ISO week. This means that if you have a six-week interval agreed between the Commissioner and the operator it is ok to have a safety inspection carried out on the Monday of a calendar week and then not have a further safety inspection carried out until the Saturday of the sixth week, rather than having to remember to follow a very strict 6 x 7 days calendar, as was insisted upon by some DVSA (VOSA) examiners and not others.
So, take control from day one and don’t ever let go. Or, your licence to operate won’t last for long!
It should be common knowledge to operators and transport managers that every professional lorry driver has a responsibility to make sure that the vehicle that they are assigned to is safe before they take it out onto the public highway. Not to do so is ‘gross misconduct’ and it is essential that the operator takes the appropriate disciplinary actions to make sure that every driver carries out an effective walk-round check on a daily basis and this is never allowed to lapse.
It’s vital that the operator and the transport manager involve the driver from day one and keep him onside and make him aware just how important his role is. It’s not just driving a truck that a driver does, he or she is taking a big and very expensive vehicle out onto the public highway day after day while being a professional driver on a road of ‘amateur’ drivers, which means making sure that everything to do with that vehicle is safe before going out onto the public highway.
If an operator is to be satisfied that his or her maintenance standards are correct and appropriate it is essential that drivers not only carry out daily walk-round checks on their vehicles, but that they also report in writing every defect that they find, however minor it may seem to them. Then each defect must be dealt with appropriately and that must be reported in writing as well.
Even a blown bulb that a driver personally replaces at the start of a daily driving period should nonetheless be reported in writing and can then be signed off as rectified by the driver. To make sure that the vehicle has a true and complete maintenance record it is vital that such defects are noted and stored within the maintenance file for the vehicle.
What’s more, if a tyre that blows out on the road and is replaced by a tyre company sending out a fitter and new tyre should still be written out as a defect and rectification at the roadside if the operator and the driver are to comply.
If not the maintenance history of the vehicle will be flawed and the operator could miss something important.
Preventative Maintenance Inspections (PMI)
When the operator licence is authorised the Traffic Commissioner specifies the interval period that is the maximum amount of time that can elapse between preventative maintenance inspections. Again, never ever forget that the optimum word here is MAXIMUM interval!
When we carry out maintenance audits it is unfortunately quite common for an operator to be non-compliant, simply because they have allowed themselves to be co-erced into extending the period between PMI’s by their third party maintenance contractor.
I don’t want to seem to be anti-maintenance provider, but what is often forgotten is that it is not the third party maintenance contractor that has made an agreement with the Traffic Commissioner, it is the Operator. So, when you’re sitting in front of the Commissioner after being called in to Public Inquiry don’t expect the third party maintenance contractor to have action taken against them………it is you, the operator, that will be in the firing line! However, should any accident or incident occur that is found to be due to poor maintenance there is now every chance that the maintenance provider will end up in court alongside the operator!
Just to make matters worse and taking into account the information in the previous paragraphs, if the operator doesn’t have in place and follow a walk-round check and defect reporting procedure that can be shown to match up with the safety inspections……….then the fall out will be even worse for the operator! Never become complacent, keep checking your procedures and spot-checking your systems, just to make sure nothing gets past you that could lead to problems.
Produce, implement and follow compliance procedures
Read through the latest edition of the DVSA Guide to Maintaining Roadworthiness (May 2018) and make sure that you understand your own fleet and how it should be maintained, then put together your own systems, practices and procedures and follow them!
As part of our operator compliance scheme (OCS) services to clients we have introduced a simple method of evidencing daily walk-round checks taking place. This procedure has been accepted as above minimum requirements and both operator’s and their driver’s have commented on the simplicity of this procedure and how it is easier to administer.
Monthly walk-round check sheets, to be used alongside a recognised defect report pad, are available on request, by e-mailing email@example.com. Their use cuts down on the ‘nil’ defect ticked report pad sheets that operators store, to provide evidence that daily walk-round checks take place, while at the same time providing an in-cab reminder to drivers’ of what they need to check and more importantly, why they must continue to check the vehicle throughout each day. So, the only completed defect report pad sheets you have should then all relate to a defect or symptom of a defect. At the end of each month the monthly walk-round sheet should be collected in and checked. Any days with a ‘X’ against them should have a defect report relating to that day and that defect should have been signed off as rectified, which can then be clipped to the monthly sheet and stored in the vehicle maintenance file.
This tidies up your vehicle maintenance records by removing the bundles of ‘nil’ defect reports that, while not required to comply, are usually kept anyway to provide evidence of a walk-round check procedure being followed.