Guidance

Guide to maintaining roadworthiness: commercial goods and passenger carrying vehicles

Updated 5 November 2024

Applies to England, Scotland and Wales

1. Introduction

There are 5 sub-sections in this section of the guide:

About this guide

The Driver and Vehicle Standards Agency (DVSA) has produced this guide in collaboration with key industry stakeholders to explain the responsibilities and systems involved in maintaining vehicles in a roadworthy condition, regardless of operating conditions, fleet size or vehicle type. The procedures and systems explained in this guide are useful for operators, drivers and all those who are responsible for operating, maintaining or providing commercial goods and passenger carrying vehicles. The general principles could equally apply to light goods and passenger vehicles below the operator licensing thresholds and for vehicles that are otherwise exempt.

1.1 Best practice

It is not enough to rely on a maintenance system alone, because this cannot ensure that vehicles are roadworthy. To ensure best practice, you will need to combine good quality maintenance practices and skills with supervision and effective management of the system.

• Where the guide says you must do something, it is a direct legal requirement set out in legislation, something that is required under Road Traffic law, Health and Safety legislations, or the legal undertakings to the Traffic Commissioner for your operator licence.
• Where the guide says you should do something, it is best practice and, while you are not required to do it, it is strongly recommended that you do unless you can demonstrate that an alternative approach provides a similar level of compliance.
• The Upper Tribunal, that is the Traffic Commissioners’ appeal court has approved of this guide for managing maintenance.

New vehicle operators

If you are a new operator, you will find practical advice on how to devise, install and monitor a system for ensuring roadworthiness. If you follow the advice given in this guide, you can make sure you are complying with the law and that your compliance can be monitored and controlled.

Experienced vehicle operators

If you are an established or experienced vehicle operator, you will be able to use this guide as a benchmark to assess whether your systems are sufficiently comprehensive or should be reviewed and improved in order to maintain compliance. This guidance applies to you whether you carry out your own maintenance, contract out maintenance or do a combination of both. DVSA do not specifically define a new or experienced vehicle operator because what constitutes an experienced operator could vary.

However, we do make suggestions as to what could make an experienced operator:

• If you have been trading under this licence or a previous licence for more than 3 years
• If you have been trading under this licence for more than 1 year, and you have been visited by a DVSA examiner and been approved as satisfactory
• If your company has been trading under this licence for a length of time such that you can prove that your roadworthiness process is effective and fully established
• If you can demonstrate suitable evidence proving your experience when questioned by DVSA or the Traffic Commissioner. This could be a combination of staff experience and skills, maintenance procedure experience and substantial defect reports/data

Roadworthiness definition

Roadworthiness means - complying with the appropriate vehicle construction, road safety, environmental and operating standards required by the law in the UK.

For a driver and operator, it is a criminal offence to use an unroadworthy vehicle on the road.

It is an offence to alter a vehicle or its operating systems in such a way that it does not meet the standards required by UK law.

Where this document refers to a “vehicle”, this terminology can equally apply to a trailer.

Maintaining compliance

We 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.

If you are an operator who wishes to adopt different systems, you 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.

There must be a firm management commitment to review and improve maintenance systems where defects are found on vehicles or when the fleet size or the nature of the business is changing. As a licensed operator, you can also be assured that the maintenance systems described in this guide will be accepted by the Traffic Commissioners, provided that the resulting condition of your vehicles remain satisfactory. If this is not the case, however, Traffic Commissioners reserve the right to require more stringent arrangements from you (such as shorter periods between inspections), and the competence of the persons who carry out safety checks may be challenged. The ultimate test will be whether a vehicle is, in fact, roadworthy.

1.2 What this guide contains

The procedures and systems described in this guide relate to responsibilities for roadworthiness, the different types of inspections, inspection intervals, records and data storage, inspection facilities, planner updates and essential reviews.

This guide includes many references to written maintenance records; however, using an electronic vehicle maintenance system can provide effective management of all the required information including safety inspections, maintenance scheduling and driver defect reporting.

Keep in mind that as a general principle electronic records are acceptable, provided that they contain the essential information that can be made available for examination.

Other guidance

It is also important to note that this guide is only concerned with systems of maintenance for roadworthiness. If you are looking for the maintenance of vehicles to achieve economy and reliability, we advise you to seek help from vehicle manufacturers, their agents or the relevant trade organisations. You can find more information on sources of further help and advice in annex 2.

1.3 Getting it right

DVSA recognises that operators of heavy goods, light goods or passenger carrying vehicles will not get everything right all the time. However, we do want you to be vigilant and responsible. The penalties for and consequences of non-compliance to you the operator and/or driver and to the general public can range from the inconvenient to the very serious and, sometimes, to the catastrophic. You and your staff may be fined or prosecuted, and your vehicles may be prohibited. At worst, you may cause serious injury or fatalities because of badly maintained vehicles.

1.4 Types of inspections and checks

Safety inspection

A safety inspection is a periodic inspection that is carried out at pre-set intervals in line with what an operator has declared on the vehicle operator licensing service (VOL). The scope of the inspection should at least include all the items covered by the statutory annual test and employ the methods of assessment that are prescribed in the respective inspection manual.

Examples of safety inspection forms can be found at:

• example heavy goods vehicle (HGV) safety inspection record (PDF, 87 KB)
• example public service vehicle (PSV) safety inspection record (PDF, 85 KB)
• example light goods vehicle (LGV) safety inspection record (PDF, 82 KB)
• example small trailer safety inspection record (PDF, 65 KB)

The safety inspection form can be any format as long as the mandatory items listed in Section 1 of this guide are included on the form.

First use inspection

Prior to using a newly acquired vehicle/trailer on the public highway, operators must conduct a first use inspection to satisfy themselves that the equipment is in a roadworthy condition.

The scope of the inspection should at least include all those items that are inspected at annual test, this includes conducting a laden roller brake test when appropriate for the type of vehicle.

In some instances, a first use inspection is not required if sufficient evidence is provided to indicate that the equipment has been subject to a safety inspection.

For example, documentation is provided to indicate that a new vehicle has been subject to a comprehensive pre-delivery inspection or a pre-rental inspection record has been provided by a hire/lease company.

Intermediate safety check

With some types of vehicles and operation, it may be necessary to check some components more often than at full safety inspections. For example, a vehicle used in urban areas such as a public service vehicle or a local delivery vehicle, or vehicles used in hilly areas, may require more frequent component checks, for example brakes, steering and suspension. It is sometimes necessary to check components following repair work. Any additional intermediate safety checks carried out should be documented and retained on the maintenance file. It should be clear on the documentation these are an intermediate safety check and not a full safety inspection.

Daily walkaround check

A driver or designated responsible person must conduct a walkaround check of a vehicle/ trailer prior to using the equipment on the public highway. At least one walkaround check should be carried out in every 24-hour period that the vehicle/trailer is in service.

Those carrying out such checks must be suitably trained and competent in identifying any faults that would render the vehicle/trailer unroadworthy.

The scope of the check should include all items that are readily visible to the inspector without the need for dismantling. To facilitate the inspection, it may be necessary to use an assistant.

1.5 Key points of a good maintenance system

Use these important key points as a guide to help you plan and set up a compliant and effective maintenance system for your vehicles.

1. A driver or responsible person must undertake a daily walkaround check, preferably immediately before a vehicle is used.
2. Any defects or deficiencies which cause the vehicle to be unroadworthy must be rectified before the vehicle is used.
3. First use inspections are essential for operators who lease, hire or borrow vehicles. These are especially important where vehicles and trailers have been off the road for some time. A first use inspection should not be confused with a drivers’ daily walkaround check.
4. Drivers must report promptly any defects or symptoms of defects that could adversely affect the safe operation of vehicles. Reports must be recorded and provision should be made to record details of any rectification work done.
5. Drivers’ defect reports used to record any faults and rectification work must be kept for at least 15 months.
6. Operators must ensure that safety inspections are carried out at the stated frequency as it is recorded on the vehicle operator licensing service (VOL).
7. Safety inspections need to include those items covered by the appropriate statutory annual test.
8. Safety inspections can also include items relating to local transport regulations or non-testable components.
9. Safety inspections should be pre-planned, preferably using a time-based programme.
10. The system of safety inspections should be regularly monitored, especially in the early stages.

11. Any remedial work carried out as a result of safety inspections must be recorded. The safety inspection record should at least include:

    • name of owner/operator
    • date of inspection
    • location of the inspection
    • the organisation who carried out the inspection
    • vehicle identity (registration mark/trailer number)
    • make and model
    • odometer (mileage recorder) reading, if appropriate
    • a list of all the inspection manual items to be inspected
    • details of any defects
    • name of inspector
    • complete details of any repair work and who did it
    • a signed declaration that any defects have been repaired satisfactorily and the vehicle is now in a safe roadworthy condition
12. On certain types of vehicles and for some operations, intermediate safety checks may be necessary.
13. Safety inspection records must be fully completed, and the vehicle declared roadworthy before it returns to service.
14. The transport manager, responsible person or delegated individual must have access to the completed safety inspection sheet or electronic record before the vehicle returns to service.
15. By exception if (14) cannot be met, the maintenance provider must send written confirmation that the vehicle is declared roadworthy before the vehicle returns to service.
16. Driver walkaround checks, safety inspections, first use inspections and intermediate safety checks must be documented using either manual systems or electronic systems (see section 4.7 – safety inspectors) or a hybrid of both.
17. Records of safety inspections must be kept for at least 15 months for all vehicles. This includes vehicles that have been removed from the operator licence or have been sold or otherwise disposed of.
18. Staff carrying out safety inspections must be competent to assess the significance of defects. Assistance should be available to support the safety inspection process.
19. There must be an internal system to ensure that unroadworthy vehicles are removed from service, with someone responsible for taking vehicles off the road.
20. Operators who undertake their own safety inspections must have the correct equipment and adequate facilities for the size of the fleet and types of vehicles operated.
21. All operators should have access to a means of measuring brake efficiency, setting headlamp aim and on-board diagnostics. For vehicles showing signs of excessive exhaust emissions, appropriate emissions testing equipment should be used to ensure that the level of emission is within the legal requirements.
22. Operators are responsible for the condition of vehicles and trailers that are inspected and/or maintained for them by agents, contractors or hire companies.
23. Operators who have contracted out their safety inspections must draw up a formal written contract with an inspection agency or garage, and this must be retained on file. Such operators should view inspection records and have a means of regularly monitoring the quality of work produced for them.
24. A maintenance scheduling system, planner or wall chart should be used to identify inspection dates at least 6 months for manual systems or can be dynamic for electronic systems.
25. Any system of maintaining roadworthiness of vehicles should be effectively and continually monitored.
26. Any changes by licensed operators to arrangements for safety inspections must be updated on the vehicle operator licensing service (VOL).
27. Drivers must be adequately trained and given clear written instructions about their responsibilities.

2. Responsibilities for roadworthiness

There are 7 sub-sections in this section of the guide:

This section gives best practice advice on the responsibilities that an operator or driver will have to undertake to ensure the roadworthiness of their vehicle. It covers what you are legally required to do according to the law.

As a user of vehicles, it is your responsibility to ensure that the vehicles you use are roadworthy. It is an offence to use an unroadworthy vehicle on the road. The term ‘user’ of a vehicle applies to the driver and the person paying the driver to act for them.

Legislation

If you are an operator of heavy goods vehicles (HGVs) and public service vehicles (PSVs), you must meet the governing legislation that the Traffic Commissioners have outlined in their Statutory Guidance Document. This is now in legislation, so if you operate within the UK or outside of the UK, you must ensure vehicles are roadworthy.

Operators must comply with the declaration they give to the relevant traffic commissioner that they will ensure that their vehicles are operated in a fit and serviceable condition.

If operators intend making any change to their maintenance arrangements, they must update the details on the vehicle operator licensing service.

Hire, loan or lease vehicles

The vehicle itself may either belong to the user or be in their possession under any agreement for hire, hire purchase, loan or lease. The user of a towing vehicle is responsible for the roadworthiness of a trailer even if it does not belong to them.

Light goods vehicles (LGV)

Operators or users of vans over 2.5 tonnes and up to 3.5 tonnes used to transport goods for hire or reward in the EU, Iceland, Liechtenstein, Norway and Switzerland will require a standard international operator’s licence.

You can find more information about transporting goods in Europe in vans or car and trailers.

Operators of light goods vehicles in-scope of operator licensing must maintain their vehicles in-line with this guide.

There is also an expectation that operator licence holders who use vehicles which are out of scope for operator licensing (for example light goods, agricultural and/or small passenger carrying vehicles) should have an appropriate maintenance regime in place to ensure the roadworthiness of these vehicles. Failure to maintain out of scope vehicles may also be taken into consideration by the traffic commissioner.

Trailers

Where reasonably practicable trailers should be specified on the vehicle operator licensing service.

This provides the operator with a more complete MOT pass rate and Operator Compliance Risk Score (OCRS) scoring with greater maintenance and compliance data accuracy.

To reduce the administration burden multiple licence holders operating as one group using the same maintenance regime where trailers are moved between operating centres may choose to specify trailers on one licence.

Operators should be aware that all trailers above 750kgs maximum authorised mass (MAM) used commercially for international journeys and all trailers used internationally irrespective of whether or not they are used commercially require registration.

Longer semi-trailers

There may be a requirement to include additional items for both the safety inspection and the drivers’ walkaround check.

Foreign trailers

If foreign trailers are operated, then the user is responsible for the roadworthiness in terms of condition and use of the trailer.

Traffic commissioners require that all vehicles be maintained in a fit and serviceable condition when operated under an operator’s licence. DVSA’s examiners support traffic commissioners by providing assessments of the effectiveness of operator’s systems in meeting this requirement. We will, therefore, focus on the levels of compliance and standards of roadworthiness rather than how operators achieve the high standards expected. This provides operators with considerable freedom to tailor their systems to the needs of their business.

2.1 Roadworthiness inspections

When it comes to ensuring the roadworthiness of a vehicle, there are 2 main types of essential inspections – which differ in scope and depth. Each type is used for a different purpose and requires different levels of skill to be carried out effectively.

The 2 types of inspection are:

• daily walkaround checks
• safety inspections, also includes first use and intermediate inspections

An inspection should not be confused with a service. A service contains items requiring routine maintenance, usually determined in scope and frequency by the vehicle’s usage and the recommendations of the vehicle’s manufacturer.

3. Daily walkaround checks

There are 2 sub-sections in this section of the guide:

This section looks at the daily walkaround check. It offers best practice advice on setting up a system for reporting faults and looks at defect reports, while clearly stating your legal position.

The driver is always legally responsible for the condition of the vehicle while in use. Therefore, conducting a daily walkaround check is a vital part of a driver’s core role. However, operators can delegate the walkaround check to a responsible person, who may not be the driver. Under these circumstances the driver needs to see evidence the check has been completed and the vehicle is free from safety defects. A minimum of one walkaround check must be carried out every day or at least once in a 24-hour period that the vehicle is used.

Where more than one driver will use the vehicle during the day’s running, the driver taking charge of a vehicle needs to make sure it is roadworthy and safe to drive by carrying out their own walkaround check; however, due to health and safety implications this may not be practical on all occasions.

An example of a system for managing in-service driver changes is where a walkaround check is carried out by a responsible person, and the drivers monitor the vehicle during the day’s running. When there is a change in driver during the day, it is sometimes unsafe to carry out a walkaround check, for example at a bus stop. This will be considered acceptable where there is a robust driver defect reporting system in place, which details the initial walkaround check and any defects or ‘nil’ defects reported during the day for the various drivers of that particular vehicle.

The check should cover the whole vehicle or combination and include all interior and exterior items that can be safely assessed without the use of a workshop. Where trailers are changed on multiple occasions, a check should be made on each trailer being used.

Walkaround check items can be found at:

• carry out HGV daily walkaround checks
• carry out bus or coach daily walkaround checks

Assistance may be required at some time during the check, for example, to see that lights are working. Alternatively, a brake pedal application tool may be used as an effective way of making sure stop lamps are working, and that the braking system is free of leaks. In addition, a torch, panel lock key or other equipment may be needed.

It could be beneficial to incorporate a post use check, to save downtime.

It is important that drivers are aware of the overall vehicle dimensions, including trailer and load. Vehicles over 3 metres high must display an in-cab overall height indicator. Where necessary the maximum height of the vehicle or load must be established using an appropriate measuring device and this height measurement correctly displayed in the cab. It is also important to consider route planning before starting your journey if low bridges need to be avoided.

Find out about how to prevent vehicles from hitting bridges.

3.1 A system of reporting and recording defects

There must be a system of reporting and recording defects that may affect the roadworthiness of the vehicle. This must include how they were rectified before the vehicle is used. Daily defect checks are vital, and any defects found must be recorded as part of the maintenance system. It is important that enough time is allowed for the completion of walkaround checks and that staff are trained to carry them out thoroughly. Drivers should be made aware that daily defect reporting is one of the critical elements of any effective vehicle roadworthiness system.

Examples of how to perform a walkaround check can be found at:

• carry out HGV daily walkaround checks
• carry out bus or coach daily walkaround checks

Drivers’ defect reports

As the driver, you are legally responsible for the condition of your vehicle when in use on the road.

Drivers must report any defects, or symptoms of defects, that could prevent the safe operation of the vehicles.

In addition to daily walkaround checks, you must monitor the roadworthiness of your vehicle when being driven and be alert to any indication that the vehicle is developing a fault, such as warning lights, vibrations or other symptoms.

When a vehicle is on site work, for example being used on rough terrain, you must walk around the vehicle before leaving the site to identify any faults or damage. Particular attention should be made to the wheels and tyres. If any safety defects are found, you must not use the vehicle on the road until it is repaired.

Providing a written report

Any defects found during the daily walkaround check, while the vehicle is in use or on its return to base, must be the subject of a written report by the driver or some other person responsible for recording defects.

The details recorded should include:

• vehicle registration or identification mark
• date
• details of the defects or symptoms
• the reporter’s name
• who the defect was reported to
• assessment of the defect
• rectification work
• date rectification work was completed
• it is also common practice to use a composite form that includes a list of the items checked each day. Where practicable the system should incorporate ‘nil’ reporting when each driver makes out a report sheet - or confirms by another means that a daily check has been carried out and no defects found.
• electronic records of reported defects are acceptable and must be available for 15 months, along with any record of repair.

Appropriate action

• All drivers’ defect reports must be given to a responsible person with sufficient authority to ensure that any appropriate action is taken. This might include taking the vehicle out of service.
• Any report listing defects is part of the vehicle’s maintenance record and must be kept for at least 15 months, together with details of the rectification work and repairer.
• It is good practice to complete and retain ‘nil’ defect reports as they are a useful means of checking that drivers are carrying out their duties and these forms can be used for audit purposes.
• A ‘nil’ defect reporting system demonstrates a check has been conducted and is a positive report that the vehicle is free from defects.
• It is recommended that ‘nil’ defect reports are retained for at least 3 months
• If you are an owner-driver, you will probably not have anyone to report defects to, except your transport manager (if you have one). In these cases, defects and the remedial action taken can simply be recorded and held for at least 15 months.

Accessing maintenance resources

Operators should ensure that adequate maintenance resources are available to rectify reported defects before the vehicle is used. Consideration needs to be given for accessing external maintenance providers, vehicle breakdown cover and managing in-service defects when the vehicle is on its journey.

3.2 Drivers’ responsibilities

Drivers must be made aware of their legal responsibilities regarding vehicle condition and the procedures for reporting defects. Operators must ensure that all drivers fully understand their responsibilities and are adequately trained to perform this function, which may be part of their driver’s certificate of professional competence training. Where English is not the drivers first language operators must ensure that additional translation or training is provided. Driver’s responsibilities should be detailed in writing, describing defect reporting systems as well as any other duties they are expected to perform. The driver should sign to confirm they have received their responsibilities in writing and understand what is required. A copy of the document should be kept on file. Drivers share the responsibility for the vehicle’s roadworthiness with the operator. They may be fined or prosecuted for roadworthiness offences found on vehicles if they are considered partly or wholly responsible.

Minor repairs by drivers

If you are an operator, you should bear in mind that drivers who are expected to repair minor defects in service would need appropriate training. Any repairs carried out must be documented using the defect reporting system.

Drivers using tachograph records must record the walkaround check and any associated repairs as ‘other work’.

Traffic commissioners can take action against a driver who fails to complete an adequate walkaround check. This could lead to a driver conduct hearing, which may result in the loss of the vocational driving licence.

Towing another company’s trailer

An operator can provide a traction only service for customers who want to use their own trailers for branding and loading purposes but do not want to operate vehicles to tow them.

Traction only operators irrespective of whether they own, keep, or maintain trailers are required by law to have an authorisation for trailers as part of their operator’s licence.

Recommendations:

• Minimum trailer authorisation should match the number of towing vehicles operated or the number of trailers that would park at the authorised operating centre/s – whichever is greater.
• It is recommended that trailers are specified on VOL, which will provide details of inspection frequency and maintenance arrangements.
• Where third-party trailers are not on the same safety inspection frequency as the operator’s trailers then as a default position the inspection frequency should not exceed 13 weeks.

#### Example

An operator may have a fleet of tipping trailers which due to the demanding nature of the work have an inspection frequency of 6 weeks. The operator also carries out traction only work where the third-party trailers carry out light load operations are only inspected every 12 weeks.

Where this is the case the vehicle operator licensing service should identify a mixed safety inspection frequency for trailers.

The operator must make sure that the trailer is safe to use and inspected on the agreed frequency.

The traction operator is responsible for:

• Carrying out a walkaround check
• Recording any defects and how they were repaired before use

Also have access to:

• The safety inspection interval
• A copy of / or access to the current safety inspection reports, including brake tests.
• A copy of / or access to current MOT certificate
• electronic braking performance management system (EBPMS) report if applicable

The operator should have in place a contract or written agreement with the trailer owner detailing the safety inspection details, frequency and defect rectification that satisfies an acceptable level of roadworthiness is maintained. See annex 5 for an example of a maintenance contract (PDF, 46 KB).

The trailer owner normally would be responsible for the routine maintenance of the trailer, including the safety inspection.

They also have the obligation to provide the required documents for the trailer user.

The trailer owner is responsible for:

• the routine maintenance including safety inspections
• providing evidence that first-use and safety inspections have been done and there are no defects
• completing any manufacturers safety recalls
• ensuring there is a current roadworthiness certificate (MOT), where required
• ensuring relevant documentation is available for the trailer user

Defect rectification

To prevent the third-party trailer being used in an unroadworthy condition there must be a robust system or process in place to ensure defects identified during the walkaround check or developed during use are recorded and rectified.

Non-UK registered trailers

A process must be in place to ensure non-UK registered third-party trailers are maintained in a roadworthy condition before being used.

• Where possible an operator towing a non-UK third party trailer should ensure it has a current roadworthiness certificate (MOT). This can often be found with the trailer documentation or see next bullet point.
• The European Commission has more information on roadworthiness certificates (RWC) and proof of test (POT) for EU member states.
• A drivers walkaround check is carried and any identified defects are rectified before the trailer is used.
• Where an operator maintains control of a non-UK trailer for longer than 13 weeks, a process should be in place to ensure a safety inspection is carried out in-line with the operator’s stated trailer frequency.
• Where an operator or transport manager cannot satisfy themselves that the trailer is adequately maintained the trailer must not be used.

Prohibitions

Operators are responsible for ensuring any prohibitions issued to vehicles or trailers being used by them are either removed or they have notified the vehicle or trailer owner that a prohibition has been issued.

• Removal inspection results are normally recorded against the operator who received the prohibition notice.
• Failure to take appropriate action when a prohibition is issued could associate the operator with the offence of using the vehicle or trailer with a prohibition notice in force.
• Operators are also urged to proactively follow up potential issues with the vehicle or trailer owner and third-party maintenance provider with the aim of addressing any issues within the maintenance systems.

The driver/operator bears full responsibility for the safe operation and roadworthiness of the tractor/trailer combination at the time it is being driven.

4. Regular safety inspections, first use inspection and intermediate safety checks

There are 11 sub-sections in this section of the guide:

This section describes why regular safety inspections, the first use inspection and intermediate safety checks are essential to an effective roadworthiness maintenance system.

4.1 Inspection scope and content

Safety inspections form part of the overall maintenance plan of a vehicle, their purpose is to assess the safety critical items and other items affecting roadworthiness and the environment.

Safety inspections should be undertaken independently from routine servicing and repair, although they can form part of a more comprehensive inspection that includes the assessment of items or specialist equipment associated with the vehicle’s work activity and its performance.

This allows the flexibility to amend frequency or to introduce intermediate safety checks or ad-hoc safety inspections, without impacting on the frequency of planned servicing or routine maintenance.

Safety inspection reports produced following an inspection not only provides the operator with the means to determine individual vehicle roadworthiness, but also the overall effectiveness of their maintenance systems that then allows them to identify areas for review.

Standards to be applied

Reference should be made to manufacturers’ recommended tolerances to ensure that each item covered by the safety inspection is inspected properly and limits of wear and tolerance are adhered to.

In addition, DVSA produces annual test inspection manuals, which give details of inspection methods and pass/fail criteria:

• MOT inspection manual: HGVs
• MOT inspection manual: public service vehicles (PSVs)

It should be emphasised that the standards for the annual test are the minimum legal standards and should be used as guidance for the safety inspection.

The inspector will need to consider the frequency of inspection, the age of the vehicle, expected mileage and type of work undertaken to assess whether a component would remain in a serviceable condition before the next inspection is due.

Being cost effective

Although primarily undertaken in the interest of safe vehicle operations, safety inspections– together with prompt remedial action– are also cost effective. The early indication of wear, damage or maladjustment may prevent sudden failure of components resulting in unscheduled downtime or prevent wear becoming so advanced that premature replacement becomes necessary.

4.2 Safety inspection intervals

Operational needs must not override safety considerations. Safety inspections should, where it is practicable, be programmed to follow a time-based pattern. The frequency at which inspections are undertaken should be determined by assessing the level of mechanical degradation likely to be incurred over a period as a result of the vehicle’s usage. This will depend on such factors as:

• the age and type of vehicle operated
• the recommendations of the vehicle manufacturer
• the nature of its load, the equipment and fittings it carries or supports
• the type and range of operations on which it is likely to be engaged
• the type of terrain and the nature of the environment in which it operates or is likely to operate
• the distance and speeds at which it travels and the journey times.

Assessing the above factors for each vehicle will, in most cases, enable a time-based programme of inspections to be formulated. Some operations, however, are subject to continuous change, or vehicles can frequently be reassigned alternative tasks or routes, making the adoption of a strictly time-based inspection programme impracticable.

Mileage-based inspection programs may be more suitable for some operators but will need to be linked to time.

Older vehicles and trailers

National statistics show that as vehicles and trailers age, the average annual MOT failure rate increases, and they are more likely to experience in-service roadworthiness defects than newer vehicles. Therefore, the guidance has reflected that older vehicles and trailers will need more frequent maintenance and has indicated a minimum safety inspection frequency of 6 weeks requirement for vehicles and trailers aged 12 years and older.

However, depending on usage, such as low mileage and light conditions, the frequency may be extended.

New vehicle operators

If you are a new vehicle operator, you will not have the benefit of experience or vehicle maintenance records to call upon.

Setting the inspection frequency will need to consider the type of work undertaken, the operating conditions, the age of vehicle and mileage covered. Whatever the safety inspection interval is, its effectiveness in ensuring that the vehicle is safe for use on the road should be regularly monitored and proactively managed.

Monitoring is especially important in the early stages.

A guide to safety inspection intervals

An inspection frequency would normally range between 4 to 13 weeks. See table below for examples of operating conditions. Operators may also consider intermediate safety checks for high-wear items. This may allow the frequency of the safety inspections to be extended, see section 4.5 – ad hoc safety inspection intervals.

Operating conditions	Frequency
A. Lightly loaded vehicles - easy operating conditions	10-13 weeks
B. General haulage - trunking	6-10 weeks
C. Arduous work - constant heavy loads	4-6 weeks
D. Off road - difficult conditions	4 weeks
E. Vehicle/trailer 12 years or older	6 weeks

Experienced vehicle operators

If you are an experienced operator, you are free to tailor these inspections to suit the nature of your operations and vehicle characteristics. You may even deploy more than one system across a fleet, where vehicles and the nature of their work vary, even where one particular aspect of vehicles’ operations require a greater inspection frequency than the whole vehicle fleet (see case study 2). Systems will be judged primarily on their effectiveness in maintaining roadworthiness.

It follows, therefore, that to maintain an inspection regime that is sufficiently flexible to accommodate these changing criteria, it might be more appropriate to adopt an inspection frequency determined by, for instance, the vehicle’s mileage. However, if you modify your inspection schedule, it is sensible to monitor the effect on roadworthiness on a monthly basis. If an unacceptable increase in defects were seen, then a change back to the original schedule would be necessary.

The vehicle operator licensing service (VOL) records a time-based frequency for both vehicles and trailers. Therefore, if a mileage-based frequency is adopted, the expected maximum equivalent time-frequency should be entered into the system (up to 13 weeks). Then ensure the mixed frequency box is ticked on VOL to record that a varied inspection frequency is being used. This same process should be used if a mixed time frequency is being used for different vehicles or trailers on the fleet.

See the case study examples in section 4.3 for a better idea of how to adapt your systems.

Leased vehicles

Leasing companies may be able to assist operators with determining the frequency of inspections, but operators are still responsible for the condition of the vehicles they use.

Whichever safety inspection (SI) interval is decided upon, the inspection frequency should not be extended without updating the vehicle operator licensing service. The following safety inspection should be carried out within the specified weekly or mileage- based time scale, and not beyond. To allow some flexibility in planning safety inspections it is recommended that the International Organization for Standardization (ISO) week numbering system is used. With this system the safety inspection (SI) should be completed within the relevant ISO week it falls. ISO defines the week as always starting with Monday through to Sunday. See annex 6 for an example of a maintenance planner (PDF, 49 KB).

Example of a 6 weekly SI interval has been decided using the ISO week planner. For this example, the vehicle came into service and had a first use inspection in week 10 of the ISO calendar. The following safety inspections should then be completed within ISO week 16, 22, 28, 34, 40, 46 and so on.

If a safety inspection was completed outside the planned schedule, for example because of a breakdown, a new schedule may need to be created. For the example given above it would not be permissible to carry out an early SI in week 20 and then have an 8-week interval to week 28. The operator would need to either carry out another SI at week 22 – and continue with the originally planned schedule – or reschedule 6-week intervals from week 20 to 26, 32 and so on.

Vehicles that are only used for part of the year, or that have been out of service for some time, should be inspected before they are brought back into service.

When they are being used, the subsequent safety inspection intervals should be determined in accordance with the table above, conditions of use and the equivalent annual mileage (for example, 20,000 miles covered over a 6-month period represents an equivalent annual mileage of 40,000).

Trailers not permanently coupled, but in regular use, need to be assessed on their conditions of work and anticipated mileage.

Where there are doubts about what interval to choose, new operators are advised to be cautious and make more, rather than fewer, checks.

Where vehicles operating in difficult conditions – for example, in quarry work or on building or land reclamation sites, and vehicles carrying corrosive substances where conditions result in accelerated component wear and vehicle damage the operator is advised to increase the number of safety inspection checks above the guidance in the table shown.

4.3 Case studies

The case studies are based on fictional examples and not related to current operators.

Case study 1 – N E Hall

N E Hall are a new haulage company who need to implement a maintenance schedule. They estimate an annual mileage of 100,000 miles and will be carrying out arduous work. Based on DVSA’s table they selected an initial time interval of 4 weeks for their inspections.

Case study 2 – All Construction

All Construction are an experienced operator and have 6 7.5 tonne trucks which operate on the road and on building sites. They found that most defects identified during the 4 weekly inspections were suspension related due to operating over the rough terrain.

They decided to modify their maintenance schedule to include intermediate safety checks so that the suspension was inspected every 3 weeks and the whole vehicle was fully inspected every 6 weeks. After trialling this for 6 months they noticed suspension components were being replaced before becoming defective. They also did not see any deterioration in other parts of the vehicle due to the reduced safety inspection frequency. Making this change has helped All Construction save money by reducing the safety inspection frequency while making the vehicles safer with the intermediate suspension checks. VOL was updated to show the new 6-week safety inspection frequency.

Case study 3 – CJS Couriers Plc

CJS Couriers Plc are a courier company that normally operate within the Bristol area but occasionally carry out national or continental deliveries. CJS found that, during normal operations, the 4 weekly system was too frequent as very few defects were ever found. However, when there is an increase in national or continental deliveries, they were seeing a spike in defects during that period. Generally, during a local delivery period, they will drive 50 miles a day on each vehicle. A national delivery could result in a daily mileage of 360 miles depending on location, and a continental delivery would be significantly more. They decided to switch the policy so that the vehicles are inspected every 2000 miles or every 6 weeks, whichever comes first.

Case study 4 – Pronto Bus Plc

Pronto Bus Plc are a large operator with great experience. They use 2 different models of buses: the Speedliner and the Retro. Because of the age difference between the 2 models, they found they had significantly different levels of reliability. The Speedliner vehicles, which were over 12 years old, were very unreliable and so they needed to inspect them every 4 weeks to maintain safety. The Retro, which is a newer vehicle, was much more reliable and so the inspection frequency was reduced to every 6 weeks.

After monitoring this for 12 months, they found no change in roadworthiness for the Retro model. An update on the vehicle operator licensing service (VOL) will be required due to the change in the inspection frequency. The maximum frequency will need to be recorded on VOL. In this case, 6 weeks and the mixed frequency box ticked.

Case study 5 – MacDonald Bus Ltd

MacDonald Bus Ltd are an experienced operator who run 152 buses around the Edinburgh area. They operated a strict 28-day inspection frequency but felt this was excessive because 75% of the fleet was relatively new. They decided to reduce the frequency to 42 days for the 114 buses, which are under 6 years old, and keep the remaining, older, buses, as they are. This was seen to have no negative effect on roadworthiness over a 12-month monitoring period.

They were able to reduce their yearly inspections by 300, thus freeing up buses and staff for other jobs. In this case, the vehicle operator licensing service (VOL) will need to be updated with the maximum frequency. The mixed frequency will also need to be ticked.

Case study 6 – Move4U

Move4U are a removal company with a fleet of vans and trucks of various sizes. They initially inspected the fleet every 4 weeks as recommended by DVSA but felt this was too often. They increased this to every 12 weeks, but after a 6-month monitoring period, they saw a large rise in defects resulting in more prohibitions from DVSA at the roadside. They then decided to reduce this to every 6 weeks as a more realistic frequency.

After 12 months of monitoring, the defect level has matched what it was at 4 weeks, and so Move4U have decided to use this schedule permanently.

4.4 Safety inspection report forms

A safety inspection report must be completed for each safety inspection for both vehicles and trailers. If the safety inspection report is to be stored electronically, then the paper version does not need to be retained. This does not rule out the use of electronic devices (for example, tablets) in place of paper safety inspection reports.

For further information relating to computer systems, see section 4.6 – electronic capture and storage of safety inspection data.

Each report should show at least the following:

• name of owner/operator
• date and ISO week of inspection
• organisation conducting the inspection
• address / location of inspection
• vehicle identity (registration/trailer number)
• make and model
• odometer (mileage recorder) reading (if appropriate)
• a list of all items to be inspected
• an indication of the condition of each item inspected
• details of any defects found
• name and signature of inspector
• details of any remedial/rectification or repair work and who carried out the work
• named signed^{[footnote 1]} and dated statement declaring that any defects have been repaired satisfactorily and the vehicle is now in a safe and roadworthy condition

Examples of safety inspection forms can be found at:

• example heavy goods vehicle (HGV) safety inspection record (PDF, 87 KB)
• example public service vehicle (PSV) safety inspection record (PDF, 85 KB)
• example light goods vehicle (LGV) safety inspection record (PDF, 82 KB)
• example small trailer safety inspection record (PDF, 65 KB)

The report may contain details of any work to be carried forward. In particular, further checks may be needed on certain items deemed likely to deteriorate during service and make the vehicle unroadworthy before the next scheduled inspection or routine service.

Additional items may be included in the safety inspection, which may be non-testable items required for specific operations or local additional safety requirements, such as the Direct Vision Standards.

Safety inspection reports must be fully completed, and the vehicle declared roadworthy before it returns to service.

The transport manager, responsible person or delegated individual must have access to the completed safety inspection sheet or electronic record.

It will normally be expected that the safety inspection record will be provided or be available to the operator before the vehicle returns to service. However, exceptionally where it is not possible to provide the record at this time the contractor should supply written evidence that the vehicle is declared roadworthy in advance of the record.

4.5 Ad hoc safety inspection intervals

Safety inspections may be needed at times outside the scheduled programme. This may include when the vehicle is used for harder work or covers greater distances than usual (for example, vehicles used on site).

4.6 Electronic capture and storage of safety inspection data

Safety inspection and repair work records, whether undertaken by operators or contracted out, must be kept for at least 15 months as part of a vehicle’s maintenance history.

Operators must, ensure that the electronic records are complete and available, or can be made available on request for inspection at the operating centre. If you hire, lease or borrow a vehicle you are responsible for its roadworthiness and must have available, if required, copies of any inspections that have been carried out while the vehicle is in your possession.

The right digital solution can add benefits to any maintenance system by providing ease of access to all relevant data in one place, including:

• safety inspections
• unplanned maintenance
• inspection reports
• driver defect reporting system
• fleet management

Linking to related data - such as technical information - means that it can be obtained quickly, as well as giving you the ability to create maintenance schedules, which are both planned and dynamic.

Systems can be linked to those run by maintenance providers, giving shared data on:

• maintenance history
• scheduled repairs
• invoicing

The automated processes that can be created help to organise and manage an efficient and well-planned system.

What the maintenance system needs to do

It is ultimately the roadworthiness of the vehicles operated that will demonstrate if the system is well designed and meets the required standards.

Operators, as well as drivers, are responsible for the condition of their vehicles. Operators need to satisfy themselves that any systems/devices used do not undermine the running of a safe and efficient fleet.

Software/hardware providers should make sure that any system they design considers the requirements of this guide.

Important features of a computerised system:

• instant access to downloaded inspection results and reports
• the availability of hard copies of records to be produced on request
• it must be tamper proof (for example, records cannot be changed at a later date)
• it must be clear what’s been checked and by whom
• there must be a clear end-to-end audit trail
• data file which covers all maintenance records for the fleet using the system
• fully electronic inspection records
• collaborative digital planners
• drivers walkaround check and defect reporting application
• compliance dashboard
• meet data protection requirements (including the general data protection regulation)
• data back-up and disaster recovery system

Any maintenance software should be developed in line with the maintenance schedule agreed as part of the operator’s licence requirements, and in consultation with this guide.

Making sure your vehicle maintenance system is secure

To make certain that your system is secure you should consider:

• digital authentication – for example, a login or PIN
• date and time stamping
• an audit trail on both the part of the maintenance provider and the operator

Whilst enforcement action for non-compliance rests with the operator, it is their responsibility to make sure that the system provider can guarantee the reliability of the data.

Recording the maintenance of hired or temporary vehicles

Digital systems must take account of such vehicles as defined within this guide.

Keeping old data

Where vehicles or trailers change ownership, the records relating to these - even in digital format - must still be available to the original operator in accordance with this guide.

Sharing data

You may need to share information digitally, for example a traction operator may need access to safety inspection records for your trailer. Any data shared should be done securely.

Managing the system

Regular administration and backup of electronic data should be undertaken. It is ultimately the responsibility of the operator to ensure the safekeeping of such data, along with an effective management process.

Easy access to the data - for management and enforcement purposes - must also be available. Data security and integrity must exist with any system used - this may include some form of clear audit trail.

The operator must have a plan in place to ensure the system can be accessed by sufficient delegated people to maintain effective management control in the event of staff absence.

It is ultimately the operator’s responsibility to make sure that the maintenance system used meets the requirements of their business and operator licence.

Conducting the daily walkaround check

The daily walkaround check can be done using a handheld device, and the results stored digitally.

These can include devices like tablets or smartphones, which can be given to the driver or allocated to the vehicle. The system must provide:

• a suitable method of digital signature
• secure data input and storage
• confirmation that the vehicle is in a roadworthy condition at the start of the journey

Forms can also be completed by hand and then scanned and saved digitally. Images must be easily accessible by date and vehicle.

It should always be possible to produce a minimum of the current day’s record at the roadside. Systems must include effective date and time stamping to make sure data is reliable, including nil defect reporting where it is included.

Nothing in this guide prevents the operator from using systems with additional functions.

Recording in-service defects

The same systems can record defects which happen whilst a vehicle is in use. This can be an extension of the same process, with the ability for the driver to ‘add’ a record for that day including information about the action taken. Such systems should reflect the requirements as shown above.

In all cases, there must be confirmation that the vehicle is roadworthy and safe to use.

Planning safety inspections

Safety inspections should ideally be planned 6 months in advance. Vehicles that are subject to a statutory annual test can plan their year’s programme - such as cleaning and major servicing - to avoid duplication of work associated with the test.

A simple method of drawing up a programme is to use a year-round planner or flowchart. Digital systems are equally fine, and electronic record management and storage systems will often include a planning feature.

Please use the guidance set out in this guide when using a digital system. Such systems must:

• be capable of providing records in ‘real time’ to the operator
• include an audit process that shows date and time stamping

Regular safety inspections

You can collect and store safety inspection information using an electronic device. The records must show a clear audit trail from inspection to sign-off after repair (if one is needed). It is very important that it includes a declaration that the vehicle is fit for service or whether repairs are required.

Completing safety inspection report forms

A separate record must be completed for each safety inspection of a vehicle or trailer. Where the record of the safety inspection is to be stored digitally, then the checklist used for the inspection does not need to be kept. You can use an electronic device (for example, a tablet) in place of a checklist.

Capturing and storing safety inspection data electronically

Barcoding or scanning of defects found or work done is acceptable providing that a means of interpreting each code is available. See important features of a computerised system.

Safety inspection records stored digitally must be:

• tamper-proof
• capable of producing hard copy information if required

Computer records must contain the same information as any comparable manual form.

4.7 Safety inspectors

A person undertaking safety inspections must be technically competent and operationally aware of the safety standards that apply to the vehicles they examine. They should have been trained in the techniques of vehicle examination, diagnosis and reporting, and possess a sound working knowledge of the relevant inspection manuals produced by DVSA. A safety inspector could prove technical competence by solely time served experience. However, with modern vehicle systems and working practices, it is strongly recommended that inspectors obtain relevant technical qualifications and achieve an automotive technical accreditation such as IRTEC (Inspection Technician Accreditation) or similar - meeting a recognised quality standard for the vehicles they inspect.

Inspectors must have undertaken specific training about risks and hazards of working on alternative fuelled vehicles where applicable – see section 5.5 – vehicle emissions and fuel management.

A safety inspector should not be expected to carry out repair or servicing work during the examination.

4.8 Use of assistants

There will be times during an inspection when the inspector will require the assistance of someone to operate certain vehicle controls. The operator should ensure that this assistance is available when required. The vehicle’s driver can often provide such assistance.

4.9 Authority to remove or reinstate a vehicle

If you are the operator, you must ensure that someone within your organisation has the authority to decide whether a vehicle is fit for service at all times.

That person must be available to decide whether a vehicle needs to be taken out of service and when it can be allowed back on the road after repairs. This responsibility may be delegated, in writing (for example, in the form of a standard agreement) provided that it is made clear what their responsibilities are.

The transport manager retains legal responsibility for vehicle roadworthiness, regardless of whether their activities are delegated.

4.10 Vehicle cleanliness

Vehicles should be cleaned regularly on top, inside and underneath. This will make it easier to spot defects at scheduled safety inspections and during the daily walkaround checks.

4.11 Duties of staff

It is important that all staff with an involvement either directly (for example, drivers and workshop staff) or indirectly (for example, transport management) are made fully aware of the company’s legal and moral responsibilities as an operator of road vehicles. They should also be made aware of the subsequent importance of ensuring the effective operation of the vehicle maintenance programme.

Drivers, workshop staff and those otherwise responsible for the condition of vehicles should be individually informed in writing of their specific duties and responsibilities – particularly regarding safe vehicle operation.

Emphasis should be placed on the importance of maintaining an effective safety inspection programme and the role they play in promoting and sustaining its integrity.

One method might be to write to each relevant employee in duplicate, thus permitting a returned signed copy to be retained by the company.

5. Safety inspection and repair facilities

There are 16 sub-sections in this section of the guide:

This section covers the facilities needed to undertake safety inspections and the arrangements needed if you do not undertake your own inspections. The same guidance applies to the repair of any defects found during safety checks.

If you are an operator, you must decide whether to undertake your own safety inspection and maintenance work in-house or to contract all or part of the work to someone else.

If you decide to provide your own safety inspection facilities, you must ensure that they are adequate for the job.

If you choose to outsource any of your maintenance, you need to take steps to ensure the maintenance facility is adequately equipped and completes any work to a satisfactory standard. The quality of the work and the workshop facilities should be periodically reviewed by undertaking quality assurance checks.

It is strongly recommended that the maintenance facility demonstrates their competence by achieving a recognised accreditation for workshop standards. This can be gained through manufacturers’ franchised workshop quality standards or by an independent assessment, like the IRTE National Workshop Accreditation scheme.

The industry is trialling a new Maintenance Provision Rating Scheme (MPRS), this will award a rating to participating workshops. The rating level will be based on the quality of the training and competence of the engineers and the equipment available within the facility.

The aim of the MPRS is to help improve commercial vehicle maintenance facilities and allow operators a method to identify the quality of workshops.

The MPRS will be trialled over 2024/25, with the intention of a formal launch in 2025/26, for further details contact your trade association.

5.1 Safety inspection facilities

Facilities must be a safe working environment and 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 (for example, a roller brake tester, decelerometer)
• access to headlamp test equipment
• brake temperature sensing device (if relevant for the fleet)
• tread depth gauge
• tyre pressure gauge
• access to on-board diagnostic equipment (if relevant for the fleet)
• access to emissions testing equipment
• access to steam or pressure under-vehicle washing facilities

If an operator fails to maintain vehicles in a safe and roadworthy condition with the facilities provided the Traffic Commissioner may take regulatory action.

Find out about approved MOT testing equipment.

Technical information

As part of promoting good practice and improving safety standards, the Society of Operations Engineers (SOE) has produced a series of technical guides. Most are free to download and include the best practice for wheel security and safe working practices.

Wheels and tyres

The code of practice for the selection and care of tyres and wheels for commercial vehicles (developed jointly by the Department for Transport, the British Standards Institute and industry and trade associations) recommends that following road wheel removal and refitting, the wheel nut torque should be checked – after the vehicle has been standing for 30 minutes or after having travelled for between 40 km and 80 km (25 to 50 miles). It is also important to check manufacturers’ recommended procedures when refitting road wheels.

All re-torque checks must be recorded and retained on file.

More information on wheel security can be found at commercial vehicles: wheel maintenance.

5.2 Tyre management system

A robust tyre management system is essential for any professional vehicle operator and should ensure:

• that tyres in service are appropriate to the vehicle and operating conditions
• that tyre age is recorded and monitored for the entire fleet on the tyre management system and that tyres aged more than 10 years old must not be used on the front steered axle(s) of HGV, bus or coach or any single wheels fitted to a minibus (9 to 16 passenger seats)
• where tyres more than 10 years old are legally used, their age should be recorded and a specific risk assessment is completed that considers the distance, speed and loading conditions that the vehicle will operate under (for example, operating only in urban areas)
• the tyre manufacture date code must be legible on all tyres fitted to HGV, bus or coach, trailers over 3.5t and minibuses (9 to 16 passenger seats)
• where a date code cannot be seen due to the position on the inside of a twin wheel fitment, this should be advised on the safety inspection. The operator should ensure that the date code is present on the tyre
• safety inspections must report all tyre defects, for example where a manufacturers date code is illegible or whether a tyre is unserviceable and record the rectification action that has been taken
• when a tyre is 9 years old this should be advised on the safety inspection. When over 10 years old and cannot be legally used, these must be reported as a defect
• tyre pressures are monitored, recorded as presented on the safety inspection report, and maintained to the correct pressure. Where a tyre is found to be under inflated this should be investigated and any rectification action recorded on the safety inspection report
• that vehicle tyres are regularly and closely examined for damage and wear with mechanisms in place to address any identified issues
• tyre tread depths are monitored, recorded on the safety inspection report
• an accurate tread depth gauge is used
• that processes exist to distribute best practice in tyre management throughout the fleet
• that staff dealing with tyre management are properly trained and empowered to act with sufficient authority
• that any technician dealing with tyre inspections or repairs is properly trained and qualified
• that any on-site tyres are properly stored
• that drivers are properly trained and equipped to recognise and report tyre issues

The British Tyre Manufacturers’ Association has information and advice for professional road users relating to tyres and tyre repairs.

5.3 Braking performance assessment

A high percentage of MOT braking defects are only found during a braking performance test; therefore, every safety inspection must assess the braking performance of the vehicle or trailer.

An electronic braking performance monitoring system (EBPMS) may be used to monitor in-service braking performance and provide a braking performance report for the safety inspection.

Where EBPMS is not being used a calibrated roller brake test is the most effective method of measuring individual and overall braking efficiencies. A plate brake testing device may also be suitable depending upon the design of the equipment.

It is acceptable to use an approved and calibrated decelerometer to measure overall brake efficiency values for rigid vehicles without trailers or for vehicles that cannot be tested on a roller brake tester (RBT). A decelerometer will measure the overall brake efficiency but it may not identify individual braking issues.

A temperature check needs to be carried out before and after the decelerometer test to help identify if individual brakes are operational. Final brake temperature readings need to be significantly higher than the initial readings to properly assess the brake performance, with relatively consistent readings taken for each brake across an axle. Where satisfactory results cannot be achieved another method to assess the brake performance needs to be used.

Brakes which are cold (ambient temperature) or showing an inconsistent reading from the brake on the opposite side on the same axle, need to be investigated further.

Where possible brake testing should be undertaken with the vehicle or trailer in a laden condition to achieve the most meaningful results. A competent person may carry out a risk assessment based on use, working conditions, mileage and the age of vehicle to determine if some of the brake tests carried out in the year can be unladen; however, it is strongly recommended that at least 4 of the brake tests carried out are laden. Risk assessments need to be retained on file and made available for inspection.

From 1 January 2023 vehicles and trailers must be appropriately laden when presented for annual test. For further information refer to section 2.1 of the heavy vehicle brake test guide for details of vehicles that may be presented unladen.

See section 5.3a for brake assessment expectations from April 2025.

More information regarding brake testing and the use of RBTs can be found at:

• prepare your HGV for the brake test
• MOT inspection manual: public service vehicles (PSVs)

Small trailers up to 3.5t with overrun brakes should normally be tested using one or a combination of the following methods.

1. A static test where the trailer is jacked up and the hand brake is applied progressively to check the brake application on each wheel
2. a park brake drag or gradient test
3. a laden road test with brake temperature check where the brake temperatures checked before and after the road test and compared to the opposite brake on the same axle. The brake temperatures should increase due to the application of the brakes and be similar to the other brake across the axle

Operators must satisfy themselves that the methods used to assess brake performance are sufficient to meet the requirements of Regulation 18 of The Road Vehicles (Construction and Use) Regulations 1986:

18(1) Every part of every braking system and of the means of operation thereof fitted to a vehicle shall be maintained in good and efficient working order and be properly adjusted.

It is required that brake test reports are reviewed and understood to ensure the brakes are working correctly.

Guidance on how to interpret roller brake test reports is available at understanding your HGV or trailer’s brake test report.

A signed printout of the brake efficiency test from either the RBT, plate tester or decelerometer should be attached to the safety inspection record. If the brake test equipment cannot produce a printout, the test results need to be recorded by the inspector on the safety inspection report.

If the braking performance is being monitored by EBPMS the performance value should either be detailed on the safety inspection report or a braking performance report attached separately.

To help operators arrange a brake performance assessment with safety inspections, it is acceptable for a satisfactory brake performance assessment to be carried out no more than 7 days before the date of the safety inspection. The RBT report needs to be provided to the maintenance contractor when presenting the vehicle for inspection or if in-house maintenance to the vehicle technician conducting the safety inspection.

The safety inspection should record the date of the assessment, how the braking performance was assessed and whether the vehicle or trailer was laden.

If deficiencies in brake performance have been identified either during the use of the vehicle or trailer or at the safety inspection appropriate remedial action must be taken to address the issue. A measured brake efficiency test must also be carried out to confirm the brakes are performing satisfactorily before the vehicle or trailer can be considered as roadworthy, the vehicle should be laden. The results of this brake test must be kept as evidence of repair with the operator’s maintenance documentation.

5.3 (a) Braking performance assessment requirements from April 2025

To follow best practice and comply with legislation there is an expectation that every safety inspection will include a brake performance assessment using either an RBT, a suitable electronic brake performance monitoring system (EBPMS) or a decelerometer with temperature readings.

If EBPMS is not used it is expected there is a minimum of 4 laden brake tests spread evenly across the year, this can include the annual test.

Where a laden brake test is not carried out a risk assessment detailing the reasons, must be completed by a competent person^{[footnote 2]} who understands braking systems and components (for further details see below).

If using EBPMS to monitor brake performance, there must be an evaluation of the vehicle/trailer performance report before every safety inspection by a competent person who can interpret the data. The evaluation must be signed, dated, and attached to the vehicle record together with the performance data report. The evaluation and data report may be a single document.

To allow flexibility vehicles can be presented for brake testing up to 14 days before the safety inspection date; this allows the operator to conduct a laden brake test during the vehicle/trailer normal activities without the need to specially load it.

It is the operators’ responsibility to ensure that the braking performance of any vehicle or trailer meets the applicable requirements of The Road Vehicles (Construction and Use) Regulations 1986, Section 18, Maintenance and efficiency of brakes.

Risk assessment when not carrying out a laden brake assessment

A risk assessment must be available to support every safety inspection where a laden brake test is not completed, or where an EBPMS evaluation is not available.

The risk assessment must be evaluated as part of the safety inspection to confirm that it is still relevant and reviewed every 12 months.

Where it is anticipated that there will be no change in the use of the vehicle/trailer during a twelve-month period a single risk assessment may be used. Any change in use would require an updated risk assessment.

The risk assessment should consider the following:

• age and type of vehicle
• recommendations of the vehicle manufacturer
• nature of the vehicle’s load, the equipment, and fittings it carries or supports.
• type and range of operations on which the vehicle is likely to be engaged.
• type of terrain and the nature of the environment in which the vehicle operates or is likely to operate.
• distance and speeds at which the vehicle travels and the journey times.
• Previous inspection brake performance results.
• Previous inspection brake system and component condition.
• Acceptable reasons for not carrying out a laden brake assessment.

The risk assessment must be retained with the vehicle maintenance documents for 15 months and produced if required.

A risk assessment template can be found in annex 7 – risk assessment template (PDF, 100 KB).

Acceptable reasons for not carrying out a laden brake assessment.

Vehicles where laden brake assessments may not be possible or where additional loading would be difficult are listed below (this is not an exhaustive list), however there is an expectation that at least 4 of the assessments will use an RBT unless the construction or weight of the vehicle prevents its use.

Where these acceptable reasons are used, they must be detailed as part of the risk assessment and the operator must be satisfied the reasons are appropriate for their operation.

There is still a requirement to carry out a braking performance assessment and an assessment of the braking components at every safety inspection.

The brake performance can be assessed with either an RBT or decelerometer with temperature readings where appropriate.

• Unladen Tri-axle Semi-Trailer (ULTAST) – Trailers where under normal operating conditions (more than 70% of the time) run at less than 65% of the permitted axle weights.
• Vehicles where under normal operating conditions (more than 70% of the time) run at less than 65% of the permitted axle weights. This may include car transporters where they are designed for that specific task.
• ADR – Only when the load is considered dangerous and specialist facilities are not available.
• Livestock carriers – Where other means of loading are not possible.
• Noxious load carriers – Only when designed and constructed for this purpose.
• Furniture removal vehicles – Only when designed and constructed as a furniture removal vehicle.
• Vehicles operating at 50% or more of permitted axle weights when unladen – This could include fixed plant, mobile libraries, compactor vehicles, exhibition type vehicles, bullion vehicles
• PSV – Includes prisoner transfer vehicles.
• Where the construction or weight prevent the use of an RBT - This could include vehicles where their load compartment consists of racking, the design of the floor compartment cannot withstand the necessary load that would need to be imposed on it, the load compartment is used for carrying food products and simulated loads would cause contamination of the compartment

It is your responsibility to ensure that the reasons for the risk assessment are justified for your operation.

Laden brake testing and risk assessment examples

#### Example 1

An operator runs a fleet of 6 tippers and is working from a quarry delivering loads to multiple sites both on and off-road. Due to the arduous nature of the work, they carry out a safety inspection every 4 weeks. The mileage varies between inspections depending on the distance of the deliveries.

The operator successfully passes an annual test which included a laden brake test, at the next 4 weekly inspection the operator considers they meet the criteria and completes a risk assessment stating that an unladen roller brake test will be carried out. During the safety inspection no issues are found with any of the braking components or in the operation of the brakes.

Four weeks later, based on the previous safety inspection and other factors including the type of work that has been carried out during that period and the mileage, the operator completes a risk assessment again stating that an unladen roller brake test will be carried out. During the safety inspection no issues are found with the braking system.

Due to the requirement for 4 laden brake tests to be carried out at evenly spaced intervals throughout the year, the operator carries out a laden roller brake test at the next safety inspection.

This pattern can continue for the remainder of the safety inspections unless any issues are found with the braking system where braking performance may be affected.

#### Example 2

An operator runs a fleet of 500 vehicles and 1000 trailers, the vehicles have a safety inspection every 6 weeks and the trailers every 12 weeks.

Half of the vehicles and trailers are used on a dedicated contract hauling plastic sheets between 2 factories, the vehicles and trailers are operating at about 50% of the permitted axle weights. The other half of the fleet carries out general haulage with various loads carried and distances covered, both vehicles and trailers normally operate at or near the plated weights.

Vehicles and trailers on the plastics contract

Although best practise is to carry out a laden brake test at every safety inspection, the operator may decide to use one of the ‘acceptable reasons for not carrying out a laden brake test’ and complete a risk assessment for each vehicle and trailer. If the operator does not think the use of the vehicles or trailers will change in the next 12 months the risk assessment can cover that period.

There is still a requirement to complete a brake performance assessment at every inspection, this can be achieved with an unladen brake test or where appropriate, by using a decelerometer with temperature measurement.

For the vehicles and trailers on general haulage

Vehicles used on the general haulage work are inspected every 6 weeks.

To satisfy the requirement for 4 laden brake tests evenly spaced throughout the year, the operator carries out a laden brake test at least every other safety inspection. The operator may complete a risk assessment at the other safety inspection. The risk assessment criteria must be satisfied, and braking performance must be assessed using either an unladen brake test or where appropriate, by using a decelerometer with temperature measurement.

A risk assessment needs to be completed for every safety inspection that does not include a laden brake test.

An electronic brake performance monitoring system (EBPMS) is fitted to 250 of the trailers used on general haulage. These trailers would only require a laden brake test if there was insufficient data to produce a report to confirm the correct operation of the system or where work has been carried out on the braking system that may have affected braking performance.

Any EBPMS report produced must be evaluated, signed, and attached to the vehicle/trailer safety inspection documentation.

In this example trailers not fitted with EBPMS, should undergo a laden brake test at every inspection. This is dictated by the 12-week safety inspection period and the expectation for 4 laden brake tests evenly spaced throughout the year.

5.4 Electronic braking performance monitoring system (EBPMS)

Braking performance of the vehicle and/or trailers can be monitored and assessed using EBPMS. Using this system braking performance is continually monitored and compared against the statutory requirements for the type of vehicle or trailer fitted with EBPMS.

To enable EBPMS to provide a braking performance value for the operators’ preventative maintenance system, it must be able to measure sufficient braking events over the monitoring period. Therefore, infrequently used vehicles may not provide enough braking event data for the system to produce a braking performance value.

It is important that operators ensure that any system used to assess braking performance meets their own operational requirements and the undertakings of their operator licence.

In-service braking performance defects

The system must be capable of alerting the operator to under-performing service brakes, where the system does not alert the driver, the operator must. Any such alerts should be recorded and investigated in the same manner as a defect reported during a daily walkaround check. After any repair or maintenance of the brakes a roller brake test should be carried out before return to service.

Safety inspection brake performance evidence

It is essential that the system provides braking performance evidence where this is to be used for the safety inspection braking performance report. Evidence can either be stored electronically or as a printout, which should be retained in-line with the Guide to Maintaining Roadworthiness.

Reports must be in a format that clearly identifies:

• the vehicle or trailer
• assessment date and the monitoring period
• a value for the service braking performance for the assessment period

The monitoring period shall be the period between the scheduled safety inspection intervals.

Operators who use EBPMS as service braking performance evidence, are expected to include a braking performance report on every safety inspection record, unless either a suitable roller brake test or decelerometer test was conducted.

If EBPMS provides insufficient data to deliver a service braking performance value an alternative method must be used to assess service braking performance and the records retained.

Parking brake performance

The following procedure will be acceptable to assess the park brake function when a trailer is fitted with an electronic brake performance monitoring system.

1. Confirm the EBPMS system is working correctly, and sufficient data is being captured to record the brake performance.
2. Check the EBPMS data captured indicates the brakes are performing within the systems accepted limits.
3. Check drivers are carrying out a tug test when the trailer is coupled to the unit. As well as testing the king pin security it also confirms the park brake is operating, this should be evidenced.
4. Check driver defect reports for any issues with the function of the system.
5. Ensure all park brake components are checked at the safety inspection to confirm they are correctly functioning.

If there is any doubt over the parking brake performance, further tests must be conducted.

EBPMS cannot be used as a replacement for the statutory MOT brake test.

There is more information on the industry standard specification for electronic braking performance monitoring systems.

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.

Furthermore, if an operator demonstrates an adverse compliance history whilst meeting the requirements outlined above it will be necessary to introduce further measures.

Electronic Braking System (EBS) trailer connection

It is a legal requirement for the trailers fitted with EBS to be correctly connected to the towing vehicle with an ISO 7638 ABS/EBS lead. Without this lead the trailer EBS will not function and EBPMS will not monitor the trailers braking performance.

The ISO lead not only operates the EBS but also allows other critical trailer systems to function, including:

• Anti-lock braking - to prevent wheel lock during braking
• Braking response time - EBS activates trailer brakes more rapidly
• Roll stability - to help prevent roll-over
• Load sensing valve - for correct proportional braking to load weight
• Air suspension - ensures correct ride height

The ISO lead must be inspected for damage and correctly connected as part of the driver’s walkaround check.

If there is an issue with either the ISO lead, trailer connection or the operation of any of the critical safety systems, the trailer must not be used until the fault is rectified.

Operators must also have systems in place to ensure that the trailer connections and leads are inspected and maintained.

Drivers must be properly trained in how to correctly connect a trailer, including the importance of the ISO lead.

As part of the operator’s quality procedures drivers should be regularly monitored to ensure they correctly couple vehicles to trailers.

5.5 Vehicle emissions and fuel management

To ensure that vehicles comply with legislation relating to exhaust emission requirements they should be maintained in-line with manufacturers’ recommendations.

For vehicles showing signs of visible smoke a diesel smoke meter should be used to ensure that the level of smoke emission is within the legal requirements.

Information on the levels of permitted exhaust smoke should be detailed on the manufacturer’s vehicle identification number (VIN) plate or engine number plate.

Where available the manufacturer’s value should be used to test the exhaust emissions. These are normally stricter than the default testing value contained in DVSA‘s annual test inspection manual.

To ensure the correct operation of emission control systems (ECS), operators should have documented systems in place to monitor the use of diesel exhaust fluid (AdBlue®).

Drivers and operators are also required to monitor ECS warning lamps and ensure the diesel exhaust fluid level (AdBlue®) is maintained correctly.

Any emission control system faults need to be rectified as soon as possible and repaired in line with manufacturer’s standards.

Any engine management system re-mapping, for example to increase engine power may invalidate emissions approval.

It should be noted that a person who fails to maintain an emission control system, or modifies or removes it, could be found guilty of an offence. This would put your operators’ licence at risk, and the potential penalties are unlimited fines. Find out about the implications of modifying your vehicle’s emissions.

By implementing some simple procedures operators can help reduce emissions, whilst saving money and reducing fuel consumption. The key components to achieving this are:

Maintenance systems

By ensuring vehicles are maintained in-line with manufacturer’s standards, fuel consumption can be increased, and harmful exhaust gas emissions reduced.

Driver behaviour

Effective driver training can help reduce fuel consumption and associated maintenance costs, for example, brake and tyre wear.

Fuel management

Fuel consumption is directly linked to vehicle emissions. Decreasing unnecessary fuel use will reduce costs and assist in the reduction of harmful emissions.

Tyre management

Fitting energy efficient tyres can help reduce fuel consumption, as can ensuring tyres are correctly inflated. A 20% drop in tyre pressure can result in a 2% increase in fuel consumption.

Planning

Planning the most fuel-efficient route will improve fuel consumption and reduce emissions.

Aerodynamics

Fitting wind deflectors can reduce drag and fuel consumption.

Telematics

Telematics systems can monitor driver behaviour and performance. They encourage safer practices and optimise routes based on data, resulting in a more efficient operation and reduced fuel consumption.

More information about reducing fuel consumption can be found at The Freight Portal.

Alternatively fuelled vehicles

Alternatively fuelled vehicles (AFVs) are any that run on something other than just petrol or diesel. Many manufacturers now offer a full range of AFVs, some also offer ‘retrofit’ options. AFVs can include the following categories:

• Hybrid Electric Vehicle (HEV)
• Battery Electric Vehicle (BEV)
• Plug-in Hybrid Electric Vehicle (PHEV)
• Hydrogen Fuel Cell Vehicle (FCV)
• Compressed Natural Gas (CNG)
• Liquefied Natural Gas (LNG)
• Liquefied Petroleum Gas (LPG)
• Biodiesel and Bioethanol vehicles

There are specific risks for each fuel type. Maintenance staff and drivers must be trained, provided with suitable safety equipment and aware of measures to be taken in emergency situations.

5.6 Advanced Driver Assistance Systems

Advanced Driver Assistance Systems (ADAS) provide drivers with active safety support features that use automated technology. Sensors and cameras are used to detect nearby obstacles, lane markings or driver errors, and respond accordingly.

Many ADAS features support safety critical systems such as braking and steering; therefore, effective maintenance procedures are essential to ensure that they function correctly and deliver the road safety benefits they are capable of.

It is vital that all maintenance activities associated with ADAS are completed by a competent person. It is important that the vehicle manufacturers’ technical specifications are met to reinstate the correct function of ADAS features. In certain circumstances it may be necessary to use On-Board Diagnostics (OBD) equipment to verify the correct operation of some ADAS systems.

Any repair or calibration activities carried out should be fully documented and certified as appropriate to confirm that the ADAS is functioning correctly.

Cameras and sensors should be checked for calibration:

• when a windscreen is replaced
• if a device is registered as faulty
• if the engine control unit develops a fault
• after a wheel alignment geometry adjustment
• after a mechanical repair affecting vehicle geometry
• after body repairs

Operators should ensure that all drivers, including agency staff and new employees, are familiar with the different types of ADAS fitted across the fleet.

In addition to the inspection of any warning lamps, externally mounted sensors should be examined for condition and security during safety inspections and walkaround checks.

Warning lamps that remain illuminated following initial activation of the systems may indicate a fault. Any issues highlighted must be fully investigated before a vehicle is deemed serviceable. Functionality checks should also be carried out on any systems that can be deactivated by the operation of a switch, for example, advanced emergency braking system (AEBS) and lane-keeping assist.

Operators should have a documented policy on action to be taken if the ADAS system is defective or is deactivated.

It should be remembered that a correctly functioning ADAS is designed to support a driver, not replace them. The driver is always responsible for the safe operation of any vehicle under their control. It is therefore essential that staff are adequately trained to confirm that any ADAS fitted is functioning correctly and that faults highlighted are rectified before a vehicle is used on the highway.

5.7 PSV Automatic vehicle location systems

Operators of registered local bus services in England are required to make details of their services available, including real time vehicle location data, this is also known as bus open data. More information can be found in the bus open data implementation guide.

Where possible the driver of a PSV on registered service operations should verify that the Electronic Ticket Machine (ETM) or its equivalent, which provides real-time location information is functioning correctly. Any issues identified must be notified to the responsible person using the driver defect reporting system.

Operators should ensure that the real time location data is being supplied before the vehicle is operated on a registered service.

5.8 Vehicle body repairs

The potential for a serious incident with a badly repaired heavy vehicle is much greater than any car so it is essential that body repairs are carried out correctly.

It is strongly recommended that any repair facility used demonstrates their competence by achieving a recognised accreditation for bodyshop standards. This can be gained through manufacturers’ franchised bodyshop quality standards or by an independent assessment through the National Body Repair Association (NBRA).

The Vehicle Body Repair Association (VBRA) Commercial is a trade association dedicated to commercial vehicle body repair and bodybuilding in the UK and is a division of the National Body Repair Association (NBRA).

5.9 Accessibility (PSV)

The Public Service Vehicles (PSV) Accessibility Regulations apply to any Public Service Vehicle with a capacity exceeding 22 passengers used to provide a scheduled service or local service. These vehicles are referred by regulation as ‘regulated public service vehicles’.

The schedules within these regulations are:

• Schedule 1 - Wheelchair Accessibility Requirements
• Schedule 2 - General Accessibility Requirements for Single Deck and Double Deck Buses
• Schedule 3 - General Accessibility Requirements for Single Deck and Double Deck Coaches

The features within these requirements include:

• a wheelchair space with suitable safety provisions
• a boarding device to enable wheelchair users to get on and off the vehicles
• a minimum number of priority seats on buses for disabled passengers
• the size and height of steps
• handrails to assist disabled people
• colour contrasting features such as handrails and steps to help partially- sighted passengers
• easy-to-use bell pushes throughout a bus
• audible and visual signals to stop a bus or to request a boarding device
• equipment to display route and destination

Familiarisation with all the features of a vehicle is important. Operators must ensure that drivers are fully aware of the form and function of accessibility features required by PSVAR.

These features must be taken into account within any safety inspection or drivers walkaround check to ensure these features are maintained in good condition and function correctly.

Training material and guidance for PSVAR is available at REAL training: bus and coach modules.

5.10 Quality standards recognition

It is strongly recommended that providers of vehicle safety inspections and maintenance have achieved recognised Quality Standards for maintenance facilities, working practices and staff competence.

5.11 Contracted out arrangements

If you decide to use a contractor, you are still responsible for the condition of vehicles that are inspected and/or maintained for you by your agents or contractors.

Care must be taken to ensure that the facilities used by the contractor are adequate, this includes any work carried out by subcontractors.

The list of facilities in section 5.1 can be used to check a contractor. Make sure that the contractors’ staff are competent, this can be done by obtaining evidence of technical training, qualifications and continuing professional development (CPD). You should also establish that the contractor uses appropriate technical data, inspection manuals and has suitable systems to record safety inspections and repairs. Further details at the beginning of section 5 – safety inspection and repair facilities.

5.12 Drawing up a contract

It is essential to have a written contract that sets out precise details of vehicles covered, inspection frequency, type of check and repair policy. Any subcontractors used should be detailed in the contract. The contract/s must be kept on the operator’s maintenance file and produced on request. You must also make sure the contracted maintenance provider details are up to date on the vehicle operator licensing service (VOL). See annex 5 for an example of a maintenance contract (PDF, 46 KB).

5.13 Contract limitations

Even when a maintenance contract exists between you (the operator) and a contractor, you remain legally responsible for the condition of the vehicle, the authorisation of any repair work undertaken and the retention of records. You need to be satisfied at all times that the level of maintenance agreed matches the demands placed upon vehicles and that the standards achieved by the contractor are kept at a sufficiently high level. You should, therefore, talk regularly with the contractor to ensure that they are familiar with the operational needs of the vehicles they are required to inspect and repair. This knowledge is important if the contractor is to be called upon to advise on a particular course of action – particularly when your technical know-how is limited.

Even when you get on well with a contractor, you should have a system for regularly monitoring the quality of work done.

Obtaining first time pass rate annual test data from the contractor is one way of checking that their performance is satisfactory, as the vehicle should be presented to pass the test. This should be supplemented by other evidence of quality assurance such as external audits or accreditation to recognised quality standards.

Any sign of unreliability, incompetence or other shortcomings causing a reduction in the standards achieved should receive prompt attention. Here again a good working relationship can help, but if problems persist you may well consider a change of contractor.

5.14 Visiting agents

As an operator, you may employ a visiting agent to undertake safety inspections, repairs and routine maintenance. However, you should ensure that the agent is qualified to work on the type of vehicles you operate and that adequate facilities and tools are used. As is the case for contracted- out maintenance, you are responsible for vehicle condition and upkeep of records.

5.15 Roadside safety inspections

Only emergency repairs may be done at the roadside. Routine maintenance, including safety inspections and repairs, may not be carried out on the public highway.

5.16 Planning a safety inspection programme

Safety inspections should be planned in advance. Vehicles that are subject to a statutory annual test may have their year’s programme planned around the anticipated test date to avoid duplication of work associated with the test, such as cleaning and major servicing. An electronic scheduling system can be used to effectively plan maintenance activities for the fleet. Or, a simple method of drawing up a programme is to use a year planner or flow chart. See annex 6 for an example maintenance planner (PDF, 49 KB).

Electronic vehicle maintenance management and storage systems often incorporate a dynamic electronic planning feature which automatically schedules the next inspection. The information should be kept in the simplest form possible and displayed prominently. This will serve as a reminder of programmed inspections or of any changes that have been necessary.

All vehicles subject to programmed maintenance should be included. Planning systems should set safety inspection dates at least 6 months in advance.

Vehicle test dates should be included, as should servicing and other ancillary equipment or calibration dates, for example, tachographs or lifting equipment.

Any planning system should be updated regularly, indicating the progress of the programme and recording any extra work carried out. Vehicles that have been taken off the operator’s licence - or other vehicles temporarily off-road - should have their period of non-use identified, and a note should be made when vehicles have been disposed of.

When a vehicle is declared off the road (VOR) you must record this on the vehicle maintenance file, stating the date and reason.

You must have a robust system in place to make sure they do not use vehicles with VOR status. This is particularly important when the vehicle is unsafe.

You can suspend the safety inspection schedule for a vehicle if the period of VOR extends over the next planned safety inspection.

Operators often use this for seasonal-use vehicles or vehicles that need extensive repairs.

You can only bring a vehicle that has VOR status and has missed the scheduled safety inspection back into service after a safety inspection confirms that it is roadworthy. You can reschedule future regular inspections based on the date of this inspection.

You can legitimately move a vehicle with VOR status before it’s brought back into service, for example for a journey to a maintenance facility, MOT inspection or road test after repair.

The planning system may be used to record other items in the vehicle maintenance programme, such as servicing, unscheduled work and refurbishing. Each activity should be clearly identified.

6. Monitoring

There are 7 sub-sections in this section of the guide:

This section examines why the continuous reviewing and monitoring of the quality of safety inspections is essential for all systems in maintaining a vehicle’s roadworthiness.

Continuous reviewing and monitoring of the quality of the systems in place is essential to ensure that they are sufficiently comprehensive to do the job.

One method of monitoring is to invite a technically competent third party to periodically re-inspect or undertake a safety inspection, irrespective of whether inspections are done in-house or are contracted out.

The content of completed inspection reports can also be analysed. Checks should reveal any incomplete records and may also show patterns of faults. If many faults are reported regularly, this could indicate that:

• there are not enough safety inspections
• daily walkaround inspections are not being completed correctly
• defects are not being corrected promptly or effectively

If no defects or few defects are reported regularly, safety inspection intervals may be too short, or the quality of the inspection may not be good enough.

Effective monitoring will enable you, the operator, to adjust the intervals between safety inspections to suit the operation of vehicles. In this respect, there is considerable flexibility provided within the framework of this guide.

6.1 Monitoring of drivers’ daily checks

The daily walkaround check is a vital part of any maintenance system, and so requires continuous monitoring to ensure the checks are being performed correctly. Electronic driver defect reporting systems can be effectively used to manage drivers’ walkaround inspections. Operators can also use tachograph analysis to monitor the time taken to carry out a walkaround check.

A way of monitoring the quality of the daily check is to have a visiting agent or competent in-house member of staff re-examine the vehicle as it leaves or enters the operating centre. The inspection result can be checked against the driver’s defect reports to ensure the driver’s check is of sufficient quality.

Another approach could be to use the safety inspection. The person carrying out the safety inspection could note which defects found should have been detected during the driver’s daily walkaround check. A review of the driver defect reports could be performed and appropriate action taken to establish why the defects were not detected during the walkaround check.

Continuous monitoring is essential to ensure effective management control of the maintenance system, for example analysing a comparison of defects throughout the year to identify any trends. A risk-based approach should be adopted. Where issues are identified more frequent checks should be carried out and measures put in place to address any problems found.

It is essential that those carrying out monitoring/audit functions receive adequate training/instruction and fully document their findings.

Any issues highlighted should be discussed with relevant staff and actioned appropriately.

You are advised to retain any relevant documentation, including follow-up action generated during the monitoring process.

6.2 Annual test results

Attention should also be paid to annual test results, the issue of prohibitions and inspection notices. Regular monitoring of all available information, including on-line MOT history will enable you to check the effectiveness of your system in keeping your vehicles roadworthy.

What does the annual test for commercial vehicles involve?

Full details of what is tested can be found in the HGV MOT inspection manual and the public service vehicle (PSV) inspection manual.

What happens at the end of the test?

If the vehicle passed the test, the test certificate will no longer be printed, the result can be viewed, downloaded and printed freely from the MOT history service. If the vehicle failed the test, you will receive documentation, which lists where the vehicle failed the test. You can also ask for copies of the smoke test report and the brake test report.

What happens if faults are found?

During the test, the inspector may find minor defects, which you can ask to repair. If the inspector thinks that these repairs can be carried out quickly and safely, you may be given permission to do so.

Dangerous defects

Sometimes the test shows up defects that are so serious that the vehicle cannot be moved on the public highway and a prohibition may be issued.

If your vehicle fails the annual test

If defects on your vehicle cannot be repaired at the time of the test, you will need to rectify the defects and resubmit your vehicle for retest.

Information on annual test results and statistics can be found at commercial vehicle testing data for Great Britain.

6.3 Operator compliance risk score

DVSA uses the Operator Compliance Risk Score (OCRS) system to decide which vehicles should be inspected during roadside checks. OCRS is used to calculate the risk of an operator not following the rules on roadworthiness (the condition of its vehicles) and traffic (for example, drivers’ hours, weighing checks). It is more likely that your vehicles will be inspected if your OCRS is high.

Operators who have a high score are more likely to be targeted than those with a low score. However, this does not mean that operators with a low score will never be subject to checks. It does mean, though, that these operators are unlikely to be targeted because of their OCRS score.

Operators who are accredited for DVSA earned recognition have a ‘Blue’ OCRS status, which is the lowest possible score.

Therefore, operators that achieve and maintain good standards are likely to be stopped less often.

As an operator, you get positive or negative points depending on the result of a test or enforcement encounter. The more serious the defect or infringement, the more negative points you attract. The positive interactions will offset the negative points; therefore, it can be beneficial to share optional test data with OCRS for PSV and trailer assets.

Operators should regularly access their OCRS to check compliance and address any identified issues.

Further information and guidance about OCRS, test histories and roadside check reports is available.

6.4 British standards

British Standard BS EN ISO 9001 is a standard for quality management systems. If you are an operator who has been awarded this standard, you must observe systems of working set out in a quality manual. Such a manual would contain details of the organisation of the business, responsibilities of staff and methods of operation.

Those businesses aiming for BS EN ISO 9001 accreditation would need to consider the training, documentation recording, planning, standards and monitoring aspects of their organisation.

6.5 Vehicle safety recalls

Operators should act promptly to make sure rectification work is carried out if they receive notification of a safety recall from a manufacturer. This will remove the risk that the potential defect may cause the vehicle to become unsafe to drive or break laws.

Operators should record a vehicle safety recall notification and evidence of rectification on the vehicle maintenance file.

Operators should have a robust system in place to make sure:

• vehicles do not have an outstanding vehicle safety recall
• rectification is arranged as soon as possible when they receive a recall notification
• operators should normally carry out rectification work at the next scheduled safety inspection unless parts are unavailable or there is a long lead time for the manufacturer’s workshop

Details of vehicle safety recalls can be found at check if a vehicle, part or accessory has been recalled.

The operator should take a vehicle out of service immediately if the recall notification is urgent until the safety recall is actioned. They should get advice from the manufacturer about the nature and severity of the recall.

Operators should be aware of how to:

• report any potential safety defects to DVSA
• provide evidence that safety defects have been identified, appropriately actioned and reported

6.6 PSV reportable incidents (PSV112)

By law, all public service vehicle (PSV) operators must report any incident involving a failure or damage which affects the safety of the passengers or other road users to the Driver and Vehicle Standards Agency (DVSA).

An incident must be reported by using the form to report an incident involving your organisation’s bus or coach, also known as a PSV112.

Reportable incidents:

• fatalities
• serious injuries (such as broken bones, damage to major organs or overnight hospitalisation)
• allegations of a safety defect
• serious damage as a result of the incident (such as major body or mechanical component damage, which needs specialist recovery and the vehicle being taken out of service to be repaired)
• a safety critical component failure or history of the same component failing
• a vehicle catching fire

6.7 DVSA earned recognition scheme

DVSA earned recognition is a voluntary scheme run by DVSA with an aim to reduce the burden of enforcement on operators with a strong track record of compliance and adherence to standards.

Operators must be able to demonstrate that they have robust systems and processes that promote effective and proactive transport management. By maintaining audited compliance systems, operators will ‘earn recognition’.

Key performance indicators will provide an effective means of monitoring the level of compliance, which may avoid the need to carry out a roadside inspection or operator visit and provide DVSA with the assurance and confidence that the operator is effectively managing the transport operation and functioning in a compliant manner.

The main benefits for an operator in DVSA earned recognition are:

• you’ll be provided with a DVSA marque to use on your website and other publicity materials
• you’ll be recognised as a DVSA approved operator through a published list on GOV.UK
• your OCRS will show a ‘Blue’ DVSA earned recognition status, which is the lowest risk score
• your vehicles are less likely to be stopped at the roadside for inspections
• DVSA enforcement staff are less likely to visit your premises
• you’ll have direct access to a DVSA earned recognition team

DVSA earned recognition status will recognise ‘exemplar’ operators and their investment made in compliance.

Annex 1 - Enforcement of the operator licensing scheme

There are 5 sub-sections in this section of the guide:

The Goods Vehicles (Licensing of Operators) Act 1995 requires that any person who uses (‘operates’) a goods vehicle or vehicles with a maximum gross weight over 3,500 kg in the course of a business must have an operator’s licence (generally referred to as an ‘O’ licence). Operators of public service vehicles also require a PSV operator licence issued under the Public Passenger Vehicles Act 1981 (as amended). A separate ‘O’ licence is required for each Traffic Area in which the user has an operating centre, but one ‘O’ licence will cover any number of operating centres within the same Traffic Area.

From May 2022, operators or users of vans or other light goods vehicles over tonnes and up to 3.5 tonnes maximum gross weight used for hire or reward internationally must have a standard international goods vehicle operator licence.

When considering an application for an ‘O’ licence, the Traffic Commissioners must consider, amongst other matters, whether there will be satisfactory facilities or arrangements for keeping authorised vehicles in a fit and serviceable condition. They will seek assurances that the applicant will conduct regular safety checks and inspections of the vehicles at specified intervals and keep records of those checks and inspections and their results. These details are ‘undertakings’ (formerly known as ‘statements of intent’) made for the purposes of obtaining a licence. Operators must ensure their listed inspection provider is up to date on the vehicle operator licensing service.

At any time after a licence has been granted the Traffic Commissioners may direct that it be revoked or suspended, or that its scope be reduced on several grounds, including:

• that the holder of the licence gave for the purpose of procuring a licence an ‘undertaking’ that has not been fulfilled
• convictions relating to the maintenance of vehicles in a fit and serviceable condition
• the issue of a prohibition on the use of a vehicle

Examiners (employed by DVSA) may provide the Traffic Commissioners with a technical assessment of a licensed operator’s maintenance arrangements. This assessment is normally made:

• shortly after the grant of a licence
• when advice might be needed because of a request by the operator for a variation to the licence or because evidence of maintenance problems has come to light; following the issue of prohibition notices, poor annual test results or similar evidence following complaints about smoky vehicles where no satisfactory response has been received from the operator; and if the licence is being reviewed for other reasons not related to maintenance

During a maintenance assessment, vehicle examiners may wish to examine vehicles from the operator’s fleet, examine records of vehicle safety inspections and inspect maintenance facilities. The extent to which records are inspected will depend on vehicle condition and the operator’s history. Failure to keep records of safety inspections is a regulatory matter. The vehicle examiner may discuss with the operator appropriate safety inspection procedures and will report whether they consider the maintenance arrangements to be satisfactory; any deficiency may result in an unsatisfactory report, leading to possible regulatory action by the relevant Traffic Commissioner.

In certain circumstances, for example, where facilities at the operating centre do not allow adequate inspection, the operator may be asked to bring their vehicles and records into a suitable location for inspection.

More detailed explanations and guidance on maintenance assessments are available in vehicle operator maintenance investigations. This is a resource that operators are encouraged to use to conduct self-assessments on their own maintenance systems.

Examiners may at any time:

• enter and inspect a goods or public service vehicle and for that purpose detain the vehicle during such time as is required for inspection
• enter any premises on which they have reason to believe a goods vehicle or public service vehicle is kept
• divert vehicles that are stationary at the roadside to another location for inspection within 5 miles

DVSA also employ Enforcement Support Officers who have the power to stop a moving vehicle for the purpose of examining vehicles. These activities may be carried out by an officer in uniform standing by the roadside directing vehicles into a check site or using a marked vehicle displaying a matrix sign giving directions to the driver.

Examiners may make visits to operating centres to examine vehicles or to check drivers’ records. They also conduct spot checks at the roadside. Examiners’ activities may extend beyond a visual inspection. Examiners have a range of equipment that operators may encounter, including roller brake testers, diagnostic equipment to check vehicle systems.

When vehicle examiners encounter a defective vehicle at the roadside, on an operator’s premises or at an approved testing facility, they may issue a prohibition notice (form PG9) or a vehicle inspection notice, depending on the severity of the fault(s). A prohibition is a ban on the further use of the vehicle on a road. Prohibitions may take effect immediately or may be delayed for up to10 days, depending on whether there is an immediate danger to public safety. Exemptions may be issued, for example, to allow a vehicle to be towed away for repair. A prohibition will not be removed until a vehicle examiner is satisfied that the vehicle is fit for service. As a minimum, this will entail an examination of the components and systems affected by the defects. However, at the examiner’s discretion it may be extended to include as much of the vehicle as needs to be inspected for the examiner to be satisfied it is roadworthy.

Other sanctions available to DVSA Examiners at the roadside include the issue of a Fixed Penalty Notice in relation to roadworthiness defects.

Defects that relate to brakes, steering and tyres may also be endorsable and attract penalty points on the driver’s licence. In certain circumstances, your vehicle could be immobilised until the defects are rectified. If your vehicle is immobilised you will be required to rectify any dangerous defects and pay a release fee before you are allowed to use your vehicle.

Prohibition notices endorsed

Examiners will endorse each defect in terms of its significance in roadworthiness compliance and maintenance:

• ‘S’ for significant failure of roadworthiness compliance
• ‘-‘ (blank) for defects which may or may not be attributable to poor maintenance
• ‘X’ where the defect is no reflection on the maintenance system

Defects ‘S’ marked – significant failure of roadworthiness compliance

Roadworthiness prohibitions both immediate and delayed, will be endorsed ‘S’ if, in the Examiner’s opinion, any of the defects which led to the prohibition were an indicator that there is significant failure of roadworthiness compliance.

These are defects that the operator and/or driver should have been aware of through any or all of the following:

• Long standing defect that should have been detected and repaired at the last safety check.
• The defect or issue should have been detected at the first use/daily walk round check.
• Performance, handling and/or warning systems would have made the defect obvious to the driver.
• Poor workmanship should have been apparent to repairer.
• The nature of the defect(s) observed at annual test were such that they should have been found before the vehicle was presented for test.
• The number and nature of defects present on this notice indicates a significant failure in maintenance.

Defects(s) NOT considered to be maintenance related – ‘X’

Appropriate for defects of an entirely random failure nature such as a lighting bulb failure or a new fracture in a road spring leaf, where it is also apparent that it would not have been noticed by the driver.

Unable to determine whether a defect is attributable to poor maintenance

If it is not possible to determine whether or not the operator, driver or the maintenance arrangements are culpable, then the defect is not endorsed.

If a person obstructs an authorised examiner acting in the course of their duty, they are guilty of an offence.

Delayed defect concession

For roadside inspection, only under the following circumstances should a delayed prohibition be deviated (downgraded) to an inspection notice.

Where there is evidence that:

The delayed defect/s occurred on the current day’s journey (24-hour period).

and - the vehicle was clear of defects at the beginning of the current journey (24-hour period), supported by a nil driver defect report.

and - an in-service driver defect report, with recorded assessment (date and time) stating that the vehicle is safe to drive for the remaining current day’s journey.

or

when the vehicle is encountered it is on direct route to a repair facility for the delayed defect/s to be repaired.

and - there is evidence that the journey is directly to a place where the vehicle is to undergo repair for the delayed defect/s. (for example, defect report with evidence the vehicle is directly on-route to the repair facility).

This applies to both Great Britain (GB) and non-GB encounters.

This concession does not apply if any other prohibition defect is detected on the encounter other than what is described above. Under these circumstances, all defects should be actioned in accordance with the categorisation of defects manual. It is the responsibility of the driver to provide sufficient evidence at the time of the inspection for this concession to apply.

Annex 2 - Where to get additional help

There are 5 sub-sections in this section of the guide:

2.1 Technical support

The Traffic Commissioners and DVSA provide advice and assistance to operators to help improve professional standards in the industry.

Examiners can advise on safety inspections and can help operators set up acceptable record-keeping systems or maintenance facilities. Together with the Traffic Commissioners, we view this part of our duties as an effective and important means of improving road safety.

The vehicle manufacturer is an important source of advice on the characteristics and technical requirements of the vehicles that the operator is using. Such advice is published in the vehicle handbook and other publications. Further advice can be obtained from the local specialist dealer and/or direct from the manufacturer.

The trade associations such as the Confederation of Passenger Transport, the Guild of British Coach Operators, Logistics UK, the Road Haulage Association (RHA), Vehicle Body Repairs Association (VBRA) and the British Vehicle Rental and Leasing Association (BVRLA) are important sources of advice for operators.

The trade associations provide a national inspection service that can range from a regular programme of safety inspection checks to monitoring those undertaken by an outside garage or by the operator themselves. They also provide operator compliance audits, which help ensure continuous and effective management of maintenance and operator and licensing systems. The trade associations also represent the road haulage and bus industry when talking to the Department for Transport. Operators will find it beneficial to participate in their work in order to understand better the importance of effective vehicle maintenance.

2.2 Training

The trade associations, individual colleges, training organisations such as Go Skills, and vehicle manufacturers offer courses and seminars covering operator licensing and maintenance systems. Further advice and information regarding training can be obtained from the relevant sector skills councils (for example. Go Skills for public service vehicles and Skills for Logistics for heavy goods vehicles) and trade associations.

2.3 Saving fuel and protecting the environment

There are a number of government recognised organisations that offer help and assistance when considering fuel consumption and protection of the environment.

The Energy Saving Trust works to cut greenhouse gases and air pollution from the road transport sector. It promotes cleaner, lower carbon vehicles and fuels, eco-friendly driving techniques and low carbon transport alternatives.

SAFED (Safe and Fuel Efficient Driving) is the Department for Transport (DfT)-approved programme, which has demonstrated average fuel savings of more than 10%, a corresponding saving in fuel and reduction in carbon and CO2 emissions, and a reduction in gear changes of 37%. SAFED can qualify as a training module under the EU Training Directive Driver CPC requirements.

2.4 Fault finding

Many Authorised Testing Facilities (ATFs) and other private sector sites are now suitably equipped to offer brake performance and other roadworthiness checks.

2.5 Publications

The following publications are available to download free of charge.

• MOT inspection manual: HGVs

Inspection procedures and minimum roadworthiness standards for the statutory testing of heavy goods vehicles

• MOT inspection manual: public service vehicles (PSVs)

Inspection procedures and minimum roadworthiness standards for the statutory testing of public service vehicles

• How vehicle defects are categorised in roadside checks and vehicle tests

Standards (primarily for use by DVSA enforcement staff) on the issue of prohibitions for roadworthiness defects on all classes of vehicles

• DVSA enforcement sanctions policy

Sanctions and procedures DVSA officers will take for road traffic and construction and use offences

• Vehicle operator maintenance investigations
  DVSA Maintenance investigation visit - assessment guidance

Provides details of DVSA assessment criteria for commercial vehicle maintenance systems

1. These may be secure digital signatures ↩

2. For these purposes competence can be described as the combination of training, skills, experience, and knowledge that a person has and their ability to apply them to perform a task safely. Other factors, such as attitude and physical ability, can also affect someone’s competence. As an operator, you should take account of the competence of relevant employees when you are conducting your risk assessments. If you use contractors, you have a responsibility to make sure they are competent. ↩