Heavy vehicle testing review: executive summary and conclusion
Published 10 March 2021
Executive summary
This report concludes the Heavy Vehicle Testing Review. This review was commissioned by the Secretary of State for Transport, following discussions with stakeholders regarding potential improvements to the vehicle testing regime. In particular, views raised during passage of the Business and Planning Act 2020 made it clear there was appetite for a review of the existing heavy vehicle testing system.
The purpose of the review and this report is to determine whether current roadworthiness testing is fit for purpose and to provide evidence as to whether it supports or hinders the effective operation of the haulage and logistics industries. The report follows the specific considerations set out in the terms of reference (TOR) in Annex A.
To support the drafting of this report, a stakeholder panel was convened, chaired by Department for Transport (DfT) officials and made up of stakeholders from the haulage industry, as well as the Traffic Commissioners, Driver and Vehicle Standards Agency (DVSA) and road safety bodies. This panel met (via teleconferencing) 6 times during this work to discuss and inform the content of this report. We are grateful for the input of panel members.
The report gives an overview of the performance of the testing system in respect of the 4 main considerations in the TOR. These may be summarised as:
- performance during the 2 years before February 2020
- performance during the coronavirus (COVID-19) pandemic and the restart of testing
- relationships within the testing system
- data collection and performance measures within the testing system
Each section gives an overview of the issues identified by the panel about each of these considerations, and a summary of discussions.
Data considered as part of the report confirms that testing plays an important role in maintaining vehicle safety, alongside the other requirements for vehicle maintenance and training to which operators are subject.
Significant service delivery problems about heavy vehicle testing during 2017 were confirmed as having since been addressed in large part. Also, although significant disruption has been caused by the COVID-19 pandemic, significant efforts by DVSA to reduce this disruption appear to be paying dividends since the restart of testing.
The utilisation of DVSA resources at Authorised Testing Facilities (ATFs) is a useful measure of some aspects of the current system, and the level achieved is appropriately high.
In summary, the report draws the following conclusions and recommendations.
Conclusions
Role of testing
The review has confirmed annual heavy vehicle testing is an important element of the regulatory regime designed to support public safety. Testing is an independent check of the effectiveness of vehicle maintenance systems and its effectiveness must be viewed in that context.
The overall effectiveness of the annual testing, operator licensing rules and compliance activities together merits continued attention outside the review to ensure that they work well together to best assure the safe and environmentally sound operation of heavy vehicles, in ways that still enable the industry to thrive.
Safety (and environmental protection)
The pass rate at the annual test and the improvement in it over recent years, has been greater than the improvements in underlying roadworthiness levels. This demonstrates the positive effect that the test has on bringing vehicles up to the minimum roadworthiness standard at least once a year. It also shows the effect that vehicle preparation for test has over normal operating standards.
Some vehicle operators do demonstrate very good roadworthiness compliance, including excellent systems for ensuring compliance demonstrated through very high pass rates.
It is not possible from current data to indicate whether the lack of heavy vehicle testing for 3 months (or for longer periods in some cases) was associated with a reduction in standards or public safety.
Performance of the testing system
The introduction and predominant use of ATFs to form a larger network than that of DVSA testing stations has increased choice and flexibility for many users.
The requirement to use independent testers (fundamental to the purpose of testing) who are not involved in the operation or maintenance of the vehicles and spread over many sites, necessarily constrains flexibility.
Currently, the system generally delivers the most fundamental requirement of customers of enabling vehicles to be tested and kept in service.
Efficiency and examiner resource constraints
The operation of the testing system inevitably results in costs to industry. Where there are difficulties in obtaining reasonably timed and located bookings, there are unnecessary costs to industry.
The utilisation of DVSA resources at ATFs is a useful measure of some aspects of the current system. However, some in industry have indicated that they may value more capacity being available.
The current system results in less choice of testing site, extra mileage to reach sites, administrative time booking, scrambling for re-tests and vehicles being tested at peak demand periods or busy days of the week.
Contractual changes were made in 2015 to facilitate more evening and weekend working, but the levels of operation in these periods is limited.
The short-term moratorium on new testing sites is inconsistent with the current system. It is a temporary measure for the ATF network, implemented into a system designed to be open and market-driven. The market-driven provision of ATFs is in the context of a fairly static size of vehicle fleet, with more ATFs reducing the average tests done per ATF.
Performance measurement
The current principal measure of DVSA performance – cancellation rates of confirmed testing sessions due to DVSA examiners not attending – is important.
While DVSA does measure additional areas, these are not all transparent and do not cover all aspects of the system. There would be benefits in a broader set of transparent measures covering the whole system.
There may also be a benefit in determining an approach to how performance is monitored and areas for improvement identified. This could include ensuring that all parties – DVSA, operators and ATFs – all have a stake in understanding and improving performance.
Relationships
The three-way DVSA-ATF-operator relationship is complex and there is some dissatisfaction and ambiguity about how it works. There may be value in ensuring clarity by refreshing the main obligations and responsibilities of the 3 groups. This may then result in changes to contractual relationships. A basis for further consideration is in Annex C.
The rapid suspension of mainstream vehicle testing in March 2020 (lasting more than a quarter) has damaged the relationship between DVSA and parts of industry.
Recommendations for potential future work
The following summarises areas recommended for further attention.
1. Continued service improvement
The objective to optimise the use of tester capacity and hence reduce pressure on fee levels contributes to many of the pressures in the normal operation of testing. While the system is not in crisis, it does require continued improvement to ensure that changing user needs can be met and the service continues to best service industry.
Continued attention in doing this – with DVSA ensuring robust customer insight through working with customers (ATFs and Operators) – is essential for a healthy and effective service, while recognising that aspirations may need to be constrained by fees or the willingness for customers to pay for improvements (through fees) be tested. Longer-term service improvement should also include consideration of altered testing intervals for Earned Recognition operators, with an analysis of the road safety effect and whether this could be implemented practically.
2. ATF scheduling and moratorium
The current moratorium on new ATFs should be reviewed in more detail and proposals for change should be developed for review in April 2021. It is noted that this may have impacts on required tester numbers (see recommendation 6).
This review should be done in concert with a consideration of the advantages and disadvantages of scheduling testers to ATFs further in advance than at present (suggested as up to a year – but details of how best to implement will need to be understood through some robust user insight). This would tie in with some operator requirements about planning testing well ahead. As part of the proposed review of performance measures (see recommendation 5), the effect of improvements should continue to be reviewed to understand whether further steps are needed.
3. Booking of tests
Further work needs to be done on how easy it is for operators to book at ATFs. Work should consider the potential for greater transparency in the booking system.
DVSA has recently made improvements in transparency (through its new ATF Capacity Service), but it is too early to know how effective this has been, or whether further central control would be beneficial. As part of the above ongoing review of performance measures (see recommendation 5), the effect of improvements should continue to be reviewed to understand whether further steps are needed.
4. Communications
DVSA should work towards reinvigorating relationships with stakeholders in this area and develop improved communications plans concerning the operation and medium-term development of the testing service.
5. Vehicle testing performance measures
While the current principal measure of DVSA performance, as noted in its business plan, and the supporting measures are important to the functioning of the current system, they need to be part of a more balanced set of measures that reflect the whole service. So, some measures could be introduced to reflect system-wide performance, not specifically DVSA performance.
These measures should be developed and refined in conjunction with stakeholders and the end-users of the system and a system for regular joint review (with DVSA and those representing vehicle operators and ATFs) and agreement of improvement actions should be established. As part of agreeing to this approach, there will be value in documenting the responsibilities and commitments of the 3 groups in respect of vehicle testing – DVSA, vehicle operators and ATFs.
6. Tester capacity
An increase in tester capacity should be considered to enable testing facilities to compete more effectively and operators to have more flexibility around appointments. Willingness to pay for the extra capacity and implementation proposals would need to be tested, with the status quo or more modest increases in tester numbers to allow some new facilities to open being possible alternatives.
Increases in tester capacity would mean higher fees than would otherwise be the case. Any proposals for fee changes would need to be consulted about and introduced via regulation. This is not expected to be a ‘quick fix’. It is noted that the ease of implementation will be linked to other recommendations.