DfT outlines next steps on ER vehicle testing

The Department for Transport (DfT) has issued an update on its call for evidence on heavy vehicle testing, which sought feedback on a range of options that would relax current rules around the testing of HGVs and PSVs for operators participating in its Earned Recognition scheme.

The voluntary Earned Recognition (ER) programme enables operators to demonstrate their compliance by remotely submitting data, including on vehicle maintenance, to the Driver & Vehicle Standards Agency (DVSA). As a result, ER fleets’ vehicles are less likely to be subject to roadside stops.

The call for evidence, which opened in April last year, has now closed, and responses have been analysed. The options on which industry input was sought included the removal of the current requirement for ER operators to have vehicles tested every 12 months (Option 1), and allowing them to test their own vehicles and trailers (Option 2).

A streamlined test was a further option, which would reduce test content, such as removing some items covered in routine inspections or those that could be effectively monitored by in-vehicle systems (Option 3); while a shift in DVSA focus to improve service provision for ER operators, such as via guarantees of test slots or improved flexibility, was also posited (Option 4).

DfT reports “moderate support” for changes to vehicle testing frequency for ER operators, “but this was based on limited responses and evidence to support the possible benefits,” it said.

“It is our view that a change to the frequency of vehicle testing could increase road safety risks if not supervised properly and without adequate safeguards.”

On Option 2, the department said, “there would be delegated tests every year. Unlike Option 1, this would maintain the volume of data fed into ER, but it would mean that it is not under the control of the DVSA and may not be independent from the maintenance.

“We also note that for many ER operators, there would only be a benefit of this option if ‘sub-delegation’ of testing by ER operators to third parties was possible – in which case responsibility for the quality of testing would be further complicated.”

DfT identified two main areas regarding these two options in which its call for evidence had not provided significant information: “whether ER ‘as is’ provides the confidence to implement either option and if adjustments can be made to ER to mitigate any risks of these changes; [and] how the day-to-day practicalities could be handled, both from a legal and practical perspective.”

While both options would increase choice for ER operators and help increase productivity by avoiding time being wasted awaiting tests and through inconvenient scheduling of slots, said DfT, it was weighing against these benefits concerns that the changes could lessen or remove roadworthiness data feeds.

“Some comments within the call for evidence pointed out that some of the benefits of these options could be to reduce downtime for vehicle preparation for test,” said the department.

“This is a concern because the vehicle should meet, at least, that minimum standard all of the time.

“Understanding whether the removal of some or the delegation of all tests will result in this road safety risk is vital to having a clearer view on the way forward for either of option and if ER could now, with some modifications, mitigate this risk.”

As a result of its findings, DfT says further work will now be done as regards Option 1, including an assessment of whether lessening test frequency could result in a reduction in in-use condition between tests, and whether changes to ER could mitigate this.

The department will also look at ways of ensuring the ER scheme would still receive sufficient data to ensure high compliance if annual tests were completed only every two years – which might include, for example, records of specific periodic inspections at the mid-point between tests being included in ER data.

It will also consider whether ER should be put on a statutory footing in conjunction with any changes; whether to require higher frequencies of testing for vehicles used in international circulation; the status of vehicles moving between ER and non-ER operators; and the position of vehicles whose operators had lost ER status.

“Subsequently Option 2 will continue to be assessed before a final decision is taken about which of the options to implement or whether to retain the status quo,” added DfT.

“Work on improving service provision, consistent with Option 4, is already being implemented as a ‘business as usual’ activity by DVSA for all operators. It does not require any legislative powers and is being taken forward now.”

Hayley Pells, policy lead at the Institute of the Motor Industry (IMI), which represents more than 100,000 automotive professionals, said: “It seems that the statement published by the Department for Transport… was more of a presentation of findings rather than a full conclusion, with more work clearly needed to reach a satisfactory approach for the HGV sector.

“The IMI made a full and informed submission to the original consultation and we will continue to work hard on behalf of those in the heavy duty vehicle sector to ensure that the experience of professionals is properly accounted for.

“Investment in skills development is critical to maintain the integrity of this vital component of the automotive sector; without properly maintained heavy goods on UK roads our economic infrastructure is under serious threat. The DfT’s proposals seem to suggest that reduced testing for those part of the ER scheme is likely.”

IMI said several points pertaining to DfT’s Option 1 (reduced test frequency for ER operators) should be examined further, including the concerns over the potential impact on in-use vehicle condition between tests and ensuring sufficient ER data; and the questions around ER statutory footing, vehicles in international circulation, those moving between ER and non-ER operators, and those whose operators’ ER status has lapsed.

There were 49 formal responses to the DfT’s call for evidence, and six additional written submissions. A full analysis of the responses can be found here.