Tachograph records: clear and compliant
Mark Lewin, director at Novadata Transport Training, outlines the essentials of accurate and robust record keeping
Incorrect use of tachographs, or poor tachograph record keeping, is still one of the reasons that operators come to the attention of the DVSA and, potentially, the traffic commissioners.
Over four years ago, the record keeping rules for drivers’ hours and tachographs changed. The methods of keeping records narrowed, while those who fell within the scope of the rules expanded.
Perhaps the biggest change was that drivers’ hours rules now apply to everyone who carries out any in-scope driving at all, and records must be kept for everyone, even those who only drive in-scope on rare occasions. This will often include the transport manager or supervisor who is primarily office based, but who occasionally fills in for an absent driver.
The acceptable ways to keep tachograph records all include the clear identification of the driver, so that there is no ambiguity in determining whether they are complying with drivers’ hours rules, and the options for keeping proper records have been narrowed to just a few. Drivers should complete records of their work activities, rest periods, sickness absences or holidays.
On a digital or smart tachograph, manual entries can be made. It is essential that each driver is very clear about how to do this, as manual entries remain one of the biggest areas of error for digital tachograph users.
Mistakes in making manual entries can happen when a driver selects the incorrect activity; or if the driver is distracted for more than a few minutes after inserting their card and fails to make the manual entry.
Unfortunately, there is no electronic way to rectify a manual entry mistake. A written correction note can be made on digital tachograph paper, but it is obviously better if the mistake is avoided.
It is also acceptable to make a manual record on a record sheet or on tachograph printout paper. You can use an analogue record sheet, provided that each individual driver is clearly identified on every record. On the tachograph printout, you should record the driver’s name, or their driver card or driving licence number.
You may no longer use a diary, or any other form of record. If you are compliant with drivers’ hours rules, but your form of record keeping is no longer acceptable, any DVSA investigation would deem this as non-compliant, so you may be putting your O-licence at risk.
The exact process of making a digital or smart tachograph manual entry varies slightly from manufacturer to manufacture. As there is more than one make of digital tachograph, it is vital that each driver is familiar with their vehicle unit’s make and model, and knows how to make the manual entry correctly.
It is wise to include a Driver CPC course on drivers’ hours and tachographs as part of each driver’s periodic Driver CPC training. However, it is also important that the transport manager or supervisor is equally clear about making accurate manual entries, so they can remind the driver and ensure that they are making entries correctly.
We provide specific digital tachograph training for managers and supervisors for this very purpose; these have proved very popular since the changes. Tachographs and drivers’ hours are also covered in our Transport Manager CPC Refresher courses.
It is a requirement to keep records for every driver who carries out any in-scope driving. This will include those whose main role is something other than driving, and who drive only occasionally.
Full-time drivers need to be confident and accurate in making manual entries, as they are required to manually enter both their daily and their weekly rest, as well as sickness and annual leave. They must also ensure that the tachograph is on the correct setting when working.
When conducting their daily vehicle walkaround check, for example, it must be set to ‘other work’. If not, it will appear that the workaround check was not completed before driving.
If the individual’s role includes little, but regular, in-scope driving, records must be kept of the time spent in all their work activities, including driving, other work, breaks, rest, periods of availability, annual leave and sickness leave. Records must be kept in one of the acceptable methods, as with individuals whose principal roles are that of drivers.
UK government guidance is as follows: “Where a driver fails to record other work and duties or attempts to hide insufficient rest periods DVSA will take enforcement action.” There is guidance on record keeping for occasional in-scope drivers on the UK government website.
Errors in manual entries on a digital tachograph may still occur, but it is possible to spot problems early on by means of your digital tachograph analysis. If a driver fails to make a manual entry, you want to know as soon as possible. After all, if the driver has a problem, so does the operator.
Some digital tachograph analysis solutions have a specific report for highlighting missing manual entries, while others have a driver activity module. These can both be used to give the manager or supervisor an early warning that the driver has made a mistake and may need further training on using their vehicle unit.
We are always happy to explain to operators how they can use the analysis solutions that we provide to monitor driver behaviours and head off problems with driver error at an early stage.
Failure to use the digital tachograph correctly has potentially serious consequences with the authorities, from verbal warnings and rectification notices, to prohibitions, fines, and even prosecution, depending on the gravity of the infringements. Compliance is still the best way to avoid all of these measures.
