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Zed Aziz
Picture this: a DVSA examiner arrives at your operating centre, clipboard in hand, ready to conduct a thorough audit of your maintenance procedures. This, my friends, is the essence of an MIVR. It's a comprehensive inspection that leaves no stone unturned, delving into every aspect of your maintenance regime to ensure you're meeting the stringent standards set by the Driver and Vehicle Standards Agency.
Why Would You Get an MIVR?
There are several scenarios that might trigger an MIVR:
Routine Check-ups: Think of these as regular health checks for your operating licence. The DVSA wants to ensure you're keeping your side of the bargain by maintaining your vehicles in a roadworthy condition.
Red Flags: If the DVSA has reason to believe your maintenance practices are slipping – perhaps due to a routine roadside check of your vehicle resulting in a prohibitions, poor MOT first time pass-rate, Red Roadworthiness rating on OCRS, a poor TEVR or even a tip-off, they might pay you a visit to investigate.
Following Up: An MIVR can also be a follow-up measure after a public inquiry or in response to an RFE (Request for Evidence).
The Nitty-Gritty: What Does an MIVR Cover?
An MIVR is incredibly detailed, examining all aspects of your maintenance system, including:
Vehicle Inspections: The examiner will conduct a walk-around inspection of your vehicles and trailers, checking for any defects that might compromise road safety.
Maintenance Records: Prepare for a deep dive into your maintenance records! The examiner will meticulously scrutinise every document, ensuring they are complete, accurate, and up-to-date. They'll be checking for evidence of regular safety inspections, preventative maintenance, and timely repairs. They'll also be looking for those mandatory roller brake test reports, ensuring you're ticking all the boxes. To help with their analysis, they use a nifty Excel tool called SIPCAT (Safety Inspection Period Calculator and Analysis Tool). This allows them to record and analyse trends in your maintenance regime, essentially checking whether you're fulfilling your commitment to regular safety inspections (PMIs) as stated on your operator's licence. But it doesn't stop there. They'll also be cross-referencing your PMI reports with driver defect reports, checking whether any defects identified during the PMI should have been spotted by the driver during their daily walkaround checks. Think bulbs, markers, horns – those everyday checks that are crucial for keeping your vehicles roadworthy.
Defect Reporting System: Hold onto your hats, because the scrutiny of your defect reporting system is about to get serious! The examiner won't just be checking how effectively your drivers identify and report defects; they'll be digging deep into how quickly and efficiently those defects are rectified. Be prepared to provide daily walkaround documentation for random dates – and trust me, they have a knack for requesting the one that's gone walkabout or tucked away in the deepest corner of your filing cabinet. They're not just assessing the robustness of your defect reporting (DDI & DDR) system; they're also scrutinising the entire paper trail. They might ask you to produce a record with an identified defect and then expect you to demonstrate the full circle of defect management. How was it reported? What management controls were in place? Who made the decision on whether the vehicle was roadworthy? What VOR (Vehicle Off Road) process or policy is in place? How was the rectification carried out? And finally, who signed off on the vehicle's roadworthiness? They're leaving no stone unturned in their quest to ensure your defect management system is watertight.
Maintenance Contracts: When it comes to your maintenance contracts, the examiner will be checking that they are comprehensive, comply with regulations, and cover all aspects of preventative maintenance. They might also quiz you on the qualifications of the technicians carrying out the work and how you monitor the quality of their work. Be prepared to show evidence of how you monitor your providers' performance, including service level agreements, key performance indicators, and any performance reviews or audits you conduct. The examiner may also ask for evidence of communication between you and your maintenance contractors, demonstrating that you're actively managing the relationship. This could include emails, letters, meeting minutes, or even informal notes. They'll be looking for evidence of two-way communication and how you've resolved any issues or disputes. A clear audit trail is crucial, so document every interaction with your service providers.
Wheel & Tyres: The examiner will delve deep into your tyre management procedures, scrutinising every aspect of your control systems. They'll be checking for evidence of regular tyre pressure checks, including how you monitor pressure and ensure it's maintained at the correct levels. They'll want to see records of wheel torque checks and evidence that re-torquing procedures are followed whenever a wheel is removed. They'll also be looking for evidence of checks conducted outside of the regular safety inspections, demonstrating a proactive approach to tyre management. Essentially, they're seeking assurance that you have robust systems in place to identify and address tyre-related issues before they become a safety hazard.
Load Security: When it comes to load security, the examiner will be meticulously reviewing your arrangements, including equipment, procedures, and staff training, to ensure you're complying with safety regulations. They'll be checking that you have the appropriate equipment for securing loads, such as straps, chains, and load-locking devices, and that it's all in good working order. They'll also want to see evidence of clear procedures for loading and securing cargo, including risk assessments and load plans. But it's not just about the hardware and procedures. The examiner will also be looking closely at your staff training records, ensuring that everyone involved in loading and securing cargo has received adequate instruction and is competent to carry out their duties safely. They might even quiz your staff on load security procedures to assess their understanding. Remember, a poorly secured load is a danger to everyone, so it's crucial to demonstrate that you're taking this aspect of your operation seriously.
Vehicle and Site Security: When it comes to vehicle and site security, the examiner will be assessing your measures to prevent theft and unauthorised access. They'll be looking for evidence of robust procedures, such as perimeter fencing, CCTV, security lighting, and alarm systems. They'll also want to see evidence of access control measures, such as key control systems, visitor logs, and staff ID cards. But it's not just about the physical security measures. The examiner will also be looking at your procedures for managing keys, vehicle movements, and staff access to the site. They might also ask about your procedures for reporting and investigating security breaches. In essence, they'll be looking for a comprehensive and integrated approach to security, where physical measures are complemented by robust procedures and staff awareness. Remember, preventing theft and unauthorised access is not just about protecting your assets; it's also about ensuring the safety and security of your staff and the wider community.
Transport Manager/ Responsible Person Competence: The examiner won't just be scrutinising paperwork; they'll be assessing the competence and control of your transport manager, ensuring they are effectively managing your maintenance system and fulfilling their legal responsibilities. In my experience, if the operator, responsible person, or transport manager takes their responsibilities seriously, things generally run smoothly. However, industry pressures, such as driver shortages and demands from senior management, can sometimes lead to a culture of cutting corners, which can be a slippery slope to disaster. The key takeaway here is to establish firm and fair standards within your operation, where good practice is celebrated and poor, risky actions have consequences.
Once the DVSA examiner has completed their inspection, they'll compile the MIVR, documenting their findings and assigning a rating for each section. You'll receive a copy of the report and have the opportunity to respond to any shortcomings identified. But don't underestimate the importance of this stage! You'll typically have just 14 days to reply, so don't delay. If the report reveals any "unsatisfactory" areas, it's crucial to seek expert help immediately.
This is where Fleet Transport Consultants can step in to provide invaluable support. Crafting a comprehensive and compelling response to the MIVR is essential, as it can significantly influence the outcome of the investigation.
Remember, the MIVR will directly impact your Operator Compliance Risk Score (OCRS), and a poor score can lead to increased scrutiny, further investigations, and even a Public Inquiry where you'll have to face the Traffic Commissioner. A well-crafted response to the MIVR can help mitigate these risks and demonstrate your commitment to compliance.
Why Should You Care About MIVRs?
Simply put, MIVRs are vital for keeping your operation safe, compliant, and efficient. They help you identify areas for improvement in your maintenance practices, reducing the risk of vehicle breakdowns, accidents, and costly legal battles.
In my experience, the best way to approach an MIVR is to be proactive. Don't wait for the DVSA to come knocking on your door. Instead, take control of your compliance by conducting regular internal audits and seeking expert advice from a reputable transport consultant like Fleet Transport Consultants.
We can provide comprehensive support with all aspects of compliance, including:
Mock MIVRs: We can conduct mock MIVRs to help you identify any weaknesses in your maintenance system before the DVSA does.
Compliance Audits: Our comprehensive audits cover all areas of compliance, including maintenance, driver hours, and operator licensing.
Expert Advice: We can provide expert advice and guidance on all aspects of transport compliance, helping you navigate the complexities of legislation and best practice.
Public Inquiry Support: If the worst happens and you find yourself facing a public inquiry, we can provide expert representation and support.
Remember, prevention is always better than cure. By investing in proactive compliance measures, you can protect your business, your reputation, and most importantly, the safety of your drivers and other road users.
Don't leave compliance to chance. Contact Fleet Transport Consultants today and let us help you stay ahead of the curve.