The Great Roadworthiness Update That Wasn't

A Let-down for Fleet Operators?

Zed Aziz

Guide to Maintaining Vehicle Roadworthiness:

A Review of the November 2024 Update

The much-anticipated November 2024 update to the Guide to Maintaining Roadworthiness (GTVRW) has finally arrived, and to be fair, it turned out to be somewhat of an anti-climax. Despite the build-up and expectations, the new guide doesn't bring any ground-breaking changes. In fact, many areas that were expected to see significant updates have been scaled back. Here, we will break down the key elements of the update and explore the implications for operators.

The Big Change: Selecting Good Service Providers

The most notable change in the new GTVRW is the emphasis on operators choosing reputable service operators for their vehicle Preventative Maintenance Inspections (PMIs). The guide now expects operators to have tighter control over their service providers and to use accreditation and MOT pass rates as indicators of quality.

The November 2024 update (actually labelled as October 2024) to the Guide to Maintaining Roadworthiness introduces a significant challenge for operators, particularly regarding third-party service providers. The current landscape is devoid of regulation for these maintenance and safety inspection providers, leaving them largely unaccountable. Consequently, operators are tasked with ensuring their service providers meet high standards, despite having limited control over their operations.

Theoretically, market competition should drive service providers to improve their offerings. However, in reality, demand for these services far outstrips supply, diminishing any incentive for providers to enhance their quality. Instead, they can simply raise their prices, knowing operators have no alternative but to comply. This dynamic creates a challenging environment where operators are forced to endure subpar service without any effective recourse.

Moreover, the notion that operators can simply switch providers is impractical. The limited availability of reputable service providers means that even if operators are dissatisfied, they have nowhere else to go. This lack of options further entrenches the power of existing service providers, exacerbating the challenges faced by operators in maintaining roadworthiness.

The Service Pack Dilemma 

For many operators, particularly those tied to specific manufacturer service providers like Mercedes, Volvo, and Scania, this new expectation adds another layer of complexity. These service providers often operate as franchises, offering varied levels of service quality. Operators bound by service packs from these manufacturers find themselves with little wriggle room, forced to endure inconsistent service with no effective recourse for complaints.

On the other hand, operators not tied to specific service providers face a different set of challenges. The market for good, independent service providers is already saturated, with the best outfits operating at full capacity and unable to take on new clients. This leaves operators with limited options and forces them to settle for subpar service providers, perpetuating a cycle of inadequate maintenance and roadworthiness issues.

Brake Test Requirements

One of the most anticipated updates was the requirement for brake tests on each PMI. However, this update has been underwhelming, with the new guide merely reiterating that at least four laden brake tests need to be conducted, including the MOT. This is essentially the same requirement as before.

An interesting, albeit impractical, addition is the new mandate for a risk assessment every time a laden brake test is not conducted. The guidance is vague on who should perform these risk assessments, and the infrequent occurrence of laden brake tests makes this requirement seem more of a bureaucratic hoop to jump through than a practical safety measure.

Inconsistencies in Laden Roller Brake Test Guidance

Another challenge posed by the new November 2024 update to the Guide to Maintaining Roadworthiness is the inconsistency regarding the timing of laden roller brake tests. The guidance is unclear, with one section suggesting that these tests should take place within 7 days of a PMI, while another section extends this period to 14 days.

This inconsistency creates confusion for operators who are striving to maintain compliance. For those operating on a six-week PMI cycle, a 14-day window for brake tests seems excessively long. It disrupts planning and scheduling, making it harder to ensure that vehicles are tested and maintained in a timely and efficient manner.

Operators need clear and consistent guidelines to effectively manage their maintenance schedules. The current ambiguity only adds to the burden, making it challenging to uphold the standards of roadworthiness expected by the regulatory authorities.

Electronic Brake Performance Monitoring Systems (EBPMS)

The new GTVRW also highlights the importance of Electronic Brake Performance Monitoring Systems (EBPMS), particularly for trailers. Operators are expected to have a better understanding, usage, and application of these systems. However, for the majority of operators, this expectation will have little to no impact, as EBPMS is not widely applicable across majority of the operators.

What should be added to the next Guide.

Here are some suggestions for what should be included in the next Guide to Maintaining Roadworthiness (GTRVW) to address the current issues and improve road safety:

1. Stricter Regulation of Third-Party Service Providers:

• Implement a licensing system for third-party service providers.

• Establish clear standards and guidelines for maintenance and safety inspections.

• Create a regulatory body to oversee and enforce compliance.

2. Enhanced Protection for Operators Tied to Manufacturer Service Contracts:

• Provide clear guidelines and dispute resolution mechanisms for operators.

• Encourage competition and transparency in the service market.

• Consider introducing a "right to choose" provision for operators.

3. Mandatory Regular Brake Testing:

• Introduce a requirement for more frequent laden roller brake tests, ideally with every PMI, keep things simple for operators, even though its adds to costs.

• Simplify the risk assessment process to make it more practical.

4. Increased Focus on Training and Awareness:

• Develop mandatory training programs for drivers on vehicle maintenance and safety checks.

• Mandate that technicians and mechanics employed by third-party service providers or in-house by operators must hold IRTE or equivalent qualifications.

5. Technological Advancements and Data-Driven Maintenance:

• Encourage the adoption of telematics and predictive maintenance technologies.

• Promote the use of standardised data formats to facilitate data sharing and analysis.

• Explore the potential of AI and machine learning for optimising maintenance schedules.

By addressing these issues, the next GTRVW can significantly improve road safety and efficiency in the commercial vehicle industry.