Brake Performance Risk Assessment (Non-Laden RBT)
Guidance on Performing a Robust Risk Assessment
A robust risk assessment must clearly link the operating constraint to specific compensatory controls, satisfying the DVSA that your system maintains full roadworthiness.
- Identify the Hazard: Clearly state the GTMR justification for avoiding the laden RBT (Section 2.B).
- Quantify Risk: Assess the risk before controls (Inherent Risk) using the matrix (Section 2.C).
- Detail Controls: Specify Permanent Controls (EBPMS, planned Laden RBTs) and Procedural Controls (Decelerometer use, load simulation) that directly mitigate the specific brake components or performance gaps.
- Assess Residual Risk: Re-rate the risk based on all controls to ensure it is LOW/ACCEPTABLE, and document this in Section 4.F.
This assessment is designed to support compliance with the DVSA Guide to Maintaining Roadworthiness, specifically:
- Section 5.3 – Brake performance testing
- Section 5.5 – Alternative brake performance assessments
- Section 6 – Responsibilities for maintenance systems
- Annex 2 – Brake testing methods and defect indicators
1. Operator & Document Details
| Operator Name / Licence No. | |
|---|---|
| Vehicle Identity (Reg. Mark/Trailer No.) | |
| Brake System Type / Manufacturer | |
| Competent Assessor Name & Qualifications |
|
| Assessment Date |
2. Operational Profile & Risk Quantification
A. Vehicle & Operational Context (GTMR Section 5.3)
| Key Operational Factor | Details (Vehicle Type / Weights) | Relevance to Brake Risk |
|---|---|---|
| Vehicle Type & Body | ||
| Plated Max Weight (GVW/GTW) | Maximum braking performance required by law. | |
| Typical Carried Weight (Average) | Direct justification for non-laden test if <65% max plated weight. | |
| Operational Environment / Duty Cycle | ||
| Safety Inspection (SI) Frequency | The time period over which component wear must be confidently monitored. | |
| Brake Defects in Last 12 Months (SI / PMI History) | ||
B. Justification for Non-Laden Test
The accepted reason for excluding a laden RBT at this inspection is:
Detailed explanation of constraint:
C. Inherent Risk of Undetected Brake Failure (Before Controls)
Risk is assessed as Severity × Likelihood. This rating assumes only a visual inspection is performed, with no performance test.
| Hazard | Severity (S) (1=Minor, 2=Moderate, 3=Catastrophic) | Likelihood (L) (1=Unlikely, 2=Possible, 3=Frequent) | Inherent Risk Rating (S × L) |
|---|---|---|---|
| Failure to meet service brake efficiency (Road Traffic Law) | 3 (Catastrophic – Accident / Prohibition) | 2 (Possible – component wear is hidden from view) | 6 (HIGH) |
| Axle imbalance >30% (unsafe stopping, vehicle pulling) | 3 (Catastrophic – loss of control) | 2 (Possible – cannot be detected visually / non-laden RBT skewed) | 6 (HIGH) |
| Overall Inherent Risk | HIGH (6) – Requires mandatory, documented control measures. | ||
3. Risk Mitigation & Control Strategy
D. Mandatory Permanent Controls (The Backstop)
| Control | Action/Detail | Evidence Requirement |
|---|---|---|
| EBPMS (Trailer Only) | Is EBPMS fitted? If Yes, the evaluated report must be attached to this assessment. | Evaluated EBPMS report signed and dated. |
| Planned Laden RBT Frequency | Policy confirms a minimum of four laden RBTs per year (including MOT), regardless of operational difficulty. | Maintenance planner showing four evenly spaced laden RBTs / MOTs. |
E. Procedural & Compensatory Controls (The Tailored Solution)
These detailed controls directly address the gap created by omitting the laden RBT.
| Specific Risk Mitigation Focus | Detailed Procedural Control | Residual Risk Rating (S × L) |
|---|---|---|
| Alternative Assessment Reliability |
The
is performed in accordance with GTMR guidance. Where a decelerometer is used, brake temperatures are recorded immediately before and after the test for each axle / wheel group: |
4 (MEDIUM) |
| Load Sensing Valve (LSV) Integrity | For unladen RBTs, the Load Sensing Valve (LSV) is manually actuated or system-simulated to check maximum possible unladen force and confirm functionality. Any sticking, leaks or anomalies are defected and rectified before vehicle release. | 2 (LOW) |
| Component Wear Monitoring | Visual brake component checks (e.g., pad wear, slack adjuster travel, disc/drum condition, air leaks) are supplemented by an intermediate check every for high-wear operations (e.g., urban buses, quarry vehicles). | 1 (LOW) |
| Operational Feedback (Driver Defect) | Enhanced daily defect reporting requires the driver to explicitly confirm satisfactory brake performance (no pull, smell, fade, noise or excessive pedal travel) after laden journeys, with clear reporting routes and prompt rectification. | 1 (LOW) |
F. Supporting Evidence (Attach / Reference)
List the documents attached or cross-referenced to this assessment (digital or hard copy):
- Latest RBT / decelerometer print-out and/or road test report
- Latest MOT brake performance print-out
- EBPMS evaluation report (trailers), if applicable
- Relevant SI / PMI brake defect sheets and rectification records
- Maintenance planner showing scheduled laden RBTs
4. Conclusion & Declaration of Roadworthiness
F. Residual Risk Summary (After All Controls)
Following the implementation of the permanent and procedural controls, the assessor must review the residual risk using the same matrix (Severity × Likelihood):
| Hazard Group | Severity (S) | Likelihood (L) | Residual Risk (S × L) |
|---|---|---|---|
| Overall brake performance & imbalance | 6 HIGH |
Once controls are fully in place and the residual risk has been reduced to a LOW / ACCEPTABLE level, the following statement should be true:
“The maintenance system, including the specified alternative and documented procedural checks, satisfies the requirement to ensure the vehicle is maintained in a fit and serviceable condition, fulfilling the operator’s undertaking to the Traffic Commissioner.”
G. Triggers for Early Review of This Assessment
This assessment is normally valid for 12 months, but must be reviewed earlier if any of the following apply:
- Change in vehicle operation (route, terrain, duty cycle, load type).
- Change in SI/PMI frequency or maintenance provider.
- Any brake-related prohibition, MOT failure or unsatisfactory RBT/decelerometer result.
- Repeated driver reports of poor brake performance (pull, fade, smells, noise).
- Significant brake component change (e.g., different lining material, disc/drum type).
H. Contingency Plan if Alternative Test Fails
I. Declarations
I confirm that this risk assessment has been reviewed as part of the current Safety Inspection and remains appropriate for this vehicle’s operation.
I confirm that this risk assessment has been completed by a competent person and confirms the vehicle is maintained to satisfy the requirements of Regulation 18 of The Road Vehicles (Construction and Use) Regulations 1986.
Assessor (Competent Person) Signature: Date:
Operator / Transport Manager Signature: Date:
Review: This assessment is valid for 12 months, provided vehicle operation remains unchanged, but must be formally evaluated at every scheduled Safety Inspection and updated where required.
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