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Brake Performance Risk Assessment (Non-Laden RBT)

Skipping the laden Roller Brake Test needs a documented, DVSA-defensible justification — not just a note in the file. Build that record here: the GTMR justification, your compensatory controls, and a residual risk rating you can evidence at any Safety Inspection.

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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.

  1. Identify the hazard — state the GTMR justification for avoiding the laden RBT (Section 2B).
  2. Quantify risk — assess the risk before controls (inherent risk) using the matrix (Section 2C).
  3. 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.
  4. Assess residual risk — re-rate the risk based on all controls to ensure it is LOW/ACCEPTABLE, and document this in Section 4.
DVSA / GTMR reference: this assessment supports compliance with the DVSA Guide to Maintaining Roadworthiness — Section 5.3 (brake performance testing), Section 5.5 (alternative brake performance assessments), Section 6 (responsibilities for maintenance systems) and Annex 2 (brake testing methods and defect indicators).
Disclaimer: this tool and guidance are provided by Fleet Transport Consultants Ltd (FTC) as a template only and do not constitute legal advice or a regulatory guarantee. Compliance responsibility remains solely with the Operator Licence Holder. FTC accepts no liability for any regulatory action, penalties or vehicle issues arising from the use or interpretation of this guide.

1Operator & Document Details

2Operational Profile & Risk Quantification

A. Vehicle & operational context (GTMR Section 5.3)

B. Justification for non-laden test

C. Inherent risk of undetected brake failure (before controls) — risk is assessed as Severity × Likelihood, assuming only a visual inspection with no performance test.

HazardSeverityLikelihoodInherent risk
Failure to meet service brake efficiency (Road Traffic Law)3 — Catastrophic (accident / prohibition)2 — Possible (component wear hidden from view)6 (HIGH)
Axle imbalance >30% (unsafe stopping, vehicle pulling)3 — Catastrophic (loss of control)2 — Possible (not detectable visually / non-laden RBT skewed)6 (HIGH)
Overall inherent riskHIGH (6) — requires mandatory, documented control measures

3Risk Mitigation & Control Strategy

D. Mandatory permanent controls (the backstop)

Policy confirms a minimum of four laden RBTs per year (including MOT), regardless of operational difficulty — evidenced via the maintenance planner showing four evenly spaced laden RBTs / MOTs.

E. Procedural & compensatory controls (the tailored solution) — these directly address the gap created by omitting the laden RBT.

For unladen RBTs, the Load Sensing Valve (LSV) is manually actuated or system-simulated to confirm functionality — any sticking, leaks or anomalies are defected and rectified before release. Visual component checks (pad wear, slack adjuster travel, disc/drum condition, air leaks) are supplemented by an intermediate check for high-wear operations, and enhanced daily defect reporting requires the driver to confirm satisfactory brake performance after laden journeys.

F. Supporting evidence — documents attached or cross-referenced (digital or hard copy): latest RBT/decelerometer print-out or road test report, latest MOT brake performance print-out, EBPMS evaluation report (if applicable), relevant SI/PMI brake defect sheets, maintenance planner showing scheduled laden RBTs.

4Conclusion & Declaration of Roadworthiness

Residual risk summary (after all controls) — review using the same Severity × Likelihood matrix.

Hazard groupSeverityLikelihoodResidual risk
Overall brake performance & imbalance 6  HIGH
Residual risk is currently UNACCEPTABLE. Additional or stronger controls are required before the vehicle can be released to service.

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."

Triggers for early review — this assessment is normally valid for 12 months, but must be reviewed earlier if any of the following apply:

I confirm that this risk assessment has been reviewed as part of the current Safety Inspection and remains appropriate for this vehicle's operation, and that it 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.

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.

This produces a risk-assessment record you can print or save as PDF for your maintenance file. Pair it with our guide to why an RBT "PASS" can be a trap and SIPCAT.

Reading your brake test correctly

An imbalance over 30% is a fail; over 20% is a warning even if the machine prints "PASS". Tests under 65% of design weight are unreliable. Read the full method in our guide on why a brake test "PASS" can be a trap and understanding your RBT.

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