The Guide to Maintaining Roadworthiness is the DVSA’s official guidance document for fleet operators. It is used by businesses and managers in charge of operating a fleet, to understand the regulations and best practice guidance for maintaining the compliance, safety, and roadworthiness of their vehicles.
In a previous post, we covered the section of the guide related to driver daily walkaround checks, with a breakdown of exactly what the checking, reporting, recording and repairing defects means for fleet operators, drivers and anyone else involved in the fleet
What is the difference between ‘regular’ and ‘first use’ checks?
The key difference between regular checks and first use checks is evident in the name:
- First Use Checks are inspections carried out before a vehicle is used for the first time by an operator – that can be a new or second-hand vehicle, and rented vehicle or a vehicle that has been out of use for an extended period of time.
- Regular Checks are inspections carried out by the operator on a regular basis, as part of regular service and maintenance of the fleet.
In terms of the actual checks undertaken, the two have exactly the same requirements (which is why the guide includes them together)
It is worth noting that sometimes the phrase ‘first use checks’ is also used to refer to driver’s daily walkaround checks (i.e. the first use of the day).
Why are regular and first use checks important if you’re already doing daily walkaround checks?
Regular and first use checks, as referred to in the guide, go into a much more detailed and thorough inspection than is possible in a daily walkaround check.
They bridge the gap left by statutory annual tests, which are only required once each year. First use inspections, give operators the knowledge that any vehicle entering their fleet starts its lifecycle at a good standard and, thereafter, regular checks ensure that that standard is maintained.
Regular checks can also be used to gauge the effectiveness of an operator’s overall vehicle maintenance system, offering an easy way to assess whether a system is robust enough, and to make any changes necessary to keep the fleet safe and compliant.
Just like the daily walkaround checks, regular and first use checks are an essential part of an effective roadworthiness maintenance system. Properly undertaking and recording regular and first-use inspections helps to keep fleets safe, compliant and on the road.
Even besides the need to maintain vehicles in order to keep drivers and the general public safe, the use of regular safety inspections is also cost-effective. Catching and correcting early indications of damage reduces the risk of sudden failure (and the associated unscheduled downtime and disruption to service), and regular maintenance can prolong the lifetime of each vehicle, reducing overall long-term fleet costs.
The latest version of the guide, released in 2018, also highlights initiatives like the Earned Recognition Scheme, the EU Roadworthiness Directive, and Clean Air Zones, which will only increase the importance of monitoring vehicles.
Who is responsible for completing regular and first use checks?
The guide makes it clear that ultimate responsibility for vehicle roadworthiness, and authority to decide whether a vehicle is fit for service, falls to the operator’s Transport Manager, though they can delegate safety inspection activities and authority to a safety inspector (either internally or contracted), with the use of a written agreement.
In the guide, it is also advised that all staff with any involvement in safety inspections (be that drivers, maintenance staff or management) are informed in writing of the operator’s legal and moral responsibility for vehicle safety, and of the expectations of their duties and responsibilities within the overall fleet maintenance programme.
In terms of the person actually undertaking the safety inspections, the guide sets very clear requirements. They “must be technically competent and operationally aware of the safety standards that apply to the vehicles they examine”. This means that inspectors should have training in vehicle examination, diagnosis, and reporting techniques, as well as a good working knowledge of any relevant DVSA inspection manuals.
Though technical competence could be proven with experience level alone, the guide “strongly recommends” that inspectors achieve relevant technical qualifications, accreditations or quality standards.
When should you complete regular and first use checks for your fleet?
The main distinction between the regular checks and the first use checks is the in when they should be carried out.
First use checks
First use inspections should be carried out on vehicles before they are first used in your organisation, or when they have been out of use for an extended period of time. The guide specifies three cases when a first-use inspection would be required
Vehicles brought into use
A safety inspection should be conducted when a vehicle first comes into use with an operator unless it is a brand new vehicle which has undergone a recorded pre-delivery inspection (PDI)
Vehicles returning to use
When a vehicle has been off the road for a period of time greater than the usual interim between regular checks, a safety inspection should be conducted before the vehicle returns to use
Hired, loaned or leased vehicles
Vehicle users have the responsibility to ensure that any hired, leased or borrowed vehicles are in a roadworthy condition and have all the required certifications. The rental company should undertake a pre-rental inspection (PRI). A record of PRI is sufficient as a first-use check but if the operator is in any doubt, or has no record that the PRI was carried out, they should undertake their own safety inspection.
Regular checks are required, between the annual statutory tests, to maintain roadworthiness and ensure vehicles are always safe to use.
The guide recommends following a time-based pattern for regular safety inspections (instead of a purely distance-based pattern). Using a week numbering system (like the International Organisation for Standardisation (ISO) system) offers some flexibility in planning and scheduling the checks, as the inspection can be carried out any time during the given week that it is scheduled. The actual frequency or timing between checks will vary, depending on:
- Vehicle type and age
- Load, equipment or fittings typically carried or supported by the vehicle
- Nature (type and range) of operations the vehicle is typically engaged in
- Terrain and environment in which the vehicle typically operates
- Time on the road or typical distance and speed of travel of the vehicle
- Ultimately, systems will be judged on their effectiveness in maintaining roadworthiness
The planned inspection frequency must be recorded, maintained and regularly monitored to ensure effectiveness – if an operator changes the planned frequency of safety inspections, the Central Licensing Office must be notified.
The latest version of the guide, released in 2018, gives a table of clear examples of the inspection frequency required in various scenarios.
The guide does, though, acknowledge that some components may require more frequent checks than others – he checks report should include details of any additional checks that will be required before the next scheduled check.
The timing of these additional, or ad hoc, checks may fall outside the scheduled inspection programme. The planned frequency of inspections must not be exceeded, so operators have two options for handling the return to regular checks after an ad hoc check:
- Continue the Schedule as Planned – e.g. if scheduled checks should take place every 6 weeks (in week 6, week 12, week 18, week 24, etc.) and an ad hoc check takes place in week 9, the actual inspection schedule would go: week 6, week 9, week 12, week 18, week 24, etc..
- Adjust the Planned Schedule – e.g. if scheduled checks should take place every 6 weeks (in week 6, week 12, week 18, week 24, etc.) and an ad hoc check takes place in week 9, the actual inspection schedule would go: week 6, week 9, week 15, week 21, week 27, etc..
In the above scenario, the operator must not use the ad hoc check in week 9 to replace the planned check in week 12 (i.e. week 6, week 9, week 18, week 24, etc.) as the interim between the week 9 and week 18 checks is longer than the planned frequency of checks every 6 weeks.
How should you complete regular and first use checks?
Once the frequency of regular and first use inspections has been established, a responsible inspector should complete the checks.
The inspection should be carried out in line with the requirements for the statutory annual test, with reference both the DVSA’s annual test inspection manuals and to the vehicle manufacturers’ recommended tolerances.
Additionally, the guide was updated in 2018 to define the responsibility of operators to ensure that inspection facilities are “adequate for the job”, even where inspections are contracted out, and that both workshops and technicians should have achieved some recognised quality standard or accreditation.
A thorough record of all safety inspections should be kept. Records can be taken and stored electronically or on paper, but must, at a minimum, include:
- Name of owner/operator
- Date of inspection
- Vehicle identity
- Odometer (mileage recorder) reading (if appropriate)
- A list of all items to be inspected
- An indication of the condition of each item inspected
- Details of any defects found
- Name of inspector
- Details of any remedial/rectification or repair work and by whom it was done
- A signed statement that any defects have been repaired satisfactorily and the vehicle is now in a safe and roadworthy condition
- The report may also contain details of any work to be carried forward.
Certain aspects of the inspection are likely to require assistance for the inspector. This must be provided for by the operator, and it can usually be undertaken by the vehicle’s driver.
The inspector must report defects and ultimately sign the vehicle off as being in a roadworthy condition, but they are not expected to carry out repair or servicing work themselves – this can be passed on to maintenance staff or a contractor, to be completed before the inspector verifies that the vehicle is now in a safe and roadworthy condition.
Specific Guidance Added
In the Guide to Maintaining Roadworthiness 2018 update, specific sections were added to guide operators in inspecting and maintaining some of the most common defects and issues. These include:
- Tyre Management – Guidance on managing tyre maintenance, including monitoring tyre age.
- Brake Testing – The guide now includes strong advice to assess brakes with a laden roller brake test instead of a road test, and to take brake temperature readings where only a road test is available. The section now also includes detailed guidance on using EBPMS as part of brake testing.
- Emissions – In a completely new section, the guide now highlights the importance of having a correctly maintained emissions control system for each vehicle, with crackdowns on emissions fraud and changes to HGV levy rules.
What is the easiest way to complete regular and first use checks?
As with driver daily walkaround checks, the regular and first use checks can be completed and stored electronically – even if it is completed on paper, provided an electronic record is kept, there is no need to store the physical paper copy. Electronic records of details of defects found or work done just need to be “complete and available, or made available on request”. The guide advises that the system used for electronic capture and storage of inspection information must:
- Be secure and tamper-proof
- Be capable of producing hardcopy information for use at public inquiries held by Traffic Commissioners
- Contain the same information outlined above, with the exception of:
- A full list of the items inspected (provided these are indicated on a paper report used for the inspection)
- An indication of the condition of each item inspected (it is sufficient to provide details of defective items only).
Planning and monitoring the inspection schedule for regular checks can also be part of an electronic vehicle maintenance system, making it easier for operators to plan and monitor the maintenance of their vehicles, and leading to higher standards and improved compliance.
Conveying staff responsibilities to them in writing is another key requirement in regular and first use checks. This can also be managed electronically, with a message outlining specific duties and responsibilities, for drivers, maintenance staff and management to ‘accept’ before they log into the vehicle checks and maintenance system.