The promises, and the clocks each one starts #
Read the undertakings as a set of continuing obligations and the paperwork stops looking arbitrary. Each promise produces a record, and each record has a retention period.
| Undertaking or duty | What it produces | Clock |
|---|---|---|
| Vehicles kept safe and in good condition at all times | Safety inspection records, repair records | At least 15 months, including for vehicles removed from the licence or sold |
| Defects reported and rectified | Drivers' defect reports and rectification records | At least 15 months |
| Drivers' hours rules observed | Charts, manual records, digital data | Produced to enforcement officers for 12 months |
| Drivers hold the correct licence and training | Licence checks, Driver CPC evidence | Continuous, and checked before each driver drives |
| Relevant changes notified | Notifications to the traffic commissioner | Within 28 days of the change |
| Financial standing maintained | Bank or building society statements and accounts | Statements covering the last 28 days when evidence is called for |
DVSA's guide to maintaining roadworthiness is explicit on the awkward part of the first row.
records of safety inspections must be kept for at least 15 months for all vehicles, including vehicles that have been removed from the operator licence or sold or otherwise disposed of
A vehicle leaving the fleet does not take its paperwork obligation with it.
The numbers behind the licence itself #
Financial standing is the clearest example of a licence condition that is pure arithmetic. GOV.UK sets the evidence required for an operator licence:
8,000 pounds
First vehicle, standard national or international licence
GOV.UK, apply for a vehicle operator licence: financial evidence
4,500 pounds
Each additional vehicle, standard licence
GOV.UK, apply for a vehicle operator licence: financial evidence
3,100 pounds
First vehicle, restricted licence
GOV.UK, apply for a vehicle operator licence: financial evidence
1,700 pounds
Each additional vehicle, restricted licence
GOV.UK, apply for a vehicle operator licence: financial evidence
Evidence can be bank or building society statements covering the last 28 days, among other options.
Applications carry their own timing rule. GOV.UK states that an advertisement must appear at least once within the period of 21 days before to 21 days after an application is submitted, and that the date of receipt of the application and the date of publication must not be more than 21 days of one another.
Operating centres must be big enough, have safe access and be in an environmentally acceptable location, with sufficient off street parking for vehicles and trailers.
The transport manager is a person, not a box #
A standard licence requires a professionally competent transport manager, and GOV.UK describes what that means in terms that resist being satisfied on paper: sufficient capacity, relevant knowledge and skills, and involvement in transport decision making. The word doing the work there is capacity.
That is also the strongest argument for taking the clerical layer seriously. Every hour the transport manager spends reconciling download dates is an hour not spent on the part of the role the licence actually asks for, which is judgement about vehicles, drivers and risk. The specific cycles involved are on tachograph download deadlines, drivers' hours record keeping and Driver CPC records.
What good looks like, in DVSA's own numbers #
DVSA's earned recognition scheme is worth reading even by operators with no intention of joining it, because it is the clearest published statement of what the regulator considers an acceptable standard. The entry conditions are an operator licence held for at least 2 years and no regulatory action other than a formal warning in the last 2 years, with an audit every 2 years thereafter.
| Indicator | Standard |
|---|---|
| Complete set of safety inspection records | 100 per cent |
| Safety inspection records completed correctly | 100 per cent |
| Safety inspections completed within the stated frequency | 100 per cent |
| Driver defect reports actioned | 100 per cent |
| Vehicle and trailer MOT initial pass rates | 95 per cent |
| Overall infringements as a share of tachograph days | 4 per cent |
| Working time | 4 per cent |
All of these are measured over 4 week periods, reported at the end of the period and sent to DVSA 4 weeks later.
Which parts of licence paperwork run on rules #
Runs on rules
- Knowing which safety inspections are due or overdue against the stated frequency, which is date arithmetic
- Knowing which inspection records are incomplete, which is a field check
- Knowing which defect reports have no rectification recorded against them, which is a gap in a set
- Knowing which records fall out of the 15 month window next month, which is date arithmetic
- Knowing that a change is inside its 28 day notification window, which is a countdown
- Producing the evidence when an examiner asks, if it was filed against the vehicle and the date
Needs the operator and the transport manager
- Deciding whether a vehicle is fit to go out today, a duty that does not delegate
- Deciding what a pattern of defects means about a maintenance provider, which is a management responsibility
- Deciding what to change so a failure does not recur, which is the substance of the undertaking
Compliance calendars of this shape are not unique to transport. The lettings compliance diary is the same animal with different certificates: rolling dates, statutory retention, and evidence that has to be produced on demand years later. What is different in transport is the consequence, because the licence itself is at stake rather than a fine.
To sort the arithmetic from the judgement in your own operation, use the which tasks run on rules checklist, and the cost of admin time calculator to see what the left hand column is costing you a month.