In a public Inquiry before The Traffic Commissioner at Eastbourne recently the issue of the Operator Compliance score held by the DVSA (formerly DSA and VOSA) was again brought up. For the uninitiated this is a system whereby a goods vehicle operator is screened as their vehicles pass DVSA check vehicles with ANPR systems mounted on them. These are usually Ford Galaxy's or similar, marked up with the yellow and black VOSA markings but with what appears to be a CCTV camera with a black front to it on the roof. The system reads the number plates of passing vehicles and checks them against the Operator Licencing Data Base.
This is significant as each operator has a compliance score which leads to a green (no problems) amber (previous compliance issues) or Red (compliance a problem) marker. The officer in the vehicle will then use this information to decide whether to stop the vehicle. If the operators score is red then it is almost certain that the vehicle will be stopped and checked, conversely if it is green then the vehicle is unlikely to be checked.
The issue here is whether the red score becomes a self fulfilling prophesy.
If operators on red get stopped then it will be operators on red that are found with further compliance issues.
How the score is allocated is also something of a hot issue and brings us back to the Public Inquiry, it is in part derived from "roadside encounters". In other words on the occasions when an operators vehicles have been stopped or dealt with in the past have there been any offences. If it was simply done on the number of offences large operators would be disadvantaged. A correction factor is applied according to the number of vehicles on the operator licence. Points are allocated for each offence, the most serious offences carrying a lot of points being able to take a score straight to red.
There are some statistical anomalies though:
- if you operate a single vehicle and get stopped once and an offence is detected then it gives the impression that you are offending 100% of the time and put you to amber. Whereas a stop of a single vehicle for the same offence as part of a large fleet might have little impact.
Another factor taken into account on the score is first time pass on presentation for MOT testing.
This is something which has been the source of significant debate. The logic is that if your vehicles are properly inspected by the drivers daily, and by workshops at 6-10 week intervals for safety inspections then any problems should be detected and fixed before test. In practice though there are defects which are unlikely to be picked up on inspections which are picked up at MOT. The two most frequently cited are rolling road (and simulated load) brake tests and headlight alignment. Many safety inspections are carried out by simply applying the brakes harshly and checking that all the wheels lock and in some cases using a device to check how quickly the vehicle slows when the brakes are applied. This will not however show up a defective load sensing valve or warped discs or ovaled drums. Likewise headlights are frequently aligned by pointing the vehicle towards a wall and having an educated guess, whereas on test they are checked using an optical device, at a fixed range and which defines the acceptable area precisely.
Such errors can be expensive in that they can lead to a substantial increase in the number of stops, this can knock on, at the lowest end to a driver running out of hours and not getting back to the operating centre at the end of the day, at the highest end to the loss of contracts or operators licence where further stops lead to the detection of further offences.
How to avoid the trap
The DVSA would no doubt say that running your vehicles with thorough inspections will mean no offences are detected at roadside.
However this does not deal with the pass at first presentation issue or situations where a vehicle suffers tyre damage when driving on site. There are things you can do to limit the impact though.
- Changing the safety inspection contract to require a rolling road brake test every second or third inspection (and keeping the print out with the vehicles records)
- If you have a group of companies where each subsidiary company has its own operators licence, consider putting them together as one, the more vehicles operated the less significant each stop is overall. (Note that should you find yourself in a Public Inquiry directors involved in other companies with poor compliance histories are considered)
- Keep track of your own OCRS score by accessing on line, obtain password from DVSA.