TALKING COMPLIANCE

With Marc Caplin, our Compliance Manager

IS YOUR TACHOGRAPH ANALYSIS SOFTWARE FIT FOR PURPOSE?

Ever since the introduction of digital tachographs back in 2006, operators have been required to download data from their drivers’ cards and vehicles into some form of software to analyse the information. This approach was new to many operators at the time, some of whom would have been used to analysing their analogue charts manually, or by a third-party analysis provider.

As you would expect, there was some initial resistance to this change of approach and, although comprehensive packages such as ClockWatcher were available from day one, some operations did not fully appreciate the value of employing full analysis systems and were content with more basic “entry-level” software. This is certainly true of smaller operations where driving was not their primary function with the explanation of “we only have X drivers” given as a justification as to why full analysis was deemed unnecessary. As such, there remains a huge amount of these packages in use across the UK; this being the case, I thought it might be useful to examine what a tachograph analysis package needs to provide in 2023.

It is our perception that the expectations of what an operator needs to evidence in the event of any sort of intervention by enforcement authorities has only become more rigorous over time so operators need to ensure that their analysis system is able to provide the relevant information.

You need to keep an eye on downloading!

As a minimum, systems need to give clear information regarding when driver cards and vehicles were last downloaded. Many systems such as ours will have a colourcoded “traffic light” system that can be configured to reflect the downloading policy of the company. Gone are the days where the legal download intervals of 28 days for the driver card and 90 days for the VU are viewed as sufficient with many operators downloading cards daily and vehicles weekly.

How are you managing infringements?

The primary function of any analysis system has always been to manage driver infringements and there are still some software packages out there that do not provide automatic analysis of Drivers’ Hours and Working Time (RTD). This means that the onus is on the operator to manually calculate the data and decide whether or not drivers have committed infringements. This is now an outdated approach and is, inevitably, prone to human error. The best approach is to employ a system that will automate this for you and allow you to generate reports for the driver to sign off.

This leads us on to driver debriefing; operators are required to provide a clear audit trail evidencing any debriefing conversations that they may have had with the driver, along with any subsequent actions. Often, this can be carried out electronically, for instance using something like Aquarius’ eSign system, but operators can still use paper-based reports, so long as a clear audit trail can be evidenced.

In turn, this debriefing procedure must be clearly integrated with the operator’s own internal policies and procedures. It is surprising how many companies we speak to that don’t have anything written down that outlines what the expectations are for the drivers, or what will happen in the event of repeated infringements. Many operators seem content that simply having a system is sufficient, not appreciating that it is only part of the story!

What about Working Time (RTD)?

Although the Road Transport Directive is often viewed as a poor relation to Drivers’ Hours and sometimes gets neglected by both drivers and operators, they are still required to monitor it both on the road and as an overall operation. If your analysis system is not able to provide infringement data against Working Time or does not allow you to track Working Time averages across a Reference Period, you are leaving yourself vulnerable to enforcement action.

Keep an eye on record-keeping!

Less comprehensive systems may not contain seemingly basic functions such as a clear driver calendar that graphically displays driver data across time. In this current age of 24/7 roadside record-keeping, the absence of this would leave the operator unable to track whether or not drivers are making the relevant manual entries on their driver cards. Yes, the onus is on the driver to make these records, but the inability to monitor this would be seen as a failing on the part of the operator as it is their responsibility to ensure drivers are trained on the current regulations and record-keeping methods.

Analysis of vehicle data is crucial!

Rewind the clock 10 or 15 years and the emphasis was very much on driver infringements with less of a focus on vehicle data. Over time, attention has been increasingly turned to various aspects contained within the VU file, usually centring around three main areas; unaccounted or missing mileage, unaccounted vehicle movements, and vehicle overspeeds.

If your analysis package does not provide this information, it’s worth giving serious consideration to upgrading to a more comprehensive system to avoid being caught unawares in the event of any enforcement action. A compliant system should enable the operator to add explanatory notes to any occurrences of missing mileage and fully investigate any instances of a vehicle being driven without a card, as well as record any driver debriefing that may follow from this.

In summary, whether you are an owner-operator, if haulage is not the primary element of your business, or if you run a multi-depot road haulage company, the compliance requirements are the same and will be enforced in exactly the same way regardless of fleet size. On that basis, ALL operators must ensure that any compliance software they are using is fit for purpose and covers all the required areas. Choosing a proven software provider that’s at the forefront of the legislation and who are experts in their field will ensure you have all the tools to manage all your compliance needs.