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Senior Traffic Commissioner Updates Advice Note to Operators

07 April

Senior Traffic Commissioner, Richard Turfitt, has previously issued an emergency Statutory Document setting out interim guidance on the approach being adopted by the Traffic Commissioners in response to the COVID-19 outbreak and an accompanying Advice Note for Operators.

In light of further developments to the coronavirus response, the Senior Traffic Commissioner has updated the Advice Note for Operators in relation to a number of areas.

Vehicles Returning to Service

In normal circumstances, pre-use inspections are always recommended for vehicles returning to service after a period out of use; however, the Traffic Commissioners recognise that this may not be achievable on the large scale that will be required following the current crisis – operators will want to use their vehicles as soon as possible and there may not be enough maintenance slots available, which will cause delays to businesses getting up and running again.

The Senior Traffic Commissioner has therefore identified a number of principles that can be applied for fleets that are unused during the crisis period:

  • The PMI schedule is frozen or paused during the period that the vehicle is not used
  • The time to the next inspection can include any relaxation in PMI intervals that applied to relevant vehicles (in accordance with the principles identified at Section 6 of the Advice Note)
  • If the vehicle has exceeded its normal or, if it qualified for the PMI relaxation (identified at Section 6 of the Advice Note), its extended PMI period, a technically competent person (technician if possible) is to carry out an enhanced walkaround check, which includes tyre pressure measurement and brake performance test. The brake performance test, if not undertaken on a roller brake tester, will include a measured temperature check of the brakes after a road test. The temperatures are to be recorded and retained
  • Vehicles over 12 years old and more than 50% or 4 weeks, whichever is greater, over their PMI cycle will receive a full preventative maintenance inspection before use
  • Regardless of the combination of relaxations applied, no vehicle will be put into service if more than 17 weeks has elapsed since the last full PMI

The Advice Note for Operators contains various examples of how these principles can be applied.

Transport Managers

The Senior Traffic Commissioner anticipates changes in the working arrangements of transport managers as a result of the COVID-19 pandemic – whether that be transport managers working from home, self-isolating, absent through ill-health or being furloughed.

The Advice Note for Operators deals with each of these scenarios and reminds operators of the overriding duty of transport managers to continuously and effectively manage the transport activities for which they are responsible.  The Advice Note confirms that the Traffic Commissioners will take a view on what is practicable in all the circumstances to comply with the statutory duty but specifically reminds operators and transport managers of their obligation to notify the Traffic Commissioner of changes to their transport manager arrangements and/or apply for a period of grace in relation to professional competence.

Training Undertakings

The Senior Traffic Commissioner recognises that, due to the current situation (and the indefinite suspension of classroom-based training), operators and transport managers may encounter difficulties completing training required to comply with specific undertakings attached to their Operator’s Licence.  Where this applies, operators and transport managers should communicate these difficulties (supported by evidence of the steps taken to try to secure appropriate training) to the Traffic Commissioner as soon as possible.  The Traffic Commissioners may agree to extend the relevant deadlines and/or accept online/remote training alternatives.

Request for temporary exemption from requirement to hold a standard licence

The updated Advice Note for Operators now includes (at Annex A) a specific application form to be used to apply for a temporary exemption from the requirement to hold a standard licence.

Temporary arrangements for varying local bus services

The updated Advice Note for Operators now includes (at Annex B) detailed guidance explaining the temporary arrangements which have come into force with immediate effect to assist operators seeking to make variations to registered services which are impacted by the current COVID-19 outbreak.

The updated Advice Note for Operators can be accessed here.

Please contact the Regulatory team on 01254 828300 if you have any queries.

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