Consultation outcome

Allowing NHS ambulance services to carry out driving tests for their staff

Updated 11 October 2021

Applies to England, Scotland and Wales

Introduction

The driving test in Great Britain (England, Wales and Scotland) is conducted by the Driver and Vehicle Standards Agency (DVSA). However, some organisations are allowed to conduct driving tests for their own staff. This includes the Ministry of Defence (MoD) and police and fire services.

We call driver testing by the police and fire services ‘delegated testing’. The MoD is slightly different because they have their own powers to conduct tests, but DVSA works closely and collaboratively with them.

This consultation is about extending the delegated testing arrangements that are available to police and fire services to NHS ambulance services and foundation trusts. It is also about allowing the services to conduct driving tests for one another, which we call ‘cross-testing’.

It has been DVSA’s intention to make these changes for some time. This is because some police and fire services have told us that they would like to co-operate in the way that they go about driver training and testing. More recently, the MoD has also expressed an interest in this idea.

Finally, the coronavirus (COVID-19) pandemic has reinforced our view and given urgency to the need for delegated testing to be available to NHS ambulance services. Although DVSA was able to provide tests for ambulance drivers and paramedics during the national lockdowns (for England, Scotland, and Wales), the proposal would have provided good options and additional resilience.

This consultation seeks your views on both of these proposals. It applies to Great Britain, but not to Northern Ireland as driver testing there is not run by DVSA. There is a series of questions about the possible impacts on road safety and how the NHS and emergency services might adjust their approach to driver testing if these changes are made.

The consultation is being conducted in line with the government’s consultation principles.

If you have any comments about the consultation process email consultation@dft.gsi.gov.uk.

Proposals

The rules about who can conduct driving tests in Great Britain are in the Motor Vehicles (Driving Licences) Regulations 1999. To introduce these changes, we’ll have to amend these regulations.

Overview

This consultation sets out our proposals to introduce delegated testing for NHS ambulance services and to allow cross-testing between the emergency services and the MoD.

There are other organisations that conduct delegated tests for their employees and for people who are potential lorry, bus or coach drivers. This consultation only relates to arrangements that apply to the emergency services and to the MoD.

Some NHS ambulance services use private ambulance services for transportation for non-emergency passengers. This proposal will only permit testing of NHS ambulance service employees, not employees of third parties, contractors, or private ambulance services.

Background

Delegated testing helps organisations to streamline their supply of newly qualified drivers. If they have their own examiner then they can schedule recruitment processes, training and testing so that they get qualified drivers as and when they need them. They do not have to book a test with DVSA, so they are not dependent on our theory and practical test waiting times.

Passing the driving test with the emergency services is usually just the first stage of a driver’s ongoing training. For example, they may take additional training in driving at high speed under ‘blue light’ conditions. The standard of the licence acquisition test remains the same, but drivers are required to gain advanced skills.

Including NHS ambulance services in delegated testing arrangements will give them the same control and flexibility that is available to police and fire services.

Cross-testing will allow the managers who control delegated testing at each police and fire service and the MoD to make suitable arrangements between themselves. This could mean that neighbouring police and fire services co-operate with each other, or that they make testing arrangements on a bigger scale, allowing them to save money and resources.

If NHS ambulance services are permitted to conduct delegated testing, then they will also be able to join in cross-testing arrangements. This will mean that they can recruit their own examiner, or send candidates to an examiner at a service that is already approved to deliver delegated driving tests.

We’ll need new control procedures will to make sure that only properly eligible candidates are tested. To underpin this DVSA will have to approve any arrangements that are put in place.

How delegated testing works

Delegated driver testing is well established. It includes conducting all parts of the driving test that are relevant to the organisation. Vehicles used in certain circumstances by the MoD and emergency services are not subject to Driver Certificate of Professional Competence.

The candidate is generally an employee of the service, although there are slight variations around this to take account of different types of employment.

The Secretary of State for Transport must approve any organisation that wants to provide driving tests for its employees.

To maintain local accountability, organisations that deliver delegated testing must have a responsible person in charge. An organisation can only conduct delegated theory tests if they have an examiner in place to conduct practical tests.

Training and fees for delegated testing

Each delegated examiner must qualify by training with DVSA and then passing an assessment. The training course is 5 weeks long and currently costs £6729.50 plus VAT.

Examiners have to pay an annual registration fee to covers DVSA’s costs for supervision. The current annual fee is £950.

When qualified, a delegated examiner is supervised and assessed by DVSA about 4 times a year.

All examiners, including delegated examiners, must undertake 4 days training every 2 years. This is to enhance their examiner skills. DVSA provides this at a current cost of £98 per day. All examiners must also undertake 5 days training during a 5 year period to refresh and enhance their driving skills. Examiners can use any method of training but they must provide evidence to DVSA.

A delegated examiner must conduct at least 40 tests each year in order to maintain their skills.

Proposal 1: Delegated testing for NHS ambulance services

The main purpose of this proposal is to allow NHS ambulance services and foundation trusts the same flexibility as the other emergency services in regard to the driving test.

This will allow them to streamline their driver testing and training arrangements by testing internally if it benefits them to do so.

In order to do this, they would have to apply to DVSA to become a delegated test authority and have a person authorised to appoint a driving examiner. They would then recruit an examiner that’s already qualified, or up-skill someone from within their driver training team or elsewhere.

Delegated testing comes with some costs in terms of both staff and equipment. The test has to be conducted robustly and to a consistently high standard. For example, for reasons of impartiality, an examiner cannot test a candidate that they have trained. This means that up-skilling a person from the driver training team could result in the service needing to recruit another driver trainer.

The national emergency situation created by the coronavirus (COVID-19) pandemic has highlighted the need for NHS ambulance services to have access to different resources for driver testing. Currently all their ambulance drivers and paramedics must take a test with DVSA. Our strategic response to the pandemic worked well and key workers were able to take a driving test. However, had the situation deteriorated, then it could have proved difficult for DVSA to cope.

Allowing NHS ambulance services to test drivers themselves puts testing within their own control. It would not prevent DVSA from testing NHS drivers if that was necessary to support the service.

Finally, including NHS ambulance services in delegated testing should release some of DVSA’s large goods vehicle (LGV) examiner resource; which could benefit wider industry.

Proposal 2: Cross-testing between emergency services and the Ministry of Defence

The proposal to allow cross-testing will allow the emergency services (NHS ambulance services, fire services and the police), and people appointed by the MoD to test candidates for one another. For example, an examiner approved to conduct lorry (LGV) tests for a fire service could also conduct tests for other fire services, the police, NHS ambulance services, the armed forces or for MoD personnel when they have an officer who needs an LGV licence.

Including the MoD in this proposal will mean that they could conduct tests for the emergency services, or have military personnel tested by an examiner from an emergency service.

Cross-testing in this way may not always be a practical proposition. Each force tends to use specialist vehicles. For example, most police vehicles are either cars (category B) or motorcycles (category A), but there are also minibuses and vans. Fire engines require a category C licence, and ambulances require a category C1 licence. Military vehicles are wide-ranging and include tracked vehicles that fall into category H.

There may also be logistical issues with regard to where tests can be conducted, and security issues in regard to accessing some sites.

There are occasions when co-operation between services can be effective. As a result, DVSA has been approached by stakeholders to reconsider the rules.

Under the current regulations each service has to pay the annual registration fee of £950 for each examiner that it employs. There are some examiners that are currently employed by both the police and the fire services. Currently both services each have to pay the fee. Under this proposal the examiner would only need to be authorised by one service, but they could still conduct tests at the other.

With cross-testing in place, it is possible that local co-operation could become a fixed arrangement, and that services could share test capacity. However, that would be dependent on overcoming the practical and logistical considerations already mentioned.

How NHS services could use cross-testing

Cross-testing could also help to ease NHS ambulance services into the delegated examiner scheme. Without cross-testing, each NHS ambulance service that is permitted to conduct delegated tests would have to have its own examiner. They could be either a newly recruited examiner or an up-skilled person trained by DVSA. However, this could create a short term drain on examiner resource and on DVSA’s capacity to train new delegated examiners, particularly under the current coronavirus (COVID-19) related restrictions.

Cross-testing would allow NHS ambulance services to make short term arrangements with a delegated service while recruiting their own examiners. They could also share examiner resource so that drivers from different NHS ambulance services could take their test with the same examiner. That could reduce the number of annual examiner registration fees that would otherwise need to be paid to DVSA.

Under cross-testing arrangements the NHS could decide whether to have examiners based centrally, with candidates being sent to a test centre from all NHS regions. Alternatively, they could have mobile examiners that travel to a number of local test centres. They would also have the option of using examiners from fire services, the police, or MoD.

We plan to write the regulations in a way that will allow emergency services that do not have a delegated examiner to use the resources of those that do. This will allow the emergency services and MoD to take maximum advantage of the proposal, and could lead to them restructuring driver testing in the long-term.

DVSA will need to approve arrangements for a delegated examiner to test for another service and closely control and monitor them.

If there are any issues DVSA will be able to withdraw approval for any arrangement, revoke the examiner’s approval, or revoke the organisation’s authority to appoint an examiner.

In conclusion, we think that cross-testing would allow for co-operation, cost savings, efficiencies, and combined testing schemes at various levels. It also builds in resilience, whether that is cover for examiners who are off sick or on leave, or for continued testing during a national crisis.

Risk assessment

Before making any change to the regulations DVSA has to consider if the proposals bring any potential risk to road safety. In this case the primary risk lies in allowing other organisations to conduct driving tests.

It is DVSA’s view that all the emergency services and the MoD will continue to conduct tests to the correct standard. There are several reasons for this:

• they are recognised for their levels of professionalism and diligence in all aspects
• driver training at these organisations often goes well beyond the level required for licence acquisition, because driving is a highly specialised and skilled role where drivers need to be capable of protecting their colleagues, service users and vehicle assets
• any new NHS examiners will have to qualify in the normal way, meaning that they are trained and assessed by DVSA
• new NHS examiners will undergo supervision and continuous professional development in line with the requirements for all examiners
• DVSA will need to approve any cross-testing arrangements, provided there are robust management processes to confirm the identity and legitimacy of the candidate
• DVSA conducts supervisory and audit visits to ensure that the correct procedures are followed and that they have been followed in the past

The proposals could also bring short and long-term impacts in other areas. For example, if NHS ambulance services decide to up-skill trainers there may be short-term resource implications for DVSA.

There could also be some impact on the number of annual examiner fees that DVSA receives and on the number of supervisory visits that we need to conduct. We’ll monitor the effect of these changes and may need to adjust fee levels.

Impact assessment

These proposals relate to the public sector and have no material impact on businesses, so there is no requirement for DVSA to produce a formal impact assessment. However, we will take account of responses to this consultation, which asks the emergency services and MoD to tell us how they might adjust their test processes under these proposals.

What will happen next

We’ll publish a summary of responses, including the next steps, within three months of the consultation closing. You’ll be able to request a paper copy.

How to respond

The consultation period begins on 16 July 2021 and will run until 14 August 2021. Make sure your response reaches us before the closing date.

You do not have to give an answer to every question as some may not be relevant to you and you might not have a strong view on others.

Respond online

When responding to the consultation, comment on the costs and benefits, giving supporting evidence wherever possible. You can also tell us about:

• other ways to reach the objective
• any possible unintended consequences of the policy
• practical enforcement or implementation issues

Other ways to respond

You can respond by email if you cannot use the online form. If you respond by email, use the consultation questions to format your reply.

DVSA consultations
consultations@dvsa.gov.uk

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If you think someone else might be interested

If you have any suggestions of others who may wish to be involved in this process, share the consultation with them or contact us.

Consultation questions

About you or your organisation

Question 1

Please tell us if you are:

• a member of the public
• someone who has a vested interest in delegated testing (such as a trainer or examiner at a delegated test centre), but is not the formal spokesperson for the organisation
• a representative of an NHS ambulance service or foundation trust
• a representative of a police or fire delegated test service
• other

If you’re responding on behalf of an organisation, make it clear to us who the organisation represents and, where applicable, how the views of members were collected.

Delegated testing for NHS ambulance services

Question 2

Do you agree that NHS ambulance services should be able to be authorised to conduct driving tests?

Please give the reasons for your answer.

Question 3

Do you think there is any road safety issue or risk attached to the proposal to allow NHS ambulance services to conduct delegated tests?

Please give the reasons for your answer.

Question 4

Do you have any general comments on the proposal to allow NHS ambulance services to conduct delegated tests?

Questions for representatives of NHS ambulance services

Questions 5, 6 and 7 are only for representatives of NHS ambulance services.

Question 5

If you represent an NHS ambulance service, would delegated testing benefit your organisation and would you be likely to seek approval?

Please give the reasons for your answer.

Question 6

Having gained approval to carry out practical tests you can also seek approval to conduct theory tests. Is that something you would likely want to do?

Question 7

If, in answer to Question 5, you indicated that you would want to apply for delegated testing, please tell us how many driving test candidates (ambulance drivers and paramedics) you might expect to test in a year.

Cross-testing

Question 8

Do you agree, or disagree, that the emergency services and Ministry of Defence should be able to test for each other?

Please give the reasons for your answer.

Question 9

Do you agree that this proposal to allow cross-testing will assist in easing driver recruitment pressures caused by the coronavirus (COVID-19) pandemic and provide additional resilience?

Question 10

Do you see any issues or problems with the proposal to allow cross-testing?

Questions for delegated test authorities and potential NHS test authorities

Questions 11 to 15 are only for representatives of delegated test authorities and potential NHS test authorities.

Question 11

Which other services do you think you might cross-test for? For example, services that are the same type as yours or services in the same region as yours.

Question 12

Do you think that cross-testing arrangements would be fairly informal, for example covering sick leave, or fixed in that your examiner would exclusively test candidates from another service?

Question 13

Do you think that cross-testing will ultimately result in national restructuring of driver testing by the emergency services?

Question 14

Do you agree that DVSA should have to approve any cross-testing arrangements?

Question 15

Under these proposals the detail of any cross-testing arrangements, including any fee for the test service, will be entirely between the respective parties. Do you have any comment on this?

Freedom of information

Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000 (FOIA) or the Environmental Information Regulations 2004.

Under the FOIA, there is a statutory code of practice that we have to follow. If you want information that you provide to be treated as confidential you must explain to us why you think the information should be kept confidential.

If we receive a request to disclose the information, we’ll take full account of your explanation, but we cannot guarantee that your information will be kept confidential in all circumstances.

If your IT system generates an automatic confidentiality disclaimer this will not be regarded as binding.

Data protection

DVSA will process your personal data in accordance with the Data Protection Act (DPA). In most circumstances this means that your personal data will not be disclosed to third parties.

You can read the DVSA privacy statement for consultations.