The Traffic Commissioners for Great Britain are warning commercial vehicle operators to improve their approach to brake performance testing.
Their intervention comes as the issue of poor brake testing – or the complete absence of any checks – is appearing ‘far too frequently’ during investigations by enforcement officers.
The regulators added that, despite the clear lessons from the Bath manslaughter case, operators are simply paying lip service to brake performance testing. In many cases, there’s too little recorded on the brake test to offer a meaningful assessment. In others, no information is recorded at all.
Operators are also failing to carry out testing at the required frequency.
Sarah Bell and Kevin Rooney, the lead traffic commissioners for enforcement, said:
Despite the clear warnings for industry, traffic commissioners are still receiving reports about a lack of effective and proactive brake performance testing regimes.
This is not limited to a specific type of licence, size of operator or a particular sector – it is across the board. That is why TCs are highlighting the need for a change of attitude within the industry towards brake testing.
There should be no compromise in any operator’s approach, no flexibility around standards.
The Driver and Vehicle Standards Agency (DVSA) Guide to Maintaining Roadworthiness (2014 revision) makes clear that every safety inspection must include a metered assessment of the braking performance of vehicles and trailers. It adds that a road test method to assess the brake performance for all planned safety inspections will usually be inadequate.
Where deficiencies in brake performance are identified, either during use of the vehicle or trailer or at the safety inspection, a measured brake efficiency test must be carried out. The efficiency test must confirm the brakes are performing satisfactorily before the vehicle or trailer can be considered as roadworthy.
DVSA also publishes detailed guidance on how to prepare a vehicle for the brake testing element of the MOT.
In recent cases at public inquiry, traffic commissioners have seen:
- a Barking operator with missing brake figures on PMI sheets
- a Louth operator with brake test results not added to PMI records and no evidence of periodic brake testing being carried out - the DVSA vehicle examiner also identified the use of a vehicle with a braking defect for a whole week, despite the driving identifying the defect during daily checks
- a Coddenham firm with the brake test section of PMI records not completed and 4 brake performance tests not conducted annually on each vehicle / trailer
- a London operator who failed to comply with a public inquiry undertaking to have roller brake tests carried out every 6 weeks, with PMIs
- an Ashford firm which had not subjected its vehicle to a brake test since 6 December 2016, with the brake testing section of PMI records left blank on 5 out of 7 inspections
- a Rainham business which failed to comply with a specific undertaking to have quarterly brake testing
- a London operator with ‘not applicable’ written in the brake test section of every PMI
Offering advice to the industry, Kevin Rooney and Sarah Bell added:
Operators should carry out an urgent review of their brake testing regime now.
This should include an analysis of safety inspection records over the last 15 months, looking at whether the type of test and the information recorded is sufficient. Operators must make sure their brake tests are planned in line with DVSA guidance and satisfy themselves that the vehicles and trailers running under their licence are roadworthy.
We want licence holders to be sure their brake testing regimes are effective.