Guidance

Approved tachograph centre special notice 07-19

Published 31 August 2019

1. 1C introduction: relaxation of rules update

Very limited numbers of 1C motion sensors are now becoming available and, where possible, they must be used to meet the legislative requirements.

The continued lack of equipment means that the relaxation of the 1C introduction deadline is still in force until further notice.

No updates have been received from the equipment supplier as to when the supply chain will be back to normal.

Further instructions will be issued when more is known.

2. Clarification on retrofitting and 1C tachographs

This instruction is to clarify previous guidance.

1C tachographs are only mandatory in vehicles registered from the 15 June 2019.

Any vehicle registered before this date, that requires a tachograph to be fitted, may either have the latest 3rd version of the 1B (tachograph with IMS switched on) or a 1C tachograph if they wish.

The above interpretation also applies to replacement tachographs.

3. Security of 1C seals

As mentioned in special notice 01-18, EC legislation came into force for annex 1C ‘smart’ tachographs on 15 June 2019.

All vehicles first registered from this date must have an annex 1C tachograph installed with the relevant Kitas 4 sender unit and the new type seals.

The new 1C type seals are now classed as “accountable documents” and should be secured accordingly.

Enough 1C seals may be brought out from the main safe to cover that day’s work only and these must be secured during the day awaiting final use.

Any unused 1C seals must be returned to the main secure facility.

The Regulations do not apply to analogue tachographs.

Approved Tachograph Centres must record 1C seal numbers used during calibration and put onto the vehicle. This process ensures that there is a full audit trail available for the life on the 1C seal.

4. UK approved seal distributors

All 1C seal manufacturers must register with JRC and are provided with identification letters that are recorded on the JRC database. For example, 1C approved seal providers within the UK are:

1. BP – Continental and Time provide.
2. UN – Skillray provide.
3. RP – Skillray provide.
4. PR – Encompass provide

Once the 1C seal manufacturer produces the 1C seals, they must keep a record of all 1C seal numbers.

The manufacturer is then is required to log 1C seal numbers supplied to each distributor.

The distributor is then required to record 1C seal numbers sold to Approved Tachograph Centres.

UK 1C seal distributors are responsible for the security and management of 1C seals within the UK tachograph scheme whilst they are under their control.

If the distributor uses a third-party agent to distribute 1C seals on their behalf within the UK, then it is the distributor’s responsibility to ensure that the third-party agent has a robust and secure handling system in place before they release seals into their control.

This process and system must be fully documented and agreed between the two parties.

Once this process has been agreed and a third-party distributor takes control of a 1C seal. they will be held to the same standards as a 1C seal distributor and approved tachograph centre.

Any breaches of the control and security of the handling of 1C seals may result in the distributor being refused permission to continue to supply 1C seals as a third-party agent within the UK tachograph scheme.

Each 1C seal must be accounted for from point of manufacture to fitting on a vehicle.

Approved tachograph centres will be informed through the special notice system as to which distributors and third-party agents have been approved to supply 1C seals within the UK.

If the 1C seal provider has not been approved, then the approved tachograph centre cannot use those 1C seals.

If an approved tachograph centre does use one of these 1C seals from a source that is not approved, then they will be subject to enforcement action.

5. 1C uplift training

Previous special notice 01-18 and special notice 01-19 clearly stated that nominated testers needed to receive their 1C uplift training by the end of June 2019.

The majority of nominated testers have now received their 1C uplift training package. However, there are a small number who have not received the training.

It is now no longer possible to attend a 1C only uplift training course module, as they have now been absorbed into the full initial tachograph training course.

Therefore, any nominated tester who has not received their 1C training must now attend a full initial calibration course by the 31 October 2019 for their authorisation to install, calibrate and undertake periodic inspections for all tachographs to continue.

Nominated testers who require and have not received the 1C training will have their authorisation to install, calibrate and undertake periodic inspections revoked on the 30 September 2019.

Those nominated technicians affected can continue to calibrate 1B vehicle until the 30 September 2019 when it will be revoked until they have attended and passed an initial calibration course.

Any installation, calibration or periodic inspections undertaken by these nominated testers after 1 October 2019 will be classed as invalid.

The appropriate disciplinary action will be taken against both the nominated tester and the approved tachograph centre who continue without having received the required training.

Any vehicles that have been subject to these calibrations will also need to be recalled by the approved tachograph centre for the appropriate corrective action to be undertaken. This will be at the approved tachograph centres cost.

There will be no exceptions to this rule.

As mentioned previously it is the responsibility of both the approved tachograph centre and the nominated tester to ensure the needed training has been undertaken.