Research and analysis

Driver Certificate of Professional Competence review: final report

Published 2 March 2023

Executive summary

The purpose of the review was to identify whether current rules for, and organisation of, Driver Certificate of Professional Competence (DCPC) training are useful and proportionate for drivers and to consider changes to the regulations. This has included how any changes may be made (legislatively or administratively) and the evidence supporting these changes.

The review was conducted between November 2021 and January 2022 and supported by stakeholder engagement, including a stakeholder forum, chaired by Department for Transport (DfT) officials. This met 4 times during the term of the review and comprised of 20 members from the road transport industries incorporating:

• freight and passengers
• union representatives
• traffic commissioners
• training organisation representatives
• devolved administrations (driver training is devolved to Northern Ireland (NI))
• the Driver and Vehicle Standards Agency (DVSA)

Further evidence was sought and considered, namely from previous reviews and new primary data collection in the form of surveys completed by drivers, operators and training providers. Details of this evidence is provided in the report and given in support of the conclusions.

The overall aims of the review were to advise ministers on:

• how compulsory periodic training requirements for professional lorry, bus and coach drivers should be developed to increase the standing of the training amongst drivers, be more valuable to those drivers and increase skill levels and professionalism, including to support public safety

• whether there should be a presumption reflected in law that employers pay employees periodic training costs and that time spent doing periodic training counts as paid working time

• whether all the drivers and driving for which DCPC is required should continue to be within a standard DCPC regime and, if the scope of DCPC was reduced, whether there should be alternative compulsory requirements

Specific issues examined were whether:

• different training requirements should apply for more experienced drivers

• the current requirement for 35 hours’ (5 working days’) periodic training is appropriate and how this should be organised

• drivers new to DCPC should cover a specific range of topics

• minimum durations for each training course should remain rigid (currently a minimum of 7 hours, or split into 3 and a half hour sessions across 2 consecutive days)

• the content and delivery of periodic training best supports driver learning

• the scope of DCPC should be amended to either include, or remove, further classes of driving licence

• there should be more of an obligation on employers to support drivers with the cost of training

• DCPC qualifications obtained in the EU should continue to be recognised in the UK for drivers moving to live and work here

As a product of this review, 5 key findings have been identified, these are:

• Finding 1: DCPC should be retained but would benefit from reform

• Finding 2: legislative change is required to implement some of the important changes to DCPC

• Finding 3: important aspects can be achieved without legislative change and should be progressed

• Finding 4: if necessary, divergence between DCPC requirements for UK drivers operating internationally and DCPC requirements for UK drivers operating within the UK, or Great Britain only, would be justified to enable important changes to be made

• Finding 5: DCPC once reformed should be kept under review

Finding 1: DCPC should be retained but would benefit from reform

The review’s first key finding is that DCPC should be retained but would benefit from substantial reform. While most drivers and operators from a large survey base sought change, some wanted complete abolition.

The review identified some aspects of DCPC where change would be beneficial, which would meet some of the apparent causes of dissatisfaction and which could be implemented without compromising the principle of DCPC (put simply, to improve the skills and knowledge of lorry, bus and coach drivers, before they start driving professionally and during their working lives and hence improve road safety).

In line with this first key finding, the review recommends that ten conclusions should be considered for implementation. These are:

• Conclusion 1: DCPC should be retained, but drivers should have the choice between completing reformed DCPC training or a formal pass/fail test to renew a qualification or re-join the sector

• Conclusion 2: improvements could be made to the way in which training is delivered and to the quality of training provided

• Conclusion 3: give more flexibility in training requirements by removing the requirement for courses to be a minimum of 7 hours and the requirement that when courses are split that these must be completed across 2 consecutive days

• Conclusion 4: provide flexibility to the operational rigidity around the way e-learning modules are completed

• Conclusion 5: encourage the continued development of suggested core content for courses

• Conclusion 6: encourage the continued re-focus of training from prescriptive course completion to outcome-based learning (use more informal assessments in courses)

• Conclusion 7: change the training burden on those looking to return to vocational driving by either removing or reducing the requirement to complete training to restore a lapsed qualification

• Conclusion 8: introduce the capability to grant short-term extensions, in urgent situations, to the validity of existing Driver Qualification Cards (DQCs), which show completion of DCPC training

• Conclusion 9:  introduce the capability to grant short-term exemptions, in urgent situations, from the need to hold a valid DQC for certain classifications of driver

• Conclusion 10: consider further, and potentially consult about, changing the current exemptions from DCPC for ‘non-core’ professional drivers, to ensure they are appropriate

Finding 2: legislative change is required to implement some of the important changes to DCPC

The second key finding of the review is that legislative change is required to implement some of the important changes to DCPC and this is required soon. This includes introducing a test option for renewal, increasing flexibility of training and e-learning, the regime for returning drivers and the ability to extend validity of DCPC qualifications or provide exemptions from the need to hold DCPC qualifications in some circumstances.

The requirement for DCPC is rooted in EU Directive 2003/59/EC (‘the directive’), transposed for both Great Britain and Northern Ireland by the Vehicles Drivers (Certificates of Professional Competence) Regulations 2007 (S.I. 2007/605) (the ‘DCPC regulations’). The directive was transposed using section 2(2) of the European Communities Act 1972 (‘the ECA’).

There are no permanent primary legislative powers under which the DCPC regulations can be amended. However, there is potential for some proposed changes to be made under the Retained EU Law (REUL) Bill. As introduced, these are time-limited powers which may be amended during the passage of the bill and therefore alternative primary legislation may still be needed to create permanent powers to implement some of the proposed changes, not covered by the REUL Bill and allow for potential future changes if required, via secondary legislation.

Finding 3: important aspects can be achieved without legislative change and should be progressed

The third key finding is that some important aspects can be achieved without legislative change and should be progressed. These include some of the quality improvements, specifically the greater use of informal assessments (supporting outcome-based learning) and creating more core content for periodic training courses.

Finding 4: if necessary, divergence between DCPC requirements for UK drivers operating internationally and DCPC requirements for UK drivers operating within the UK, or Great Britain only, would be justified to enable important changes to be made

The fourth key finding of the review is that, if necessary, divergence between DCPC requirements for UK drivers operating internationally and DCPC requirements for UK drivers operating within the UK, or Great Britain only, would be justified to enable important changes to be made.

Many of the review’s conclusions recommend changes that would not be consistent with the UK’s treaty obligations in the UK and EU Trade and Co-operation Agreement (‘the TCA’) which requires the drivers of UK operators transporting goods to, from, through or within the EU, to hold a DCPC. The DCPC must comply with the requirements of annex 31, part B, section 1 of the TCA, which mirror the main requirements set out in the directive.

Therefore, existing DCPC requirements will need to be maintained for international driving, but not for driving exclusively within the UK. This means that UK drivers driving in both the UK and the EU would need a DCPC that is compliant with EU standards as applied through the TCA, and EU drivers operating in the EU and the UK would also need a DCPC compliant with EU standards.

The UK has also made commitments, similar to those in the TCA, through the Interbus Agreement and agreements/arrangements related to the European Conference of Ministers of Transport haulage access system, to Norway and to Switzerland. To note, the review has been conducted with the participation of Northern Ireland officials. Its conclusions relate to Great Britain but can be applied in whole or in part to Northern Ireland if the responsible authorities there wish for them to do so.

For UK drivers therefore, the DCPC compliant with EU standards could also be used for domestic driving and so 1 DCPC would cover a driver for driving in the UK and the EU, whilst EU drivers operating cabotage in the UK would use their EU-recognised DCPC. However, if a UK driver chose the reformed model of DCPC (which factors in the changes mentioned above) they could not use this DCPC for driving to, from or within the EU.

Some key aspects of the content of DCPC as in place now (for example, the necessity of 7-hour courses, allowed to be split across consecutive days) are contained in the appendix to annex 31, part B, section 2 of the TCA. Other aspects of the review’s proposals, such as special arrangements for drivers returning to the profession, would contradict parts of the TCA if applied to driving into the EU and are therefore not possible to implement for those drivers without renegotiation of the TCA. All of these could only be changed in respect of DCPCs used for international transports through agreement with international partners and cannot be amended unilaterally.

Finding 5: DCPC once reformed should be kept under review

The level of dissatisfaction with some of the current arrangements that has been registered is significant and the fifth key finding of the review is that DCPC, once reformed, should continue to be kept under review. The fundamental issue of whether DCPC is worthwhile and should be retained will be reviewed periodically. Substantial changes will need time to take effect. Their effectiveness in developing DCPC, including its standing, should be monitored with a view to returning to the issue of whether it should continue or not, including whether further significant reform should be instigated.

Introduction

DCPC review

The review was set up to identify whether current rules for, and organisation of, DCPC training are best meeting their stated aims and to consider changes. This included how any changes may be made (legislatively or administratively) and the evidence to support these.

The review was launched by Grant Shapps, former Secretary of State for Transport on 8 November 2021, in the context of the heavy goods vehicle (HGV) and public service vehicle (PSV) driver shortages and the UK having more control over DCPC rules following EU exit.

The aims of the review were to advise ministers on:

• how compulsory periodic training requirements for professional lorry, bus and coach drivers should be developed to increase the standing of the training amongst drivers, be more valuable to those drivers and increase skill levels and professionalism, including to support public safety

• whether there should be a presumption reflected in law that employers pay employees for periodic training costs and that time spent doing periodic training counts as paid working time

• whether all the drivers and driving for which DCPC is required should continue to be within a standard DCPC regime, and if the scope of DCPC is reduced, whether there should be alternative compulsory requirements

DCPC background

The purpose of DCPC is to increase safe driving, raise professionalism of drivers, standardise driving levels across Europe as well as help drivers meet the demands arising from the developments in the road transport market.

Under the DCPC regime, there is an obligation to hold an initial qualification and to undergo periodic training. The qualification applies to drivers with category C and D driving licences and their subcategories. These are drivers of lorries of all sizes, buses, minibuses, or coaches. There are some specific exemptions from the requirements of DCPC, such as, vehicles under the control of the fire service, police, or military. A full list of exemptions can be found within the regulations.

The Vehicle Drivers (Certificates of Professional Competence) Regulations (as amended) 2007 (hereafter ‘DCPC Regulations’), implemented the EU Directive 2003/59/EC (hereafter ‘directive’).

The UK did not add legal requirements that were not needed to meet the directive. There was significant consultation with the relevant industries in the negotiation and implementation of the DCPC Regulations, including the amendments that were made to the directive in 2018, which were adopted into domestic legislation in 2020 (S.I. 2020/662).

The directive, transposed into UK legislation, amongst other things:

• prescribed tests that must be passed before an initial qualification is awarded
• prescribed a 35-hour periodic training requirement to be completed every 5 years to maintain the DCPC
• made provision for the regulation of training courses and the quality assurance of those who may deliver them
• put certain driving activities out of scope of the requirement to hold a DCPC

The 2020 amendments, amongst other things:

• introduced new, and modified existing, exemptions to the requirement to hold a DCPC
• updated the subjects that should be covered in training courses
• allowed training to be split across 2 consecutive days

Since the introduction of DCPC, around 1.94 million driver qualification cards (DQCs) have been issued, of which around 380,000 were to new drivers completing the initial qualification and around 1.56 million for existing drivers completing their periodic training. In the 5-year period to September 2022, around 910,000 DQCs were issued and were valid (although a small number will have been revoked).

Methodology

This review has taken evidence from 3 main sources to support its findings and subsequent conclusions.

Previous reviews of DCPC

These include a ‘2013 Consultation’ undertaken by the European Commission to look at how effectively Directive 2003/59/EC had achieved its objectives and a ‘2015 GB Post Implementation Review’ undertaken by the UK government to review DCPC legislation and assess how it had been delivered and to what effect (see Appendix 1).

Stakeholder engagement collected through written submissions and discussions held between mid-November 2021 and January 2022

Evidence was sought from:

• drivers’ representatives through unions
• employers
• training organisations
• road safety groups
• officials from devolved administrations

Evidence was also obtained in written submissions and discussions in stakeholder forums, details on membership of the Forums and written submissions received can be found in Appendix 2.

Stakeholder engagement through surveys devised by DfT

These were conducted as part of this review (as well as wider independent surveys carried out by stakeholders during the period of the review, November 2021 to January 2022). Details on survey methodology, survey questions and number of responses received to these can be found in Appendix 2.

The review team would like to thank everyone who took part in the review.

Findings and discussion

The detailed findings from previous reviews, the stakeholder forum and responses to the surveys have been analysed. This section appraises the evidence and discussions, splitting these into 7 distinct areas with proposed conclusions at the end of each thematic section.

The key areas are:

1. Value of DCPC

2. Test option

3. Structure and content of DCPC training

4. Returning drivers

5. Exemptions, extensions and exceptions

6. Payment

7. Other matters

Value of DCPC

One of the aims of the review was to consider the value of the DCPC for drivers and whether it should be retained. This, and the following sections, consider the evidence gathered on this.

There was strong support for the principle of DCPC along with thoughts that there should be scope for greater flexibility in how periodic training is delivered, making it more manageable, flexible and focused than it is at present. For example, among drivers surveyed, measures they considered would encourage them to maintain their DCPC included 50% supporting more flexible training arrangements.

Within the stakeholder forum discussions there was agreement that the scheme delivered value to the industry. This was also supported in many of the formal written submissions by stakeholder forum members. In a survey of road haulage drivers and operators by the Road Haulage Association (RHA), 67% of respondents said that DCPC should be retained, with the majority (62%) saying there should be some kind of reform (although 33% said it should be abolished). In survey evidence submitted to the review by Road Skills Online, 59% of operators said that DCPC made a positive impact on their business, but 95% requested changes.

However, concerns were expressed about the variability in quality of the training. This is despite quality control measures being in place through the initial training provider and course approvals processes and regular auditing of training delivery. It was considered more could be done to improve outcomes for drivers and their employers.

There was support from the stakeholder forum that the overall quality of training should be improved but not by regulation, mandatory content or formal testing following a periodic training course. Furthermore, while there should be changes to the DCPC, there was resistance to full abolition or diminution of the current DCPC.

Stakeholder forum members were in support of the integration of the initial DCPC acquisition with the driving licence test acquisition processes and believe this should continue.

A key reason for supporting DCPC is that of perceived road safety benefits. In the 2015 post-implementation review, survey data was cited which showed that following drivers’ attendance at periodic training aimed at improving road safety, 70% of managers reported that staff were better equipped for their roles and 85% of drivers said the course had made them a safer driver. Likewise, the importance of DCPC to road safety was shared in the written submission from the Confederation of Passenger Transport UK (CPT) and Logistics UK which can be found in Appendix 2.

Identifying categorical evidence to demonstrate road safety improvements as a result of DCPC is challenging. Nevertheless, DfT statistics demonstrate that from 2007 (the year before drivers were required to hold the DCPC qualification) to 2020, the number of accidents HGVs have been involved in has declined.

During this time accidents involving cars also fell, however, the percentage decrease in accidents in this period was considerably higher for HGVs than it was for cars (68% decrease compared to 54%). This, triangulated with survey data indicating 85% of drivers felt DCPC training made them safer drivers and qualitative feedback from the stakeholder forum, allows for the reasonable assertion that DCPC is likely to positively impact road safety.

In summary, while there was wide ranging support for the value of DCPC, there was strong support across the review that there is scope for reform to make the qualification more useful and proportionate and to reduce burdens and barriers to joining, remaining in and returning to the workforce.

Test option for periodic renewal

The review examined how the process for renewing and re-acquiring the DCPC could be better structured to increase its standing amongst drivers, whilst supporting public safety and the professionalism of the sector. Elements of the current training regime were considered onerous and the review has considered better ways to address this whilst not detracting from the value of having post-qualification assurance of drivers’ competence.

Feedback from drivers and operators/employers suggests the following are 3 key factors in determining whether a driver will renew their DCPC qualification:

• relevance of training material (60% of drivers and 65% of operators)
• cost (56% of drivers and 50% of operators)
• time to complete (45% of drivers and 58% of operators)

Furthermore, 57% of training providers surveyed stated that cost of training is seen as a significant consideration when determining if a driver renews their qualification and 62% of training providers also expressed concerns with the variability in quality and relevance of training available to drivers. Finally, 61% of training providers reported that they were concerned about the time needed to complete the training, with many commenting that 35 hours is too much and disproportionate for experienced drivers.

In addition, for drivers returning to the sector, there was support in the stakeholder forum that having to complete 35 hours of training was a disproportionate burden and a barrier to re-entry.

It is accepted that survey responses are based on a relatively small survey group of 607 respondents and may not be fully representative. However, in order to reflect these findings about factors determining whether a driver remains in, or re-joins, the sector, and to support DCPC as a measure of professional competence, the review suggests providing drivers with an option to complete a formal pass/fail theory test.

This would not remove the option of completing training, but rather be offered as an alternative to the requirement for training. It would also not be used to assess understanding following completion of a training course (for which the recommendation is for the increased use of informal assessments accompanying training courses).

A test option could mitigate concerns around relevance of training and be cheaper and less time consuming for drivers than training, whilst continuing to provide an appropriate assurance of competence. Crucially, in order to provide this vital reassurance, further development of a test option would be required and stakeholder views on this could be sought at consultation.

As suggested by stakeholders feeding into the review, the implementation of a test option would need to be done in a robust way to ensure that it is valid, reliable and continues to provide assurance on the capabilities of professional drivers. The review does not recommend a specific format or mechanism by which the test could be developed or taken, but instead suggests that further consultation is conducted to establish the best way for a test allowing periodic renewal.

This consultation might include, for example, the gathering of views on whether there should be and if so the degree to which variation of test content/material might be appropriate depending on driver specialism. A consultation could also capture input on the most proportionate and appropriate mechanism for and format of a test.

It would also be important to consider the best ways of ensuring the test provided a meaningful measure of driver knowledge, for example being set against defined learning objectives. This could ensure that drivers are able to prepare for the test in an appropriate way.

Conclusion 1: DCPC should be retained, but drivers should have the choice between completing reformed DCPC training or a formal pass/fail test to renew a qualification or re-join the sector.

Structure and content of DCPC training

The review considered how compulsory periodic training requirements for professional lorry, bus and coach drivers should be developed to make it less of a burden and improve its quality. This section considers the evidence gathered on this, cited above and recommends the following conclusion:

Conclusion 2: improvements could be made to the way in which training is delivered and to the quality of training provided.

The following section provides a number of ways for how this could be achieved and starts by giving the current context.

There are around 1,500 approved training providers, who offer over 3,000 approved courses. Course content must be aligned to the DCPC syllabus, which covers a broad set of road safety and environmental objectives.

The criterion for successful periodic renewal of DCPC  by a driver is determined by attendance for the full 35 hours, which is 7 hours per module, or 3 and a half hours if split provided these are completed across 2 consecutive days. Once the full 35 hours of training is completed a DQC (Driver Qualification Card) is given to the driver.

Courses are not required to include an element of formal assessment, although some do involve informal checks to ensure that training is focussed and learning outcomes are being achieved.

Delivery of courses in a classroom setting can include 1 trainer leading a session involving a group of trainees. DVSA has also authorised a number of providers to deliver remote courses online.

Courses may also be delivered in part through e-learning modules, taken independently without a trainer present. The general rules inherited from the EU and contained in the TCA, permit a maximum of 12 hours e-learning for every 35 hours of training. However, in the UK, operational requirements laid out by the DVSA allow up to 2 hours of every 7-hour course to be completed by e-learning. When this 7-hour course is ‘split’ the legal requirement to complete training across 2 consecutive days also applies even where part of the course is taken as ‘e-learning.’

Course duration and timing of periodic training

Stakeholders raised concerns that 7-hour training courses were too long. Discussions in the stakeholder forum supported allowing greater flexibility in their length.

Shorter courses could help uptake of DCPC and retention of drivers in the sector, noting the finding that 50% of drivers felt more flexibility in training (shorter modules) would encourage them to maintain their DCPC qualification. Additionally, 55% of operators agreed that it would be beneficial if DCPC could be completed via shorter training modules totalling 35 hours, 35% did not agree, while 10% didn’t know if it would be beneficial.

Amongst drivers, when asked what the optimum length of modules in hours should be, 41% said these should be 3 and a half hours, with 7 and 5 hours (22%, 26%) the next most popular.

Operators generally agreed with this, with 44% stating modules should be 3 and a half hours each, 10% stating these should be 7 hours, 19% stating these should be 5 hours, 5% stating these should be zero hours i.e., there should be no DCPC modules and 22% stating periodic modules should be another amount of time.

Smaller and medium sized operators were more in favour of shorter 3 and a half hour modules (46% and 44% respectively) than large operators (37%). Around a quarter (26%) of large operators thought modules should be 5 hours with 15% of large operators thinking that modules should be 7 hours long.

70% of training providers would welcome shorter training modules and 61% of training providers were concerned about the time needed to complete the training, with many commenting that 35 hours is too much.

A minority of stakeholders proposed that drivers should be mandated to complete 1 day (7 hours) of periodic training each year out of the 5-year cycle. This was to prevent the risk of some drivers cramming the majority of the 35 hours into the final months. This would also ensure that drivers’ knowledge is updated every year.

Shorter courses would offer more flexibility and may result in better retention of knowledge. Wincanton’s formal review submission said that shorter module lengths could be better accommodated into a driver’s working pattern and would be easily deliverable. They continue that based on measuring outcomes of other training they provide to employees, flexibility in module length allows drivers to more easily undertake training and affords greater value, due to increased retention of learning.

When asked how periodic learning should be organised in the future, drivers’ responses were split as follows:

• drivers should retain flexibility to arrange training over the 5-year life of their DQC (41%)
• drivers should be required to do at least 1 course per year (36%)
• monthly modular sessions (7%)

Some forum members proposed that drivers should have a rolling programme of 1 day’s training per year. This would spread the training out across the 5 years, preventing drivers cramming the majority of the 35 hours of training into the final months, and to ensure that drivers’ knowledge was continuously renewed (as opposed to doing the full 35 hours in 1 go, sometimes in the final year). However, strong support for this was lacking as it was perceived to be too restrictive for little gain.

Currently the rules give flexibility to drivers to complete their periodic training at any time in the 5-year cycle. Retaining this flexibility was considered important by the majority of stakeholder forum members, citing qualitative evidence that individuals should be able to choose when to undertake the training at a time that best suits them.

In addition, if yearly requirements were placed on drivers, a new system of monitoring and enforcement would need to be developed. This would be costly, time consuming and, given the lack of majority support for this suggestion, disproportionate.

Therefore, the review recommends that there should be increased flexibility of course duration.

Conclusion 3: give more flexibility in training requirements by removing the requirement for courses to be a minimum of 7 hours and the requirement that when courses are split that these must be completed across 2 consecutive days.

Course delivery and further inclusion of e-learning

When asked about preferred delivery methods of training, drivers were split between:

• in-vehicle/in-yard toolbox-type training (37%)
• classroom (30%)
• e-learning (26%)

Despite only 26% choosing e-learning, when specifically asked whether future training courses should include an option for e-learning, 72% of employers and 69% of drivers agreed that it should. CPT submitted that e-learning offers the opportunity to measure and deliver training more effectively that better suits the needs of many learners.

To date, take up of e-learning within DCPC has been limited.  Training providers report that the current requirements are too restrictive, allowing 2 hours’ e-learning independently and then delivering the remaining 5 hours of a course is reported as being too complicated and results in the same burden as a 7-hour classroom course.

Drivers believed that the barriers to e-learning were access to technology (computer or smartphone) (44%), time availability (21%) and work pressure (19%). When asked if monthly e-learning modules would be useful, 56% agreed it would, 44% thought it would not.

For operators, 47% felt the main barrier to e-learning was access to technology, the same proportion (30%) thought work pressures and time available were the main barriers. A large minority (29%) gave another reason as the main barrier to training being delivered via e-learning.

Amongst training providers, whilst a percentage would welcome e-learning, concerns around access to technology and the computer literacy of some drivers suggests that this solution may not be welcomed by all. Classroom-based training is ranked as the most effective way of delivering training to this audience, with e-learning ranked least effective of the 5 options given.

Drivers and employers reported similar factors currently preventing greater take-up of e-learning. While time availability, and by implication time available for training due to work pressures, would be supported by allowing a more flexible approach to e-learning. It is recognised that e-learning may not be appropriate for all those needing to complete the DCPC, and that face-to-face options should therefore be retained (i.e., there should be greater choice and flexibility).

It is recommended that the maximum 12-hour e-learning limit within the directive, and the TCA, across the whole 35 hours, should remain. However, the requirement that an e-learning course, when taken as part of a split 7-hour training course, must be completed across 2 consecutive days, should be changed for domestic driving purposes and this will improve the options for course delivery.

The review therefore recommends that there should be more flexibility in when e-learning can be completed to increase accessibility and options for drivers while not being at the expense of other forms of training.

Conclusion 4: provide flexibility to the operational rigidity around the way e-learning modules are completed

Course content

The review assessed whether DCPC training content delivered value for drivers, promoted road safety, and followed good practice. The following section provides consideration of whether there should be prescribed course content and how this could be structured to improve the knowledge of drivers (outcome-based learning).

Mandating courses for all drivers and creating core content

‘Relevance of training’ was reported in the driver survey as the most important consideration when determining whether drivers would renew their DCPC with 60% of respondents citing this, above the cost of training (56%) and time needed to complete training (45%).

There was support for mandating some training content for certain classes of driver. Surveys showed 70% of employers and 68% of drivers felt that training topics should be mandated for new drivers. However, support for this fell for existing drivers (44% of employers thought training should be mandated) and returning drivers (56% of drivers felt course content should be mandated).

Support for some mandated courses or key topics was higher among larger operators (79%) than medium (74%) and smaller (66%) operators. While Wincanton’s formal submission to the review supported the development of core content as industry guidance, to mandate this would take away flexibility to adjust the training to operational needs.

To address concerns about the relevance of information delivered by trainers, it is proposed that DVSA continues to work with a range of stakeholders and subject matter experts to develop core content for training courses. It is the intention to publish this content, making it available to all training providers to use as part of relevant courses. DVSA propose to address the most common course subjects first:

• drivers hours
• loading
• health and safety
• tachographs
• manual handling
• defensive driving
• customer service
• safe urban driving
• disability awareness

This approach was welcomed in the stakeholder forum, and DVSA propose to further encourage the sharing of good practice and training materials (such as e-learning modules or DVDs) within the training industry.

Developing core content and encouraging the sharing of good practice within the training industry can be done administratively without significant additional cost, new legislation, or systems changes, provided subject matter of training remains within the bounds of section 1, annex 1 of the directive as replicated in the TCA.

While there was support from members of the stakeholder forum for the creation of core content, the review finds that this should not be mandated as this would be too prescriptive. Instead, the review recommends that DVSA continue working to address concerns of relevance of course content with a range of stakeholders and subject matter experts to develop suggested core content for training courses.

Conclusion 5: encourage the continued development of suggested core content for courses

Outcome-based learning

In surveys, 31% of training providers felt an assessment would improve driver engagement. However, other stakeholders felt that training arrangements should not include a formal test to assess whether training had been successfully completed.

Some stakeholders suggested that DCPC periodic training was not currently focussed on content learnt. CPT’s formal submission to the review stated that their members (drivers and employers) cite insufficient regard to the actual result of the training as the main reason for dissatisfaction with DCPC.

Outcome-based learning would represent a shift from simply completing a specified amount or duration of training to outcomes, demonstrating that knowledge or skills have been learnt through training.

Outcome-based learning in this review is defined as having a focus on outcomes of training (content learnt) as opposed to time spent in training sessions. This may be achieved through the use of informal assessments following training courses.

Good practice in the delivery of periodic training courses already includes a base assessment and an end of course assessment in the form of a Q&A session or quiz to evidence knowledge transfer/learning outcomes. The review therefore encourages the continuation this good practice and a form of informal assessment to determine comprehension of training materials.

Conclusion 6: encourage the continued re-focus of training from prescriptive course completion to outcome-based learning (i.e., through more informal assessments in courses)

Returning drivers

Stakeholders suggested that the requirement to complete 35 hours periodic training to regain a DCPC qualification was a barrier to returning to the workforce. The balance of opinion was that 35 hours of training before being able to start driving vocationally again was disproportionate and unnecessarily onerous.

The review therefore recommends that changes should be made to reduce the barriers for returning drivers while maintaining safety standards. Further to conclusion one, if a new periodic renewal test was implemented it is proposed that returning drivers could take advantage of this to regain a DCPC entitlement to drive.

Alternatively, there was consensus that some form of ‘refresher’ training would be necessary to give assurance of competency, as legislation governing requirements on drivers may have changed since potential returners had left the industry. There was also discussion about what thresholds returners should need to meet in order to potentially be exempt from the initial 35-hour obligation, as well as what length and format the refresher training should be.

One possible policy option is an initial ‘return to driving’ course to retain assurances about a driver’s knowledge. It would follow that the driver would complete the remainder of any periodic training during the subsequent 5 years of their return to driving. This would require changes in the administrative processes for checking a driver’s entitlement to return, to record that they had completed the relevant training, to issue a DQC and to monitor subsequent completion of training.

For this to be effective, the period in which the DCPC has lapsed should not be so far in the past that driver knowledge is out of date, nor too soon after it has lapsed, to prevent drivers from purposefully letting the qualification slip. It is therefore proposed that this period should be:

• no more than 2 years since DCPC lapsed
• no sooner than 2 months after it lapsed

Conclusion 7: change the training burden on those looking to return to vocational driving by either removing or reducing the requirement to complete training to restore a lapsed qualification

Exemptions, extensions and exceptions

Varying requirements in urgent situations

Stakeholders considered that the ability to vary requirements in response to urgent situations, such as those experienced during the COVID-19 pandemic and the threats this created to supply-chains, would be useful. This was suggested in order to retain the number of eligible drivers in times where it may not be possible or practicable to complete DCPC training. Powers to vary requirements, and the circumstances in which they could apply, are outlined below.

It is proposed that a power is sought to enable regulations to be made to grant an extension of up to 12 months to an existing drivers’ qualification in defined circumstances, such as severe, acute driver labour shortages, if the supply of training is heavily constrained or if certification cannot be issued. The extension lengths would be similar to extensions that were available across Europe in 2020 in the context of the COVID-19 pandemic. This extension would only apply to driving within the UK, unless agreed with other European authorities.

It is also suggested that a power is sought to temporarily exempt a driver from the need to hold a DCPC, in similar circumstances as those applicable to the extension, for up to 3 months. It is proposed to allow drivers with the relevant driving licence, who had previously held a DCPC and had left the profession, to return before completing the usual requirements for returning drivers in the following conditions:

• the vehicle must be a goods or passenger vehicle and exemptions could be targeted towards certain vehicle types

• validity would be for a temporary period of, for example, 3 months, start date to be determined in regulations

• the driver must have held a DCPC qualification in the past, and the date at which a previous entitlement lapsed should be limited. The precise conditions need further consideration and should be informed by consultation

Conclusion 8: introduce the ability to grant short-term extensions to the validity of existing Driver Qualification Cards (DQCs).

Conclusion 9: introduce the ability to grant short-term exemptions from the need to hold a valid DCPC for certain classes of driver who used to hold a DCPC.

Varying outside urgent situations

The review also considered whether all the drivers and driving situations for which DCPC is required should continue to be within a standard DCPC regime, and, if the scope of DCPC is reduced, whether there should be alternative compulsory requirements. This, and the following sections considers the evidence gathered on this.

For drivers surveyed, 43% agreed that other driving activities should be added to those already exempt from DCPC rules, while 57% disagreed.

Some concerns were raised in the stakeholder forum over the detriment to competition in a commercial market that exemptions can create. Under current regulations some exempt operators are able to bid for commercial contacts to carry school children, which some stakeholders considered unfair. They contended that section 19 and 22 permit holders have much lower costs than ‘core’ drivers, as they do not have to comply with the operator licence regime, on top of that, at least some of their drivers do not appear to have vocational licences or hold the DCPC. It was asserted that these drivers should be brought into scope because they are driving vulnerable people. However, in contrast, passenger transport representatives raised concerns about the risk this could pose to the availability of such drivers being able to transport vulnerable groups.

Additionally, in its submission to the review, the Society of Motor Manufacturers and Traders stated, “we would emphasise the need to retain continuing exemptions from DCPC for technicians and other ‘non-professional’ drivers.”

The complexity of the definitions and their interpretations for various categories of exempt driving and drivers is a clear reason to review this position, although no specific proposals have been identified by the review in relation to exemptions currently. It is recommended that further evidence is collected, with a view to considering whether definitions should be made clearer. Also, there should be the ability to change the position for some people driving vehicles outside of the ‘core’ professional lorry and bus driver workforces, if the evidence suggests it would be safe to do so or alternative arrangements more appropriate than DCPC could be put in place instead.

Exemptions for some categories of driver, outside the ‘core’ workforce, were included as part of the UK’s original implementation of the directive in domestic legislation, with widespread stakeholder support. There was consensus at the stakeholder forum that the principal consideration of any potential change to these exemptions must remain road safety. Since original implementation there have been amendments to exemptions, including in 2020 following extra exemptions by the directive. Exemptions have been a continued area of concern over much of the lifetime of DCPC.

The review proposes that primary powers are created to enable amendments to be made to these exemptions. This would allow for given categories of driver, outside the ‘core’ workforce, to be removed, or for new ones to be added.

Conclusion 10: consider further, and potentially consult about, changing the current exemptions for ‘non-core’ professional drivers to ensure they are appropriate.

Payment for DCPC training and drivers time for training

A key aim of this review was to consider whether a presumption that employers pay employees for periodic training costs be reflected in law. This section considers evidence gathered in the review on this.

Current guidance 

DfT guidance issued in 2007, based on the Road Transport (Working Time) Regulations 2005, regarding what constitutes ‘working time’ states in relation to training that ‘working time’ should include: “training that is part of normal work and is part of the commercial operation”.

Review findings 

The costs of undertaking periodic training and the completion of that training outside of normal working hours were considered by some drivers as a barrier to maintaining a DCPC qualification (56% of drivers stated this in surveys).

The forum reported that support provided to drivers to maintain DCPC by employers varied widely. Some operators provide funded in-house training which is included in the drivers’ working hours. Others pay the course fees, and for the drivers’ working time. There were, however, some that pay for neither course fees nor drivers’ working time when attending courses. Although these were believed to be in the minority, it was accepted that given the large number and diffuse nature of operators within the industry, having a clear picture of this is difficult.

As such, surveys conducted as part of this review asked these questions of both operators and drivers. In the PSV sector, generally there was wide-spread consistency of employers paying for training fees and drivers’ time while training.

The Health and Safety Executive (HSE) were approached to clarify the extent to which health and safety legislation placed obligations on employers in respect of payment for DCPC. The HSE position is as follows:

Everyone needs to know how to work safely and without risk to their health, so employers must give workers clear instructions and information as well as adequate training. Health and safety training should take place during working hours and must be free for employees. There are external trainers who could help, but you can often do effective training in-house. Staff will need extra training if you get new equipment, or your working practices change.

Training providers responding to the survey, stated that 86% of organisations who employ drivers pay for their DCPC training. Fewer employers, however, pay their drivers for the time it takes to complete the training (62%).

Of the drivers surveyed, a third reported that they pay for their own training and around the same proportion reported to have their training provided in-house by their employer. Over half (54%) of drivers said their employers paid them for time needed to complete training.

For employers/operators, 77% of responders said they (the employer) pay for training fees, with 18% reporting the driver pays for training fees and 6% stating someone else paid. Payment for training by the operator is reported as more common for large companies (93%) than smaller companies (69%). Just under a quarter (24%) of small operators say drivers pay for their own periodic training fees. A small minority say ‘others’ pay.

With regards to paying for time to complete training, 59% of operators say their organisations pay for all the time needed to complete periodic training, 11% of operators pay for some of the time needed to complete periodic training and 31% of operators pay for none of the time needed to complete periodic training. Again, this proportion is higher for large operators with 81% paying for all the time needed to complete training compared to 53% for small companies.

On the subject of who should pay for training, amongst drivers, 44% thought that the government should, 12% thought employees should pay, while 41% indicated that employers should pay.

For operators, 42% thought the government should pay for drivers’ periodic training, 22% thought employees should pay, 32% thought employers should pay, and 5% thought another body or person should pay for drivers’ periodic training. Large operators are more likely to say that the employer should pay for DCPC training compared to smaller operators who are more likely to say that the government should pay. A minority of large operators (16%) think that the employees should be responsible for paying for their DCPC training.

Of training providers surveyed, slightly over half (52%) of the respondents, felt the employer should pay for this training, with 28% stating the employee should pay and 21% stating the government should.

Stakeholders agreed that to attract and retain staff, it was good practice for employers to cover the costs of DCPC training for their employees. They suggested that those employers who did this gained benefits from having competent, well-trained drivers. Survey data also demonstrates that whilst many employers do pay for drivers’ course fees, the majority of small businesses do not.

This is important, in terms of both the financial burden it places on such drivers, but also as an indication of the financial implications which would be placed upon small businesses, who operate with very small profit margins if legislation was made in relation to who should pay.

Furthermore, the view of the stakeholder forum was that there was wide variety in how the position of payment is interpreted across the sector. This was seen to be contingent upon whether a driver is choosing to do DCPC periodic training of their own volition, rather than at their employer’s behest. Their position is that when drivers arrange to attend training during a rest period or day off it is not treated as working time. They also said that if an employer organises non-compulsory training for drivers which takes place outside of a driver’s normal working periods and where participation is voluntary, this will not count as working time.

The existence of this variation is supported by survey evidence. 40% of drivers working for small companies reported that employers pay for their time spent attending DCPC courses as working time, whereas this was 77% for those employed by large operators.

The review concludes that the existing guidance from HSE provides the right type of indication of how DCPC should be treated. It allows for choices to be made by employers and employees. It also provides guidance that there will often be circumstances when DCPC training should be paid by employers and counted as working time.

Other matters

International driving and recognition

Currently, requirements for obtaining DCPC in the EU and the UK are the same and many features of DCPC are included as agreed through requirements in the TCA. Without the renegotiation of international agreements, the conclusions of the review for regulatory change can be applied to GB and (with the agreement of the Northern Ireland authorities) NI drivers when operating within the UK only.

This means separate domestic and international DCPC qualifications, with UK-based drivers having to follow the current arrangements for DCPC, in order to drive in Europe. The review proposes that implementing legislation provides for the possibility of 2 qualifications and only applying changes to international driving when and if they are consistent with relevant international agreements. This includes allowing for the eventuality that current agreements are modified in the future. In all cases a driver with a TCA compliant DCPC obtained in the UK would be able to do any type of driving requiring a DCPC in the UK. A driver who obtained a reformed model UK DCPC recognised only domestically would, if they chose to drive internationally when a DCPC was required, have to switch to a TCA compliant DCPC.

From the drivers surveyed on the question of territorial extent of their driving, 88% drove only in GB (England, Scotland, and Wales), 4% drove in GB and Northern Ireland, 5% drove in the UK and EU member states, whilst 2% drove in the UK and Europe including non-EU member states. This strongly implies a clear value in implementing changes for domestic drivers even if they cannot apply to drivers working internationally.

The review did not consider the implications of the EU’s current position of not recognising DCPCs issued in the UK for drivers who move to work for operators based in the EU. The UK has continued to recognise DCPCs obtained anywhere within the EU. Following evidence collected as part of this review, it is recommended this should remain the case. This means drivers based in the UK who obtained their DCPC abroad avoid having to reacquire DCPCs. This is despite the asymmetry of UK-gained DCPC not being recognised by the EU for drivers of EU-based operators.

This asymmetry may be subject to change in the future for which further evidence or consultation will be collected.

Driver qualification card

Stakeholder engagement queried whether the need for a physical DQC should remain, suggesting an electronic version may be better, lowering the number of items drivers have to carry day to day. Currently, the TCA and the EU Directive (2003/59/EC) does not allow this for UK drivers in the EU. However, for domestic only drivers with a reformed model DCPC qualification, the UK could legislate itself to make these changes, including electronic forms of evidencing.

Electronic forms of evidencing will be considered as part of those developments, although extensive work would need to be undertaken by the Driver and Vehicle Licencing Agency (DVLA) to explore further the integration of DCPC accreditation and licence records.

Conclusion

This report has provided a background to DCPC, including the reasons for its establishment, and the mechanisms by which it was introduced. It has outlined a body of supporting evidence, both existing and that collected as part of the recent review process, and the extensive stakeholder engagement that was undertaken.

Following this, the report summarises 10 conclusions for change. These are stated again below, indicating where legislative change is needed and changes that can be made without the need for legislation.

Conclusion 1: DCPC should be retained, but drivers should have the choice between completing reformed DCPC training or a formal pass/fail test to renew a qualification or re-join the sector (requires legislative change).

Conclusion 2: improvements could be made to the way in which training is delivered and to the quality of training provided (requires legislative change).

Conclusion 3: give more flexibility in training requirements by removing the requirement for courses to be a minimum of 7 hours and the requirement that when courses are split that these must be completed across 2 consecutive days (requires legislative change)

Conclusion 4: provide flexibility to the operational rigidity around the way e-learning modules are completed (requires legislative change).

Conclusion 5: encourage the continued development of suggested core content for courses (does not require legislative change).

Conclusion 6: encourage the continued re-focus of training from prescriptive course completion to outcome-based learning (i.e., use more informal assessments in courses) (does not require legislative change).

Conclusion 7: change the training burden on those looking to return to vocational driving by either removing or reducing the requirement to complete training to restore a lapsed qualification (requires legislative change).

Conclusion 8: introduce the capability to grant short-term extensions to the validity of existing Driver Qualification Cards (DQCs), which show completion of DCPC training (requires legislative change).

Conclusion 9:  introduce the capability to grant short-term exemptions from the need to hold a valid DQC for certain classifications of driver (requires legislative change).

Conclusion 10: consider further and potentially consult about changing the current exemptions for ‘non-core’ professional drivers to ensure they are appropriate (consideration does not require legislative change, but implementation would).

Appendix 1: previous DCPC reviews:

Consultation on the implementation of Directive 2003/59/EC

In 2013, the European Commission carried out a consultation on how well Directive 2003/59/EC achieved its policy objectives. The Commission asked for feedback about:

a. the general relevance, effectiveness, and impact of DCPC

b. the scope of the requirements and exemptions

c. the structure and content of the training, including the subjects covered

That consultation drew on feedback from 1,318 respondents from a range of sectors including the ‘road haulage’ and ‘bus and coach’ sectors.

To inform the UK government’s official response DVSA consulted widely with industry stakeholders. Over 200 interested parties in the UK responded directly to the commission’s consultation (more than half of all responses they received).

The government’s official response recognised the importance, and supported the promotion, of education and training for professional drivers. It concluded that the directive provided a useful framework through which that training could be provided.

The principal observations about how DCPC had been operating in the UK and in response to the specific points covered by the Commission’s review were:

• The alignment of the initial qualification test route for new drivers of large vehicles to the licence acquisition tests had worked well. It ensured pre-test learning covered the appropriate topics, as well as the knowledge and skills required by the driving test. DVSA recommended retaining this.

• DVSA wished to retain the flexibility for individual drivers to plan the timing and content of their periodic training. DVSA expressed concern that a more prescribed training regime and uniform syllabus defined at a European level could undermine standards in UK.

• DVSA supported greater flexibility to be applied to enable periodic training courses to be delivered in periods less than 7 hours. DVSA also sought clarification of whether an assessment of learning outcomes could be included within a training course but were not supportive of a post-training testing regime.

• DVSA requested that the scope of the directive and the exemptions be further clarified.

• DVSA were not supportive of the proposal to align DCPC exemptions with those provided under Regulation 561/2006/EC, as this would take a large number of drivers out of scope of DCPC, including many drivers of local service buses. Such an arrangement was considered to be counter-productive and could undermine the wider application of DCPC

The Commission’s evaluation concluded that the directive had been implemented without major problems. It had improved labour mobility and contributed to the free movement of drivers. The evaluation also confirmed that the directive had made an effective contribution to its primary objective of ensuring road safety.

The evaluation also identified shortcomings that are hindering the effectiveness and consistency of the legal framework and undermining the original objectives of the directive. Amendments were therefore brought forward to address issues of:

• difficulties for drivers to obtain recognition of completed/partially completed training undergone in another Member State
• content of the training only partially relevant for drivers’ needs
• difficulties and legal uncertainties in the interpretation of exemptions
• inconsistencies in minimum age requirements between the directive on the training of professional drivers (2003/59/EC) and the directive on driving licences (2006/126/EC)
• ambiguity regarding the possibility to combine professional driver training with other training courses required under EU law, and
• lack of clarity regarding the use of information communications technology (ICT) in training courses.

2015 GB post implementation review

In 2015, the government undertook a post-implementation review (PIR) of the DCPC legislation to assess how it had been delivered and what effect it had. The PIR was completed because of amendments to DCPC legislation introduced in 2011 but covers the full set of regulations as introduced in 2007. It therefore focuses on the breadth of the policy area and a range of evidence was considered such as, but not limited to how DCPC has:

• impacted driver training and skills
• affected drivers and the driver labour market
• affected road safety
• affected businesses

Additionally, the PIR used a range of sources to obtain this information such as literature reviews, stakeholder consultation, secondary data analysis and break-even analysis.

The review concluded that:

• there is clear evidence that drivers are undertaking continuous professional training that should contribute to their skill levels
• there is some indication that earnings in the affected occupations have outperformed the broader occupational class since the introduction of the DCPC, but this does not appear to have been accompanied by increased inflows to the occupations
• safety outcomes have improved, but improvement has been seen across the board and safety trends were positive well before the introduction of the DCPC
• on balance, firms’ views of the DCPC are more positive than negative but there is limited evidence on precisely how they have been affected, something that is also true of competition across the EU
• there may have been some unintended consequences from the periodic training requirement which may have dissuaded existing licence holders and drivers near to retirement with expired acquired rights from obtaining a Driver Qualification Card (DQC)

Based on the available evidence, coupled with the continuing validity of the objectives of the regulations, the review recommended that the regulations remain in place.

The department estimated that DCPC had imposed an average annual cost of £149 million on business.

Appendix 2: stakeholder engagement

Stakeholder engagement - surveys

In conjunction with the stakeholder engagement, several surveys were also conducted as part of this review to capture the important views of employers/operators, drivers, and training providers.

For drivers, the surveys were distributed to Road Transport Industry Training Board (RTITB) members. Unless stated otherwise, mentions of ‘driver surveys’ refer to that of RTITB members (approximately 1,000 respondents). The vast majority of drivers who responded to the survey were male (97%). The main age group was between 45 – 64, with the largest category of licence holders being C+E. Approximately 72% drive HGVs and 28% PSVs. The size of organisations surveyed was split between 38% large, 34% medium, and 27% small companies with 14% being self-employed. 84% of drivers have a current DQC, more than 50% of them take 1 course every year, and 35% take courses when they are available.

For employers’/operators’ views, surveys were distributed to:

• Logistics UK and CPT members
• licensed operators via the Office of the Traffic Commissioner (OTC)
• Earned Recognition members
• Driver Shortage Ministerial Round Table attendees

There were approximately 4,100 responses to this survey. Responses reported for individual questions may vary where questions have not been answered by all respondents. This survey is not likely to be a representative sample of operators as the participants were self-selecting. Thus, our focus in sub-group analysis is commentary on the similarities and differences between different groups.

In the case of training providers, the DVSA Customer Insight team conducted research with vocational training providers asking them for their views on the future of DCPC. There were 607 responses. Responses to individual questions may vary if not answered by the participants. The research was conducted via online survey distributed via DVSA communications channels.

Where there are differences between survey responses between these groups, there could be bias in what respondents reported, for example drivers may understate how often they pay for DCPC courses, and operators may overstate this. The findings of this research will be reviewed, as part of the overall vocational driver shortage work, to identify if there are ways in which we can make it easier to comply with the mandatory training requirements and improve its efficiency.

2021 DCPC review survey questions

Operators

• How many vehicles does your company operate?
• Your organisation is best described as working in which sector of transport?
• Who pays for your drivers periodic training?
• Does your organisation pay drivers for all/some/none of the time needed to complete periodic training?
• Who do you think should be responsible for paying for the DCPC training?
• Which considerations are most important in determining whether drivers will renew their DCPC qualification?
• What measures would encourage drivers to maintain their DCPC qualification?
• Do you think that the training could be delivered, with no detriment to road safety, in fewer hours than the current requirement of 35 hours over 5 years?
• Appropriate training amounts - How do you feel training should be structured?
• How long should periodic DCPC modules be?
• Would it be beneficial if DCPC could be completed via shorter training modules totalling 35 hours?
• Should future training courses include e-learning?
• Should all courses include e-learning?
• What are the main barriers to training being delivered via e-learning?
• What is the most effective method of training?
• How should periodic training be organised in the future?
• Should any training topics be mandated for newly qualified vocational drivers?
• Should training to be mandated for new drivers, if so which training?
• Should any training topics be mandated for existing vocational drivers if so what training?

Drivers

• What gender do you identify as?
• Which age group do you belong to?
• Which categories of vocational driving license do you hold?
• Which categories of vehicle do you currently drive as part of your job?
• Do you drive in GB (Scotland, England, and Wales) only, in GB and NI (UK), in UK and EU Member states, in UK and Europe including non-EU member states?
• Do you currently have a DQC? If yes, how often do you undertake a periodic training course?
• Are you currently employed as an HGV or PSV driver? If yes, is your employer Large company (> 300 vehicles), Medium sized (between 20 and 300 vehicles) or Small (<20 vehicles)
• Are you currently self-employed?
• Who organises your periodic training?
• Who pays for your periodic training?
• Does your employer pay you for the time needed to complete your DQC periodic training?
• Who do you think should be responsible for paying for the DCPC training?
• Which considerations are most important in determining whether drivers will renew their DCPC qualification?
• What measures would encourage drivers to maintain their DCPC qualification?
• How long should periodic training courses be?
• Should any future training courses include an option for e-learning learning?
• What would be the main barrier to training delivered via e-learning?
• Would e-learning training available in monthly modules be useful?
• Do you think on the job learning/experience should count towards training time hours (e.g., CPD)?
• What is your preference for how training should be delivered?
• Should any training topics be mandated for newly qualified vocational drivers?
• Should any training topics be mandated for returning vocational drivers?

Training Providers

• What is the size of your organisation?
• Do you employ HGV and/or PCV drivers?
• Do you pay for your drivers’ DCPC periodic training?
• Do you pay the drivers for the time taken to complete DCPC periodic training?
• Who do you think should be responsible for paying for the DCPC periodic training?
• Which considerations are most important in determining whether drivers will renew their DCPC qualification?
• What measures would encourage drivers to maintain their DCPC qualification?
• How long should DCPC periodic training courses be? (Drivers would still need to complete a total of 35 hours in 5 years to renew a DQC)
• Would it be useful if a DCPC qualification could be completed via shorter training modules totalling 35 hours?
• Please rank the following training methods (detailed) in order of effectiveness (1= Most Effective - 5= Least effective)
• Should future training courses include e-learning?
• What are the main barriers to DCPC periodic training being delivered via e-learning? (select all that apply)
• How should DCPC periodic training be organised in the future?
• Should any DCPC periodic training subjects be mandated for newly qualified vocational drivers
• Should any DCPC periodic training subjects be mandated for existing vocational drivers?

Stakeholder written submissions

Engagement took place over 2 and a half months from mid-November 2021 to January 2022. Evidence was sought from:

• drivers’ representatives via unions
• employers
• training organisations
• road safety groups
• officials from the devolved administrations

Evidence was obtained in written submissions, detailed below, and discussions in stakeholder forums.

Four evidence-gathering stakeholder forums took place virtually. These contained representatives from:

• The Confederation of Passenger Transport UK (CPT)
• Logistics UK
• Road Transport Industry Training Board (RTITB)
• Office of the Traffic Commissioner (OTC)
• Transport Scotland
• Northern Ireland’s Driver and Vehicle Agency (DVA)
• Welsh Government; Association of Local Bus Managers (ALBUM)
• Unite the Union; Parliamentary Advisory Council for Transport Safety (PACTS)
• National Express
• Wincanton
• DPD (UK)
• DHL

The review team would like to thank all stakeholders for their valued responses.

Membership organisations involved in the review were also asked to seek views from their members. Finally, the review also engaged with the Commercial Vehicle Road Safety Forum (CVRSF). CVRSF includes representation from industry, public sector bodies, including the Health and Safety Executive (HSE), and the Traffic Commissioners.

Logistics UK

Logistics UK supports the Driver CPC regime. Members have consistently reported that they value the flexibility the current framework offers to allow them to train their drivers with the content they need to keep their operations safe and effective.

Members oppose the inclusion of mandatory content, but support efforts to encourage drivers and employers to identify worthwhile content which improves road safety. Members are concerned about the effectiveness of the quality control system, with apparent increases in bureaucracy not yielding commensurate improvements in standards – Logistics UK members regret that cowboy training providers continue to be able to operate in the DCPC marketplace.

Greater flexibility should be offered in the delivery of periodic training, including smaller training units to be delivered and increased use of e-learning, subject to identity and quality controls.

The definition of “a day of learning” should be reviewed subject to consultation with experts in adult learning. The DQC should be abolished in favour of enforcement at the roadside from the electronic record. Pre-pandemic plans to migrate the driver training record to the driver licensing record should be re-started and developed to allow the record to offer a meaningful description of training undertaken.

Department of Infrastructure, NI Government

The Department for Infrastructure consider that continued periodic training for professional lorry, bus and coach drivers remains essential. In the wider context all stakeholders agree that since DCPC was introduced, driving lorries, buses and coaches has become more professional and safer with companies seeing savings through reduced accidents, insurance liability and the health and safety of drivers. In the Northern Ireland context DCPC remains essential for continued alignment with European standards and access to EU member states for drivers from Northern Ireland.

Whilst employers should pay employees for periodic training and working time, The Department for Infrastructure do not have a position on whether legislation should require it. This is 1 aspect of terms and conditions which should however be highlighted given the current driver shortage. Employers offering time and paying the costs of training should be seen to be more desirable to work for and this could be reinforced through a communications strategy rather than through legislation.

As previously stated, the current alignment with European standards remains essential to the coach and goods vehicle sector in Northern Ireland. Any reduction in coverage would need to be carefully considered with this European angle. Given the land border between Northern Ireland and the Republic of Ireland, small changes may have unforeseen consequences for industry sectors in Northern Ireland.

The Department for Infrastructure recognises that there are areas within the current DCPC regime relating to the specifics of training and delivery which can be amended to make DCPC safer and more effective to deliver but cannot comment until proposals are put forward. The Department does however agree that EU qualifications should continue to be recognised.

Traffic Commissioners for GB

Traffic commissioners recognise the benefits that DCPC has brought, raising standards within the industry and mitigating risks to road safety and fair competition. They support the need to review the current framework to allow greater flexibility over the provision of training.

In the past year, traffic commissioners have encouraged operators and drivers to develop the skills to manage the risks in their own businesses. Operators know their businesses best. Traffic commissioners expect operators to proactively manage their own risks to head off any potential problems. Doing so would avoid the need for many of the public inquiries and driver conduct hearings undertaken.

Operators who find deficiencies in their operations need to draw on good practice and change their control procedures, before they attract regulatory action. Although the challenge of fees is appreciated, it is thought that many operators and drivers would benefit more from shorter training provision and that more focus can be placed on certain topics.

Government for Wales

Drivers of heavy goods and public service vehicles should be subject to periodic training to ensure a consistency of standard and understanding of safety and other compliance requirements. From a good practice perspective, 1 module per year should be taken to ensure that all modules are completed sufficiently within the 5-year period.

Safety is paramount and as such it is important that new drivers cover as a minimum, modules relating to driver hours regulations and general processes of compliance and good practice in ensuring safety at all times. New drivers should have a degree of understanding about the Traffic Commissioner’s role and function and be made aware of the seriousness and repercussions of non-compliance and how this will impact on their own vocational licence as well as potentially the operating licence of their employer. Training provision of a minimum of 7 hours per module may be counterproductive in ensuring the concentration span and buy-in of those attending the training; shorter training sessions may also be more advantageous.

A national curriculum of core subject areas should be considered for consistency delivered within a wider UK training programme. There needs to be equality and consistency in the core training provided to ensure that all subject areas are fully covered especially in case of changes to law and regulations around driver hours or compliance requirements and procedures. There is a danger and risk of inconsistency of training as well as course content between EU requirements and that of the UK. It may be prudent to consider that basic core modules are undertaken initially around drivers’ hours and compliance within the UK and to consider how other modules completed in the EU buys additional credit towards the statutory length of modules in the UK.

Confederation of Passenger Transport (CPT)

CPT believes that DCPC plays an important role in improving road safety, but that the current system of training can be improved to make it more relevant to the work undertaken by individual drivers and their particular circumstances, the current DCPC rules as applied in the UK are too rigid, and as such, do not, in most cases take into account the specific training needs of the driver.

CPT believe that much more flexibility should be considered and possibly introduced into the DCPC regime that will allow those employers who deliver exemplary continuous professional development training to their drivers to continue to do so, but also allow other trainers to develop and deliver training in different ways that may produce better outcomes for other drivers. The focus on training being measured only in hours spent in a classroom, with no regard to the actual result of the training is the main reason why there is widespread dissatisfaction expressed by both drivers and employers towards both the purpose and usefulness of DCPC.

E-learning offers the opportunity to measure and deliver training in a different way, and CPT feel that the amount of e-learning allowed during a 5-year cycle should be increased. CPT see no reason for the DCPC to be removed or diluted in any way and will continue to support the Government review to ensure that the regime continues to promote the continuous professional development of drivers and continues to improve road safety for all road users.

The Parliamentary Advisory Council for Transport Safety (PACTS)

PACTS was pleased to be invited to take part in the Driver Certificate of Professional Competence (DCPC) Stakeholder Forum Meetings. The DCPC review was established at least partly in light of the shortage of HGV and (to a lesser extent) public service vehicle (PSV) drivers. PACTS was therefore concerned that this might be used as a reason for scrapping or downgrading DCPC requirements.

Forum members were clear that DCPC is not a significant obstacle to driver recruitment or retention. The real problems are working conditions, work-life balance, etc. PACTS agree with other forum members that DCPC is valuable, and PACTS oppose any reduction in hours. There may be opportunities to improve flexibility or quality. No doubt some drivers would value help with costs.

PACTS have also raised concerns about the safety of vans and van drivers. The regulations for van drivers are far below those for professional HGV and PSV drivers and van vehicle safety standards below those for HGVs and cars. PACTS’s report, ‘What kills most on the roads?’ highlights high the fatality involvement rate of vans.

Wincanton

The main goal of DCPC is to ensure drivers are attending training on a regular basis and receiving updated material to keep them safe on the road. Wincanton’s view is that DCPC should be accumulative, where candidates can register approved training hours or training modules.

This model will allow training to be modular, where instead of having to commit to 1 class of 7 hours at a time, a driver can do short e-learning training, practical training, classroom training and distance learning training at different days and times that will count towards their DCPC.

The use of e-learning should be further expanded to allow short refresher trainings on specific topics, Wincanton has the plan to create bite-size e-learning modules to refresh the knowledge on topics such as driver hours, bridge strikes, key safety systems of work (e.g. coupling and uncoupling, safe loading and unloading, etc), and other refresher training according to operational needs. The first 3 e-learning modules are due to be launched in Q1 2022, subject to meeting IT requirements.

Wincanton strongly recommends reviewing the controls in place by DVSA/Joint Approvals Unit for Periodic Training (JAUPT) to ensure all approved training centres adhere to strict quality control measures and systems when delivering DCPC training.

Last year Wincanton saw the introduction of new rules where evidence of relevant qualifications and experience had to be submitted for every trainer in order to renew the application of a training centre; Wincanton has invested in the qualification of driver trainers and has put controls in place to evidence this in all approved trainers to ensure the standards are maintained, however comments from the members of the DCPC forum review, as well as other council meeting members, have given examples of training centres delivering poor quality training and still continuing to have their centre approved by JAUPT/DVSA.

This has not been discussed in the previous forums, but as a recommendation, can government incorporate a robust accreditation system similar to The Royal Society for the Prevention of Accidents that demonstrate that their courses adhere to an accepted standard when seeking to be registered with JAUPT/DVSA to deliver DCPC training.

National Express

We at National Express (NE) believe the consultation was a very worthwhile process. Whilst the scope of the debate was wide-ranging, NE would like to address the following key points for consideration. The current set up for DCPC course delivery requires a consolidation to be completed as part of the objectives which NE include in all our courses.

It would not be our preference for DCPC courses to have formal tests / assessments in order to achieve accreditation as this would be difficult to govern and also imply that a delegate is no longer competent to carry out their role regarding that specific subject. The consolidation(s) NE use do confirm knowledge and understanding of the subject and highlight any shortcomings should they arise and revisit that subject matter to ensure the required standard is reached.

With regards to shorter courses, it is a preference that courses are made up of modules which NE were able to deliver in a variety of ways (i.e. e-learning, face to face, practical drives etc) that can add up to 7 hours to be taken at various stages throughout a year and subsequently 35 hours over a 5 year period. The 3 and a half hour modules that must be completed within 48 hours or 7 hours in 1 hit does not allow flexibility or the effective use of blended learning.

The DCPC syllabus allows organisations like NE to cover all key content that a bus or coach driver needs in order to carry out the role effectively. NE do not agree that training should be mandated on particular subjects as it would remove flexibility for businesses to identify what subjects they would like to cover at any particular point. As an example, NE identified an issue with low-speed collisions and were able to design a DCPC course for all drivers which focussed on this particular topic. This is helping drivers improve their skills and competence as well as delivering a business benefit.

Association of Local Bus Managers (ALBUM):

ALBUM recognises the importance of the driver CPC but feels there are necessary improvements to the guidelines for delivery. Album believe more flexibility is required in how the training time is scheduled and question whether 35 hours training over 5 years is necessary, especially in the case of PCV drivers returning to the industry after a period away in a different sector.

ALBUM do support the concept of guidance being provide to direct training providers to cover some core subjects each year. The most important consideration currently is the backlog of driver CPC training following the COVID-19 pandemic and urge DfT to allow as a matter of urgency a one-year extension to DQC cards in response to this crisis.

Road Transport Industry Training Board (RTITB):

RTITB believes that improving the flexibility of, and integrating e-learning into, driver CPC learning delivery would be effective in increasing driver retention. Improved flexibility (requested by 50% of the drivers RTITB surveyed) can be achieved by removing minimum course durations and by introducing e-learning so that drivers can access and complete learning in blocks of time that fit around their schedules rather than taking them off the road for hours at a time.

Drivers should be able to accrue the required 35 hours across the 5-year period in learning modules and courses of any duration. By accessing e-learning and blending it with traditional classroom sessions we can improve knowledge retention and therefore road safety.

Industry research and our experience show RTITB that learning is evolving, and that e-learning (accessible on mobile phones, tablets, and computers) plays a crucial role in improving accessibility and can deliver a 50% higher engagement rate. Crucially, 69% of the drivers RTITB surveyed wanted to see e-learning as an option for Driver CPC (including 57% of those aged 55 and over).

As well as benefiting drivers, e-learning will reduce the time and costs associated with Driver CPC course development because it is 3 times faster and more cost effective to develop than traditional courses. (TalentCards, 2014).