Changes to the HGV & PSV Test Regime for Earned Recognition Operators

In March 2021 the Government began a review into the processes for commercial vehicle testing to look at ways it could improve the regime for operators whilst still maintaining high safety standards for any vehicle used commercially on the UK’s roads.

The outcome to that review was published earlier this year with four proposed options for changing the testing regime for operators who hold the DVSA’s Earned Recognition status.  Click here to read the full document.

The DVSA earned recognition for vehicle operators is a voluntary scheme within the UK, for PSV & HGV operators to “prove” that they are meeting both the driver and vehicle standards required by the regulatory regime. In return for sharing information about the maintenance and performance of the vehicles the company owns, with them, the DVSA “promises” to be less likely to stop your vehicles for inspections.  When it works, Earned Recognition status saves “ER” operators time and money by keeping your vehicles on the road and giving the DVSA confidence that Earned Recognition vehicles are safe and compliant.

The four proposed options were as follows:

• Option 1: Increasing the time between tests for earned recognition operators.
  • Remove the requirement for ER operators to have vehicles tested every 12 months.
• Option 2: Delegated testing
  • Allow ER operators to test their own vehicles and trailers.
• Option 3: Reduced test content
  • Reduce test content, such a removing some items that are covered in routine inspections, or in the longer term, those that can be effectively monitored by in-vehicle systems.
• Option 4: Improved service provision
  • The DVSA could focus its service improvement on ER operators, for example, by giving complete or greater guarantee of requested authorised test facility slots and greater flexibility around days and hours worked to match maintenance requirements.

What Responses did the Department for Transport Received?

The Department for Transport received 49 formal responses from operators and six additional written submissions, and of those respondents a total of 59% of those who did respond stated that the current testing regime for earned recognition operators should be altered.

The most popular option for changes to the annual testing regime was the option to delegate testing (option 2), which made up 42% of the overall vote. Second came the option of increasing the time between tests for ER operators (option one) with 34% of the vote.   Options three and four garnered just 12% each and as a result, both have since been dropped from further consideration by the Department for Transport.

Commenting on the review outcome, The Department for Transport has stated that increasing the time between tests would help reduce “unproductive time whilst awaiting tests” and that there was “moderate” support for this option among those who had responded, but that there was a strong view that changing the frequency of vehicle testing could increase road safety risks if not “supervised properly and without adequate safeguards”.

The responses on Option 2 – delegating of testing were generally positive.  This option would maintain the volume of data feeding into the ER scheme, but it would mean that it is not under the control of the DVSA and may not provide an independent review of maintenance undertaken by the operator.  They go on to state that for many ER operators, there would only be a benefit with this option if “sub-delegating” of testing by ER operators to 3^rd parties was possible, which would just add yet more complexity into the testing regime.

 Options 1 and 2 have the benefits of increasing choice for ER operators and allowing more opportunities to reduce unproductive time awaiting tests.  They also help with scheduling issues but set against these possible benefits are the concerns around lessening or possibly removing roadworthiness data and also a real worry about increasing road safety risks.

Some “non-ER” operators argued that all vehicles should be subject to the same testing regime and that the Earned Recognition Scheme for operators already has many benefits – chief amongst these the promise not to be pulled over by the DVSA for roadside inspections - testing of vehicles should not be one of them.

Next Steps for the Review?

The Department for Transport is suggesting further work should be done on Option One (increasing time between tests for ER Operators) and that further assessment on the following areas should be undertaken:

• Whether lessening testing frequency will result in a reduction in in-use condition of vehicles between those tests and whether changes to the ER scheme could mitigate any such risk,
• How to ensure ER continues to have sufficient data to be effective in identifying highly compliant operators with safe operating practices,
• Whether ER should be put on a statutory footing in association with any test changes,
• Whether to require a test to have been completed within the last year for vehicles used in international circulation,
• The position of vehicles (tractors and trailers) which move between ER and non-ER operators,
• The position of vehicles of operators who lose their ER status, and
• The procedures to implement the option for both HGVs and PSVs.

If you have any questions regarding the changes discussed in this article, or questions about your eligibility for the earned recognition operator scheme, or vehicle maintenance in general, then please click here to send us an email, or call us directly on 01279 818280. We are here to help.

(c) Richard Pelly, May 2024