Memorandum from Road Haulage Association
Limited
NATIONAL AUDIT OFFICE REPORT: VEHICLE AND
OPERATOR SERVICES AGENCY: ENFORCEMENT OF REGULATIONS ON COMMERCIAL
VEHICLES
I note the NAO's report on VOSA, published a
week ago. While agreeing with much of the content, I would highlight
several points of concern.
The Road Haulage Association represents, in
the main, companies whose main business is providing road haulage
and related services. Our members range from small to very large
firms, operate around 100,000 trucks and provide much of the £26
million a year that makes up the bulk of VOSA's enforcement budget.
The Association works to improve standards in the industry. It
provides extensive advice and training (Appendix 1), not least
on compliance issues and will shortly launch a strong campaign
aimed at improving further the HGV driving culture in the UK.
ENFORCEMENT
The report underplays the significance of operator
visits, which have been neglected as VOSA has pursued the roadside
check targets set by the Department. An increase in visits, with
a sharpening of the enforcement edge, is needed to increase deterrence
and detection of the worst operators. Operator visits should be
renamed operator or depot checks, to align them with roadside
checks.
EDUCATION AND
TRAINING
The report makes several references to education.
It notes that VOSA "does not have a comprehensive education
programme for operators or drivers" (Summary 8). It recommends
that VOSA "should use the opportunity of its enforcement
activities to educate drivers and operators" and says there
should be "an educational element" to all operator visits
(Recommendation 14).
It is unclear exactly what is envisaged. We
are concerned that enforcement funds may be diluted by a build-up
of education activity. Many organisations can educate but only
VOSA can enforce (apart from the police); and there is no greater
incentive to get educated—or to comply with regulations
one knows but ignores—than strong enforcement.
It would be a positive step if VOSA inspectors
took the opportunity of operator/depot checks to make operators
aware of the education and training options available—of
which there are many, from the RHA, other trade bodies and independent
trainers. In this way, VOSA would be working with the private
sector, rather than risk duplicating services that are already
offered.
The report finds that the Department should
"encourage operators to develop further systematic and long-term
driver training programmes to improve performance and behaviour
on the road" (Recommendation 14b). This opportunity is already
provided by the Driver CPC. Training providers are already assisting
operators in identifying the key skills needed to improve their
business and providing suitable training packages.
These comments mirror points made to the Department
as it prepares its new compliance strategy. I hope that they are
of use to the Committee.
18 January 2010
APPENDIX 1
RHA ADVICE AND
TRAINING
The RHA delivers compliance advice to members
through: free-to-use regional help desks; specialist advisors
(for example on hazardous goods); area managers who undertake
paid-for compliance audits; and vehicle compliance inspections.
RHA Training has a full range of courses for
managers and drivers available to all operators. This includes
an industry-leading, five-day "train the trainer" course
that has been used by many fleets to form the basis of new in-house
driver training aligned to the new requirement for continuous
professional development for drivers, the Driver CPC. In the past
year, more than 500 trainers, mostly from SMEs, have successfully
completed the course.
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