Haulage Permits and Trailer Registration Bill

Written evidence submitted by PC Daniel Cox, Avon and Somerset Police (HPTRB05)

Haulage Permits and Trailer Registration (LORDS) Bill


I am police constable Daniel Cox of the Avon and Somerset constabulary; I am the lead for the UK within Roads Policing, with regard to untested trailers.

I am a qualified mechanic and have experience of using trailers within the commercial sector prior to joining the police in 1997. For the past 15yrs I have been within Roads Policing, attended serious collisions. I have been trained within the police as a Forensic Vehicle examiner. I am responsible for identifying and removing defective vehicles and trailers from the road. Also examining vehicles involved in serious and fatal road traffic collisions. In some cases attended court as an expert witness for the prosecution and presenting such evidence.

I have been very proactive with regard to trailers throughout my service. I have set up a training course for colleagues and the DVSA to access nationally. I have travelled throughout the UK giving presentations to the public to improve education. I have also had many articles published with regard to road safety and the use of vehicles and trailers on the road, which are untested. I believe I have a unique view, stopping trailers on the road each day and interacting with the users and trailers dealers.

I am on the Towing Working Group and have worked closely with Karin SMYTH MP to highlight the serious issues with the trailer market.

1. My interest with regard to this enquiry relates to the roadworthiness of trailers used in the UK, which have no MOT testing and are unregistered. It should come as no surprise that nearly every untested trailer I stop has defects, in most cases serious enough to remove the trailer from the road. It is not common for the police to stop trailers, due to limited resources and a lack of understanding. Hence the course Avon and Somerset Police have built. The officers are very confident after the course and are now seeing what I have seen for many years.

2. Unless a collision has serious or fatal injuries, any trailer involvement goes unrecorded. It is common to hear a trailer becoming detached, the road is cleared and we move on, the cause would not be discovered. The same circumstances on a different day, it could well be a fatality. This we cannot predict, but we could at least be removing the most likely issues which may lead to a serious collision.

3. It is common for me to find defective trailers that are only a year old. Most trailer users have no understanding of how the various systems work on a trailer, so they don’t understand the necessity to check. They are very surprised to find it takes only a few minutes to check over a trailer, with no real expertise required provided you are trained correctly. The cost of a service is very low compared to a car, so it makes no sense for so many trailers to be so defective. After many years of enforcement within our constabulary, I have learnt that education does not work on those we actually need to reach. I paid a visit to a trailer dealership last week; I inspected their hire trailer whilst waiting. The brakes were defective and it was for carrying cars! In society there will always be the caring compliant users, such as the first owner caravan market. This is not representative of the trailer market.

4. I have been surprised by some of the remarks made within the Lords and Parliament. It is clear that people are misinformed, if people saw the facts for themselves, they would have the passion and drive that Karin SMYTH MP has shown. Karin is very well informed and provides the confidence for change. The representatives of the houses are seeking to avoid changes, in the name of unnecessary burden on users or government. Such as business users only to be tested! Last week I stopped a car, towing a car transporter trailer on the motorway network. The trailer had no brakes and the driver knew this. He is not a business user; the consequences are the same for anyone interacting with him. The most defective trailers I have found have come from the farming community. They are carrying livestock large distances on our motorways, to regional markets. However it is also true of horse trailers and plant carrying trailers. Last year I dealt with a 3.5 tonne catering trailer which had detached and gone along the motorway on its own and up the embankment!

5. I understand we do not want huge cost or burden, perhaps when we have true statistics we will be informed enough; to measure how often testing should be done to accommodate this. I tow a horse trailer several times a week and a large caravan several times a year. I personally do not want it to be too costly, but most of the trailers on the road are defective, approximately 10% are roadworthy. The increase in road safety due to testing should bring insurance down, this could offset personal costs. The dealers are more than happy to carry out testing, just like any car. The trailers are set up to be tested.

6. Registration is a huge issue for law enforcement. If I take a trailer off the road, we depend on the owner being compliant. We have no way of monitoring the use of that trailer every day across the UK, 40 different police force areas with defects in place and not likely to get stopped. The same for it being stolen!. Trailers should have their own identification.

7. I have been advised that resources are low for the DVSA and Police. We are not in a position to tackle such a significant amount of trailers. This is another reason why there needs to be a system of testing. However there does need to be a big deterrent, which is where we can help. If we obtain statistics on defect rates for buses and trucks, it is very low indeed. In fact very few collisions are caused by mechanical defects across the board from tested vehicles. As there is a limit to how defective they can get between testing. The DVSA have done a fantastic job, but they are now being tasked to look at roadworthy vehicles, they do not look at none-testable vehicles and trailers. We cannot predict which vehicles have collisions, but it would be a wise person at least to check the defective trailers and not the roadworthy vehicles. We have outstanding operatives within the DVSA, they know they should be looking at this area, but there operating criteria prevents it.

8. In relation to the scope of this enquiry, I would suggest you include trailers which are not tested full stop. Many years ago the farming sector were in fields, now they have the biggest trailers and can travel up to 250 miles a day on the road per machine. Some farms having up to 30 tractors. The machines are much larger than the LGV market, that the RHA represent. Trailers being used and in use at the moment have reached over 30 tonnes, no MOT for life, no secondary coupling to prevent detachment. Driving through our towns across the UK, they represent equally defective trailers to that of the up to 3.5tonne sector, if not worse! The public would expect us to deal with un-roadworthy vehicles, they would not expect us to focus on the small trailers and ignore the largest vehicles on our roads.


I have campaigned for change for many years; anyone with my insight would without question. However I have found that the political will of various unions which represent their member’s interests have done everything possible to prevent change.

I urge you to listen to Karin SMYTH MP. She has worked very hard to make sure she is well informed. These are the most defective items on our roads today, interacting with every road user. We have totally ignored this entire sector for years, it is time for change. We need to bring them up to a standard that all find acceptable.

May 2018


Prepared 22nd May 2018