I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

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alexMinny
Posts: 16
Joined: Tue May 16, 2023 7:13 am

I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by alexMinny »

I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the 6 months the company has been running? How does this fair?
I've informed them. But what would be the repercussions?
Thanks
McCuthwor
Posts: 11
Joined: Tue May 16, 2023 8:26 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by McCuthwor »

What is their Undertakings on the O-Licence?
What’s has been getting done at each PMI?
alexMinny
Posts: 16
Joined: Tue May 16, 2023 7:13 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by alexMinny »

McCuthwor wrote: Tue May 30, 2023 3:55 pm What is their Undertakings on the O-Licence?
What’s has been getting done at each PMI?
6 weekly pmi’s and just pmi but no rbt’s
McCuthwor
Posts: 11
Joined: Tue May 16, 2023 8:26 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by McCuthwor »

alexMinny wrote: Tue May 30, 2023 3:56 pm
McCuthwor wrote: Tue May 30, 2023 3:55 pm What is their Undertakings on the O-Licence?
What’s has been getting done at each PMI?
6 weekly pmi’s and just pmi but no rbt’s
Road test with temperatures or Tapley test?
alexMinny
Posts: 16
Joined: Tue May 16, 2023 7:13 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by alexMinny »

McCuthwor wrote: Tue May 30, 2023 3:56 pm
alexMinny wrote: Tue May 30, 2023 3:56 pm
McCuthwor wrote: Tue May 30, 2023 3:55 pm What is their Undertakings on the O-Licence?
What’s has been getting done at each PMI?
6 weekly pmi’s and just pmi but no rbt’s
Road test with temperatures or Tapley test?
no brake tests have been done.. just a pmi tick sheet
GrzeJolly
Posts: 8
Joined: Thu May 18, 2023 3:00 pm

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by GrzeJolly »

alexMinny wrote: Tue May 30, 2023 3:57 pm
McCuthwor wrote: Tue May 30, 2023 3:56 pm
alexMinny wrote: Tue May 30, 2023 3:56 pm

6 weekly pmi’s and just pmi but no rbt’s
Road test with temperatures or Tapley test?
no brake tests have been done.. just a pmi tick sheet
Unacceptable, TC would not be impressed, especially following an RTA. Read up on the Bath fatalities of 2015 and ask yourself how you would feel about being TM if something like that happened on your watch.
kempGo
Posts: 8
Joined: Tue May 16, 2023 8:28 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by kempGo »

McCuthwor wrote: Tue May 30, 2023 3:55 pm What is their Undertakings on the O-Licence?
What’s has been getting done at each PMI?
4 rolling road brake tests laden as a minimum. Does include the MOT. I ensure a rrbt every inspection.
McCuthwor
Posts: 11
Joined: Tue May 16, 2023 8:26 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by McCuthwor »

kempGo wrote: Tue May 30, 2023 3:58 pm
McCuthwor wrote: Tue May 30, 2023 3:55 pm What is their Undertakings on the O-Licence?
What’s has been getting done at each PMI?
4 rolling road brake tests laden as a minimum. Does include the MOT. I ensure a rrbt every inspection.
That’s a guidance & best practice, not actually law (unless it’s a Undertaking).
kempGo
Posts: 8
Joined: Tue May 16, 2023 8:28 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by kempGo »

McCuthwor wrote: Tue May 30, 2023 3:58 pm
kempGo wrote: Tue May 30, 2023 3:58 pm
McCuthwor wrote: Tue May 30, 2023 3:55 pm What is their Undertakings on the O-Licence?
What’s has been getting done at each PMI?
4 rolling road brake tests laden as a minimum. Does include the MOT. I ensure a rrbt every inspection.
That’s a guidance & best practice, not actually law (unless it’s a Undertaking).
yes but if you have an accident you may need to explain why you haven't. Always go best practice and be aware the Traffic Commissioners call the shots, law or not. Better safe than sorry.
ciorrow221
Posts: 6
Joined: Thu May 18, 2023 3:08 pm

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by ciorrow221 »

kempGo wrote: Tue May 30, 2023 3:59 pm
McCuthwor wrote: Tue May 30, 2023 3:58 pm
kempGo wrote: Tue May 30, 2023 3:58 pm

4 rolling road brake tests laden as a minimum. Does include the MOT. I ensure a rrbt every inspection.
That’s a guidance & best practice, not actually law (unless it’s a Undertaking).
yes but if you have an accident you may need to explain why you haven't. Always go best practice and be aware the Traffic Commissioners call the shots, law or not. Better safe than sorry.
as much as they call the shots, they still can’t take your licence away (or curtail) for not doing something that’s mot the legal requirement. Already had that argument with them, specifically about RBT’s which were being done every PMI but not laden
WellCapo
Posts: 11
Joined: Tue May 16, 2023 8:31 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by WellCapo »

Brake tests are a legal requirement at every PMI. See page 63 of the guide to maintaining roadworthiness.
“As per the annual test, every safety inspection must assess the braking performance of the vehicle or trailer. It is strongly advised that a calibrated roller brake tester (RBT) is used at each safety inspection to measure individual brake performance and overall braking efficiencies for the vehicle or trailer to the annual test standards. However, it is also acceptable to use an approved and calibrated decelerometer to measure overall brake efficiency values for vehicles without trailers.”
As you can see, RBTs are strongly recommended
https://assets.publishing.service.gov.u ... hicles.pdf
JassFinal
Posts: 12
Joined: Thu May 18, 2023 3:27 pm

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by JassFinal »

WellCapo wrote: Tue May 30, 2023 4:04 pm Brake tests are a legal requirement at every PMI. See page 63 of the guide to maintaining roadworthiness.
“As per the annual test, every safety inspection must assess the braking performance of the vehicle or trailer. It is strongly advised that a calibrated roller brake tester (RBT) is used at each safety inspection to measure individual brake performance and overall braking efficiencies for the vehicle or trailer to the annual test standards. However, it is also acceptable to use an approved and calibrated decelerometer to measure overall brake efficiency values for vehicles without trailers.”
As you can see, RBTs are strongly recommended
https://assets.publishing.service.gov.u ... hicles.pdf
They are not a legal requirement at every PMI👍
WellCapo
Posts: 11
Joined: Tue May 16, 2023 8:31 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by WellCapo »

JassFinal wrote: Tue May 30, 2023 4:04 pm
WellCapo wrote: Tue May 30, 2023 4:04 pm Brake tests are a legal requirement at every PMI. See page 63 of the guide to maintaining roadworthiness.
“As per the annual test, every safety inspection must assess the braking performance of the vehicle or trailer. It is strongly advised that a calibrated roller brake tester (RBT) is used at each safety inspection to measure individual brake performance and overall braking efficiencies for the vehicle or trailer to the annual test standards. However, it is also acceptable to use an approved and calibrated decelerometer to measure overall brake efficiency values for vehicles without trailers.”
As you can see, RBTs are strongly recommended
https://assets.publishing.service.gov.u ... hicles.pdf
They are not a legal requirement at every PMI👍
this was covered in a recent transport manager refresher course I attended through the RHA and the trainer concluded it was every PMI (indirectly). I’ll need to go through my notes to remind myself how he got to that conclusion.
Nevertheless, the guide does say “every PMI.” Do you know something I don’t?
davidGroup
Posts: 9
Joined: Tue May 16, 2023 8:35 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by davidGroup »

WellCapo wrote: Tue May 30, 2023 4:05 pm
JassFinal wrote: Tue May 30, 2023 4:04 pm
WellCapo wrote: Tue May 30, 2023 4:04 pm Brake tests are a legal requirement at every PMI. See page 63 of the guide to maintaining roadworthiness.
“As per the annual test, every safety inspection must assess the braking performance of the vehicle or trailer. It is strongly advised that a calibrated roller brake tester (RBT) is used at each safety inspection to measure individual brake performance and overall braking efficiencies for the vehicle or trailer to the annual test standards. However, it is also acceptable to use an approved and calibrated decelerometer to measure overall brake efficiency values for vehicles without trailers.”
As you can see, RBTs are strongly recommended
https://assets.publishing.service.gov.u ... hicles.pdf
They are not a legal requirement at every PMI👍
this was covered in a recent transport manager refresher course I attended through the RHA and the trainer concluded it was every PMI (indirectly). I’ll need to go through my notes to remind myself how he got to that conclusion.
Nevertheless, the guide does say “every PMI.” Do you know something I don’t?
I think it’s because your referring to the “GUIDE” to roadworthiness and JassFinal is referring to the actual legislation in place. The 2 are completely different and need to interpreted correctly the guide is there to help you reach what is enforced via legislation. But the guide actually makes the safety level higher than what legislation is.
WellCapo
Posts: 11
Joined: Tue May 16, 2023 8:31 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by WellCapo »

davidGroup wrote: Tue May 30, 2023 4:06 pm
WellCapo wrote: Tue May 30, 2023 4:05 pm
JassFinal wrote: Tue May 30, 2023 4:04 pm

They are not a legal requirement at every PMI👍
this was covered in a recent transport manager refresher course I attended through the RHA and the trainer concluded it was every PMI (indirectly). I’ll need to go through my notes to remind myself how he got to that conclusion.
Nevertheless, the guide does say “every PMI.” Do you know something I don’t?
I think it’s because your referring to the “GUIDE” to roadworthiness and JassFinal is referring to the actual legislation in place. The 2 are completely different and need to interpreted correctly the guide is there to help you reach what is enforced via legislation. But the guide actually makes the safety level higher than what legislation is.
that’s a good point about the word “guide” but it also uses the word “must” rather than “should” in the guide?
The RHA trainer seemed to use the guide as the main “authority.”
On which piece of legislation do you think Richie is basing his comment?
davidGroup
Posts: 9
Joined: Tue May 16, 2023 8:35 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by davidGroup »

WellCapo wrote: Tue May 30, 2023 4:07 pm
davidGroup wrote: Tue May 30, 2023 4:06 pm
WellCapo wrote: Tue May 30, 2023 4:05 pm

this was covered in a recent transport manager refresher course I attended through the RHA and the trainer concluded it was every PMI (indirectly). I’ll need to go through my notes to remind myself how he got to that conclusion.
Nevertheless, the guide does say “every PMI.” Do you know something I don’t?
I think it’s because your referring to the “GUIDE” to roadworthiness and JassFinal is referring to the actual legislation in place. The 2 are completely different and need to interpreted correctly the guide is there to help you reach what is enforced via legislation. But the guide actually makes the safety level higher than what legislation is.
that’s a good point about the word “guide” but it also uses the word “must” rather than “should” in the guide?
The RHA trainer seemed to use the guide as the main “authority.”
On which piece of legislation do you think Richie is basing his comment?
I can’t comment as to which he is referring to as there’s so many references across so much legislation.
I completely understand as the term “must” and “should” interpretation in the likes of HSE publications is easy defined but within our industry there are 2 major governing bodies DVSA and TC and sometimes these create overlapping grey areas. But a title of guide would not take over the title of road traffic act, licence undertakings or a multitude of other legislation.
Easiest way I deal with this is which ever is the safest or more extensive option is where I side with. I still hold my head in my hands and wonder why it’s all so complicated.
WellCapo
Posts: 11
Joined: Tue May 16, 2023 8:31 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by WellCapo »

davidGroup wrote: Tue May 30, 2023 4:08 pm
WellCapo wrote: Tue May 30, 2023 4:07 pm
davidGroup wrote: Tue May 30, 2023 4:06 pm

I think it’s because your referring to the “GUIDE” to roadworthiness and JassFinal is referring to the actual legislation in place. The 2 are completely different and need to interpreted correctly the guide is there to help you reach what is enforced via legislation. But the guide actually makes the safety level higher than what legislation is.
that’s a good point about the word “guide” but it also uses the word “must” rather than “should” in the guide?
The RHA trainer seemed to use the guide as the main “authority.”
On which piece of legislation do you think Richie is basing his comment?
I can’t comment as to which he is referring to as there’s so many references across so much legislation.
I completely understand as the term “must” and “should” interpretation in the likes of HSE publications is easy defined but within our industry there are 2 major governing bodies DVSA and TC and sometimes these create overlapping grey areas. But a title of guide would not take over the title of road traffic act, licence undertakings or a multitude of other legislation.
Easiest way I deal with this is which ever is the safest or more extensive option is where I side with. I still hold my head in my hands and wonder why it’s all so complicated.
indeed! Why so complicated!!
JassFinal
Posts: 12
Joined: Thu May 18, 2023 3:27 pm

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by JassFinal »

WellCapo wrote: Tue May 30, 2023 4:05 pm
JassFinal wrote: Tue May 30, 2023 4:04 pm
WellCapo wrote: Tue May 30, 2023 4:04 pm Brake tests are a legal requirement at every PMI. See page 63 of the guide to maintaining roadworthiness.
“As per the annual test, every safety inspection must assess the braking performance of the vehicle or trailer. It is strongly advised that a calibrated roller brake tester (RBT) is used at each safety inspection to measure individual brake performance and overall braking efficiencies for the vehicle or trailer to the annual test standards. However, it is also acceptable to use an approved and calibrated decelerometer to measure overall brake efficiency values for vehicles without trailers.”
As you can see, RBTs are strongly recommended
https://assets.publishing.service.gov.u ... hicles.pdf
They are not a legal requirement at every PMI👍
this was covered in a recent transport manager refresher course I attended through the RHA and the trainer concluded it was every PMI (indirectly). I’ll need to go through my notes to remind myself how he got to that conclusion.
Nevertheless, the guide does say “every PMI.” Do you know something I don’t?
The legal requirement is a RBT at MOT and the GTMR is a guide 🤷 but the TC's use it as they're bible so that's why they state a minimum of four per year including MOT.
I agree, best practice would be RBT at every PMI and laden correctly to a minimum of 60% of the vehicles gross weight but life isn't perfect.
I'm a RHA professional member and three of my operators are RHA members and I had another RHA OTC audit yesterday so my name is known to the RHA.
I believe you when you say the RHA trainer told you it was a legal requirement as you'll find a lot of organizations do this but when they try and dictate certain information then take it with a pinch of salt.
I had the audit yesterday, a different auditor I'd never met before and she soon realized I was well experienced and knowledgeable so at no point did she try to tell me anything but she was very helpful.
The phrase "legal requirement" does get used a lot in this industry, when in fact it should be "best practice" which I try to force on all my operators and is the best way to go as it gives the ETM more work and is then able to charge accordingly 👍
WellCapo
Posts: 11
Joined: Tue May 16, 2023 8:31 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by WellCapo »

JassFinal wrote: Tue May 30, 2023 4:09 pm
WellCapo wrote: Tue May 30, 2023 4:05 pm
JassFinal wrote: Tue May 30, 2023 4:04 pm

They are not a legal requirement at every PMI👍
this was covered in a recent transport manager refresher course I attended through the RHA and the trainer concluded it was every PMI (indirectly). I’ll need to go through my notes to remind myself how he got to that conclusion.
Nevertheless, the guide does say “every PMI.” Do you know something I don’t?
The legal requirement is a RBT at MOT and the GTMR is a guide 🤷 but the TC's use it as they're bible so that's why they state a minimum of four per year including MOT.
I agree, best practice would be RBT at every PMI and laden correctly to a minimum of 60% of the vehicles gross weight but life isn't perfect.
I'm a RHA professional member and three of my operators are RHA members and I had another RHA OTC audit yesterday so my name is known to the RHA.
I believe you when you say the RHA trainer told you it was a legal requirement as you'll find a lot of organizations do this but when they try and dictate certain information then take it with a pinch of salt.
I had the audit yesterday, a different auditor I'd never met before and she soon realized I was well experienced and knowledgeable so at no point did she try to tell me anything but she was very helpful.
The phrase "legal requirement" does get used a lot in this industry, when in fact it should be "best practice" which I try to force on all my operators and is the best way to go as it gives the ETM more work and is then able to charge accordingly 👍
thanks for your helpful comments
mihaftexpe
Posts: 6
Joined: Thu May 18, 2023 3:33 pm

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by mihaftexpe »

JassFinal wrote: Tue May 30, 2023 4:09 pm
WellCapo wrote: Tue May 30, 2023 4:05 pm
JassFinal wrote: Tue May 30, 2023 4:04 pm

They are not a legal requirement at every PMI👍
this was covered in a recent transport manager refresher course I attended through the RHA and the trainer concluded it was every PMI (indirectly). I’ll need to go through my notes to remind myself how he got to that conclusion.
Nevertheless, the guide does say “every PMI.” Do you know something I don’t?
The legal requirement is a RBT at MOT and the GTMR is a guide 🤷 but the TC's use it as they're bible so that's why they state a minimum of four per year including MOT.
I agree, best practice would be RBT at every PMI and laden correctly to a minimum of 60% of the vehicles gross weight but life isn't perfect.
I'm a RHA professional member and three of my operators are RHA members and I had another RHA OTC audit yesterday so my name is known to the RHA.
I believe you when you say the RHA trainer told you it was a legal requirement as you'll find a lot of organizations do this but when they try and dictate certain information then take it with a pinch of salt.
I had the audit yesterday, a different auditor I'd never met before and she soon realized I was well experienced and knowledgeable so at no point did she try to tell me anything but she was very helpful.
The phrase "legal requirement" does get used a lot in this industry, when in fact it should be "best practice" which I try to force on all my operators and is the best way to go as it gives the ETM more work and is then able to charge accordingly 👍
100% JassFinal. When I'm training I have to be very careful with my choice of language. Delegates will only remember snippets of what you say, and often they are simply listening for and hoping for you to validate what they already believe to be right.
Operators should, of course strive to be as safe as possible, but as an industry, we can at times with confuse guidance and best practice with actual law.
Laws are made in our name, with great scrutiny and for good reasons and generally Parliament gets it right. While I'll always advocate for operators to use the very best of practices we must never loose sight of the law and be prepared to challenge overreach by regulators or law enforcement agencies.
TomBauer
Posts: 8
Joined: Tue May 16, 2023 8:37 am

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by TomBauer »

Legally as it stands it’s no rules have been broken. Has the operator made and declarations to have 12 week brake test to the TC? Pass the operator your finding with best practises. Advise them what you feel is needed moving forward. Review with the TM about why no brake tests are being completed. Get an understanding from both of them. How experienced is the TM, maybe OLAT course for them both as a recommendation.
SwarHiro
Posts: 36
Joined: Thu May 18, 2023 3:38 pm

Re: I have carried out an audit for company, the current TM Hasn't had any RBT’s carried out other than at MOT, in the

Post by SwarHiro »

I would look up the RHA's video on brake testing, it explains the required minimum
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