How good are you? 07 March 2017

For nearly 50 years, operators have held their O licences on trust, with compliance assumed until found otherwise. Brian Tinham examines recent calls for voluntary, possibly, mandatory audits

Late last year the FTA (Freight Transport Association) announced that Bidvest Foodservice, London Borough of Redbridge and Sainsbury’s were the first to have achieved its then recently launched voluntary Truck Excellence accreditation (see panel). What had these three operators done to merit the accolade? Each, explained FTA deputy chief executive James Hookham, had been successfully audited for compliance with the requirements of their O licences.

At first glance, that might seem slightly strange. Surely, without strict adherence to the mandatory O license undertakings, operators are – at the very least – risking an unwanted audience with the traffic commissioners? So, why bother with the cost and administrative effort of an independent audit to prove what they should already know? Why vote for yet more red tape?

Well yes, but the plain fact is that every year more hauliers than we would want are found to be in breach of the terms of their O licenses. Sometimes the issue is drivers’ hours’ infringements. On other occasions operators are caught out for vehicle roadworthiness lapses, following roadside encounters with DVSA (Driver & Vehicle Standards Agency). Driver defect reporting, as well as vehicle inspection and maintenance processes may then be called into question – and we’re all familiar with the implications of PG9s and ‘S’ marked prohibitions.

More often than not, all are symptoms of nothing more sinister than underlying inadequacies concerning processes, policies and/or custom and practice. And those are the result of no one (at least no one with enough clout) being tasked with checking, reviewing and imposing remedial action, where necessary.

Either way, operators get away with it, goes the FTA’s argument, because the O licensing system takes operators on trust – with the enforcement and regulatory agencies only getting involved when they are found wanting. And while Truck Excellence doesn’t directly alter this state of affairs, Hookham believes that recognising and rewarding operators (of any size, in any type of operation and sector) that are prepared to submit to an independent audit will encourage change for the better.

Last month, however, RHA (Road Haulage Association) took up the cause, calling for a “major overhaul” of the O licensing system, and counselling draconian measures. Chief executive Richard Burnett wants the government to audit all HGV operators, arguing that this approach would “raise the bar” for hauliers.

Burnett points to the fact that, currently, new licences are granted “on the basis of promises on the [O license] application, without any inspection of the operating systems and procedures”. For him, audits have become essential not just because vehicles have increased in complexity, size and weight since the O licensing system was established nearly 50 years ago. Nor because operations are more demanding and that, as a result, expectations of competence and compliance are now much higher than in the past. No, mandatory auditing would “flush out operators that should not have a licence”, he insists.

“It would be a decisive step towards minimising road safety risks,” says Burnett. “And it would eliminate much unfair competition faced by the great majority of hauliers who are working within the rules.” Hence the RHA’s proposal that new applicants receive a provisional, interim licence until satisfactorily audited. Hence also its suggestion that follow-up audits take place every five years to ensure revalidation.

All well and good, but why now? Cynics might suggest that both the FTA and RHA could have been stung into action by recent moves on the part of FORS (Fleet Operator Recognition Scheme) to march beyond its original Greater London and construction logistics remit? FTA’s Hookham doesn’t deny it: “Truck Excellence owes its origins to a reaction by members to the assertion that what the country needs is FORS going national. Members say we’ve had such a scheme for almost 50 years: it’s called O licencing.”

Hookham concedes that FORS membership is already conditional on independent audits, but points out that these don’t come close to the O licence in scope. “Truck Excellence audits are based on an enduring standard that examines operators’ compliance with all 20-plus aspects of their O licences. It’s not just about vehicle roadworthiness, defect reporting, inspections, documentation, etc. It’s also about the robustness of operators’ policies and procedures around monitoring, recording and, where necessary, initiating remedial actions fleet-wide and across the business.”

Just as important, though, annual accreditation offers successful operators an opportunity to celebrate. “It gives them something to brag about,” he asserts. “They can be rightly proud – and they can share their success with customers, staff and other stakeholders.” Meaning that, in this compliance-aware era, they might expect to be looked upon favourably when it comes to new contracts, investment, etc.

He’s not suggesting FORS is irrelevant. Far from it/ For him, FORS and Truck Excellence can comfortably coexist – although he argues that some aspects of the former should fall under C&U (construction and Use) regulations. However, in much the same way as OCRS (operator compliance risk score) should never have been used by customers’ procurement departments as a proxy for excellence, neither, he argues, should FORS – certainly outside urban-based construction logistics.

Incidentally, Hookham says FTA has also mapped aspects of FORS it sees as having general application but that fall outside the O licence – such as WRRR (work-related road risk) – to Truck Excellence and is offering additional audit modules to demonstrate compliance. “We recently revised our WRRR standards to match the latest version of FORS and have submitted these to TfL [Transport for London] for approval as equivalent to FORS Bronze,” he says. And he adds that many operators working outside London and/or construction will see this as making more sense that going for FORS.

One such is Sainsbury’s, which, having led on achieving Truck Excellence, says it next intends to go for WRRR compliance, instead of FORS. Before tackling that, however, operations support manager Gary King urges others throughout transport to step up to the plate. “Truck Excellence mirrors your O licence, so the audit process allows you to benchmark against your undertakings and find out how good you really are. Getting it right raises the bar. It ensures not only that you meet the standards, but also that you have everything in place, in terms of overarching policies and detailed procedures – for your transport operations and right across the business.”

For King, Truck Excellence uniquely provides an opportunity to formalise what are so often informal processes. That, he says, leads to the ideal of a model of compliance that is sustainable and robust – and capable of fitting any transport company’s operations. “Remember, it’s not just the transport manager who own your O licence: it’s the whole management structure. Truck Excellence ensures that the chain of responsibility is aligned and that the business is behaving exactly as it says it is.”


What the operators say

Eddie Cross, head of transport engineering services, London Borough of Redbridge: “We have worked with the FTA on Van Excellence, and Truck Excellence was a natural progression to bring our O licence fleet policies and procedures into line. Not only does this accreditation give confidence in our fleet operation, but it is a big boost to the team that has worked hard to meet the requirements of the standard.”

Graham Rennie, director of fleet, Bidvest: “It’s a privilege to receive this accreditation and be recognised by the FTA for our strong compliance culture, first rate processes and high levels of attainment in relation to the Operator licensing undertakings.”

Nick Davies, head of transport and sustainability, Sainsbury’s: “We are constantly looking to raise the bar on compliance so we are proud to obtain the FTA’s Truck Excellence accreditation... This has been an 18-month journey, working with the FTA and some of the UK’s best fleet operators, to design and implement the Truck Excellence standard within our business and raise the bar in the industry.”


Truck Excellence standard

Truck Excellence is based on standards for freight vehicles in excess of 3.5 tonnes gvw. It follows in the footsteps of the FTA’s Van Excellence programme, which is aimed at operators of goods vehicles up to and including 3.5 tonnes gvw. Operators can apply to become members of either or both schemes.

According to the FTA’s own documentation, Truck Excellence aims to:

1 Demonstrate consistent attainment of high levels of compliance by road freight transport operators with their O licence undertakings

2 Provide a route to attainment of DVSA’s (Driver & Vehicle Standards Agency) incoming ‘Earned Recognition’ scheme

3 Create a recognised compliance quality mark for use by members with other parties

4 Provide equivalence to ‘comparable schemes’ and alternative means of achieving them.

The Truck Excellence standards consist of requirements and assessment criteria rooted in the O licensing system. The ongoing development of the scheme lies with its governance group, which consists of a wide range of truck operators.

Prior to being accredited, each operator will be required to provide information before undergoing and passing an independent audit that examines the organisation’s systems in relation to the standards. This will be achieved in the first instance by passing a systems audit conducted at a location identified as the most appropriate.

One central systems audit will be carried out provided the operator employs a coherent national standard, and the same policies, procedures and systems are applied throughout the organisation. Otherwise, audits at a number of locations may be required.

Author
Brian Tinham

Related Downloads
151974/How_good_are_you.pdf

Related Companies
Driver & Vehicle Standards Agency (DVSA)
Freight Transport Association Ltd
Road Haulage Association Ltd

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