Lane discipline 04 June 2014

First-time MOT pass rates continue to rise at the heavy-duty end of the spectrum – but not as fast as dealer network figures suggest. Robin Dickeson examines the real world and opportunities available to make a difference

Rising first-time MOT pass rates may be a useful indicator both of truck health and of workshop competence, but there's rather more to it. On the one hand, high ratings can lead to a 'job done' attitude and hence unjustified complacency. On the other, operators need to consider the remaining 364 days in their trucks' operating years and the undertakings they sign up to under the 'O' licence – asking themselves, are they roadworthy outside the MOT preparation envelope?

The fact is that, while OEM dealer networks regularly hit 100% MoT first-time pass rates, the average remains at just 82%. And much of the former's achievement is put down to dealer preparation. So for Kevin Rooney, traffic commissioner for the north east of England, it's easy to conclude that too many operators must be treating the MOT test merely as an annual inconvenience required to keep their trucks on the road – rather than a proof of excellence in regular inspection and maintenance.

"A first-time MOT pass is a useful indicator, but it is not the whole story," he insists. He also believes that too many operators rely on inadequately trained technicians sliding about underneath trucks on creeper boards. "They need highly-trained people with sophisticated instruments." And he points to non-dealer prepared truck MOT pass rates – the vast majority – which still struggle to hit a 75% or even 70% first-time pass rate.

Let's look at the figures: the last VOSA (now DVSA – Driver and Vehicle Standards Agency) Effectiveness report showed 403,162 truck MoTs and 79,096 for buses in 2012—2013. John Davies, UK head of service support for MAN – who also chairs the SMMT's (Society of Motor Manufacturers and Traders) CV Aftermarket committee – reckons that franchised truck dealers prepared about 110,000 (22%) of the trucks. "Stagecoach and First Group also take MoTs very seriously," he says. "Add their data in and you're looking at a third of all truck and bus MOTs."

"We are only there or thereabouts for buses and dealer-prepared trucks," comments Rooney. "The rest have a long way to go. Perhaps we should encourage more people to contract out their maintenance?" And you can see his point, given that first-time pass rates are often part of maintenance contractor service level agreements. However, Rooney suggests that the industry needs to get operators to make wider DVSA data a condition of contract. "Freight operators need to ... make use of first-time pass rates but also DVSA encounter records," he advises.

Intelligent analysis of that data gives a much better picture of any transport company's commitment to road safety – and hence also that of its maintenance providers. "All the information is there – freight operators just need to ask," says Rooney. Many local authorities already do: they look for pass, fail and encounter history and regularly use that to help audit and evaluate bus operators' performance.

VOSA's, and now hopefully now DVSA's, willingness to share data with the SMMT's truck makers and bus operators has helped them and their dealers raise MoT standards.

Volvo Trucks, for example, recently reported that its UK dealer network hit a record 97.4% average first-time pass rate in January this year. In the same month, 43 of the firm's UK dealer points hit 100%. Volvo says its UK dealer network carried out 17,975 MOT tests in 2013, with a 94.9% first-time pass rate. Meanwhile, market leader DAF Trucks says its dealer network prepared 24,728 trucks and achieved a 94.27% first-time pass rate in 2013. It is already up to 95% this year.

Enforcement options
Looking at roadworthiness from the other perspective – that of operator enforcement – many truck makers and their dealers feel that DVSA should go all the way with its ATFs (Authorised Testing Facilities), fully privatising heavy vehicle MoTs. This might allow DVSA to concentrate on enforcement, where its resources are clearly stretched. But Rooney is doubtful: "Look at the people who would apply to run vehicle test facilities and their commercial incentives to keep vehicles on the road." For him, the risk is again lower vehicle safety standards.

There are also suggestions that MoT preparers be legally obliged to report operators that fail to make vehicles available for test or inspection. This is unpopular with dealers who fear the commercial consequences. And there are lessons to be learned from the way tachograph calibration centres operate. These are required to report devices that might interfere with the legal running of tachographs. "However, to my knowledge none have made any reports along those lines," explains Rooney.

So what's the answer? Davies says most dealer-prepared vehicles are on some form of R&M contract, most of which specify that operators maintain or make their vehicles available for safety and maintenance inspections and MoTs at agreed intervals. Failure to do so is effectively a breach of contract and may leave the operator liable for the financial consequences of missed maintenance. Worth a thought?

What's behind van failures?
With only a 50% first-time MOT pass rate, van roadworthiness does not look good. An extrapolation of that data suggests well over one million unroadworthy vans running illegally on UK roads at any time.

Why? "I wonder whether van designs are fit for purpose," muses traffic commissioner Kevin Rooney. "What are manufacturers doing to make them a little more bombproof?"

Many fail on significant matters at four years and he believes this may be as much a design issue as a maintenance failure. Unsurprisingly he suggests that van operators should use truck style operations for van maintenance. Lex Autolease does just that, using HGV style maintenance standards and MOT pre-inspections across its 70,000 strong van fleet.

At a recent FTA Van Excellence conference, a surprising number of professional van operators seemed relaxed about suggestions that UK vans be subject to 'O' licence style regulation, perhaps from as little as 1.5 or 2 tonnes gvw. Many said they would welcome such a move, as it would make for fairer competition. But operators doubt that either the traffic commissioners or DVSA would have the resources to cope with an extra million vehicles a year.

Roadworthiness gets a Euro lift
The European Union published its 'roadworthiness package' as three separate but linked directives in its Official Journal, on 29 April 2014.

Directive 2014 / 45 / EU Periodic Technical Inspection covers tests, along the lines of MOTs and safety inspections. Directive 2014 / 46 / EU Vehicle Registration looks at aspects of vehicle registration and data. Directive 2014 / 47 / EU Roadside Inspection covers roadside inspections.

The aim is to harmonise all these liked activities across the EU, so that tests and roadside inspections all produce comparable data in each member state – ultimately improving road safety and environmental protection. Implementation dates range from 2017 to 2023, so don't expect a sudden flurry of change. And as each state will need to ratify any changes, possibly with adjustments to its national laws, there will be a need for local consultation.

Specifically for the UK, however, the directive on technical tests and inspection isn't a back door to forcing more legislation on vans – for instance, lowering the 'O' licence weight threshold below 3.5 tonnes.

Author
Robin Dickeson

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