TCs reassert importance of brake testing on traction-only trailers30 August 2022

Traffic Commissioners of England Sarah Bell, Tim Blackmore, Nick Denton, Gerallt Evans, Kevin Rooney and Richard Turfitt have commented on maintenance of trailers used in traction-only transport in the annual report, which was published in July.

They write:

“In several high-profile cases this year it has been suggested that some trailer suppliers (including those based offshore) are avoiding responsibilities to ensure safe operation of trailers on GB roads. The lack of adequate arrangements regarding regular and frequent brake testing has been a prominent failing. The potential impact on British roads is significant and the traffic commissioners have felt the need to issue several warnings regarding this to companies involved in this type of third-party trailer operation.

“For the avoidance of doubt, operators providing traction-only services to third-party trailers are responsible in law for the condition of that trailer when in use. Transport managers are also required by law to manage the transport operation continuously and effectively. The operator’s licence requires “satisfactory facilities and arrangements for maintaining the vehicles used under the licence in a fit and serviceable condition”. In that context, “vehicles” includes any trailer (including those from abroad) being drawn. An operator providing traction-only services must have trailer authority on that licence and must specify an inspection period. The trailer provider is likely to have its own inspection periods, which should be based in part on the age and characteristics of the trailers and work involved. However, the operator needs to satisfy themselves that it is appropriate. The operator must ensure that any trailer it operates meets the stated frequency for inspection. If the operator cannot satisfy themselves that a suitable assessment has taken place, then the operator must make their own assessment, as per the declared intervals.

“Operators involved in this type of work should refer to the current DVSA Guide to Maintaining Roadworthiness, the link to the brake testing guidance, and may be further assisted by reference to the IRTE publication: Roadworthiness: Industry Best Practice for third party trailer operators, which includes a suggested “Co-operation request letter to trailer owner”.

“Responsible suppliers of trailers have already taken the advice of DVSA to ensure that operators have access to relevant information which indicates the annual test expiry, the date of the last Preventative Maintenance Inspection, for trailers not fitted with electronic brake performance monitoring the date of last roller brake test and to confirm that this was laden, and contact details for reporting of defects. Drivers may also require additional training on conducting an effective walk-around check.”

Transport Engineer

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