Planes, trains and Automobiles

Dear ATF,

As a preamble, I wanted to, again, thank all of you who have shown their support by joining ATFOA as a fully paid up member.

It is reassuring, that our voice is being recognised, please read the article in full and you will see there is some hope. There is likely to be a few questions to her Majesty’s government in The house of Lords.

It has been another fast moving week (June 8th 2020) in the ATF world, its a shame that the action is not on the testing lane.

It is apparent DVSA are holding back on releasing their timeline for testing. Following ATFOA’s communication with DVSA, they hinted at a June start for testing, and the testing process could potentially be assisted by ATF staff (to speed up the test time and so reduce the testing back log).

DVSA later confirmed that Certificates of Temporary Exemption (CTE) would be issued for all vehicles requiring an MOT test in June and also for those issued with a CTE in March.

We have also learnt more from The FTA article released late last week. If you didn’t catch it, I have copied the FTA’s forecast table for HGV testing below.

If this forecast comes to pass, it will be extremely disappointing, especially when ATFOA’s arguments for ‘delegated’ testing has the backing of most stakeholders because it is universally thought that it is the only feasible solution to overcome the challenges.

The FTA forecast table establishes ATFOA’s worst nightmare; ATFOA have maintained that, whatever plan DVSA decide upon, they should not push all tests back 3 months, let alone 6 months. We have significant support from other stakeholders on this argument for a number of reasons, some featured here:

Pushing tests back 3 months means that ATF’s lose 25% of their test lane income
Hauliers, that normally test in September will have to test in December, which is their busiest period, which negatively impacts productivity and income.
Other examples, such as gritters for the frosts and summer multi-car transporters used for European repatriation, will both have to be tested at the height of their busy season.
By September 2020, vehicles that should have been tested in March 2020 will be tested, this equates to vehicles potentially not being tested for 18 months,

ATFOA members that have been in contact, are not confident that DVSA can meet the testing demand as the evidence has shown they have always struggled historically.

The pressure for DVSA to supply testers and keep up with the extra demand will be exacerbated with the introduction of the amended Covid 19 Standard Operating Procedures (SOP’s) and Risk Assessments (RA’s). ATF partners, who have had time to digest DVSA’s recent release have suggested the tests will most probably take longer, this will reduce DVSA’s productivity so less tests will be carried out daily therefore reducing ATF’s income. ATFOA will be asking DVSA what measures they will be putting in place and what support they will be offering ATF’s to counter the expected reduced productivity.

Historical evidence tells us that it will probably be the ATF’s, not DVSA, who will be picking up the cost for the amended SOP’s and RA’s.

Regretfully, ATFOA are expecting this outcome, because it’s generally been DVSA’s policy to expect ATF’s to yield; You may recall previously, DVSA, without consulting ATF’s, increased trailer test times, more recently, again without consultation, DVSA announced they would expect ATF staff to help set up the lane during the testing time we’d purchased.

Members have commented that DVSA’s amendments to SOP’s and RA’s for COVID 19 are a step in the right direction, but the new SOP’s & RA’s are all a bit academic; The rest of the sector, including DVSA enforcement, have been delivering vehicle services, such as preventative maintenance, testing and inspection, all along. The sector has been able to successfully continue its program by implementing practically the same measures that DVSA are only introducing 3 months later.

Q & A
In ATFOA’s next communication with DVSA we will ask them to address questions that have been put to ATFOA by members. Please do not hesitate to send in your questions.

The RA’s quote “when in-cab check is complete use the DVSA supplied anti-viral wipes to clean any PPE as necessary e.g. gloves” – Can DVSA confirm that they will be supplying all their own staffs PPE, anti viral wipes and cleansing gel?

Concerning disposal of their staff’s PPE – Will DVSA offer compensation for leaving their waste with ATF’s.

Will DVSA consider compensating ATF’s for “use of a third person to relay instructions whilst following social distancing”

Will DVSA be able to supply 2 testers, as per usual?

If testing commences in July – Will DVSA offer any rules or guidelines as to what vehicles will have prevalence?

Planes, Trains and automobiles
ATFOA must be doing something right. Following our communications with government and a multitude of blogs and press releases, we have been contacted by Lord John, 3rd Earl Attlee, grandson of the post war Labour Prime Minister. Lord Attlee thinks ATFOA may be on to something.
For those of you who are not aware of his exploits, Lord Attlee, who is a hereditary peer that sits in the House of Lords, was instrumental in changing the law so it was no longer mandatory for the police to escort abnormal loads. ‘Self escorting’ is now carried out by private enterprise. The argument, at that time, was similar to our plight: why should a government agency be required to deliver the service. The service was unreliable, long booking times were the norm and the sector (and the building sector it served) suffered long delays. Ring any bells? It was argued that the private sector had the capacity, flexibility, reliability and moreover, were the experts with the knowledge, training and experience to deliver the service.
Lord Attlee, like ATFOA, is struggling with the logic as to why our sector is being singled out and treated differently to other transport sectors. For example;
Trains and planes weigh more, go faster and are potentially more hazardous when things go wrong than heavy goods vehicles. They also carry more people per vehicle so why are they not tested by a government body?
Lord Attee will be asking for her majesty’s government’s response in The House of Lords…watch this space
DVSA were quick to suspend testing but are too slow to counter re-act
The argument for delegated testing tends to raise its head when the DVSA are being challenged, which, if you listen to ATFOA members, is practically all the time.

DVSA’s latest challenge is being questioned; A few weeks ago, when asked if DVSA’s action to suspend testing was flawed, nearly 80% of respondents agreed.

76% Said the logic is deeply flawed to suspend testing

20 % Said it is correct that DVSA suspend testing

So, ATF’s concluded that the logic to suspend testing was flawed. It came to pass, that the private sector interpreted government guidelines and used social distancing rules to create safer working environments to function during COVID 19. DVSA used the same guidelines and rules to suspend testing.

The next challenge DVSA face is their decision (or indecision) to delay testing further, until July. By then, it’ll probably be a month after schools open and 2 weeks after non essential shops open. So, it’s taken about 3 months for DVSA to amend their SOP’s and RA’s, when most of private enterprise created them in the first week of lockdown.

DVSA’s greatest challenge is keeping up with the private sector, they do tend to be behind the curve, even their amended SOP’s will probably be out of date before July testing starts, as the conversation in government has already shifted to just 1 metre social distancing being acceptable. 

The argument for delegated testing continues to grow stronger with DVSA’s response to new challenges.

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