ATFOA – Q1 2021 Update

Why not take our survey first then read the update later?

Hello from ATFOA

It’s been some time since we last communicated with you. It’s not because we’ve been quiet, because we haven’t. Following our landmark victory in the house of Lords in the summer of 2020, where master tactician Lord Attlee (who was fighting in ATFOA’s corner) played a blinder and forced the government’s hand to hold a ‘Heavy Vehicle Testing Review.’ The ‘Review ‘ lasted a few months over regular online meetings with ATFOA and the other stakeholders participating. The Review has been in draft for a few weeks and has since been whizzed through Whitehall (to cleanse and ratify, no doubt) and we have now received a summary letter from Baroness Vere of DfT and the full report on the government’s website.

Unlike the rest of us, DVSA and government still think the earth is flat when it comes to testing

When the ‘Review’ was first announced we were ecstatic, we really thought we had won a victory for the instigation of a road map for delegated testing, but as soon as I had sat back down in my seat, an old cynical hack was on the phone teasing me that the process had been negotiated to keep us quiet and the ‘Review’ would be a whitewash.

Looking back, whitewash is perhaps the right description because DfT refused to include plausible alternatives, such as delegated testing, to be debated in the ‘Review’ process. This directive was hugely disappointing, as we all know that the only real solution for the inadequacy of DVSA’s delivery of testers to site would be to remove them from this historically painful responsibility. As the main attraction was ‘off the menu’ from the get go, the process, in our opinion, was no longer a ‘Review’ at all. It resembled a DVSA internal appraisal.  DfT had given up the opportunity of the decade to take the small risk and steer their ship towards the edge of the earth in the hope of finding a land of great opportunity  and benefit from a reliable, flexible, customer focussed, efficient alternative for the future of testing.

It’s not even much of a risk, it’s not like we’re the first to go over the edge. Government decided not to get physically involved with testing cars (class IV), now the industry does it. The arguments about HGV’s being heavier, therefore more dangerous doesn’t work when you consider the government has no consideration to get involved with testing planes, trains, large electromechanical plant, cranes, lifts and even generators so why are HGV’s treated different? It’s difficult to see their logic on this one and when you ask them they struggle to answer it.

Omitting delegated testing from The Heavy Vehicle Testing Review was like organising a panel to review the best football players of all time but not allowing them to discuss the merits of Pele. It makes the debate rather pointless unless you’re on the other side protecting something.

The Review in full

Those of you who have time to digest the detail, the report can be downloaded in full here.

“Yes, the industry will be paying for the improved service”

The Review in Summary

The contents of Baroness Vere’s letter gives us some insight into what to expect. It is likely that some change is coming, that said, the oil tanker that is the government hasn’t even given the order to turn the rudder yet so we are a good way off before we even think about changing course. There will need to be a public consultation to understand industry sentiment and how it reacts to increases in DVSA statutory testing fees to fund the extra testers required to deliver the flexibility and supply needed. Yes, the industry will be paying for the improved service despite DVSA already offloading their costs onto ATF’s and increasing fees at the onset of the ATF testing regime. In my opinion, knowing a little about how the government works, I would think it will be at least a year to 18 months before anything solid comes to fruition, that’s if COVID doesn’t rear its ugly head again.

Baroness Vere – “The review found that the testing system was not in crisis, but did identify a number of recommendations for future work, falling into six areas”

I am sure most ATF’s and stakeholders would disagree with the statement that the testing system is not in crisis. I would argue that it has been in crisis since NGT (Next Generation Testing) was introduced. That was when DVSA first restricted our supply of testers by up to 50% at some ATF’s. I personally lost 25% of tests. That was a crisis. That was when they removed overtime for testers and annual requests for tests so the flexibility we had was reduced. How can it not be in crisis when the whole industry can’t get a test on time due to exemptions that were invented, not because the haulage industry didn’t want to be tested or because of any COVID restrictions being in place – the rest of the industry, including DVSA enforcement, solved that problem at the onset of COVID and carried on to keep Britain moving, ATFOA presented DVSA with evidence of thousands of IRTE qualified private sector testers ready and willing with the capacity to start testing; exemptions were introduced to protect DVSA’s embarrassment of not being able to supply testers. That is by definition, a crisis.

RecommendationWhat this meansATFOA OpinionWould delegated testing deliver this recommendation?
Continued service improvementDVSA is to continue to work to improve the service, ensuring that robust user feedback is used to develop any changes. Testing intervals for Earned Recognition operators should be considered further.Nothing new here, the industry has been promised improvement for a decade. More often than not, improvement in service has been paid for by ATF’s. Unless DVSA can resist its protectionism or the public consultation results in funding for more testers, then expect no real improvement in service provision.
YES
Slots for tests at Authorised Testing Facilities (ATFs)The moratorium on new sites should be lifted in the near future and the effects of allowing testers to be booked further in advance should be examined.Expect more ATF’s to open which will increase competition. This will diminish the demand for your test station. However, DVSA will have to massively increase their pool of testers before they can open more ATF’s and deliver the supply & flexibility they are promising. Historically DVSA tester availability has reduced year on year. ATFOA welcomes competition, however, in a normal free market, businesses control their supply lines and charges (amongst other things) to help counteract the effects of competition. The greatest inhibitor will be the challenge DVSA will have to resist their protectionismYES
Booking of testsMore work is needed to make it easier for operators to book a test at an ATF.Nothing new here. This issue was well known prior to the review. The testing regime is reliant upon DVSA delivering their resource efficiently, flexibly which has always been a challenge. DVSA online system may be the answer…YES
Communications:DVSA should work to reinvigorate stakeholder relationships and develop improved communications plans.DVSA have promised this at every juncture, NGT was supposed to resolve communications, but it got worse. DVSA need to bring back local managers, not rely on the under resourced and distant network managers.YES
Vehicle testing performance measures:A more detailed set of measures that reflect the whole service (and user experiences in particular) should be developed.User experience measurement is important, Up to now DVSA have focussed on internal measurements from their perspective. This data, such as capacity utilisation has been used to justify their protectionism.YES
Tester capacity:An increase in tester capacity (paid for through higher fees) should be considered, in order to provide greater capacity for users of the system. This would require public consultation.Nothing new here. This issue was known prior to the review. NGT was supposed to deliver more testers, efficiency, choice and greater flexibility. The main problem though is a creaking 1970’s public body process not being able to respond to fluctuations in private sector supply and demand – coupled with DVSA protectionism restricting tester flow when the industry needs to ramp up. The important point here is that at last DVSA understand that they need to increase tester remuneration to attract their ever diminishing pool. So expect an increase in charges to fund more testers and more flexibility. Subject to a public enquiry.YES

Conclusion

DVSA and Government – Will they always be too scared to risk changing course towards delegated testing?

It doesn’t take a lot to surmise that DVSA will not be steering a course towards delegated testing in the mid term, that’d be like sailing towards the edge of the world for them. Unlike the rest of us, DVSA and government still think the earth is flat when it comes to testing, their protectionism overrides any decision process that might see them lose control over their supply lines – so with these priorities coded into their DNA it’ll be a continued challenge for them to deliver any type of flexibility and efficiency that matches what the private sector can deliver.

A new hope

Loveday Ryder – It’s good to talk

More recently, ATFOA were genuinely delighted to be approached by the incoming Chief Executive of the DVSA, Loveday Ryder, who was appointed to her new role on 1st January 2021. Loveday got in touch and took the time to listen to us so we had a great opportunity to communicate The ATF industry’s woes, thoughts and future requirements and expectations. Let’s hope Loveday is brave enough to buck the trend of her predecessors by looking at the perspective from all the industry stakeholders for a more balanced strategy, instead of protecting DVSA’s supply lines.

There is likely to be some industry probing over the next few months so DVSA can assess the sentiment before they implement some of the change management they will be proposing. Speaking broadly about what to expect, ATF members should start thinking about how they can benefit from increased competition and greater flexibility opportunities.

However, for the time being, expect much the same. Which leads me on to my next point….

What is much the same?

ATFOA want to record how our members are fairing as we are coming out of lockdown but still feeling the pain of the government imposed exemptions, so we are asking you to take part in this short survey. Please help us communicate your experience. Every complete survey adds to our voice.

2021 Q1 ATFOA survey – Exiting lockdown

Thank you for reading

Stephen Smith

ATFOA Chair

DFT will be reviewing HGV testing – ATFOA vindicated

Urgent update – 21st July 2020

Dear ATFOA Member,  

ATFOA can report that it is now official that ATFOA have received a letter of confirmation that HGV testing is being reviewed.   ATFOA feel vindicated in our lobbying and would especially like to thank ATFOA active members and Lord Attlee.   We are still not there yet, but via our direct lobbying, we have managed to reach government and they are acting to review our plight.  

Click join here now.  

Thank you for reading  

Stephen Smith

ATFOA Chair

House of Lords – Delegated testing amendment – update July 13th 2020

Delegated testing amendment – update

ATFOA has recognised that the Business and Planning Bill, that was arguably being implemented to provide greater protection for DVSA has given us the perfect moment to present evidence, supported by ATFOA members and other major trade bodies, to argue that delegated testing is the only feasible solution to the historical challenges DVSA has had to supply testers and deliver a HGV and PSV tests to our sector.

The best vehicle that hi-lights our plights is DVSA’s and governments protectionism of their responsibilities since the COVID 19 pandemic: Our members have always maintained DVSA’s tester allocation process restricts supply of testers, and impacts on successful ATF’s ability to provide a service that befits their customer base.

However, since the re-introduction of testing, post lockdown, the evidence supports our position that DVSA and government have planned to further prioritise mitigating their risk over their responsibility to supply testers to our sector.

The irony, at this juncture, however, is strong. By attempting to introduce legislation that makes it easier for DVSA and government to exempt testing, they have unwittingly presented ATF’s with the opportunity to table an amendment.

Prior to this juncture, DVSA’s defence to change even minor issues was that legislation would need to be changed. Now they are reviewing the legislation we are able to question the logic of government’s insistence to use DSVA to carry out this ‘service’.

Lord Attlee articulates the flawed logic very well –

“The current situation is wrong. If a private individual can be certified to pass an aircraft as fit to fly and a 1,000 tonne crane can be inspected by a private sector operator, then why is it not the same for lorries?

Today the bill will be going through the committee stage, which is a line by line dissection of the bill, followed by the report stage, which is next Monday – which is when they will vote so is the deciding stage.

What’s the chances of ATFOA succeeding with changing the law to allow delegated testers?

We need cross party support so we have the odds against us, however, the bill has provided us with the most perfect storm to hi light our plight and force the government to defend their flawed logic, and they will not want to keep doing this, so there is a slim chance that we may succeed.

ATF Operators Association Update July 2020

ATFOA have a voice in the House of Lords – Lord Attlee is to table an amendment to The Business and Planning Bill

What is the Business and Planning Bill?

The official line suggests this Bill is part of the Government’s plan to ensure economic recovery after the coronavirus pandemic. As the economy starts to re-open, the Government is committed to doing all it can to support recovery, help businesses adjust to new ways of working and create new jobs. 

In the detail is the devil
Amongst other things, The Bill will make it easier to temporarily exempt goods vehicles, buses and coaches from roadworthiness testing.

Why is this significant?
This move supports our argument that the governments intended policy appears to prioritise and protect the welfare of the DVSA over their responsibility towards vehicle roadworthiness and the stakeholder’s who depend on this industry. If vehicle safety was the priority, then the obvious and most feasible solution would be to allow delegated testing so heavy goods vehicle testing could continue in the same way preventative maintenance and vehicle inspection has continued during the lockdown.

Why are they making vehicle testing exemption decisions easier? 
ATFOA believe one of the main contributory factors was the realisation that DVSA have always been challenged with supplying testers to the market. The ATF contract, up to now, indemnified ATF’s against DVSA tester no shows. DVSA were contracted to pay a fine to ATF’s as recompense for any failure in the supply of testers. The new ‘Side letter’ has removed any risk for DVSA to supply testers (at the industry’s expense) and the new legislation further reduces DVSA responsibility to supply testers reliably as they can wave the ‘exemption flag’ at any time the supply of testers becomes stressed. 

This is not good for industry compliance and safety – we need consistency

There are already large scale reports from ATF members that DVSA have taken this opportunity to use the new terms from the ‘Side Letter’, to further reduce the supply of testers to the market. Most ATF’s have reported that their requests for testers, even using the new 7 day notice period, have been only partly honoured. The difference now, is that DVSA and government have engineered it so that they do not forfeit any payment to ATF’s for a no show.

What else is detrimental to ATF’s in the post COVID landscape
If you are looking for further evidence to support the realisation that the landscape and relationship between DVSA and ATF’s is being devalued (to the expense of ATF’s), then look no further than the latest demand to erode ATF’s revenue further: ATF’s are no longer able to carry out voluntary tests when DVSA testers are on site.

What pain are DVSA taking to help their partners?
Considering ATF’s have had their revenue reduced to zero because of the flawed logic to exempt heavy goods vehicle testing whilst government guidelines permitted vehicle repairs and inspection, ATF’s have now been told that they are not allowed to earn income from voluntary tests, coupled with reports that, despite the 7 day notice period, many ATF’s hadn’t heard until 3 days prior what their allocation was, we have not seen any evidence that DVSA are offering any assistance or taking up any slack for their partners. It is clear that their policy is for ATF’s to inherit the problems (not of their making) and pay for everything.

What opportunity presents itself with the Bill?

The Business and Planning Bill refers specifically to HGV and PSV testing, so it is reasonable and fair to take this opportunity to table amendments to provide for qualified testers employed by ATF’s.  The amendment would go in after clause 13.  

In the lead up to this opportunity, Lord Attlee has already been busy by asking questions to her Majesty’s Government.

Letter 1 – Question 1:
HOUSE OF LORDS 
PARLIAMENTARY QUESTION FOR WRITTEN ANSWER 
The Earl Attlee 
To ask Her Majesty’s Government what plans they have, if any, to require statutory inspections of boilers and pressure vessels to be conducted by inspectors who they (1) appoint, and (2) fund. HL55n77

Letter 1 – Answer 1:
Baroness Steadman-Scott: 
Under the Pressure Systems Safety Regulations 2000 the users and owners of boilers and pressure vessels have a statutory duty to have them examined by a competent person at periods specified in a written scheme of examination. 

Her Majesty’s Government has no plans to appoint inspectors or fund inspections to deliver these statutory inspections. 


Letter 2 – Question 2
The Earl Attlee (For written answer).
 
To ask HMG:
 
To ask Her Majesty’s Government what plans they have, if any, to require statutory inspections of:
 
mobile cranes of over 10,000 kgs lifting capacity,
fixed cranes of over 10,000 kgs lifting capacity,
electrical installations in public buildings, and
passenger lifts
 
to be conducted by inspectors who they (1) appoint, and (2) fund.

Letter 2 – Answer – Awaiting response from HMG

Why are we asking these questions in particular?

By asking these questions, Lord Attlee is hi lighting the flawed logic. On the one hand – government is funding and appointing testers, via DVSA, to inspect vehicles, on the other hand, the government allows expert private sector employees to deliver the statutory inspections. The logic follows; If the government has mandated that dangerous pressure systems, boilers, mobile cranes, fixed cranes, electric installations and passenger lifts, to be inspected by industry experts, and has no plans to change this, then why should goods vehicles and passenger carrying vehicles be treated differently?

The outlook is grim, ATF’s, bus operators and hauliers are asking; would the outlook be so grim if the industry could be responsible for supplying their own expert testers so we could just get on with it. The argument for some form of delegated testing is stronger now that it has ever been.

Please pledge your support for ATFOA by becoming a paid up member.

Thank you for reading

Stephen Smith
ATFOA Chair

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.

ATFOA Survey results & live map update

Go straight to the survey here ATFOA Survey

Dear ATF,
DVSA director of operations (South) has been quoted in Motor Transport as saying “We do not agree with the recommendations made by the ATFOA.”.
If true, this is extremely disappointing as last time we communicated, DVSA confirmed they were keeping an open mind.
Indeed, they reached out to their ATF partners and requested information, that ATFOA submitted on 4th May, as a series of proposals supporting the main solution of delegated testing.
Despite the absence of a formal response from DVSA, ATF Operators continue to complete the ATFOA survey that builds the real time testing resource map that now shows over 2500 potential private testers are available. – we live in hope.
Whilst the testing community and hauliers await for DVSA’s decision, there is a clear pattern forming from the result of a particular question from the survey;
Please see results below for when we asked you – “What best describes your perception on government guidelines and DVSA’s decision to suspend testing”
23.7% Answered “It is correct that DVSA suspend testing”
 
76.3% Answered “The logic is deeply flawed to suspend testing, DVSA testers, DVSA enforcement and private industry technicians all work in a similar environment so should all be treated the same.”

Screen Shot 2020-05-11 at 22.04.05

 

 

Delegated testing database for HGV/ PCV MOT – real time map of UK

Go straight to the survey to add in your testing resource here >>>
Dear ATF,
Firstly, may I thank everyone who has shown their support recently by becoming a fully paid up member. This is much appreciated.
And secondly, may I ask that if you have not yet joined, but like what we are doing, then you consider supporting ATFOA financially to help us meet the needs of our campaigning.
The ATFOA team is working round the clock communicating at the highest level of government and with DVSA and other stakeholders, lobbying on your behalf. this takes a great deal of time so any contributions will help subsidise the vital role ATFOA are playing at this time.
During our communications with DVSA, ATFOA have been asked to provide a set of proposals to help resolve the testing exemption gap. ATFOA applauds their open mindedness and hope they take on board our main drive to accept that delegated testing is the only plausible solution to resolve the situation.
Although our main proposal to resolve the issues created by the exemption is delegated testing, ATFOA have provided a whole range of suggestions – please see previous blog.
ATFOA are now looking for your assistance. We thought it helpful to build a database for DVSA to appreciate the private testing resource availability for their consideration.
Please complete the survey here >>>

 

ATFOA Proposals for DVSA to help resolve the testing gap

Proposal 1

Delegated testing

Pro’s

ATF’s can instantly mobilise and offer flexible testing 24-7

DVSA white coats can audit ATF’s with unannounced visits

Challenges

Training private sector technicians to become testers

Agreeing minimum technician accreditation, such as IRTEC and/ or 5 years experience.

Proposal 2

Start Re-commissioning ATF’s now by regions that have been least affected, such as starting with Scotland first.

Proposal 3

Use Earned recognition and OCRS scores to regulate fleet operators that also run an ATF so they can test their own vehicles

Proposal 4

Temporarily deputise a third party organisation such as DEKRA or FTA that have an infrastructure of engineers to assist with the backlog to start testing at ATF’s.

Proposal 5

Class 5 tests for PSV’s

Proposal 6

Reinstate DVSA enforcement and retirees

Proposal 7

Financially assist ATF’s that have had to fund the administrative and operational burden of test cancellations and now have to fund the re booking process.

Financial assistance

ATF’s to retain both ATF fees and pit fees to pay for the lost revenue.

Proposal 8

Lift a ban on all ‘over time’ for DVSA tester staff so they can increase their daily testing capacity to help catch up.

Not recommended

Push all tests back 3 months

Negative effects of pushing back testing

ATF’s would lose 3 months revenue which would be catastrophic and lead to some ATF’s going into administration:

Many fleet operators would be out of synch with their normal test scheduling which would negatively impact on  their delivery of services; such as

  • Gritters – presently test in October/ November so they are ready for the winter frosts
  • Most, if not all hauliers and other supply chain operators that maximise their fleet’s mobilisation for the pre Christmas delivery market. A 3 month ‘push back’ would mean testing their vehicles over Christmas, their busiest period.
  • Multi car carriers – generally the busiest time is summer for many breakdown recovery operators who repatriate vehicles from all across Europe during the summer holiday period, so they are normally tested in Spring, not 3 months later in their busiest period.

Conclusion

Consider one, all or some of the proposals above.

The longer the testing suspension continues the larger the backlog becomes, so if there is no resolve soon (by end of April 2019) the bigger the problem becomes. A resolve from government is required immediately so the market has time to adjust, the response must ensure the market has 3 weeks to prepare for the re-mobilisation of testing.

Recompense vehicle operators who have not been able to test, for their short term MOT certificate that will not last 12 months. Offer them a reduction or complete fee holiday in statutory fees, but not ATF pit fees.

Ultimately, the only feasible proposal is to temporarily delegate testing to ATF’s. The ATF industry has the expertise, the skill, the knowledge, the capacity, the infrastructure and ‘the will’ to do it. These are unprecedented times, we need unprecedented resolutions to get back to normal.

 

Elephant in the room – Why are DVSA testers treated different?

Elephant-in-the-Room-animation-still970x546-720x405Elephant in The Room – Why are DVSA testers so special?

“is a metaphorical idiom in English for an important or enormous topic, problem, or risk that is obvious or that everyone knows about but no one mentions or wants to discuss because it makes at least some of them uncomfortable or is personally, socially, or politically embarrassing, controversial, inflammatory, or dangerous”

I have had tens, if not hundreds of conversations with many ATF’s and stakeholders since the decision was made to suspend testing completely. As an industry we have largely accepted the decision without question.

ATFOA are now challenging this Taboo subject: why is it that all other partners in the transport sector, including DVSA enforcement, can continue to operate in some capacity whilst following government guidelines on social distancing, when DVSA testers are treated differently and have suspended testing in its entirety?

If you look at the logic, the reasoning to suspend testing completely but allow for all other transport partners (including DVSA enforcement) to continue, is not just contentious, its flawed.

DVSA testers aren’t different at all to the rest of us. They operate in exactly the same spaces that the rest of the industry does. The ATF environment is mostly in the open, or at least in an open area, with only the tester operating in his own space. Workshops operate in this environment. I appreciate entering the cab may be an issue (but it’s not for the rest of us who follow government policy).

There could easily be a temporary variation introduced so DVSA do not need to enter the cab, or quite simply, the cab can be cleansed, like all other private sector workshop policies.

A few stakeholders had mentioned that the DVSA union representatives had a strong influence on the decision to suspend testing. If this is so, I’d like to hear the logic so the rest of the industry can understand why testing practice is treated different to driving, enforcement, workshops, delivery and loading practice etc, etc.

The private sector has developed its services and infrastructure around the supply and demand of customer requirement, it can instantly flex and continue to function to almost any situation – even COVID 19. Why can’t DVSA testers?

ATFOA have maintained that ATF’s have the experience, the skillset, the professionalism, the infrastructure, and the knowhow to mobilise tomorrow and start delegated testing, albeit temporarily. So, if DVSA continue to say they can’t do what the rest of the industry is doing, then we can do the testing for them.

There is never a stronger argument for delegated testing, based on what is happening right now; the transport industry is continuing to operate (albeit on a reduced capacity and obeying government guidelines) but DVSA testing is being treated differently and is suspended completely.

ATFOA will continue lobbying government and DVSA so they understand this: the longer nothing is done the bigger the problem grows. A decision is needed today