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Call us on 01983 810012 ask for Steve Cocks

August 2021 - Drivex replies to the 'open letter to the logistics sector'

The UK Government is considering the biggest shake-up in driver licencing and testing since 1997 with some worrying proposals. Here is our response....


To:

Rt Hon Grant Shapps MP

Rt Hon Thérèse Coffey MP

Rt Hon George Eustice MP

 
I am writing this in reply to your open letter to the Logistics Sector dated 20 July 2021.
 
While your efforts to increase the capacity of LGV driving tests is welcome this cannot be at the expense of road safety. 
 
At Drivex we specialise in providing driver risk management and driver training solutions for companies across the UK.

 
We strongly believe the proposals you outline are flawed, particularly with regard to your statement:
 
‘We will also consider changes related to requirements for newer car licence holders to take extra tests to drive car/van and trailer combinations, with a view to consulting about removing this extra test requirement. This could also provide more testing capacity to be used for Heavy Goods Vehicle tests.’
 
This would appear to read that you are looking to do away with the need for training and testing for drivers to acquire licence category BE? This email will deal with this issue specifically.
 
Prior to January 1st 1997 category BE was given automatically when a driver passed their car driving test, together with categories C1, C1E*, D1* and D1E* (*restrictions applied). Among the population there is still a vast amount of misunderstanding about these licence categories both pre and after 1997. However, quite rightly, since that date drivers in these categories have to undergo a licence acquisition process to drive vehicles in these categories and even more training and testing if driving professionally. However, licence category BE is unique among these categories in that it does not require any further medical or theory upgrade before progressing to the practical BE driving test.
 
Safety Considerations
 
Trailers in the BE category can weigh as much as 3500kgs and have cornering and braking characteristics significantly different (worse) when compared to the towing vehicle.
The risks associated with trailer handling characteristics are magnified significantly when trailers are used in an unsafe or unroadworthy condition.
Accelerating with a heavy trailer significantly reduces the speed at which a vehicle can emerge from a junction and combined with the additional length of the vehicle, means the driver has to understand how to judge suitable gaps at junctions and roundabouts.
Navigating tight corners and junctions requires a different line when towing a trailer in order to avoid mounting the kerb, striking pedestrians and other vulnerable road users, other vehicles and / or property.
Coupling and uncoupling trailers of this type can lead to serious personal injury and damage to the vehicle, trailer and / or other property if carried out incorrectly.
Reversing with a trailer is totally different to reversing a car or van. There are many more considerations to take into account regarding steering technique, positioning, observation and vehicle sympathy. Again, carried out incorrectly there is significant risk of injury to bystanders and damage to the vehicle, trailer and / or property if carried out incorrectly.
 
Indeed, as recently as May 2019, figures from Highways England, the government organisation in charge of the country’s motorways and major A-roads, said around 4,000 accidents a year involved trailers of one description or another. That’s an average of just under 11 per day. As a result, Highways England was then calling on drivers to ensure their trailers and caravans are towed in the safest way possible. The organisation urged drivers to make sure they have the right licences to tow their trailer, and to ensure the vehicle and trailer are loaded properly. Allowing untrained, unqualified drivers to tow heavy trailers will increase the number of these crashes.
 
Within the consultation you state that you are looking to find ways to encourage people to take professional training of vehicle and trailer combinations. We already have that, it is called a DVSA driving test. There is no doubt that the formal BE driving test is the best way for drivers to demonstrate a proven, rounded ability to deal with the issues listed above.
 
Testing Data
 
Between April 2012 to March 2021 the DVSA conducted 200,732 BE driving tests.*
This represents an income to the DVSA of over £23million.
In November 2013 the DVSA made it mandatory to use loaded trailers on BE tests.
Of these 200,732 tests there were 139,345 passes*
This means there were 61,387 candidates that failed.*
This is a pass rate of 69.42%*
Due to the minimum test vehicle requirements for a BE test, the vast majority of candidates take their test in a trainer’s vehicle and trailer combination following a training course.
 
* Source: Table DRT0221
Practical car and trailer test pass rates by gender, monthly, Great Britain, from April 2012 to March 2021, 
17 June 2021 update
 
Analysing these figures:
 
1. The DVSA and the UK Government concurred, that trailers on driving tests should carry a load to greater represent the characteristics of real-life driving with these types of vehicles.
2. Even with the majority of candidates taking some training prior to test, the BE test pass rate is only just over 69%. 
3. This means that over 30% of candidates did not reach the standards required to obtain a BE towing licence.
4. In effect, abolishing the BE test requirement would have therefore allowed these candidates to tow anyway. That’s a total of 61,387 drivers.
5. In reality, the number of drivers who would not be up to the BE test standard would have been much higher since a high number of candidates take training BECAUSE THEY KNOW THEY HAVE TO TAKE A TEST! Without a formal test, many people would not invest in training, preferring to save the money and ‘make it up as they go’. On that basis, how much worst would the Highways England statistics referred to earlier be for trailer related incidents?
 
These figures surely illustrate there is an increasing need for a formal BE driving test? Whichever way the figures above are interpreted, they definitely do not show abolishing the BE driving test is a sensible option. A voluntary training program is unlikely to have a high take-up if drivers already have the licence entitlement. As an example of how the public perceive ‘voluntary road safety’ one only has to look at the poor take-up of Pass Plus among new drivers. Consider this, would drivers ‘volunteer’ for a speed awareness course if they weren’t dodging penalty points on their licence? As a further point, whenever I start a BE course with a client, I cannot recall a single candidate in over 18 years of BE instruction, who was at a sufficiently high level of ability and knowledge that they could have passed a BE test without any training…..abolishing the BE test would have allowed all of these candidates to tow heavy trailers. There is no doubt removal of BE testing will lead to an increase in trailer related crashes and incidents with a corresponding rise in deaths and serious injuries. 
 
In your letter you touch upon the advantages that Brexit can give the UK in being more independent  in making our own rules. But with independence comes responsibility. The UK has a road safety record to be proud of when compared to most of our European neighbours. Now is not the time to throw away so much of the good work that has been done to achieve this status by taking such a retrograde step in driver licencing and testing.  Another factor to consider when comparing ourselves to Europe is the corelation between UK and overseas driving licences. At present there is a direct comparison between EU and UK licence categories. By ‘giving away’ a free BE entitlement when a driver passes their category B car driving test will mean that a UK driver with a BE entitlement has no proven level of skill, knowledge and experience when towing. The UK driver would in effect have an inferior quality BE licence compared to their European counterpart. Would, as an example, the French authorities be happy letting a UK driver drive in France when towing a caravan, horsebox or boat trailer on the inferior UK BE licence?
 
Options
 
The stated aim is to increase the number of lorry drivers. I have to say as a personal observation that at present I don’t see the country grinding to a halt through lack of supplies. The qualification process to become a lorry driver involves the prospective driver jumping through several hoops, of which the practical driving tests (both Module 2 and Module 4) are the last. Throughout the last 18 months access to many facilities has been difficult to say the least. Lack of staff at DVLA processing driving licences, lack of availability of GPs for medicals, lack of theory test services as well as lack of driving tests of all categories. These are all issues that need to be addressed, not just the number of available driving tests.
 
In the provision of more LGV driving tests no options are going to give an overnight fix. The following options could be considered:
 
Train more car examiners to carry out BE tests thus freeing up those qualified to carry out LGV tests to exclusively conduct LGV tests.
Maybe create a separate reverse manoeuvre areas at test centres where BE tests are conducted and where there is space available.
At test centres where BE and LGV share the reverse manoeuvre area, stagger the start times of BE tests so that they can run in between LGV tests.
 
The possibility of having trainers sign off the candidates’ reversing and uncouple/recouple elements has been mooted. In theory this may work. However, if this is being considered as a short term fix then the following needs to be addressed with some urgency:
 
1. What accreditation will DVSA be giving to trainers, how do they apply and how long will it take to be accredited?
2. Who is going to carry out this accreditation? Taking examiners away from testing duties would surely be defeating the whole point of the exercise?
3. Will trainers be able to access DVSA reverse manoeuvre sites for signing off purposes?
4. If trainers are to provide their own reverse manoeuvre sites to sign off candidates, presumably DVSA will be required to sign these sites off as ‘up to standard’? Many trainers use part-time locations (such as village hall or sports club car parks) as reverse manoeuvre practice sites which are perfectly adequate as training locations but would not be suitable to be marked out as per a DVSA test centre. Therefore, finding suitable alternative sites that would meet DVSA standards could again be a lengthy (and potentially costly) process which defeats the whole point of the exercise?
 
Another point to consider is that, with the entire test being conducted by a DVSA examiner there is a distinct difference in role between the trainer and the examiner. This reinforces the status of the test for the candidate and also gives them confidence that the standards required are fair, in that the standards are the same across the UK at all test centres. For DVSA to sign off a trainer to deliver BE reversing and uncouple/recouple testing, there surely must be some kind of accreditation process which will take time to implement and utilise a lot of supervising staff to carry out this accreditation? I am involved with taxi testing standards implementation and delivery across the UK with the Blue Lamp Trust and it very quickly became clear that the potential conflict between the same organisation delivering training and testing was unviable. Hence, Blue Lamp Trust focus purely on testing and advise candidates to seek professional training elsewhere in preparation for their test.
 
 
As a professional trainer I have over 26 years’ experience of being a DVSA ADI, over 15 years of being a DVSA Fleet Instructor, over 12 years as a DVSA-accredited Fleet ADI trainer, and 18 years’ experience as a BE trainer and a proven track record in developing road risk management systems for clients in the UK and overseas. Prior to working in the field of driver training I gained an engineering degree at Aston University and worked for Jaguar as a Vehicle Development Engineer, so I would like to think that the points I have discussed above are accurate and my recommendations are based on both factual evidence and professional experience. I can honestly say that every single driving instructor (car, car and trailer, lorry and bus), DVSA examiner (car and vocational) and every single road safety professional with whom I have consulted on this matter have agreed wholeheartedly that the proposals to scrap BE testing and provide short cuts to CE entitlements is going to lead to an increase in road fatalities and casualties. It is quite frankly, extremely worrying that this is even being considered let alone the possibility that it may happen, in response to a temporary shortage of lorry drivers in the UK.
 
With this in mind, please can you answer the following questions:
 
1. Millions of drivers have taken and passed the BE driving test and can now tow heavy trailers more safely than ever was the case prior to 1997. How do you now justify sacrificing road safety by abolishing category BE testing in order to gain some additional lorry testing capacity? How many deaths a year are acceptable where the deaths can be attributed to lack of training and understanding of towing a loaded trailer up to 3500Kgs?
 
2. Have you taken into account the number of DVSA examiners who are leaving the industry because they disagree with this whole process on many different grounds? This is not hearsay, this is fact. This loss of experienced examiners could outweigh any gains being made through examiner recruitment and training. What steps are you taking to address this issue?
 
3. The pandemic has caused shortages of supply in terms of manpower, resources and products in many industries across the UK. There is a natural resetting going on which is affecting virtually everybody and every industry. During the pandemic the health and wellbeing of the population and the ability of the NHS to cope has appeared to be at the top of the Government’s agenda. How do you now justify sacrificing the safety of the public by allowing untrained drivers to tow heavy trailers?
 
4. What support and compensation will the government be providing to the thousands of BE trainers, who have invested heavily in vehicle and trailer combinations, committing to leasing or buying suitable practice areas etc, when they potentially are out of work overnight if BE testing is abolished?
 
 
I look forward to your urgent reply on this matter.
 
Kindest regards
 
 
Steve Cocks B.Sc.
Director
Drivex Ltd.
01983 810012
steve@drivex.co.uk