Keeping out of the Public Inquiry Courtroom (Routeone magazine  issue 199 - 29.09.07)

VOSA examiners can turn up on the doorstep at any time to review an operation. Whether unannounced or by appointment, a visit usually occurs following a roadside check where either a vehicle prohibition or traffic infringement has occurred.  A series of PG9`s or high MOT failure rate will also provoke a visit. VOSA may have received a complaint from a third party – a member of the public, a disgruntled past employee or even a current employee, over issues within the operation. It is VOSA`s policy to follow these up.

At the visit it is usual for vehicles in the depot to be inspected at random. If faults are found on any vehicles parked in the depot, which have not been prevented from being used as VOR,  PG9 prohibition notices will be issued.

Organised presentation of vehicle and other records is important. Vehicle files should be  presented containing all defects recorded by drivers, rectification details and spares fitted, job sheets, service records and detailed inspection records.  Calibration certificates for speed limiters and tachographs should also be filed. It is advisable to keep records of road wheel movements and re-torques. Wall mounted flow charts prove good organisation when recording safety inspection dates, tachograph calibration dates and MOT test dates, with time ahead of the MOT to prepare for presentation. Thorough vehicle preparation is vital to maintaining a high pass rate as even a loose seat belt anchor bolt will lead to a failure. Operators when comparing their MOT pass rate with VOSA`s often find that VOSA have recorded a higher number of failures. Remember that if any adjustment is made during the MOT, the testers report will be marked PRS (pass rectified at station) which is classed as a failure. Headlight aim is one of the most common examples. Operators are advised to arrange a pre-test of brakes, emissions and headlights. Keeping a fleet in road worthy condition throughout the year depends on monitoring by daily walk round checks and the thorough regular safety inspection.

During the visit a traffic examiner will request sight of driver records including copy licences. If a full compliance check is to  be carried out regarding drivers` hours  and the keeping of tachograph records a notice will be served on the operator to provide these by a certain date, when they will be collected an inventory prepared and a receipt issued. Payroll, clockcards, time sheets and out of scope vehicle records will be requested in addition to tachograph charts.

When the analysis is complete VOSA will return all records and raise any issues they are concerned about. This will involve interviewing the Transport Manager and drivers possibly under caution. All notes taken will be forwarded to the traffic commissioner`s office so that consideration can be given as to whether a public inquiry is necessary or not. At this stage the traffic examiner, if finding infringements will wish to see the systems and controls that are in place for scheduling work and monitoring records. Infringement reports being issued to drivers and their feed back to prevent repetition will be needed. It will also be expected that a disciplinary process will be in place to deal with more serious and repetitive infringements. Where poor scheduling has led to the law being broken it will be expected that preventative action has been taken. Proof of suitable induction and on going training of drivers on tachograph and hours rules must be shown.

Part time, casual and agency drivers are of particular concern. Traffic examiners will require proof that all drivers working on a casual basis are signing a declaration as to when they last worked, when and where they will be in future and that they have had or will have daily and weekly rest periods in accordance with EC561/2007.

Where falsification of records on the part of the operator or driver is found VOSA will apply to the magistrates court for a summons to be issued. The outcome of any court case involving the operator or one of its employees must be reported to the traffic commissioner.

Missing mileage is a serious indication that charts may not be being handed in or the vehicles used without charts in the tachograph. Every vehicle including out of scope vehicles should have a mileage record sheet on board to record.

The company partners or directors and the designated transport manager (CPC holder) will be held responsible at a Public Inquiry for failure of the company to comply with the undertakings which were a condition of the granting of the operators licence. So start by looking at the terms of the “O” licence then check your systems their control and records or obtain the services of an outside consultant to review your operation.

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Preventative Maintenance (Routeone magazine  issue 176 - 19.04.07)

One of the greatest contributors to operating cost is the roadside breakdown - stranded passengers, drivers hours ticking away and reliance on the manufacturer`s lifeline breakdown service.

Rear engined vehicles suffer with overheating problems unless the cooling system is inspected regularly. The water and charge air radiators which are double banked to save space become fouled on the airside usually in the space between the two - the powerful fans acting as vacuum cleaners drawing in leaves and plastic bags. Gradually the fouling margin will be exceeded then at full power the engine will overheat.  It is extremely difficult to clear out this debris with the radiators in situ.  Sealing the gap round the outside of the radiators not only improves air flow across the cooling surface but also reduces the ingress of larger items of debris between them.  Compressed air or high pressure water should be used regularly to keep the radiator core clear.  The inside of the radiator will remain fairly clear of contamination due to the corrosion inhibitors in coolants.  

Adequate engine cooling relies on the pressure within the system being maintained. Leakage or a failed pressure cap will reduce performance particularly at altitude or where prolonged high engine power is required.

A turbocharger centre bearing failure can lead to a high ingress of dirty engine oil entering the intercooler radiator and fouling the tube walls reducing intercooler efficiency. When replacing a turbocharger it is good policy to flush out the intercooler. Loss of power will occur if the intercooler leaks or becomes inefficient leading to the engine management system lowering the power output to compensate for the reduction of charge air to the cylinders.

Analysis of failures away from base shows that windscreen wipers are high on the list.  Keeping the wiper arm securing nuts tight saves much trouble. These loosen gradually on the tapers which causes wear by slipping necessitating spindle replacement.

Lubrication of all locks and hinges particularly on wheel arch panels saves time and effort when fitting snow chains on winter ski work. These items require regular attention and exercising to prevent seizure particularly in the winter months when road salt accelerates corrosion.

Common breakdowns occur due to fuel starvation - the prime cause being blocked filters.  Strict monitoring and regular changing of all filters will prevent many problems as will checking fuel line unions for possible air ingress points.

Compressed air filters and dryers should be checked for function. Lubricant ingress upstream of the air dryer from a worn compressor will shorten the life of the desiccant.  Air line lubricators which keep air cylinders and door actuators working freely should be topped up with the correct grade of oil.

The main cause of air conditioning plant failure is dirty airside evaporator filters causing high pressure drop.  In the summer it will be necessary to change these twice a month.

Electrical problems are mainly related to poor charging. Alternators should be checked for output.  It is possible for an alternator to fail without there being any visible warning.  This places a higher load on the other which will then burn out. Battery casings should be washed off at each inspection and terminals checked for cleanliness and security.  Chassis/body to engine earth cables should be checked for continuity and security - inadequate earthing causes poor starting and increases the risk of fire.

Top of the list for failures is belt shedding.  There can be as many as a dozen drive belts connecting the crankshaft to the water pump, aircon compressor, alternators and cooling fan.  Failure of one of these belts can “de-rail” several more.  The vehicle should carry a complete set of spare belts some of which are not readily available at the roadside.  Driver education on keeping engine revs in the green sector and regular inspection of the belts and the tensioner bearings minimises the risk of failure.

Operators having Scania Comfort Shift gearboxes should make sure that the fault code RAM (random access memory) is downloaded and analysed regularly to highlight any driver related use and abuse of the transmission.  Failure to do this will result in gear change difficulties when the memory becomes full.  Drivers should be trained on how to operate this type of gearbox in safe mode allowing movement of the vehicle to a place of safety should a problem occur.

The days have gone when the driver could be expected to solve a problem other than a minor one, although some old timers still carry a substantial tool kit.  My own experience over many years of continental touring proved that simple checks by fitting staff and drivers before leaving the depot, in addition to the mandatory walk-round safety check, will prevent many breakdowns which are beyond the driver`s ability to correct at the roadside.

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Vehicle Weight (Routeone magazine - issue 201 – 11.10.07)

 There is an issue over the GVW(gross vehicle weight) or legally permitted mass of twin axle coaches.  Experience shows that a coach carrying 49 passengers and touring luggage can  be overweight. If detected at the roadside, this will lead to an immediate prohibition and fines for the operator and driver. Many operators believe that if the seating capacity is not exceeded they have nothing to worry about – this is simply not true.
In the UK legally permitted mass was only raised to 18 tonnes on January 1st 1999, nearly 10 years after the  EU85/3 maximum was raised from 17 tonnes to 18 tonnes in the rest of Europe.

Above is a typical plate showing the maximum design weights (technically permitted mass)  and its distribution between axles for the vehicle and  the  weights applicable  in the UK (legally permitted mass)
If a vehicle is stopped on the road after being “weighed in motion” or routinely directed to a weighbridge for checking, it is the weights on the “legally permitted mass” side of the plate which will be applied.
On the example plate above for the technically permitted mass to be utilised a change in the law will be required for vehicles registered in the UK.
The difference between unladen weight (ULW) stated on the nearside of the vehicle and its maximum gross vehicle weight is payload.  As coaches have been equipped with more and more equipment; R66 rollover strength , toilets, TV`s, videos and galley equipment so the payload has gradually reduced. At the same time the average weight of passengers and luggage has increased. So the question is how many passengers and luggage can be carried legally on a twin axle coach?

A tour departure may have a crop of heavyweight passengers and luggage. When attending loading points I always carried a set of bathroom scales in the boot of the car to make discreet spot checks on heavy luggage. It was tempting on many occasions to risk all and ask the passengers to step on the scales!  Averaged over a number of checks (250 cases) I found passenger luggage weighed in at 21 kgs(44½ lbs). The heaviest case weight ever recorded was 37 kgs (81 lbs). Assuming 100 kgs allowance per passenger and luggage on a 49 (plus driver and courier) seat coach  ie  51 x 100kgs = 5.1 tonnes payload + ULW. This could exceed the legally permitted mass if the ULW weight of the vehicle is greater than 12.9 tonnes.
Gross vehicle weight can be within the plated limit with either axle being over weight, which would also be illegal. When a vehicle is checked each axle is weighed to obtain the total vehicle weight. Distribution of the load is important.

I am always surprised when checking operators` fleets, at the number of coaches put into service before 1999 which have not had plates updated to 18 tonnes.  Re-plating is a simple process involving a small fee payable to the manufacturer for the new plate.  The DVLA must be informed of a construction and use change. Without this increase the coach will invariably exceed GVW when fully laden with luggage. It is only possible to re-plate to the limit of technically permitted mass (design). If this is less than 18 tonnes the legally permitted mass will equal the technically permitted mass. For there to be an increase in technically permitted mass it would be necessary to upgrade suspension, brakes and tyres. 
 Drivers seem to have very little knowledge of vehicle weight and they do not travel lightly.  Mechanics preparing vehicles for the annual test have regularly drawn my attention to the amount of equipment they carried in the lockers - heavy tool boxes, boxes of books, water containers, oil and other items – all adding to the running cost of the vehicle and the risk of running overweight.
Weighing coaches at the point of departure on one occasion; with only 34 passengers on a 40 seat vehicle and luggage, the legally permitted rear axle weight was exceeded by 10%.  It was impossible even by re positioning the luggage to get within axle weight. 
Manufacturing to closer tolerances and using where possible lower density material would reduce weight. Advice on distribution of weight should be provided to help operators and drivers to reduce overloading risks and the effects of instability.
 Describing one medium sized suitcase by its dimensions, would be best practice , but I remember the sales department received so many calls from customers when this approach was tried we had to drop the idea.
One final thought – perhaps luggage manufacturers should be targeted to label their largest products as unsuitable for coach travel.

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LICENCING FOR PERMIT BUS OPERATORS

Section 19 Operators can employ paid drivers of hire or reward vehicles.

This does not necessarily mean that an O licence is required.

A section 19 operator would only require an O licence, transport manager etc if they operate the vehicle with a view to profit.

Section 22 drivers cannot be paid when driving a permit minibus.

The drivers licence would depend on the size and weight of the vehicle, whether paid, when they obtained the licence and where it was being driven.

Large buses 16+seats operated under a permit require to be driven by a full D licence holder regardless of whether the driver is paid or not.

Driving licences issued before 1997 can be used for driving permit mini-buses (9-16 seats) and the drivers can be paid to do so.

Licences issued since 1997 can be used to drive minibuses on the B entitlement on a not for hire or reward basis for social purposes for a non commercial body or under a section 19 or 22 permit. They must in both cases be over 21 and held a full B licence for two years and must be driving on a voluntary basis vehicles not exceeding MAM of 3.5 tonnes or 4.25 tonnes with lift. (This applies in the UK only)

For operation elsewhere in the EU permit drivers need a full D or D1.Licence.

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DRIVING TIPS

Turning right

When turning right at a road junction keep the steering wheels in the dead ahead position until the road is clear to cross. In the event of a rear end shunt to your vehicle the risk of being forced into the path of oncoming traffic will be reduced.

Turning right across double white lines

If turning right causes the vehicle to cross the double white lines the vehicle must be brought to a standstill before the right turn manoeuvre is commenced.

Left hand drive trucks

Drivers of these vehicles are now being issued with stick on Fresnel lenses for their offside cab windows at the entry ports. This improves the blind spot vision on the off-side of the vehicle.  Drivers on motorways should however ensure that they do not remain in the blind spot area to the offside of right hand drive vehicles for any longer than is necessary to carry out an overtaking manoeuvre.

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SPEED LIMITER LAW

Mini buses come in to scope on January 1st 2007. This the latest step in a phased implementation of the 1992 EU directive. The final part of the directive covering vehicles used only in the UK, over 8 seats and first registered after January 2005 will come into force on Ist January 2008.

The Latest change affects PCV`s over 8 seats(all weights) registered between 1st October 2001 and 31st December 2004 which are fitted with diesel, LPG or natural gas Euro3 engines. Petrol vehicles are unaffected. For vehicles of these types used outside the UK the change came into force on January 1st 2006.

Speed limiters should be set to a stabilized 100 km/hr and vehicles fitted with a speed limiter are automatically banned from the off-side lane of motorways having more than two lanes, regardless of weight or carrying capacity.

It expected after the final stage of the directive has been implemented, as above, after January 1st 2008 the national motorway speed limit for PCV`s will be lowered.

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CHECKING DRIVING LICENCES

Every drivers licence should be checked 6 monthly for new endorsements and entitlement to drive and to ensure that the driver remains in warranty from an insurance point of view – ie remains in the age range 25 to 70 and has the correct level of experience.

New recruits should be asked to complete the DVLA Mandate for release of information which for payment of a £5.00 per application fee provide the operator with a comprehensive full licence history.

These checks are vital to ensuring that your operators driving staff are totally legal and that there will be no insurance disputes at a later date.

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