The DVA states that there must be “satisfactory facilities and arrangements for ensuring that vehicles are maintained in a fit and serviceable condition.”
The practicalities of this are wide-ranging.
To start with you must have a documented policy of maintenance, whether this is carried out in-house or externally. If you are audited, you will need to show your inspection and maintenance scheduling processes and provide evidence of the processes being followed. Your maintenance policy must also extend to hired vehicles and trailers.
If you maintain your own vehicles:
The auditor will need to be satisfied that your maintenance facility is adequate for your needs, including the size of your facility in relation to your fleet size, suitability of tools and equipment that you have, and the competence of your staff. You may be required to show training records for staff to prove that their knowledge is appropriate and up-to-date. And you will need to provide documentation relating to servicing/calibration of your workshop equipment.
If you employ a third party provider to carry out your maintenance:
Your maintenance provider(s) must be named on your operator licence and the auditor will check that what you have stated is the reality. They will want to see a signed contract with the provider and will want to know how you regularly review and quality check the service provision.
In either case maintenance records will be reviewed by the auditor. Maintenance records must be retained for at least 15 months.
The auditor will expect you to know your statistics. They won’t just want to see evidence of test results; they will expect to see evidence of trends and issues being monitored too.
Also consider where records are kept. They must be held at an authorised operating centre specified on your licence. I know of one case recently where an operator failed an audit because its vehicle maintenance workshop wasn’t a named operating centre, but this is where the company holds its maintenance records. Whilst this seems logical, according to the letter of the law this is not the correct practice.
Your auditor will ask to see a fleet list and evidence that it is up to date to ensure that the number of vehicles and trailers authorised on your licence is not exceeded. Be aware that even vehicles on short term hire count within you authorised number of vehicles.
A robust system must be in place to ensure vehicles with vehicle off road (VOR) status are not used. The auditor may seek to cross-check VOR’d vehicles against drivers’ hours records.
Your vehicle maintenance is inextricably linked with defect identification. Check out the third in this advice series – Drivers’ First Use Checks & Defect Management.