Grumbles from the Gearbox

What is the point of the DVSA

Inner mind of the dvsa think tank- anyone found the answer yet?

At the AADI we share the frustration of many of our colleagues, who span the length and breadth of the UK. Yes we too feel deflated by the latest proposal regarding trailer tests being scrapped. This is surely harking back to an era, that the powers that be were unhappy about. Indeed for countless years driving licences have contained categories. You would not expect to take a test in a bus or lorry having never driven a car or passed a category B test.


There have been many notable incidents over the years whereby either life changing injuries or death have occurred due to unsafe loads, faulty trailers, lack of knowledge, handling just to name a few.

No one can ever forget the tragic loss of life to :-


https://www.bristolpost.co.uk/news/bristol-news/freddie-hussey-half-trailers-unsafe-3113667


We feel here at The AADI that both the government and the dvsa need  to reconsider their idea. It will have a huge impact for all the wrong reasons on our roads, it will also stretch the police, Highways England and not to mention the VOSA section of the DVSA

 Yes there are massive issues relating to any form of driving test, but this is simply not the answer to the problem. The issue surrounding the problem that we all face simply bad decisions in government and the agency. Shortage of front line driving examiners is nothing new, nor is a high volume of driving tests awaiting a slot. During the reign of Allister People's the ex CEO of dvsa, his management conveniently scrapped the national waiting lists for the UK driving tests in all categories. Customer services have never excelled in contacting customers to alert them of cancellations.


So we urge the dvsa and transport minister to reconsider their decision and retain the test and a minimum number of hours of training to ensure we do not see an increase of incidents surrounding trailer safety.  In support of this we submit our thoughts on the current situation below.

......................



Trailer Safety Statutory Report - July 2019

A report by Michael Ellis MP.

(response by the AADI)



This report is highlighting what the VOSA (now DVSA) have been doing over the past couple of years (since 2017), which are the same kind of road side checks I used to be involved with in the Heavy Goods Vehicle Traffic Group, based out of Fareham between 1989 - 2002.

 It was not uncommon to find around half those vehicles being stopped were issued with some form of Prohibition, be that Immediate, where the issue had to be rectified before they were allowed to move or Delayed where they could go back to their depot and the vehicle must then be rectified before it is allowed back on the road.

 

Trailer Safety Statutory Report 2019.[1]

Foreword.

Page 5.

 

Only in a relatively few cases do defects contribute to injury incidents. In some 
respects, trailer-related incidents share some characteristics with incidents in the 
wider light vehicle fleet, including that
human error is a far more prevalent reason. On the basis of the information assessed so far, I am not convinced that the Government should extend vehicle testing to light trailers.


Executive Summary.

Page 7.



1.2  " ….2017, there were approximately 20 collisions resulting in injury or death where a vehicle defect in a trailer was a contributory factor…


….Breakdown, trunk road and off-road monitoring data suggest tyre defects and hitching issues are amongst the more prevalent, within the relatively low levels of incidents".   Again this suggests Operator Error, which comes back to training and checks and balances via testing!!



1.9 The “Towsafe4Freddie” campaign gets a mention in this report to stop more caravans, albeit it was NOT a caravan that caused Freddie's death…


"The new campaign follows the tragic death of 3-year-old Freddie Hussey in January 2014. Freddie was walking with his mother in Bedminster, Bristol, when a 2-tonne trailer became unattached from a Land Rover. The trailer mounted the kerb before hitting Freddie."


Again, this was an OPERATOR ERROR and therefore should be good enough reason to ensure checks and balances are in place via TESTING, against just having those on a register sign off customers who they have trained. This could so easily leave the towing industry wide open to just sign customers off without doing the checks!!
 


1.11 … "In respect of the licensing and regulatory regimes, the driving licence regime was changed in 1997 and again in 2013 to increase the cases when newer drivers need to pass specific tests before they can tow light trailers in many circumstances. 
DVSA will consider whether changes can be made to how testing is done to make it 
more effective." 


So at the time of this report being put together, there were STILL discussions about how TESTING of newer drivers could reduce the towed light vehicle incidences as a road safety measure, yet on the 10th September 2021 Government (DVSA), have abolished the need to take a test, which will, in effect make those that want or need to tow a light trailer, not even take training.

This report mainly features on the more commercial trailers, however, it s interesting to see some of the CRASH STATS of vehicles involved whilst towing trailers:


2.8 The following table shows the number of each of these types of towing involved in a collision: 
Type of tow
                                     Number involved in a collision

 Articulated Vehicle                                       2,324                                   

Double/Multiple Trailer                                       50                                                       

Caravan                                                           158                                                           

Single Trailer                                                    791                                                   

Other Tow                                                         382                                                       

No Tow/Articulation                                    230,772                                             

Data Missing/Out of range                             4,449                                                         

Total                                                            238,926 


 
Table 1 Number of towing vehicles involved in collisions - 2017


Stats19 need to be taken with some kind of consideration to the understanding that all Fatal crashes get reported to police, however, not all other levels of crashes do, and only turn up as a crash stat in those where medical treatment or an insurance claim is made, which tends to show the numbers are much higher. What the Stats19 doesn't do is provide an exact reason for the crash, i.e., if the towed or towing vehicle had a defect or the driver had an medical emergency that caused the incident that caused the crash.


There is a lack of specificity in the data which makes firm conclusions of the number of incidents involving trailers from 750kg-3,500kg, in particular, difficult to reach, which is the area that the vast majority of trainers work in, and who now, due to the actions of the Government (DVSA) have lost their business, potentially completely, because now, no tests (Checks & Balances) are to take place so who is going to undergo an intensive towing course which should also include the manoeuvring part of towing a light trailer? The likelihood is not many! 


I foresee the KSI stats of those towing light trailers will rise over the next year or two, but by then it will be too late, and of course the DVSA will blame the industry for poor teaching, albeit, it has everything to do with there actions of abolishing light trailer tests because they can't manage the back log of tests for other commercial drivers, let alone Cat. B (Car) tests.


Agricultural vehicles.


2.23  Additional analysis was undertaken relating to agricultural trailers. These vehicles are exempt from roadworthiness testing. There were 41 collisions involving agricultural vehicles in 2017, including either an articulated vehicle or other tow. There were 50 casualties associated with these collisions. This is particularly of interest, because so many agricultural trailers have little or no need to have annual safety inspections!


On page 16 & 17 there are seven case studies all of which involve operator error of drivers, albeit FOUR drivers who were towing had inputs that caused the crash. (No's 1,3,5,& 7), albeit, the same conclusion is not reached by the author in 2.31.


Its important to understand that other authorities also collect data in a different format to that of the Police, which does not always tally up with STATS19 for one reason or another, which then suggests the STATS of any description should not always be taken at face value! See Table 5 under Highways England.


Within this report there is a great deal of comment about some of the mechanical failures, i.e., hand brake failure or hitching / unhitching actions the latter being an Operator Error, whereas the hand brake failure could be accepted as a mechanical failure. Tyres condition has previously mentioned as a causation for a crash, however this is a Operator Responsibility and therefore comes down to training, a does all Operator Error incidents!


Also of significance is the checks undertaken by The National Towing and Trailer Association (NTTA) who undertook 307 checks from member volunteers in the period July 2017 - Jan 2018, of which 89% were defective, compared to DVSA's random stop checks which registered a 50% defect rate. This could be down to how either organisation rates a defect, but it does suggest that because of there now being no Checks 7 Balances, more light trailer users will continue to use said trailers with defects, save when they feel they can get a free check. (Para. 276 - 278)


It is of note that some similarities can be discerned in the two data sets. Lights/electrics and tyre condition were the two most frequent defect types recorded in both sets of checks. NTTA checks reported higher proportions of defective handbrakes and electrics than the DVSA checks, and defective breakaway cables were common defects for both datasets. Again, these checks are the responsibility of the Operator, and demonstrates that Checks & Balances should not be removed from the road safety/Safe Driving for life ethos!


2.73  The correlation seen above is not as strong across the other trailer types, for  example, livestock trailers had the second highest level of compliance (64 per cent) and the second highest average age (10 years). Whereas general purpose trailers had an average age of 7.6 years and 44 per cent compliance, which would indicate that maintenance regimes play a role in increasing compliance.


2.74 A comparison of the results of these checks with those of the fleet compliance checks indicate a greater proportion of regulated trailers being found compliant (84 
per cent versus 50 per cent). This is a significant differential. However, although the 
level of compliance does give rise to concern, this cannot be entirely attributed to 
roadworthiness testing.


 2.75 In order to understand the reasons for this differential, consideration must be given to the roles of roadworthiness testing, maintenance by commercial/non-commercial users, the role of operator Licencing (typically applicable to those using heavier trailers) and increased enforcement for heavier trailers, as each is likely to play a role in increased compliance levels for O3 and O4 trailers.


NTTA trailer safety checks. 


2.76  The National Towing and Trailer Association (NTTA) provided data from 307 free safety checks they conducted at NTTA certified servicing centres, between July 
2017 and January 2018. There is a significant differential between the results of 
these checks and those recorded by DVSA. 89 per cent of trailers failing NTTA 
checks with one or more defects recorded.

 

2.77  There are significant differences in the targeting of these checks which may explain this differential, at least in part. DVSA light trailer checks (02) were conducted in a random fashion as far as possible, in order to give a dataset broadly comparable with the Fleet Compliance Check. Conversely, NTTA checks were conducted by a self-selecting set of vehicle owners who voluntarily put vehicles forward for checks at a servicing site.

 

2.78  However, some similarities can be discerned in the two data sets. Lights/electrics and tyre condition were the two most frequent defect types recorded in both sets of 
checks. NTTA checks reported higher proportions of defective handbrakes and 
electrics than the DVSA checks, and defective breakaway cables were common 
defects for both datasets.


Caravan insurance data. In paragraphs:
2.79 The Caravan and Motor Home Club (CMHC) and The Camping and Caravanning Club (CCC) provided information on the most frequent types of claims made and the variation of these through the years, CAMC 2006 to 2018, and CCC 2016 to 2018. 


2.80 The most frequent claims for caravans involved in an incident were: 
• Detachment of the trailer; 
• Nearside wheel loss; 
• Collisions generated by snaking of the trailer.


The CCC data show that claims are not primarily related to mechanical faults of trailers but relate to distracted drivers, thefts, and adverse meteorological conditions


Again looking at these data sets, it infers Operator Responsibility is lacking as is the training of those responsibilities, which the DVSA say there is no excuse.[1]. Things will only get worse now there is to be no Checks & Balances due to testing being discontinued in the weight range of 750Kg's - 3.500Kg's!  


The Light Trailer (Cat.02) is not routinely assessed for road worthiness by the authorities like the heavier class of trailers are (Cat 03 & 04) and who have other checks and balances imposed upon them with Operator Licence requirements. It is estimated there are 1.39 million trailers in use in the UK of the 02 category, of which very few are routinely checked for road worthiness, and which potentially gives rise to incidents occurring on the UKs roads, because a large number of Users do not fully understand their responsibilities, eve thought they may have time served as a Cat B licence holder.


This situation can only deteriorate over the next one or two years given how many novice drivers may be asked to drive a van or size of vehicle that is capable of towing a light trailer and not be given the correct training, which ultimately could result in fatal, serious injuries to other road users or severe damage to property as a result of the potential increased number of incidents, all because the Governing Body (DVSA) is unable to manage testing for lorry drivers!


The Trailer Safety Statutory Report indicates there is marginal scope for reduced casualties IF light trailers were to be brought into the annual testing regime, of which the recommendation is not to do that. What it does not tackle is the lack of training, yet some of the case studies it has decided to print within the report, suggests to this author, is that the potential for reducing crashes and injuries is far greater IF compulsory training followed by Testing were not to be removed, as is now to be the case.


As previously mentioned, Joe Public will not undergo training now they know there is to be no testing for towing a light trailer with a motor vehicle of a suitable category. It may also leave open for those who are also looking to cut their costs to not provide suitable training, but instead take a chance and hope for the best!


The report outlines the Driving Test Requirements in para. 5.22 - 5.29 and particularly of note is 5.26 where it indicates "stakeholder and data sources pinpoint driver error as a key factor in towing incidents, it is sensible to consider improvements to this test." In 5.27 it says,  "DVSA will be considering revisions and improvements to the B+E safety questions, which form part of the practical test, over coming months. These will seek to address issues which have been raised during this report."


In just two years the DVSA have abrogated their responsibilities and dumped the lot, including revising the national syllabus which is highlighted in Para. 528.

 

At the stroke of someone's pen, HMG and the DVSA have now managed to worm their way out of complying with any and all of the recommendations of the report. How convenient!!

...............


 
 
 


[1] DoT - Trailer Statutory Safety Report 2019. APS Group on behalf of the Controller of Her Majesty’s Stationery Office - Accessed on line 120921 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/818125/trailer-safety-statutory-report-print.pdf

[2] Comment from CEO DVSA Gareth Llewellyn - accessed on line 120921 - Make sure your trailer is safe - https://www.gov.uk/government/news/road-safety-campaign-urges-drivers-to-towsafe4freddie



Grumblers email address

There is now an email address for the Grumbler thegrumbler@theaadi.co.uk so you can drop a line if you have a question you'd like to ask, or a story/information to provide/pass on (in total confidence of course so dvsa employees need not worry). Trolls will be ignored and deleted by my pet Ork.


As usual, if there is anything that you see is incorrect or, plain wrong, I apologise, and if you drop a line via the Contact Us page it will be edited.




by Don Harris 23 April 2025
How do the dvsa compare if we measure their performance up against that expected of their ADIs using their own Standards Check criteria as the basis for comparison? For those not familiar with the requirements, they can be found from the gov.uk website. SERVICE PLANNING Q. Did the dvsa identify their customers goals and needs. A. No. Despite plenty of evidence being available no appearance of a serious consideration evident. Q. Was the agreed business structure appropriate for the client’s experience and ability A. No. Totally inadequate for the client’s needs, across all divisions of driver testing and licencing and a complete failure to adjust to modern requirements. Q. Were the practice areas suitable A. No. Lack of contact at grass roots level, too much dependency on social media and digital contact. Q. Was the business plan adapted, when appropriate, to help the client’s work towards their learning goals A. No. Just plugged along with the same business plan with insufficient adaption taking place due to lack of understanding needed. RISK MANAGEMENT Q. Did the dvsa ensure that the client fully understood how the responsibility for risk would be shared A. NO. With the dvsa’s attitude of ‘It is not our fault, it’s their fault’ no level of understanding is evident from the dvsa. Q. Were directions and instructions given to the clients clear and given in good time A. NO. Usually any direction, or guidance from the dvsa was usually in response to public outcry and bad publicity in the press, BBC, ITV or Sky news broadcasts. This usually being around 2 years after the event initiating. Q. Was the dvsa aware of the surroundings and the pupil’s actions A. No. Not all as it was taking too long to adjust the focus on the long-range telescope in the lofty top floors of the dvsa establishment to be of relevance. Q. Was any verbal or physical intervention by the trainer timely and appropriate A. NO. I refer to the previous 2 answers Q. Was sufficient feedback given to help the client understand any potential safety critical incidents A. NO. Again, I refer to the previous answers in the section. There was nothing timely in the dvsa responses as all were due to external, extreme ,and persistent complaints from the public (ADIs, and learner drivers) being forced upon the dvsa by the media. Management and development strategies development Q. Was the management and development style suited to the client’s needs and service requirements A. NO. No evidence of any development to suit the client’s needs since the C19 pandemic began at 10.30am on the 23rd March 2020 and the first lockdown order was issued by HMG. There appeared to be no serious guidance or shift in management planning or development despite having months to work out strategies whilst sitting at home playing on their expensive gov.uk funded laptops as other outside organisations did. The dvsa seemed to sit back and stare at their monitors waiting for divine intervention. It was not until around 2 years later that they seemed to finally flicker back into life following the growing out cry from amongst their howling customers, both ADI and learners alike. Q. Was the dvsa encouraged to analyse problems and take responsibility for their learning A. Yes. Due to the huge public outcry due to their apparent lack of action there was no end of ‘encouragement’ by multiple outside bodies. Unfortunately, there was no responsibility taken as evidenced by their apparent lack of understanding or action taken. Anyway, it was not their fault after all, it was firstly the ADIs who were to blame for all that was wrong in misusing the dvsa booking system and messing it up, and then it was the learners who were to blame. It was certainly not the fault of the dvsa for not being able to manage a simple appointment booking system and prevent multiple bookings from being made by outside factors, who then sold on the dvsa appointments at a large profit, that they had obtained by flooding the dvsa booking system. This of course could not be the fault of the dvsa despite their vast investment in technology and technical staff to run it........a simple appointment booking system. Q. Were opportunities and examples used to clarify client’s outcomes A. Nah. No evidence found so far. Q. Was the technical information given comprehensive, appropriate and accurate A. This raised considerable laughter and amusement. Even the PCSU in their submission to the House of Commons as highlighted in the AADI blog. The PSCU asked why it was not possible to curtail test booking to ‘one test per licence number’ the dvsa reply was that ‘it was not that easy’ The dvsa bragged that they had managed to reduce the third party bookings from 20 per licence to just 5 and this is without the learner even knowing it is being done with their licence. Therefore totally inappropriate and adequate. Q. Was the client given appropriate and timely feedback. A. NO. No feedback as everything is kept from the client unless requested under an FOI and even the PCSU cannot get answers to questions asked. My MPs don’t even try. Q. Were the client’s queries followed up and answered A. No. Queries are mostly ignored or swept under the carpet. Q. Did the dvsa maintain an appropriate non-discriminatory manner throughout the session A. As previously stated above, it’s considered to be the client’s fault and not the fault of the dvsa so this is generally ignored Q. At the end of the session - was the client encouraged to reflect on their own performance A. Again, as above. It is generally the fault of the client so not considered to be something the dvsa would concern itself with. Score For those familiar with the system the ADI (driving instructor) is awarded a score for each point raised and totalled up for each section. A grade is then issued on a sliding scale of A B C. C is generally considered to be of poor quality and can be instructed by the dvsa to stop teaching and get further training. If during the Standards Check the score for the Risk Management section is considered so low the Enforcement Officer (yes that is their title) can stop the lesson at that point and order the ADI to stop teaching immediately in the interests of public safety. Review Q Did the dvsa score 7 or less on Risk Management (A 'Yes' response to this question will result in an automatic Fail) A YES .....Fail Q. At any point in the session, (March 2020 to present) did the dvsa behave in a way which put you, the clients or any third party in immediate danger, so that you had to stop the session ( A 'Yes' response to this question will result in an automatic Fail) A. Yes..... Given the number of examiners leaving the industry (attrition rate) due to age, ill health or stress levels – V – recruitment and the number of ADIs who have left the profession due to the stress levels now involved and the short ‘life span’ of newly qualified ADIs who drop out. Add to this the enormous frustration felt by the learners and their families trying to book tests. Complete failure. Q. Was advice given to seek further development A. YES YES YES YES YES Advice has been offered on numerous occasions from many sources, the AADI in particular, but as the dvsa know it all they have duly ignored everyone and like Poo Bear and Piglet have wondered their merry way off down the wood land path. RECOMMENDATION All senior management at the dvsa to be sacked for incompetence, ineptitude, lack of foresight and planning and all benefits removed. As the PCSU put it recently in part of their submission to HMG, ‘This calls into question the dvsa’s ability to serve as a regulatory body’ . If an ADI were to receive this level of a report from the dvsa itself, they would be removed from the register of Approved Instructors and need to re-qualify, that is if they were still considered to be 'Fit and Proper' to teach, the ADI would most likely not get past the initial submission to the register to even be allowed to begin training. Even whilst the proverbial ink is drying in this blog they have excelled themselves yet again. The glorious dvsa sent an email out yesterday about changes they are trialing for the driving test this contains the following: " On 6 May 2025 DVSA will begin a trial to increase the amount of time your pupils spend on higher speed roads, including rural roads, during a driving test. We know that rural roads are some of the most dangerous high-speed roads for novice drivers. The current killed or seriously injured statistics show 48% of casualties in young car driver collisions occur on rural roads, compared to 42% for other aged car driver collisions." In other words, they want to risk their own examiners lives with inexperienced drivers on our most dangerous roads with the highest KSI (killed and seriously injured) figures. HOLY smoking exhausts, are they bonkers. They cannot employ enough examiners at the current pay grade and now they are going to ask for this too!!! This is simply not possible at every test centre, so out the window goes their claim that all tests are equal throughout the UK. Expect long delays at test centres with not so many dangerous roads with high KSI figures. Also expect a loss of many more examiners, and a higher attrition rate if this is not voluntary on their part therefore creating a two tier test system. WOW what a turn around by the dvsa. Conlcusion By their own standards, for the people that they licence to deliver driving lessons in the UK, the dvsa have failed miserably on just about every measurement there is. They are unable to recruit and maintain examiners, the very front-line staff that bring in their revenue to sustain their business model. Despite the media accepting the load of nonsense about recruiting 450 new examiners, where the hell from? They have alienated just about every member of the public that has to deal with them on the driver testing and licencing side. ADIs have no faith in the dvsa management at all, we gave up years ago. The examiners morale is so low at the present it is immeasurable, they are leaving in droves, even new recruits are leaving within a week of starting. It is, allegedly, so bad that they are considering moving the goal post for the entry level to get more applicants through the doors. The customers applying for tests either as learners, truck drivers, or people wanting to qualify as ADIs are at a loss and losing money. Their business practice is an unmitigated failure and should be handed over to Tesco to run an appointment booking system that works. You simply could not make this up as the script for one of the old music hall farces with Brian Rix, and they publishing new embarrassing edicts, almost on a daily basis. The ideas coming out from dvsa towers in are so thick and fast I just cannot type fast enough to keep up with them. They've even conned, just this week already the Secretary for transport into making a fantastic statement about 10,000 extra driving tests a month how in the merry **** are they going to achieve that when they cannot get the extra 300 promised from 2 years ago, never mind the 450 promised late last year. I hope the Secretary of State for Transport, Heidi Alexander MP, sacks the pigging lot of them for telling such big, ginormous porkies. As usual, if there is anything that you see is incorrect or, plain wrong, I apologise, and if you drop a line via the Contact Us page and it will be edited.
by Don Harris 12 April 2025
This is a copy of a submission by the PSU (Examiners Union) on the state and the effectiveness of the dvsa to the House of Commons. It details a litany of failure, incompetence and just about any other adjective to describe failure that one could think of. I would dearly love to know what the dvsa's response was, does anyone know? Many thanks to the Guardian newspaper for bringing this to my attention. Written submission from PCS (DTA0017) Introduction: PCS (Public and Commercial Services Union) is the biggest public service union for civil servants. We have a very strong membership in DVSA, and the vast majority of driving examiners and their line managers are in PCS. PCS reps and full-time officers have engaged with DVSA Ex-Co throughout the Driving Services Recovery Project. We have faced, and continue to face, challenges working with DVSA, particularly the Driver Operations division, who are responsible for the Driver Services Recovery Project. When we have challenged decisions or asked for information, there has been a delay in responding, we have been rebuffed and our reps have, at times, been subject to aggressive behaviour from some senior executives in driver operations division. DVSA Driver Operations have refrained from consulting with PCS at appropriate points in the project. This has led to two incidences of industrial dispute in the last four years over the driver services recovery project. Both were resolved without PCS members having to take industrial action, but these two disputes evidence how reticent DVSA are to work collaboratively with PCS to find workable solutions to resolve the driving test back log . There has been a concerted effort from those involved with the Driver Services Recovery Project to keep pertinent information regarding the project away from PCS. In this report we will refer to the Driver Services Recovery Project business case and subsequent workplace exception documents. These only became available to us on the 23rd of October this year. (2024) We are submitting evidence because PCS has concerns regarding the ability for DVSA to reach the targets is has set in the Driver Services Recovery Project and its subsequent Workplace Exception Reports. We also have serious concerns regarding DVSA’s ability to act as an objective regulator of driving tests at this time and we are concerned regarding the long term sustainability of the organisation as DVSA Ex-Co continue follow the route of degrading terms and conditions of Driving Examiners in a bid to achieve Driver service recovery targets, despite all evidence showing this is not an effective resolution. Summary of Report: • The new cluster contract with degraded terms and conditions, is failing to attract driving examiners of the correct calibre, and DVSA is unable to reach the recruitment targets it has set, which the success of the project is dependent on. • Reports from driving examiners that they are being pressurised by more senior DVSA employees to inflate pass rates and take out unroadworthy vehicles. our members have witnessed examiners turn away cars with tyres so bald the canvas is showing, loose exhausts, brake lights not working, no tax or insurance. • Increasing attrition rates for driving examiners because of the culture in the organisation. • The initial plan for growing the training team to successfully manage the number of new driving examiner recruits has failed. The solution to overload LDTMs is ill thought out. Proper investment and long terms solutions are needed. • Report from an HGV driving examiner that tolerances are being adjusted on the manoeuvres on an HGV test at a certain training site, and preferential leasing of the site on reduced rate is causing incidences being overlooked to enable HGV tests to continue. • DVSA have not taken decisive enough action regarding the reduction of the number of tests third party sites can book using a singular driving licence number. a huge concern from our members as has been highlighted repeatedly in our blogs • There have been critical errors and a coordinated mis-management of the driver services recovery project by a cadre of individuals in DVSA Driver Operations which have resulted in unachievable targets for the project. • There has been mis-management by DVSA Ex-Co in allowing the iterations of Workplace Exception Reports to be passed, continuing the Driver Service Recovery Project without proper and robust analysis of content and targets. • There has been a co-ordinated effort from DVSA Driver Operations to frustrate the consultation and negotiation process with trade unions Operations to hide the issues in the Driver Services Recovery Project. • DVSA are unable to function appropriately as a regulatory body at this point. What possible solutions are there for reducing waiting times and preventing slots being blocked out by automated bookings: 1)Abolish the new ‘cluster contract’ terms and conditions for new driving examiner employees and return to previous driving examiner terms and conditions to encourage recruitment and retention of the number and calibre of driving examiners needed to fill the vacancies. PCS has always been opposed to the terms and conditions of the ‘cluster contract’, first billed by DVSA as a temporary, short-term contract for driving examiners recruited to meet the increased demand for tests after Covid. This contract offers poorer terms and conditions than the substantive contracts for existing driving examiners, including, but not limited to - regular weekend working expected as part of the working week on basic rate, with no additional overtime. Increased travel to and from work, as those on new ‘cluster contracts’ will be attached to a number of driving test centres across a geographical area, as opposed to just one, and are unable to claim comparative terms and conditions to those on the previously existing contract. It is important to note that PCS has continually challenged the imposition of these contracts and moved to a position of industrial dispute with DVSA in October 2023 over elements of the contracts. PCS won some significant gains for those driving examiners on the ‘cluster contract’, including a reduction in the frequency of weekend working, and improved subsistence and mileage allowances, as well as a shrinking of the geographical areas driving examiners on ‘cluster contracts’ would cover, but PCS reps have continually warned DVSA Ex-Co members that this contract is not sufficient to attract enough examiners of the appropriate calibre to the role. DVSA Ex-Co have always maintained in meetings with PCS that attrition rates of existing Driving Examiners are not increasing, and that recruitment of driving examiners was going well. On 23rd October 2024, after PCS continually asked for project documents (with requests always being evaded), PCS received from the Driver Services Recovery SRO, the Project plan documentation and successive Workplace Exception Reports which identify changes in the project when key targets are not met. These documents have never been discussed with PCS. These documents show a continual pattern of recruitment and retention of driving examiners falling well below the targets required to meet the successive deadlines of the initial project plan and the workplace exception iterations thereafter. There is, in the documents, acknowledgement that the resolutions suggested will not meet the targets. The initial Driving Test Recovery Business Case, states: “To deliver a reduction in the current waiting time for driving tests to single figures (in terms of weeks) by the end of February 2023. Based on the recommended option, this is to be achieved by: Direct Recruitment of Additional Driving Examiners A net increase of up to 300 additional DEs will be recruited, trained, and on-boarded into DVSA. They will be employed on fixed-term contracts, maximum duration of 2 years. Successful candidates will be allocated into test centre ‘clusters’ so that demand in particular areas can be met by having a flexible pool of resource that is able to be allocated to different local Driving Test Centres (DTCs) as and when required.” This cluster contract was first billed to the trade unions as a temporary contract to be used short term to resolve the immediate issue of the Covid back up of driving tests. When it became clear that DVSA would not achieve the initial target of reduction of driving tests to a 7 week wait by March 2023, DVSA Driver Operations created their first Workplace Exception Report which details the strategy to get the driver services recovery project on target. DVSA have produced four of these that PCS has seen, in February 2022, March 2023, Feb 2024 and July 2024. The first exception report was primarily focused on the roll out on an 8-test working day, but did note that overall project success was dependent on: “There are 3 financial risks associated with the revised model: a) The model assumes very high numbers of successful new entrants and low attrition. Project risk DRRE RIS 016 refers.” Indicating awareness that poor recruitment and increased attrition would affect the success of the project. The next Workplace Exception report that PCS has had sight of is from Feb 2023 and states: “ 2.3 Since the autumn factors above, there have also been other factors that have impacted the ability of the Project to meet the Feb 2022 delivery target date: • Failure to attract as many Driving Examiners as possible in the expected period planned. • Attrition rate of Driving Examiners being higher than historically.” The Exception Report in Feb 2024 states that the project has been delayed and not reached number of targets in the project because of several reasons, inclusive of: “Fewer new entrant Driving Examiners than planned and higher than expected attrition which has impacted test delivery over the period – the volume of new Driving Examiners that we planned to recruit between October 2023 and January 2024 was lower than anticipated and attrition was higher than expected.” The risk profile section of the Feb 2024 Exception Report states the ability to recruit sufficient driving examiners, as one of three risks, to the success of the project, with an overall risk factor of twelve, a medium risk score. The most recent Workplace Exception Report that PCS has seen was dated July 2024 and covered two specific areas of scope: 1.2 Context: This exception relates to scope and time as summarised below: • Scope exception – the project will need to recruit and train around 450 additional Driving Examiners (DE) in this financial year to deliver the 7week waiting time target by the end of March 2025 (this aligns with the Business Plan), which adds additional scope to the project. • Time exception – the current baselined delivery date is September 2024, so the project requires an extension of nine months from October 2024 to the end of June 2025 to enable delivery of the target and time to close down the project. A 7 week waiting list by July 2025 is the latest proposal/ dream of the dvsa - you have to have a good laugh here. The report goes on to describe the reasons for the inability to meet targets set in previous Exception Report, and states: “2. Description of the cause of a deviation from Plan Fewer new entrant Driving Examiners than planned which has impacted test delivery over the period – the volume of new Driving Examiners that we planned to recruit between October 2023 and January 2024 was lower than anticipated.” In section 3.6 of this report, the Risk Profile shows an increase to the risk profile of the risk: “Ability to recruit sufficient DE [Driving Examiner] numbers to service increased demand.” This risk factor has more than doubled from Feb 2024’s Exception Report and is marked as twenty-five, the maximum rating a risk factor can achieve in DVSA risk assessment model. This report lists under the assumptions that: “5. Assumptions (this is a peach) 1. Recruitment of new Driving Examiners will be delivered in line with the forecast. 2. Attrition of Driving Examiners remains in line with the forecast.” It is clear from the Business Case and the subsequent Workplace Exception Reports that DVSA is unable to fill the driving examiner vacancies at a volume required to ensure the project’s success. PCS has campaigned consistently that the poor terms and conditions of the ‘cluster contract’ are a significant contributor to the lack of interest in candidates of the correct calibre. DVSA have stuck resolutely to this ideology and it is without success. I note that DVSA is currently in it’s fourth extension to the project and at a recent meeting when PCS asked how far into the current target of recruiting and retaining driving examiners DVSA were, they were unable to tell us. The most recent advertisement had borne 19 candidates, of which 9 were successful after the initial training. DVSA mentioned vaguely that there were ’previous candidates’ that contributed to the most recent Workplace Exception target of 300 but were unable to offer any clear parameters of how many driving examiners had applied, been retained and from which wave of recruitment. PCS is gravely concerned at the management by Driver Services of the project. ( Ecactly what we have been saying consistently through our blogs.) T he litany of missed targets regarding recruitment over the lifetime of the project, and the narrowing of scope for resolution from DVSA as the project continues and enters its fourth extension, reflects errors in the management of the project at every level, inclusive of those who have been involved in the development and signing off of targets and given credence to these extensions without objectively questioning the validity of the resolutions within. 2). Immediate Cessation of ‘third party’ driving test providers to buy and sell multiple tests using learners’ driving licence numbers with automatic bookings. The ability for third party companies to buy and sell on driving test times has been a significant contributing factor to the ongoing difficulty in learner driers being able to book practical driving tests. PCS has raised concerns regarding this with DVSA Drivee Operations senior management several times over the past few years. When PCS called into question the ethics of the third party organisations being able to use learner drivers driving licence numbers to book repeated tests on the system, and why this can’t be curtailed to ‘one driving licence number, one booking’ the answers from Driver Operations were evasive, with PCS being told ‘it’s just not that easy’. PCS were told by senior staff in Driver Operations that progress had been made in that that the numbers of tests third party organisations are able to book with one driving licence number (without the learner driver’s knowledge) has been reduced from twenty driving tests from one licence number to five. PCS has been led to believe from ‘off the record’ conversations with senior management in DVSA that repealing the third party buying and selling of tests is difficult as this was brought in without the correct legislative process being undertaken, and therefore admission of the problem would reveal this significant error. The impact of allowing the continuation of third-party organisations being able to book up multiple tests to then sell them on at a profit means an evercontinuing cycle of delays for those learners awaiting driving tests. 3) Review into the narrowing of resolutions for increasing first time test pass and potentially for un-regulatory conduct. In the initial Driver Recovery Business Case one of the outputs of the Driver Service recovery outputs is: “Launch communications ‘Ready to Pass’ campaign that will contribute towards a range of initiatives leading to better preparedness for tests, ideally with positive impact on the pass rate, and reduce the number of learner drivers who will need to take a retest.” With a target of the project being: “Undertake a behavioural change campaign which aims to improve learner drivers’ readiness to take their test and encourages them only to take their practical car driving test when they are ready.” Two of the key methods for delivering the element of the campaign to engage with learner drivers and increase likelihood of passing first time are listed in the initial Business Case as: “Keep learner drivers and driving instructors updated with our progress on GOV.UK, by email and by using social media……Launch the recovery campaign with a pro-active national media announcement, publish the new campaign platform on GOV.UK and relaunch our Instagram channel with tailored social media content aimed at learner drivers.” The second Workplace Exception Report in Feb 2023 states: “And maintain the trust our people, stakeholders and customers have in our services, whilst encouraging learners of the importance of being properly prepared for their test.” With the target of a “1% increase in pass rate per year” and “1500 reduction in [test] demand per month” and an expectation this target will be achieved by: “Benefit realisation forecast is expected in Jan 2023.” It is clear from DVSA’s Instagram account that there was a considerable piece of work undertaken between July 2022 and October 2023, reaching out to Learner Drivers with the Ready to Pass communications, however, from October 2023 this proactive campaigning stops abruptly on social media (although its worth noting the internet pages are still in place). This is a shame as there is obviously investment into relevant content that could have been recycled through re-posting at no extra cost to the organisation. In the third Workplace Exception Report (Feb 2024) this project output is reduced to: “Improve and maintain the trust and confidence that our people, stakeholders and customers have in our services.” But retains the same target of: “1% increase in pass rate per year.” With the method of achieving this detailed as the target “Increase in slot availability up to 45% (currently 21% as at February 2024).” It is important to note the move of the focus on this target is away from the Ready to Pass Campaign, to slot availability. In the fourth Workplace Exception Report in July 2024, the target is noted again as a “1% increase in the pass rate per year”, but with the revised benefit noting that the target “Increase in slot availability up to 45% progress” is moving further away from the target in this quarter: “(currently 18.31% as at July 2024).” It was in Spring 2024 our PCS reps began to hear of key changes in the rhetoric from Driver Operations: PCS has been led to believe that during a meeting of driving examiner line managers in May 2024 there was a discussion around ‘utilisation’ (a phrase encapsulating the ideology of making sure every booked test is productive). PCS has been told that senior managers encouraged leniency in the running of tests in ‘private runners’ (cars owned by individuals and not by approved driving instructors) that were not in a roadworthy condition or did not have a current MOT. During that meeting managers were also introduced to using Power Bi, DVSA’s project management tool that charts the pass rates of different test routes and of driving examiners, to identify specifically those routes and examiners with low test pass rates. Since then, PCS has received a number of contacts from driving examiners in the organisation who have felt pressured and bullied by managers further on in their chain of command to increase test pass rates. Additionally, driving examiner line managers have also been asked to start completing new documentation which analyses performance based on examiners with low pass rates and routes with low pass rates. This is a marked difference to previous assessment which takes a broader view of both high and low pass rates on routes and from examiners. Several PCS members have begun the whistleblowing process to report these incidences but there is a reluctance among the driving examiners and their line managers to report these incidences as they report an organised and coordinated strategy from senior management in Driver Operations from SEO to senior Ex-Co to comply with this analysis and rhetoric. 4) Invest and develop a long-term plan to increase in the number of learning and development trainers, future proofing DVSA training provisions moving forward. Recently, DVSA has moved the responsibility of the first few weeks training for new driving examiners from the qualified and experienced training team to driving examiner line managers, who are expected to undertake this duty alongside their other line and centre management responsibilities. PCS have been against this idea from the start and wrote to DVSA in June to express our concerns and the potential for industrial dispute regarding this decision. DVSA’s decision is detailed in the fourth workplace Exception Report (July 2024), but it sits at odds with the initial business plan and previous iterations of workplace reception reports. In the initial business case, the plan for training was: • Improve the training resource to allow us to onboard and start more DEs every month by doubling the size of the training team. · Speeding up the Recruitment and Training of New DEs · This is to improve the training resource to allow us to onboard and start more DEs every month by doubling the size of the training team. In the short term, this will limit the number of new examiners we can train, but from February 2022 doubles the number of new entrants who can be trained concurrently. · To support the increase in training, up to 29 LTDMs [driving examiner line managers] will be trained as trainers and required to train new entrants for a period of up to 12 months. Operations has requested that these posts are backfilled and, therefore, up to an additional 29 LTDM posts will be required.” By the time the project reaches it second extension and workplace exception report (Feb 2023), DVSA recognises the roll out of this initial plan for training has been unsuccessful: “5. DRRE RIS 057 “Attrition rate of L&D Trainers available to train new entrant DEs”. We experience an attrition rate of trainers that significantly impacts training plans and new entrants start dates. We are monitoring BAU trainer departure attrition and move trainers from other training activities over to deliver Driving Tests. DVSA also continues to recruit new trainers as BAU activity. We plan to reduce Trainee cohorts to match current resource from February 2023 - April 2023. This also supports the delegates who are in the recruitment pipeline as there are insufficient numbers to meet original planned cohorts. Plan is to increase LGV delegated courses which will reduce DVSA LGV demand to diverting those examiners to deliver car tests.” and has resulted in a high number of leavers from the training team. The expectation now from DVSA, is that driving examiner line managers, without a background in training, many of whom are undertaking 6 month, temporary, Career Development Opportunity (CDO) posts, can now successfully manage this considerable piece of work in addition to their substantive post, is unrealistic. Driving Examiner Line Managers (known in DVSA as LDTMs: Local Driving Test Managers) have borne the brunt of the changes at DVSA; in previous iterations of the project, they were moved from their substantive posts to work full time on driving tests in an attempt to relieve the backlog. Consistently throughout all the business case and workplace exception documents, the same concern is flagged regarding driving examiner line managers: “Will require a longer period of support activity than that which was originally planned for. Risk of burn out, stress, reduced morale, reduced effort provided, as the period of work support extends beyond originally planned.” Workplace Exception Report Feb 2023, Feb 2024, July 2024. DVSA’s decision that a workable solution to a successful training programme for new driving examiner recruits is to task driving examiner line managers with this responsibility, given the evidence that earlier attempts in the project failed, when DVSA employed a larger, experienced team of specialist trainers and a number of fully trained driving examiner line managers, seems particularly reckless. This decision runs the risk of pushing up the number of leavers in the manager post and reduces the likelihood of producing driving examiner candidates that can move on from successfully from their initial training into the further development stage. DVSA Driver Operations have ignored PCS’s representations on this matter and instead attempted to foster a position that LDTM line mangers can handle the pressure as they are doing nothing out of the ordinary. This is stark contrast to the concerns highlighted in their own exception reports outlined above. PCS is currently reaching out to communicate with LDTM line manager members affected by this change with a view to surveying what impact this change has had on them. How the scarcity of HGV driving tests has affected industry? PCS understands the importance of candidates being able to attain HGV driving licences, however it is important that in providing the test, the validity of the test is not degraded to obtain false positive pass results, with the safety of road users compromised. PCS can report that we have had a PCS rep that raised concerns in October 2022 regarding practices in a test centre which held Entry to Employment courses, with the HGV test included, and where DVSA rent space for testing, where the tolerances on manoeuvres were being changed to make the manoeuvres easier to the candidate and increase the chance of the candidate passing. The rep reported this to the SRO for the Driver Services Recovery Programme at a Directors Live event, and he was then contacted to give a full description of his concerns. After this, the rep in question was investigated for a 17-point complaint from the test site owner. None of the points had a case to answer, but since then the rep has been told he has to move sites at the behest of this third-party site owner, which DVSA has complied with, to a site significantly further away (it is pertinent to note here that this examiner has a visible, physical disability, which makes commuting more challenging). On raising a complaint regarding this, PCS has been told that the third-party site owner does retain the right to say which DVSA employees can work on the site. PCS questioned the right of the site owner to make this decision and requested to see the contract between DVSA and the site to see where this right was written into the contract. We were told no contract existed between the site owner and DVSA. PCS has concerns that this site has offered DVSA a very beneficial rate to hire the land, enabling DVSA to undertake HGV testing at this site, and in doing so, this third-party organisation is utilising this leverage to control which DVSA employees can work at the site and is thus, undermining DVSA’s regulatory duties in ensuring testing is carried out in a legitimate manner PCS is aware that this is not a direct response to the evidence requested regarding the impact of the scarcity of tests but we feel this is such a significant situation it cannot be overlooked, PCS has brought this to the attention of ExCo a number of times but there has not been any investigation regarding this by DVSA Driver Operations Ex-Co. This calls into question DVSA’s ability to serve properly as a regulatory body when the division responsible for regulating the testing, Driver Operations, is also the division in charge of managing the Driver Servies Recovery Project: this is a dangerous conflict of interest. Summary of PCS’s recommendations to enable DVSA to reduce waiting time and prevent blocking out tests by automated bookings. 1) Immediate cessation of the use of the ‘cluster contract’ as the standard contract for new driving examiners, with a return to using the substantive contract in place for driving examiners prior to the Driver Test Recovery Programme, and a move for all those on the ‘cluster contract’ to pre -Driver Services Recovery Programme contract to enable a more attractive employment offer to potential new driving examiners and reduction in attrition of existing driving examiners. 2) Immediate cessation of any potential research or projects into the changes/harmonisation of the driving examiner terms and conditions on the pre–Recovery Programme contract to reduce examiner attrition. PCS are aware the Supporting Future Services Programme is looking at changes to contracts which could affect driving examiners. 3)Training of new driving examiners by LDTMS to be voluntary with proper training and remuneration for LDTMS undertaking this work. An increased budget for the training team to refresh and allow for new leadership. Increase in the number of learning and development trainers to invest in future proofing the training provisions moving forward. 4) Full investigation into the Driver Operations directorate who have managed the recovery project. 5) Move the regulatory function of DVSA to outside of the Driver Operations directorate, to enable an effective, unbiased regulatory system. 6) Repeal the ability for third party organisations to be able to retain learner drivers’ licence numbers and utilise them to book multiple numbers of tests. 7) An increase in pay across the department. DfT has one of the lowest rates of pay for EOs (the driving examiner grade), with new starter’s salary at £29,525 p.a. (Nationally) and £33, 864 p.a. (London). An increase in pay would attract a wider and higher calibre of suitable candidates. 8) Proper investment into long-term solutions and a commitment to a robust project review framework to ensure DVSA can successfully continue in its role in setting road safety standard and regulating driving tests. November PCS Public and Commercial services Union DVSA Driver and Vehicle Standards Agency DFT Dept for Transport EO Executive Officer LDTMS Local Driving Test Centre Managers DTC Driving Test Centre DE Driving Examiner HGV Heavy Goods Vehicle LGV Light Goods Vehicle
by Don Harris 4 October 2023
The DVsA response to recent media criticism about the current test waiting times is to throw in the kitchen sink - but, is this the right solution?
by Don Harris 11 August 2023
Are the DvSA morally bankrupt?
by Grumbler 26 September 2022
Why bother, the job is not what it used to be?
by The Grumbler 21 July 2022
Where on earth does the dvsa thinking come from, we know where it belongs?
AADI wanting to work together with the dvsa
by Grumbler 10 July 2022
The AADI is offering to help the dvsa with its poor public image to help clear up some confusing issues on the driving test for driving instructors and learners in the UK and make their lives easier.
by The Grumbler 17 June 2022
AADI advising the dvsa, and they are at last listening.
by The Grumbler 27 February 2022
Did the dvsa go too far opening new theory centres when tests are not available?
by The Grumbler 27 February 2022
We are all Ambassadors for our chosen profession
More posts