https://www.gov.uk/government/consultations/roadworthiness-testing-for-vehicles-of-historic-interest

My bus number (if any): RML2532

I think there should be a basic test for tyres. brake efficiency relative to the build date. Lights, Underside check for structural corrosion inc suspension mounts, king pins, steering joints etc., visual excessive smoke test on warmed up engines etc. Many owners do not have access to a pit and could be blissfully unaware of any issues and it's a great opportunity for them to check on it all. I am surprised that organisations running free public running days don't insist on voluntary class 5 tests for exempt vehicles . It would only take one sad incident involving an exempt untested vehicle carrying the public for a knee jerk reaction to affect these many enjoyable events ?

My bus number (if any): RML2747

With the remarkably low accident/incident rate for pre-1960 buses up to 2014 the chances are very low, but I, like others, share your sentiments. But the number of people who have mentioned to me over the last couple of years how unfair the present exemption system is by including some RMs and not others is sizeable.

There's nothing to stop anyone having a voluntary test if they so wish. The interesting bit is that class 6 buses are also exempt, but then they are, as we discussed a while ago on here, regularly examined as a condition of the operators licencing scheme.

My bus number (if any): RML2532

Exempt or not, my view has been that, if there's an accident, I don't want to be the Operator who chose not to have his buses tested. So we continue to have ours MOTd, plus, of course, the regular PMIs.

I'm happy not to MOT my GS but get it inspected thoroughly, including a roller brake test, annually.

All my RMs are young enough to still have MOTs but I will stop MOT testing when permitted. The two I operate are carefully inspected with a PMI every 6 weeks and roller brake test every 18 weeks.

Since the privatization of government vehicle testing there are loads more places to get Class 6 tests. Unfortunately they end up costing much more and it is even more difficult to get appointments for tests and, so I am told, retests.

Another triumph for free enterprise?

My bus number (if any): RMs 238, 471 and 2213, GS17

Time to revive an old thread...

I had a conversation with someone who runs an RT (and has an RML) on a class 6 and I've done his safety checks for a number of years, but, as a safeguard he takes it elsewhere every so often as a double-check. One of the others is a regular contributor on here too.

The RT as we know is exempt from annual testing, pre 1960 as we know. The operator is thinking of having a class 6 test done anyway for "peace of mind". A couple of points here: would such a test certificate have any legal standing in the event of an incident? I suspect not as it is only valid at the time of the test, and in my view would not be a legal document anyway as there is no requirement for one! The other is that there appears to be doubts in the operator's mind on the professionalism of those undertaking safety checks.

Those of us on here who have looked at the bus professionally know that mechanically there isn't a lot wrong with it apart from the usual rusty brake pipes and oil leaks, but plenty of body rot which in my opinion could have serious consequences in the event of an incident but would not be part of an annual test.

Said operator took the bus to a commercial garage for a brake reline a few years back and has problems. The brake linings had been put on wrong, 2 soft linings one side, 2 hard linings the other side, and not trammelled up. Not knocking their professionalism, but on their own admission they didn't have the experience of the older vehicles to set the brakes up properly.

My advice to him was don't bother with a class 6 test, best stay well away from a testing station with the known body rot problems. someone there may just be very picky and you'll find yourself out of business. What do others think?

My bus number (if any): RML2532

The MOT examination has relevance regarding the vehicle's condition for no longer than it takes to drive off the forecourt of the premises of the ATF.

It won't happen until there is an incident, but maybe it is time for the insurance companies to act and insist if the vehicles are ever to carry any passengers, that the bodywork of these elderly vehicles is treated in the same way that passenger carrying craft and steam boilers are treated currently, This would mean that they would be compulsorily examined by their own nominated independent inspectors every set number of years before the company will issue cover. In this instance by the partial removal of external panels as decreed neccessary for proper examination.

Cue howls of protest and disagreement.

The insurance company I use have already started clamping down on the use of historic buses, even those used and declared as PSVs.

Since one of the leading manes in historic bus insurance, Chaucer, were taken over by one of the bigger companies, they now have a list of do's and don'ts. They forbid the use of historic buses as party buses, late returns, pub crawls, hen and stag nights and the like. They will cover use of free bus services providing the driver is properly licenced. They will cover use for hire and reward for a certain number of days a year; any more than that number of days and the premium goes up accordingly. But then that is a trade-off for a relatively cheap insurance fee.

My bus number (if any): RML2532

Back to the original Consultation - does anyone know when the results of the original Consultation will be announced ?

I understood that it was due in January and then delayed to April and then delayed due to the General Election. Whatever the result, it is due for implementation in 2018.

My bus number (if any): RM1368

Another idea that has been quietly forgotten about by the national press I suspect, like a lot of bad news, hidden from the headlines. Maybe the FBHVC has heard something?

My bus number (if any): RML2532

I believe the results of the consultation are now due to be announced sometime during September.

My bus number (if any): RM1138 RM44

I suspect it will come up with results similar to those of the original proposals in the light of experience. As was shown in that excercise, there were only about 280 pre-1960 buses on the road licenced as public service vehicles. Very few failed the annual test on anything really safety critical over and above the national average, and the most common failures were headlamp alignment.

This is less of a problem on older vehicles as the headlamps are usually fixed to something substantial like front chassis members! Brake imbalance was next and can be problematical foe some of the older stuff to get right. There is also very little to test on an old bus compared to a new bus. no interlocks, seat belts, power doors, warning buzzers, bells and lights.

But the most important as mentioned in my recent post is body condition which is not really tested at all. If the examiner can SEE something wrong, it will draw his attention. All the faults I've found are hidden from view. And the examiner cannot take parts off to look behind them. so back to what roy says, maybe an insurance examiner may get involved.

But then if we look at the accident record for historic buses, I haven't heard of anything serious where people have been injured or worse at all. the only one that springs to mind which set a few hearts beating on this forum was the RM that left the road and tipped over in Ireland a few years back. That wasn't the fault of the bus or driver, it swerved to avoid a collision and ended up in a field.

My bus number (if any): RML2532

Going back about 30 years or more there was a spate of serious coach rollovers resultig in many fatalities. In moast cases the bodywork simply collapsed, crushing the occupants. There was considerable publicity once the media discovered that safety testing of coachwork structural integrity at protptype stage, involved very carefully lowering the inverted vehicle onto matresses and if it only wobbled like a jelly it was considered a safe design.

These are the very vehicles now in preservation.

Back in the 1950's as many vehicles were built using unseasoned wood due to material shortages after the war as Roythebus mentioned in a recent post - re certification involved removing the nearside panel in front of the rear axle (usually the worst area for rot ) to check the frame integrity - many a vehicle's body was condemned after a very short life apparently many were so bad that they were rebodied .

My bus number (if any): RML 2747

How does a bus operator demonstrate they are within the law at any given time?

My bus number (if any): M1001, RML2276, T806

To whom do you want to demonstrate you are operating within the law?

My bus number (if any): RML2532

Well anyone really. How does one demonstrate to the authorities and to the potential customer that they do supply a safe and reliable service?

I have to pay various bodies including the NICEIC and a procurement accreditation company called Altius. In turn they check that we are a competent company. That includes checking all aspects of our work, staff competency and professional development, working practices, regulation compliance, safety compliance, insurance coverage etc. We also have an employment and safety compliance consultant. We spend over £25k each year on insurance and proving we comply. With less than 15 people employed you can see just how expensive proving due diligence is.

So, as a bus operator, how would I prove it. Is there an accreditation to show, beyond doubt, that all efforts have been taken to make sure the bus is safe and legal or indeed as a bus repair contractor that one is fully trained and capable of doing the work.

My bus number (if any): M1001, RML2276, T806

Beyond doubt ?

As an example, I witnessed two incidents in the space of five minutes in central London today with two different TfL contractors on London bus routes and both occurred at the centre exit of buses.

One involved a cyclist and the other a wheelchair ramp ....... but more by luck than anything else, no ambulance was required, however it was so so close.

I had better stop before Chris removes my post, as I think we are getting off topic, but in this type of operating environment it must be difficult if not impossible to show / prove any good credentials or competency.

My bus number (if any): RM1368

A difficult question to answer "beyond doubt".

You have an operators licence, that shows you meet the standards required not only of the UK Government but of the EU, love them or hate them, and your transport manager has a certificate of professional competence.
You have the correct insurance for carrying passengers for hire and reward, no doubt public liability insurance and employers' liability too.
Your bus has the correct rate of Vehicle Excise Duty paid.
Your drivers have the correct driving entitlement and their Certificate of Professional Competence.
You buses have regular safety checks according to the requirements of your operator's licence.
You comply with the terms and conditions of your operator's licence.
The buses that require annual tests have a valid test certificate, and where appropriate, a certificate of Initial fitness.
If you undertake certain work involving young people your staff have CRB checks or whatever they're called these days.

I don't see what more you can do to prove anything. Anyone that wants more than that can't be worth working for.

As for the competence of mechanical fitting and engineering staff, a lot will have been time-served apprentices and worked their way through the system, some will have degrees in engineering, some, like myself, have been self-taught over the years and have considerable experience in what we do. The major problem these days is finding people with qualifications who know about old vehicles. Even a lot of the vehicle examiners have little knowledge of older vehicles, much the same as dinosaurs like myself have little knowledge of modern braking systems or anything computerised.

My bus number (if any): RML2532

Taking this back to the original question, and opening the can of worms, so how does this affect those with preserved vehicles that are not used for 'hire & reward' ?

For example, all RTs currently do not require an MOT, and if extended, this will apply to all RMs sooner or later.

Is it simply just down to the vehicle owners to be responsible and maintain their vehicles to a safe and roadworthy standard (or words to that effect) ?

I would like to think that I am a responsible bus owner, but are there some guidelines that should be followed, especially for those coming into vehicle ownership for the first time. Our civil servants may not be moving very fast when it comes to such matters, but perhaps we could start by being prepared for these changes.

My bus number (if any): RM1368

Nothing, apart from the fact that we are all going to die, can be proved beyond doubt. One could argue that the laws of Physics should be included, but then some people spend their entire lives trying to prove the opposite about some aspect.

The nearest one can get to answering the spirit of the question is I suppose ISO 9001 accreditation. After that I think one only has to look at the string of awards Ensignbus has won over the years to see what constitutes a top notch passenger transport operator.

At the most basic level I guess one could consider an operator's OCRS score, however this is not freely accessible to other than the operator and the DVSA, so it would require the operator to publish the details. Whether a member of the public would have a clue what it signifies or the relevance of the particular score is another matter.

One other certainty you forgot there roy is that we will all pay tax!! :)

To try to get an ISO9001 accreditation for a small one or two vehicle operator like myself and many others is a virtual impossibility. The cost of the paperwork alone would no doubt be horrendously expensive and take up far more time than is spent operating the buses.

I think "the authorities" got it right a couple of years ago when they excluded all pre-1960 vehicles from annual testing. A number of other European countries have similar exemptions. In my view they have done a sensible risk assessment, how many fail their annual test, how many have been involved in fatal accidents, how many have been involved in "serious" accidents etc. How many of them are there on the roads? Well the answer to the last question was about 280 pre-1960 public service vehicles on the road. the number gradually creeps up as more are restored back to working condition, but then others come off the road for major repairs, rebuilds etc. so that would suggest the number remains about the same.

All "ought"to be inspected regularly as part of their operators licence conditions, and any inspection should pick up any faults a VOSA examiner would pick up on. If anyone cares to look at the "reasons for failure" that VOSA publish, lights are no.1, followed by brake imbalance. Other defects such as dodgy steering and excessive smoke come way down the list. So the risk is low.

It could be said that class 5 buses fail for much the same reasons.

Some of the daft things I've known buses fail for: seal missing from tacho sender unit; emergency door lettering missing; wrong type of fire extinguisher; brake imbalance (on a Leyland PD2), after 5 retests and a lot of bad language it was found the examiner was tapping in the wrong brake code assuming it was a modern twin-split system. It was vacuum braked! As I said earlier, a lot of the examiners don't know what they're looking at when it comes to older vehicles. That doesn't mean to say they can't spot a loose ball joint or a defective tyre.

Get your vehicle checked over by someone who knows what they're looking at; get a voluntary brake test done; that should put your mind at rest. VOSA's complaint was always that bus operators were using the annual test as an annual safety check, failing on 28 items then going back once they'd done everything. Things have changed a bit since those days, and that was not so long ago.

My bus number (if any): RML2532

Okay then perhaps beyond doubt was the wrong wording. How about beyond doubt that due diligence is being applied?

Are you saying that an annual check by VOSA takes place and they check all of the items listed?

My bus number (if any): M1001, RML2276, T806

No, all the items listed on their inspection manual are not neccessarily fitted to your bus. :)


Surely the fact you have an Operators Licence means you show due dilligence. Are you on the VOSA "good boys" list or whatever it's called this month? Look at the red/yellow/green system they use. Have you had any "encounters" with VOSA? Etc...

My bus number (if any): RML2532

I return to what I mentioned earlier, it cannot be beyond doubt that due dilligence is or has been applied, because just as in any other industry, we are referring to human beings and their fallibility. This is the reason why checklists are used for certain tasks humans have to complete. It is also why for example, airline cockpit crew physically read out the list to each other at the moment when the task is undertaken.

Yes very occasionally an MOT tester does fail to check an item on that checklist, but as far as the person presenting the vehicle is comcerned, would he be prepared to gamble on which item that might be? Quite often the DVSA will have a campaign focussed upon one particular testable item. If one speaks to the testing staff it is clear that continual examination of particularly modern vehicles provides knowledge of which defects a specific model may exhibit. Those who test older vehicles regularly or who used to years ago tend to have the same ability.

A read through the 200 odd pages in each of the HGV tester's manual, The PSV ditto and the Categorisation of Roadworthiness Defects manuals should give some indication of how standards are applied. Likewise a read through of the syllabus and past question papers for the Transport Manager's CPC exam, should do the same thing regarding the subject knowledge required to supervise a transport undertaking. This is the person legally accountable for the operation of the business.

No, I do not think that simply having an operators licence is enough if it is not an annual test where all other aspects of the operation are checked to retain the licence.

If I have understood the licence requirements correctly it appears my ability to operate a powered lifter is checked more frequently than the ability to operate a public service vehicle.

My bus number (if any): M1001, RML2276, T806

Leaving aside stage carriage operation which consumes a lot of the Traffic Commissioners' time with route applications and variations, his DVSA enforcement staff are primarily inteeligence led. They concentrate their efforts upon those the suspect of operating illegally or of being likely to do so. At the first level the TC will get Court reports of convictions and penalty notices for drivers and those nominated upon an operator's licence, he will take whatever action he sees fit.

Vehicles presented for test are logged against an operator's licence number and the result recorded. As soon as a vehicle fails that operator flags up on the radar. Enforcement staff will, if they deem necessary then visit the premises to carry out a fleet maintenance inspection. They are entitled to inspect ANY vehicle owned by the operator and can if they so wish have it taken away for more detailed inspection. They will however concentrate on the maintenance records for the fleet and the systems used to ensure that PMIs are being scheduled and completed when due and that drives are completing a daily walk around check. If they suspect a need then they will go into very great detail.

The results of what they call a roadside encounter, ie a stop check for tachograph or vehicle fitness is also recorded and can lead to the same level of investigation, particularly of drivers' records and the systems in place to ensure that compliance is being maintained with infringements noted and a record kept that the offender has been made aware and given any advice.

Slowly this intelligence is being improved by technology, there are now numerous locations around the country with buried sensors which weigh vehicles in motion (a PSV has the same potential to be overweight as does an HGV).

The latest vehicles are being fitted with 'smart' tachographs which will by April 2019 be required to be GPS linked. These will and are able to be interrogated in motion. The information transmitted is considerably more than previously recorded by the vehicle and links events to a geographical location. It is also able to record any attempt at tampering with the recording device.

All this information can be accessed by one of the DVSA vehicles which can be seen beside the road. The extent to which this information can be accessed from more central locations along with relevant CCTV images is not currently released.

The above indicates the monitoring which is undertaken and the potetial follow up. This leads where necessary to a Public Enquiry before the TC, curtailment of the number of vehicles authorised, prohibitions from use pending a PG9 clearance, suspension of vocational licence entitlement, loss of a Transport manager's 'good repute' effectively barring him from practice or ultimately revocation of the licence.

It is the knowledge that enforcement staff might visit at any time, with the same determination as HMRC if necessary to investigate, which encourages those who wish to comply with requirements to maintain systems to do so.


Just as in any other industry there will aways be those rogue businesses who do not intend to operate either safely or legally, it is against those that the significant proportion of effort is directed.

As with any other sphere of business there are numerous other regulations to observe with regard to employment and premises, not least being Loler.

All of this of course depends upon the amount of money allocated by central government to provide the resources necessary to ensure compliance.

I am sure that our occasioanl contributor, sometime from Norbert whose name sadly escapes me and for which I apologise may wish to add to this .

The results of the consultation have been released.

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/644455/vehicles-of-historical-interest-substantial-change-guidance.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/644412/government-response-to-exempting-vehicles-of-historical-interest-from-roadworthiness.pdf

My bus number (if any): RM44 RM1138

Hmmm. So I'll still need annual MOTs for the RMs (1960 and 1965) that I operate, and pay £500 each a year road tax. It also looks as though those operating pre-1960 buses, currently not needing MOTs, will need to get them tested from next year.

Good news for owners of pre-1978 vehicles who will be able to change the class to historic and avoid road tax or MOTs.

My bus number (if any): RMs 238, 471 and 2213, GS17

An interesting read but a lot of it totally contradictory! Government guidelines have been know to be somewhat contradictory as to what the law actually days, see the current s19 minibus saga that has been playing out over the last 5 years.

In the letter, it says vehicles used under the operator licencing regimes will need to be tested; the guidance says something totally different. See section 27. Having attended several public meetings with Traffic Commissioners over the last couple of years, they have appreciated the fact that pre-1960 buses have been exempt from the testing requirements and have had no adverse comments about that.

The arguments for additional public safety falls flat as well. Consider the mileage done by a "class 5" bus used quite a lot on free bus services at rallies. There are several I know of that do more mileage per year doing this than my small fleet of class 6 buses. Indeed my GS has only done about 8000km in the last 8 years when the last new tachograph was fitted. It may be that historic buses used in "tourist areas" like London and Edinburgh may do higher mileages, but I still don't see the improvement in road safety if they are being inspected frequently as part of the operator licencing regime.

Most items in the current annual test are irrelevant to historic vehicles, seat belts, emissions, ABS brakes, power doors..

The requirement for the re-introduction of testing for historic will provide and additional burden for such operators who have for a brief period enjoyed savings of about £200 per annum in test fees and the cost of taking said vehicles for an annual test. Account should also be taken that this would involve about 280 pre-1960 buses that are currently used under operator licencing regimes.

What may be captured under the new proposals are total rebuilds such as Ensign's pre-war RTs, the Chatham & District pre-war Bristol I have recently rebuilt, where very little is left of the original body but they have been rebuilt like-for like, in effect a replica body.

Let's see what the actual wording of the amended law says. The way I read these proposals is that the current exemption from annual testing will continue for pre-1960 buses will continue regardless of use. But I may be wrong.

Edited to add that having re-read the draft advice, it is just that. Draft, and advice! there was a similar lack of clarity when the current pre-1960 exemption was made. The EU has definitions for vehicle types. We are still legally bound by those laws as they are adopted into UK laws and I would refer to the EU vehicle type definitions. According to those, a bus is a bus, regardless of use. Buses are quite clearly category E. No difference as to whether they are used "for hire and reward" (UK definition), "commercially" (UK guidance definition), "for fiscal activity" (ECJ definition in the case of Glockner Ambulanz).

Various EU countries have exemptions for historic vehicles. Holland is 1960, I believe France has an exemption too but am open to correction on that. The UK government needs to redefine its own laws on what a bus is in various Acts and has gone part-way to doing that in road signs regulations. For instance the sign "coaches" no longer has any legal standing! So a coach parking bay marked "coaches only" is not a legal road sign. What surprised me is that most EU countries don't have an operator licencing regime. They rely on a bus being a bus, class E vehicle, regardless of use.

Again, we have to thank the s19 minibus saga for clarifying a lot of things, though of slight irrelevance to what we are discussing here. Thos investigations have uncovered what is EU case law. I mentioned Glocker Ambulanz earlier. that case involved a private ambulance firm that carried passengers "for hire and reward" to and from a hospital in Germany under contract. The local hospital authority decided they could do it themselves cheaper by using emergency ambulances in their spare time. Glockner took the case to the ECJ who found there was unfair competition and safety/drivers hours concerns. The ECJ defined such carriage of passengers as "any fiscal activity regardless of the status of the operator", thus declaring obsolete the old UK definition of "hire and reward" and effectively giving the ammunition to the s19 campaigners in their case to get those operators within the PSV licencing requirements. The brown stuff is currently colliding with air propulsion systems on that matter at the moment as some will be aware!

In my view it matters not whether the passengers are paying a fare or not as to whether or not it needs testing. Either it is exempt from testing by age or it isn't, regardless of use, the risk to people and road safety doesn't change.

My bus number (if any): RML2532

I've just read all this having also done the consultation.

It plans to end the disparity for Heritage Class taxation and MoTs by aligning both to 40 years on a rolling basis.

That makes sense.

But how anyone complaining about operating vehicles that carry passengers not being exempt is really questionable.

Sure, a preserved historic vehicle might do more miles than a fully certificated working vehicle of the same age and type. But one is carrying paying customers, the other probably a few pals.

But missing from this is the insurers take. Most heritage/classic insurers have a mileage and use restriction in policies.

As for rebuilds and modifications, it's a bit confusing and the points scoring is a bit askew.

But if say an RT is rebuilt from scratch, it is probable that the chassis will be largely intact and the source of the authenticity. If the body is renewed 100% but to the original specifications apart from verification of such it will not be an issue. How can it be? However it it were say rebuilt entirely from Aluminium and carbon fibre then it would need to be proven that it is safe and sound and comply with the specifications of a modern structure.

But in all honesty I still think any elderly vehicle, no matter how pristine or not should be tested at the very least every two years and if used regularly every year. After all, how many have rolling road facilities and suspension testing facilities at home?

And for operating vehicles? Well it's business and they must be as safe as possible and commercial use does mean commercial rates.Same as for a modern vehicle. But the tests will not be as stringent and age based exemptions will remain for all those that are over 40 years. That's better for say a 1977 DMS and in a another few years a Titan or Metrobus. But All RM types are now included instead of just pre 1961 built models.

I half tend to agree with what you're saying there Jack. But, almost every weekend in the summer there's a class 5 bus doing free bus services full of people and I'd bet that many do more loaded miles than quite a few class 6 historic buses.

As I've pointed out before, those operated under an O licence will ave had the regular preventative maintenence checks which ought to pick up any defects, that is the point of them, not to use an annual test as a safety check as has been the case with many class 5 buses. As for rolling road facilities, many commercial garages and certainly Authorised Test Facilities (ATFs) will do a voluntary brakes and headlight aim check for around £20, so there's no real excuse for any bus owner not to have them tested. My O licence is that they have to be checked twice a year, not including the annual test.

It's good that the age for no annual test and historic road tax i being harmonised. But, would the safety of PSVs be compromised by having to revert back to having an annual test? I think not.

My bus number (if any): RML2532

I would certainly disagree with the the generalisation that Class V buses only carry a few pals. These running day events are extremely popular with vehicles often travelling a considerable distance to attend, far enough in fact for there to be some concern about the duty and driving time involved if there is only one driver present.

More relevant however is the loadings, most definitely more than a few pals, many vehicles will be full up - often mainly with overweight men - and we have already had considerable discussion about the fragility of RT bodywork. Moreover the passengers are not 'pals', they are members of the general public. These events are normally advertised as a local attraction for the towns in which they are held. While enthusiast men form the majority of travellers, a significant percentage of passengers are local families out for the day wanting to show their children how things used to be.

Often the routes involved are challenging, not just negotiating narrow lanes and parked vehicles, but climbing and descending the local Alp. I can think of one route which entails a protracted steep descent into town with very often a full load. A load which the normal service bus equipped with retarder, probably never carries, nor quite probably did the type of bus back in its everyday use.

Some of the events later in the year involve a return journey in the dark. I don't know whether it is a desire for authenticity or concern for the vehicle's battery, but it is not unusual to see these vehicles copying historic and everyday pratice with all interior lights extinguished. There is nothing wrong with that for a modern bus, but the miniscule tail light of a fully darkened RT chugging along the motorway at 35mph is simply asking for trouble.

I see no difference whatsover between such Class V buses and their revenue earning stablemates.

As has been mentioned this will be insurance industry dictated.

My bus number (if any): M1001, RML2276, T806

I was referring to Privately owned Class V buses not those owned by licensed operators. Just because elements of the construction industry are vetted by industrial controlling bodies doesn't mean every industry has to be. I don't see Southern Rail etc answerable to some quango, they are answerable to the railway inspectorate or the ORR as it is now called, which like the DVSA is a Government body, albeit with industry officials participating. This is unlike Gas Safe or the NICEIC which are commercial enterprises to which there must be attached a certain amount of flag waving advertising kudos for its members.

Mmmm. Not that much flag waving for the money I pay. Perhaps it helps with domestic electricians. Of course NICEIC compliance isn’t compulsory, it and other bodies compliance is simply a requirement of all MY customers. Why? Because I have to prove that I can do the job.
Gas Safe? Now that is law, a bit like an operator’s licence but I now wonder how often a gas engineer’s competence is checked compared to a bus operator.

And it isn't just construction. Many industries do this. Fork lift drivers are forced to take a retest every five years even though there is no legal requirement to do so. It is all about reducing the chance of injury or showing you have done your utmost to prevent an issue that might result in an injury. Those that are pushing this will include insurance companies for monetary reasons and company directors also for monetary reasons and to keep out of prison. So why would any company director or sole trader employ anyone that cannot prove their ability. Timed served apprenticeship? with the greatest of respect, how would that prove that he or she is able to work on the bus you own. Without a system they cannot prove it and therefore neither can you and it is you, the operator, that is going to be explaining that in court.

I have just been looking at TfL documents for contractors and suppliers. It says;

In order to demonstrate commitment to Health & Safety in the workplace and in the completion of duties under this Contract, the Contractor will be registered under the Contractors Health and Safety Assessment Scheme (CHAS) or equivalent, such as Safety Schemes in Procurement (SSIP).

I am just surprised that for running a bus, it appears to be simply "do you have an operator’s licence"? Periodic checks are surely better than intelligence led investigations. lock the stable door after the horse has bolted springs to mind.

And to bring this back on topic, I am not sure I agree with any vehicle not having an mot, I would be happy for any bus that can carry more than 8 passengers to need a class six mot and would not have an issue with some sort of not for hire or reward operators licence system.

Edit. The NICEIC claim to be there to protect the consumer. Gas Safe is the body you have to belong to to comply with gas laws. I think the flag waving is somewhat less than you imagine.
I think Southern Rail may actually be answerable to the quangos known as Network Rail and TfL!

My bus number (if any): M1001, RML2276, T806

I referred before to HMRC and compared them to the DVSA. I also mentioned that the DVSA devote a significant part of their enforcement resources to intelligence led investigation. Just like the HMRC inspector, that does not mean that routine visits do not also feature. Operators know that their premises can be visited and a full blown investigation started out of the blue. They also know that one of their vehicles may be stopped for a roadside check at any time regardless of their compliance score. Leaving aside stage carriage vehicles which will be checked at a terminus, private hire vehicles will more likely be examined at a venue or Motorway service area when passengers are not present. That does not mean that they are never stopped roadside, as booze cruise operators have found out when prohibited for overloading at the Brenley corner DVSA site.

Moving to the Haulage industry briefly, there are several accreditation schemes, the most notorious being FORS, which is required for construction site deliveries in London.

As far as the general public is concerned the safety aspect of vehicle operation is paramount. That area is covered by the MOT, which although only a level of the absolute minimum standard which few seem to appreciate, represents something like a weekly examination of competence in that aspect for those preparing vehicles for test. This very soon weeds out the incompetent. On a level of efficient operation, which does not really interest the public, the motor trade is led by the franchised dealers sending fitters on manufacturers' training courses to be instructed on the latest model technology.

As time goes by the trade is being split into the component swappers who will do the labouring type jobs and the talented, who can progress through the manufacturer's system to become what is known as master technician. To achieve that status requires years of experience with theoretical and practical examination on the operation not just of systems but each individual component of it. As an example, there are around 30 different valves in a modern air brake system for an artic, however these can be sourced from several manufacturers with slight variations in design (viz the Clayton Dewandre RM footbrake valve re. the Lockheed one). That is for the current model range, but the same level of knowledge of earlier systems is required. A similar level of assessment is conducted by the IRTE.

Of course all this ignores the Elephant. The one person who can really impact on the customer's day. Rediculously, currently there is no need for the aimer of ANY vehicle to undergo a subsequent assessment of ability other than medical.

Some interesting points there by David and roy.

There has been a licencing system in place for many years for those buses carrying "the public" not for hire and reward, known otherwise as Section 19 and Section 22 of the 1987 Road Transport Act 9I think is the statute). Those sections of the Act have been blown clean out of the water by recent investigations by a small group of operators and the EU into the activities of these s19 operators and their operation has been in breach of the law for at least 10 years, as has well been documented in the trade press recently.

The law is that to carry passengers for hire and reward (as defined in the Lundberg case in the ECJ), the bus must be licenced as a bus; it must display an operators licence; the driver must have class D entitlement, the driver must have a current DCPC. It must be insured to carry passengers for hire and reward. To save me re-typing what has been put in the trade press on this matter recently I suggest looking through recent issues of RouteOne or Bus & Coach Buyer.

The Lundberg case dealt mainly with the issue of tachograph use, but clearly defined "hire and reward". A lot of the UK people have twisted "hire and reward" as the driver getting paid with passengers paying a fare. The new "guidance" from the DVLA has clarified that as it now includes clearer definitions on those issues. The Rout-v-Swallow Hotels case defines carriage of passengers for hire and reward. There was another case I read recently which was the British Motor Insurers Bureau-v-(a widow whose husband was killed in a car crash), can't remember her name offhand, but that case involved her husband being given a lift on a regular basis to and from work on a for petrol money. That was deemed by the UK High Court as hire and reward. The MIB had to pay out as the car drivers insurers excluded H&R use.

One problem with the DVSA testers is that they are now trained to deal with modern vehicles; the dinosaurs like roy and myself and probably most others on here know what we are looking at under old buses, the examiners may not know as they've never worked on them.

One notable bus I presented for test a few years back was the CBM Dennis open topper from 1927. It has a Certificate of Initial fitness and was up for annual test at Mitcham GVTS. I presented it, the examiner (the top bod there) was interested. Put it over the pit, hmm, no front brakes. Stop the engine. Me: No. Why? Because I won't be able to start it again. No electric starter and the handle was over an open pit. And so it went on. It was a bit of a farce. In the end he passed it and we went on our way. the following week we presented the Tilling ST! At least that had brakes on the front and a cab.

As I've said before, far too many bods these days use their buses for "mates weddings" on a far too regular basis, and the DVLA "intelligence" system rarely picks them up. Ye, I know I done it too back in 1971, but in those day there were so few preserved buses nobody bothered. We had a job even getting an annual test, but in all those years, nobody has been killed or injured by my bus.

EU law gives individual countries the right to exempt vehicles of a certain age from annual testing. the same sort of exemption is not given to those who drive large buses, i.e. those with over 8 passenger seats. they MUST have class D entitlement, and if they're carrying passengers for money, now with the new "guidelines" clearly defining others as direct family, if they're not family, you need the DCPC too. Your pre-1960 bus however does not need an annual test.

My bus number (if any): RML2532

The DfT have just recently issued the following 'clarification' regarding exemption from testing:

" The exemption from testing REMAINS pre 1960 for Public Service Vehicles providing they have not been substantially modified. To be considered a Public Service Vehicle a bus or coach needs to be used commercially. The exemption is moved to 40 years rolling FOR OTHER, NON PSV BUSES AND COACHES (provided they have not been substanially modified)."

So PSV post 1960 will still need to be tested.

That's very strange ............ the Department finally replied to my query last week and confirmed that the exemption for pre-1960 commercially used vehicles is to be discontinued ......... does the left hand know what the right hand is doing ?

Can you tell me where this announcement is, as I'm now confused (again). If necessary I will write to them straight away.

My bus number (if any): RM1368

Quoted from the Editorial in December Classic & Vintage Commercials. The wording, paragraph six of the Editorial, from DfT was in response to the Editor's request for clarification regarding contradicting statements by the DfT and the Transport Minister Jesse Norman regarding which Lorries and Buses would be exempt and which would not.

The complete Article runs to eleven paragraphs.

This would appear to be the result of brain-sharing by those in authority, a practice very common in government circles whereby the only brain available for use is kept under lock and key in a cupboard and has to be signed for. As usual our highly paid expert officials, lackeys and ministers turn out to be incompetent oxygen wasters. Not only can they no longer be put in the stocks, but hanging, drawing and quartering has sadly gone out of fashion.

I have taken this matter up with the Confederation of Passenger Transport for further clarification. I have also seen what roy said confirmed elsewhere, but can't remember where, I've been looking at so much of this stuff lately my brain is confused by it all!

I'm also seeking clarification as to whether our buses need a new Certificate of Initial Fitness and again this is a long drawn out discussion and lots of searching through various road Traffic Acts back to 1930. Basically any bus that had a certificate of fitness (usually known as an FFD) OR SIMILAR in 1981 would automatically be assumed to have a Certificate of Initial Fitness. The "OR SIMILAR" could be taken to mean a class 5 test certificate, the law does not specify. The law also does not specify when a bus is "withdrawn from service", what is service? How could the authors of those laws know that in 40 years time some buses would be put back in service, they had only been temporarily withdrawn. One of my buses was withdrawn from revenue earning service, but was on a class 5 at the change-over date in 1981, so it comes under the "or similar" category.

Anyway, hopefully all will be clarified at dome dim and distant date.

I just remembered where I heard the pre-1960 exemption will be continued, it was in a dfT document and was heard from a DVSA official at a CPT meeting.

My bus number (if any): RML2532

Final details of VHI consultation have now been finalised and released.

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/668274/vehicles-of-historical-interest-substantial-change-guidance.pdf

My bus number (if any): RM44 RM1138

Been reading the document in the above post namely the section:

My bus number (if any): RMF2771

Probably the only people qualified to answer that query would be the DVSA as otherwise it’s only someone’s opinion and at least you’d have written evidence of the interpretation ?

My bus number (if any): RML2747

On behalf of the DfT and DVLA, the FBHVC have invited organisations to be nominated VHI experts. The Routemaster Association has already flagged up queries with the guidance as so far provided and we have accepted the invitation from the FBHVC to be one of the nominated experts in order to represent Routemaster owners.

Hopefully this grey area will become less murky and between all the organisations working together this can all become clear in due course.

Andrew Morgan

My bus number (if any): RM1368