For Transport Managers and Fleet Managers
General Haulage (with Steel notes)
Want the full version? Download the comprehensive guide from checkpod.co.uk. This version covers the same ground in 1/4 of the words, with the boring bits skipped and the important bits flagged.
Colin the Compliance Cricket holding a clipboard with a cheerful but firm expression, standing next to a stylised HGV with a tick mark above it. Background: subtle Yorkshire-yard scene at sunrise. Tone: friendly authority. Colour palette: CheckPod green (#639922) on dark navy.
The 30-second version
Compliance is just running a fleet properly with the records to prove it.
Six things will land you at Public Inquiry. Get those right and the rest sorts itself out:
- Roadworthy vehicles. PMIs at the right interval, defects fixed and recorded.
- Daily walkarounds. Every shift. Every vehicle. Recorded.
- Drivers' hours and tachos. Within limits, downloaded, analysed, briefed.
- Driver competence. Right licence, current DQC, ongoing training, documented.
- Load security. Secure for 0.8g forward, 0.5g sideways. Especially on steel.
- Records. 15 months minimum on most things, longer on some.
If you can't prove it, you didn't do it. That's the rule that matters.
1. Your operator licence — what you signed up to
The licence isn't just a piece of paper. You made formal undertakings to a Traffic Commissioner. Break them and the TC takes it personally.
The headline undertakings:
- Vehicles will be roadworthy
- Defects will be reported and fixed
- Records kept 15 months
- Drivers' hours and tacho rules followed
- No overloading
- Right licences and CPC for drivers
- Notify changes within 28 days
Three licence types in goods:
- Restricted — own goods only, no TM required
- Standard National — own + others' goods within UK, TM required
- Standard International — adds cross-border, TM required
Financial standing is ongoing, not just at application: £8,000 first vehicle + £4,450 each additional (Standard licences).
2. The Transport Manager — the person on the hook
If you've got a Standard licence, you need a TM in continuous and effective control. That's not signing things once a month from a beach in Spain. It's:
- Sufficient time committed (small fleet ~4hrs/week, scales up)
- Real authority over maintenance, drivers, vehicles
- Documented involvement — signed reviews, recorded decisions
- Knowing the operation, not just signing forms
TM disappears? Notify TC within 28 days. Period of grace usually up to 6 months. After that, no TM = no licence.
3. The walkaround check
The most-checked record at the roadside. The single most important daily routine on the operation.
Driver does it before every shift. 15-20 minutes. Records it. Nil-defect counts.
Simple top-down diagram of an HGV with numbered checkpoints around it (1-19). Use the DVSA walkaround items. Colin in the corner pointing to the diagram with a "start here" arrow. Keep it clean — info-graphic style, not cartoon.
The 19 DVSA items (HGV, current as of 2025 update):
Inside: seat belts, mirrors, wipers/washers, horn, steering, brakes, warning lamps, tacho, lights from inside.
Outside: lights/reflectors, tyres, body, brake lines/electrical, coupling, trailer, spray suppression, fluids, AdBlue, battery, HV cut-off, alt-fuel.
Operator's job: make sure the system captures the records, retains them 15 months, and surfaces defects to the right person fast.
4. PMIs — the every-six-weeks job
Different from the walkaround. Workshop-based, technician-conducted, structured inspection at intervals between 4 and 13 weeks.
Setting the interval: declared on your O-licence. Bound to it.
| Operation type | Typical interval |
|---|---|
| Easy operations, lightly loaded | 6–13 weeks |
| General haulage / trunking | 5–10 weeks |
| Multi-drop, urban, off-road | 4–8 weeks |
| Vehicles 12+ years old | 6 weeks max |
| Tipper, scrap, plant | Shorter still |
Brake testing. Laden RBT at least annually, preferably every PMI. Service brake ≥50%, secondary ≥25%, parking ≥16%. Imbalance ≤25% across an axle.
First-use inspection for any new-to-fleet vehicle (purchase, hire, lease, returned from off-road). All annual-test items, laden RBT where appropriate.
5. Drivers' hours, tachographs, WTD
The headline limits — the ones you and your drivers should know cold:
| Limit | Value |
|---|---|
| Daily driving | 9hrs (10 twice/week) |
| Weekly driving | 56hrs |
| Fortnightly driving | 90hrs |
| Daily rest | 11hrs (9 three times/week) |
| Weekly rest | 45hrs (24 every other week) |
| Break after driving | 45min after 4.5hrs driving |
| WTD weekly average | 48hrs over 17/26 weeks |
Tacho download:
- Driver card: every 28 days max (good practice 21)
- Vehicle unit: every 90 days max (good practice 60)
- 12 months retention minimum, 24 good practice
- 56 days for international (since April 2025 AETR change)
Analysis is the operator job. Raw data isn't enough. Pull it, analyse it, debrief drivers in writing, document corrective action.
6. Driver competence
Three legs:
- Vocational entitlement (Cat C / C+E). Check at hire and at intervals — six-monthly is best practice.
- Driver CPC. 35 hours every 5 years. Track expiry dates 90 days ahead.
- In-house training. Toolbox talks, refresher modules, sector-specific. Document every session.
DVLA Share Driving Licence service: free, drivers generate a code, you check. Keep records.
7. Load security
Standard: secure against 0.8g forward, 0.5g sideways, 0.5g rearward.
Methods (usually combined):
- Form-fit: load against headboard, side rails, blocking
- Friction: rubber mats, anti-slip — supportive, not sufficient alone
- Lashing: straps (BS EN 12195-2:2001 — typical 300 daN/strap, 500 daN with ergo ratchets) or chains (BS EN 12195-3) — never combine the two on one load (Dec 2024 rule)
- Combinations of form-fit + lashing for most real-world loads
Three side-by-side trailer cross-sections showing: (1) form-fit against headboard, (2) over-the-load lashing, (3) loop lashing. Annotate each with "best for: [load type]". Clean technical illustration style.
Headboard: rated for at least half the rated payload. Damaged = fix before vehicle moves.
The operator's job: spec vehicles correctly (anchorage points, EN 12642-XL where appropriate), provide good equipment, train drivers, audit load security on returned vehicles.
Steel section — what changes
- Chains commonly preferred for high-mass steel. Reason is mechanical, not regulatory: at typical steel weights, the daN restraint required exceeds what straps deliver before you run out of anchorage points. DVSA describes chains as "a very effective method" for steel — not as mandatory.
- Never mix chains and straps in the same load. December 2024 update — explicitly prohibited. Pick one method per load.
- Edge protection — every chain over a steel edge, every time
- Coil cradles for eye-horizontal coil
- Re-tensioning after first short distance — write it into driver SOPs
- EN 12642-XL bodies worth specifying for steel-heavy operations
- Mill site induction culture — manage centrally, track per driver per site
The policy point — post-Dec 2024
The December 2024 DVSA update raised TC enforcement priority on operator load security policies. After a serious incident, the inquiry asks: where's the policy, where's the risk assessment per load type, where are the driver training records, where's the equipment audit log? Absence of those is grounds for action against the O-licence — not just the driver. Documented policy + training + equipment audit + spot-check log + incident review process is the minimum every TM running steel, plant, or abnormal-load work needs on file.
8. Records — the 15-month rule
15 months minimum:
- Walkaround records (including nil-defects)
- Defect reports + closure
- PMI reports
- Repair records
- Brake test results
- Annual test paperwork
- First-use inspection records
Longer retention:
| Record | Retention |
|---|---|
| Tacho data | 12 months min, 24 good |
| WTD records | 24 months |
| Driver licence checks | Employment + 6 years |
| CPC records | Employment + 6 years |
| RIDDOR | 3 years |
| Insurance / O-licence | Indefinite |
Digital is fine if it's tamper-evident, available on demand, backed up, retained for the period, and produces records on request.
9. OCRS — the score that matters
The bands:
- Blue — Earned Recognition member
- Green — low risk
- Amber — medium risk
- Red — high risk
- Grey — no recent data (new operator)
Vertical traffic light with the four bands. Green band has a tick, Red has flashing lights / DVSA stop sign, Blue has a star (Earned Recognition). Below: "Your score = how often you get stopped." Colin pointing to Green saying "Aim here."
3-year rolling window. Recent encounters weigh more. Old ones drop off.
Improves through: clean encounters, clean fleet assessments, clean MOT pass rate, time.
Worsens through: prohibitions, FPNs, prosecutions, MSI infringements.
Earned Recognition: voluntary scheme, share live data with DVSA, get reduced roadside attention. Gates: 24 months trading, mature systems, good OCRS.
10. The day DVSA shows up
Roadside
ANPR triggers, examiner stops vehicle, checks paperwork + tacho + load + vehicle. Outcome: clear / verbal / FPN / delayed prohibition / immediate prohibition.
Your job from the office: support driver, arrange recovery if needed, get clearance certificate (not just repair), document the whole event.
Operating-centre visit
Announced or unannounced. They want to see: maintenance records, walkaround records, tacho data + analysis, driver licence checks, CPC records, O-licence docs. Be ready.
Public Inquiry
If the TC calls you, get a transport regulatory solicitor. Not your normal solicitor — a specialist. PI defence runs £5k-£25k+. Don't try to save money on that.
At PI, the TC looks for four things:
- Honesty — don't deny what's documented
- Insight — do you understand what went wrong
- Remedial action — what have you changed, with proof
- Future risk — are the changes credible
Most PIs are recoverable if you turn up prepared. Most are catastrophic if you don't.
11. The five principles of a system that survives audit
- Single source of truth. One system. Not five spreadsheets.
- Forward-look. 90 days ahead — every expiry visible before it bites.
- Audit trail by default. Who did what when. Auto-recorded, not bolted on.
- Role separation. Driver creates, TM reviews, workshop closes. No one does end-to-end alone.
- Document the abnormal. "Vehicle used 2 days past PMI due to workshop unavailability; TM personally inspected, no defects, PMI rescheduled" — that's a defensible record.
Five stylised pillars under a small "compliance" temple roof. Each pillar labelled with one principle. Colin the architect figure pointing at the structure. Keep it minimal.
12. Quarterly self-audit
Run this every 3 months. Pick at random:
- One vehicle
- One driver
- One week
Find every record that should exist for that combination. Walkarounds, PMI, repairs, tacho, training, licence checks. Time yourself.
Under 30 minutes: system is healthy. 30-60 minutes: systems need tightening. Over 60 minutes: you have an audit-readiness problem. Fix it before DVSA finds it.
When things go wrong — quick action list
Roadside prohibition: stop driver, get prohibition reference, arrange recovery + repair, get clearance certificate (not just fix), document.
Accident: driver safety first, emergency services if needed, photos, no admission of liability, notify insurer within 24hrs, internal investigation, RIDDOR if applicable.
PI call-up: specialist solicitor immediately, evidence pack, full disclosure to your lawyer, prepare insight + action plan.
TM resignation: notify TC within 28 days, period of grace begins, find replacement.
Cyber incident with personal data: notify ICO within 72hrs if reportable.
Where to get more
- Comprehensive version of this guide — checkpod.co.uk (the deep dive)
- gov.uk — DVSA Guide to Maintaining Roadworthiness, walkaround guidance, load securing guide, drivers' hours, OCRS
- DVSA Moving On blog — movingon.blog.gov.uk (subscribe)
- Senior Traffic Commissioner Statutory Documents — gov.uk
- Trade bodies — RHA, Logistics UK
- Specialist solicitors — for PI, TM Conduct Hearings, prosecutions
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