Proper driver activity record keeping and manual entries

By Andrea Bennett, Transport Compliance Specialist

As part of an application to join the DVSA ER scheme, operators are required to pass an earned recognition evidence-based audit to show exemplary transport management systems and compliance are met. The audit is conducted by a DVSA Earned Recognition third-party approved audit provider.

When undergoing an Earned Recognition audit, operators are faced with some common pitfalls and challenges which can be avoided if the operator is prepared prior to the audit being conducted. These often centre around:

• Company Directors and registered address details listed on the Vehicle and Operator Licensing Service (VOLS) not matching the exact details listed on Companies House
• Correspondence address when different to registered office address not listed on the Vehicle and Operator Licensing Service (VOLS).
• Transport Managers/Responsible persons who delegate their TM responsibilities to other members of staff not carrying out checks/audits on the work delegated to ensure the work is carried out to the standard required
• Disorganised record keeping, training records or incomplete documentation – records must be up to date, accurate, consistent and easily retrievable for the auditor
• Manual maintenance systems (paper files, spreadsheets) are acceptable but evidence gathering during the audit can be tedious and inefficient for the auditor. An electronic maintenance system is a more efficient system
• Failing to act on identified driver infringements and vehicle defects
• Key Performance Indicators (KPIs) – electronic or manual systems must show that KPIs are consistently being met and that alerts are being triggered and acted upon when tolerance is exceeded
• Operators not acting upon unaccounted mileage
• The Earned Recognition scheme also requires potential operators to ensure all trailers operated by the company are specified on the operator licence

The Transport Manager/Responsible Person must be present and actively involved for the duration of the audit to demonstrate their control of the transport operation and the effectiveness of the systems.
To avoid these pitfalls and challenges, operators are advised to refer to the Earned Recognition Audit Standards on Gov.uk and complete a pre-ER audit to identify gaps, invest in training, and ensure digital systems are fully integrated and compliant before the official ER audit is conducted.

Andrea Bennett is a transport compliance specialist with more than four decades of enforcement experience from her 41-year career with the DVSA. She served as a Traffic Examiner in North Wales before moving into senior roles within the DVSA Earned Recognition team, including Audit and Standards Manager. A qualified ISO 9001:2015 internal auditor, she has extensive knowledge of operator licensing and enforcement practice. Having worked closely with Aquarius through the ER scheme, she now supports the business by carrying out system audits and helping operators maximise their use of Aquarius compliance systems.

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