Alison Moriarty FCILT, Managing Director and Head of Compliance at Beverley Bell Consulting & Training, discusses the topic of changes to the Guide to Maintaining Roadworthiness
Operators in all sectors of the transportation industry are trying to grapple with the changes made to the Guide to Maintaining Roadworthiness (GTMR) that were published in November 2024.
The first thing we need to understand is the meaning of the word ‘guide.’ To some of us, this will hark back to the days when we donned our blue uniforms and attempted to gain badges, to prove that we could cook, forage and cross the road safely. I did always wonder why competence in sewing wasn’t the first one so that we could save our mothers from the hours they spent sewing the badges on our uniforms.
But what is the meaning of the ‘G’ in GTMR? Is it a suggestion of how we might like to carry out our various responsibilities? Or is it telling us that we must do things a certain way, and how much leeway is there to say ‘thank you for the suggestion, but I don’t think that we will do it that way’?My interpretation is actually very simple and taken from the many years I spent as a Health & Safety professional. The GTMR is very similar to the many Approved Codes of Practice (ACOPs) that cover some important H&S subjects. The legal status of an ACOP is this: “It gives practical advice on how to comply with the law.
If you follow the advice, you will be doing enough to comply with the law in respect of these specific matters on which the code gives advice.” I have always taken this to mean that, unless I am doing something that is to a higher standard than the guidance, then I should follow the guidance as stated. The GTMR is a minimum standard that should be viewed as a starting point, rather than something to aim for; we never want to allow the minimum to become our maximum.
I know that operators want to make sure that their vehicles are safe on the roads, and that is really all the guide is there to do. By way of an example, the additions to ensuring that all maintenance is provided by competent people working at suitably equipped premises, makes perfect sense. Should you do this in-house, then you will need to make sure that your own facilities are adequate.
If you choose to outsource any of your maintenance, you still have the responsibility to ensure that your provider has the requisite premises, equipment and expertise. Always remember that since you are paying the provider, ensuring you receive a good service is simply good business sense.
Don’t be afraid to question unclear or missing data on the reports that you receive and ensure that your Transport Managers understand how to look for trends, duplicate work and driver-reportable defects. It is also vital that you know how to interpret roller brake test reports; although seeing ‘passed’ is always encouraging, it is only the beginning of the story.
My personal opinion is this; I would like some different terminology that says ‘you must.’ This would make it very plain for operators to understand what they need to do and leave less room for interpretation. To conclude, I would like to leave you with one piece of advice: if you ever find yourself in the unfortunate position of being in front of a Traffic Commissioner, I wouldn’t spend any time trying to debate the meaning of the word guidance, I think you will find that they already have their own interpretation.
