I would like to alert you to a matter that should be of concern to the many bakers that use a small transit van to deliver their goods.
The operation of large goods vehicles is covered by EU rules, which incorporate drivers' hours, tachographs, rest periods and other exacting operating requirements.
Vehicles 3.5 tonnes and below (transit type van and smaller) are exempt from the EU rules, but must be operated within 'domestic rules', which are far less stringent and offer much more flexibility and simplicity than for large goods vehicles. These domestic rules have not altered fundamentally since the 1960s, but the Department of Transport (DOT) is now reviewing them. As it is a consultation, the rules may be: scrapped altogether; left as they are; or made more complex and stringent.
I am part of the consultation process already, as I am a qualified transport manager and an operator of both large and small goods vehicles. We are well-known to the DOT and are members of the Freight Transport Association. But many bakers will be unaware of this review and the possible implications, restrictive and costly, that may arise from it.
Some questions that may concern bakers if rules become more stringent include:
Question 4: Should break requirements be introduced for drivers of goods vehicles in GB? In large goods vehicles the break requirements are 45 minutes after 4.5 hours' driving, which must be taken as one 45-minute break or a 15-minute and a 30-minute break. When delivering with smaller vans to canteens and food shops in multi-drop operations, we find that our drivers take several smaller regular breaks - usually with their friendly customers at convenient times. It is rare that one of our van drivers would have 4.5 hours' total driving time in a day anyway, because most of the work is spent loading and unloading. But how would the driver prove that they had not broken the rules?
Question 9: Should weekly/fortnightly rest requirements be considered for drivers of goods vehicles? Large vehicle drivers must take a full day off every week and a full weekend's (two continuous days') rest every fortnight. If this is extended to small vans, the one-man baker may not be able to drive his van every second Saturday. Some bakers I know work every day (seven days) albeit only an hour or two on Sunday. If a baker has a buffet to nip down to the local village hall on the Saturday evening, he couldn't drive the van himself if he also drives in the week.
Question 13: Should the use of tachographs become mandatory for vehicles operating in scope of the domestic rules?
New vehicles must have digital tachographs. To drive the van, the baker must have a personal digital tachograph smart card (individual for each and every driver) and a reading machine (computer) to analyse the cards, and keep records and maintenance. This effectively means that, in the event of staff shortages, it would not be possible to use a casual driver or for one of the bakery staff (without the tachograph card) to stand in.
To respond to the consultation document visit: http://tinyurl.com/lc9o8r.
John Foster, Fosters Bakery