Response of the Road Haulage Association to Transport for London s consultation on the draft Freight Operator Recognition Scheme

Transcription

1 Road Haulage Association Ltd Response of the Road Haulage Association to Transport for London s consultation on the draft Freight Operator Recognition Scheme 1. The Road Haulage Association is the UK s primary trade association representing firms providing road haulage and related services, with 10,000 member companies operating more than 100,000 commercial vehicles. Members range from ownerdrivers to very large logistics companies. RHA commitment to safe efficient and reliable freight services 2. The road haulage profession provides an essential, efficient and flexible service to the people, businesses and organisations of the UK. It comprises a healthy diversity in terms not only of company size but also of special services and geographic location. It is highly innovative within national and EU regulation. Its culture of fuel efficient and safe driving has given it an excellent safety record and was further strengthened by the SAFED programme, which the RHA launched to the industry (working with AEA Technology). We expect this culture and performance to be further enhanced by the Driver CPC and tougher Transport Manager CPC requirements. 3. The RHA is committed to championing road safety and efficiency, working with members, government and others to further enhance the performance of the industry; and we were pleased to offer our support to Transport for London in identifying these as areas it wanted to improve. We wish to continue to engage with TfL and others to drive up standards of commercial vehicle operation in urban areas and to engage with to tackle specific issues relating to London. 4. We are conscious of the frustration felt by many, and which we share, at the failure of a proportion of truck operators to achieve an acceptable standard of compliance. However, we have fundamental concerns about FORS as the best means of achieving the positive goals that we share with TfL. Concerns over FORS

2 5. This scheme appears to be incompatible with the national government objective of reducing regulation and red tape on business. London is adding, in effect, to another standard to those with which operators in the highly regulated hire or reward sector must in practice already comply. We believe that the impact of this scheme will be to add administrative burden, to reduce choice and increase the operational cost of deliveries in London without significant benefits in terms of reliability and safety. Indeed, they may distract resources from that effort. Truck operators are likely to view the scheme as cumbersome, intrusive, and of little value. 6. We are surprised that TfL sees the O-licence as merely a bronze standard. The truck operator licensing system is and should remain the gold standard. Our system of regulation is the most coherent, the toughest and therefore in many ways the best in the EU and provides an appropriate framework for raising standards. We would welcome the opportunity to engage from an early stage in any review of whether the O-licensing system needs to be strengthened or developed in its requirements, promotion and enforcement. But this should be done nationally, or even at EU level since transport is a European competence. 7. We are struck by the omission from the 43 pages of the draft specification to require FORS members to employ the services of a management CPC holder. This qualification is recognised across Europe as the cornerstone of understanding what is required to run a truck. Northern Ireland, in over-hauling its licensing system, has decided that all truck operators will in future have to have a CPC holder. In the UK, 46,000 restricted licence holders have no requirement to have a CPC-qualified manager. 8. It would be useful to include security issues within any programme for improving operational practice. The AIMSS and RHIMSS standards have much to offer in this regard. 9. We have been unable to identify clear priorities within FORS in terms of objectives, identification of the problems to be solved and analysis of the costs/benefits analysis of the scheme. FORS embraces a very wide range of issues and objectives, from good practice in truck operation to social responsibility, the wellbeing of customers, the uses of certain delivery methods and the furnishing of freight information; it is too widely drawn and too subjective. 10. Insofar as FORS is concerned with truck operation, it is unclear as to whether there is a general concern about the industry or whether the main focus is to be on specific groups or types of trucks such as tippers and skips. It has been suggested that the greater concern relates to vans, a sector which is unregulated and poses different issues.

3 11. The grading of scheme members as bronze, silver and gold is unwelcome. The test should be, are we satisfied that this organisation is meeting the commitment it has given to the nation as a whole, that is, through the traffic commissioners. Gold implies better than bronze and silver in a way that could mislead customers and the general public in respect of the quality and level of compliance of the service provided. 12. We welcome the apparent de-coupling of FORS from VOSA s internal system for targeting enforcement efforts, OCRS. 13. We see a clear implication that VOSA s enforcement and education efforts are falling short. This may be the case, for a variety of reasons, not least to do with funding. Much could be done to raise standards using the nationally recognised O-licensing system. 14. We are uneasy about the principle of giving access to London and its freight facilities, including for collection and delivery, to FORS members on preferential terms, or, even more so, if this were to lead to de facto exclusion from part or all of the goods transport market in London for those without FORS. We also question the legality of aspects of the scheme under Article 30 of the Treat of Rome; a concern which we understand has also been expressed by the IRU in Brussels. 15. There needs to be greater transparency about the relationship between FORS and operational freight data gathering. Blanket freight data may be relatively easy for large companies to provide but other than that for MHRC purposes it is not required for most operators. (The industry Europe-wide already objected to this requirement when it was proposed under new Home office legislation.) 16. Inspections of scheme members, who initially self-certify, will be costly. Who will pay? It is currently an issue for VOSA, for example. In trucks, we should be targeting inspections on those firms that we fear may be falling short of the current O-licence standard; we question that practicality of inspecting hauliers who may wish to join from outside the South-east and especially from Ireland and continental Europe. 17. How will FORS be funded? We would welcome information as to the annual budget for FORS, where funding is coming from and assurance that it is guaranteed well into the future. The FORS newsletter (Number 1) states that discounts on licence checks are being offered. We view with interest this innovative public-sector subsidy to business and seek confirmation of the extent of subsidy and period over which it will be offered. 18. At present there is no suggestion that operators would pay for membership. We would welcome confirmation that this will remain the position.

4 19. We understand that there is much concern perhaps the greatest concern over van standards. We feel that the draft scheme is not appropriate to this sector, as there is not the information recording, maintenance or drivers hours requirement that exists for trucks. 20. In the gold standard section, we are unclear as to what your thoughts are on consolidation centres. We would argue that London is already populated by very many consolidation centres, usefully spread across the capital and that this is not sufficiently acknowledged in the draft document. For examples: pallet network members, parcels companies, skip loaders, builders merchants and DIY stores. 21. Having made these observations about FORS, we would like to emphasise that we fully support the aspiration to improve road safety and compliance. We are keen to work with TfL to improve standards, addressing specific issues. We would urge that booster-training funding be targeted at smaller operators certainly no more than 25 employees and that in any case the funding available to large operators be strictly limited. It would make no sense for the bulk of funding to go to companies already geared to training and to drawing down public funds. Supporting further research and communication 22. The Freight Best Practice Programme has a number of elements relevant to operators in London, as FORS recognises, and we would support TfL approaching DfT for further research and communication funding relating to commercial vehicle operation in urban areas. 23. TfL should recognise the progress that has been made in London by truck operators, especially in the hire or reward sector, and their suppliers over the past 30 years, in terms of lower exhaust and noise pollution, better working conditions, operating patterns and partnerships aimed at improving efficiency. All these measures have, either directly or indirectly, improved safety, reliability and sustainability. 24. We welcome TfL s commitment to promoting best practice and to enforcing regulations. However, FORS appears to be a distraction of some of TfL s budget and expertise away from key concerns to do with safe, reliable, efficient and environmentally friendly freight movements. Examples include: provision of adequate delivery and collection facilities (a statutory duty for the boroughs), adequate rest areas for drivers to take statutory breaks; education of parking attendants and management of compliance standards of these contracted employees. 25. We believe that efficient truck movement must be promoted as part of any existing and future priority lane scheme. We must, for example, allow trucks to use bus lanes, especially out of the peak hours. In our view trucks are, in effect, buses for freight. The industry has requested reforms to the London Boroughs Transport Scheme (the London lorry ban) but little or no progress has been made.

5 26. These are some of the issues on which the regulated goods operating industry urgently seeks action, so that they can reduce their environmental impact, improve their efficiency and safety, attract more high quality employees and generally make a more positive contribution to the economy of London. Action on these areas should be the core function of TfL, either acting directly or promoting efficiency where responsibility lies with the boroughs. We would be very pleased to discuss these points in greater detail. Yours sincerely JACK SEMPLE Director of Policy