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Open letter to the Transport Secretary from the DITC

Posted 27 October 2022 — Anyone

The following open letter has been sent to the latest Transport Secretary, Mark Harper, and interested parties including DVSA CEO Loveday Ryder and Baroness Vere. We welcome your interest and feedback. If you would like to send a copy to your constituency MP under your own name, please feel free to do so.

Dear Mr Harper,

Congratulations on your new role as Transport Secretary.

We are writing to you as the founders of the Driving Instructor and Trainers Collective which is a national collective of Approved Driving Instructors (ADIs). Our members have raised concerns in the past which we would like to make you aware of in the hope that you can help us improve road safety in your new role as Transport Secretary.

One of the biggest issues facing driving instructors is that of clear and timely communication. The decisions being made by DVSA, Department for Transport and central Government to manage the current demands seem to have questionable benefits to road safety, the transport industry and society as a whole. In September 2021 the Department of Transport announced that the requirement to take a car and trailer test (B+E test) to tow a large trailer was no longer necessary after 24 years of being necessary. Their main reasoning was that they wanted to make more tests available for lorry drivers and they also removed the need to take a category C (lorry) test before taking a category C+E (lorry and trailer) test. This has not resulted in the increased number of lorry drivers promised but has led to examiners not being fully utilised.

At The Driving Instructor and Trainers Collective we would like to see the B+E test reinstated, the reasoning for its abolishment was not logical and led to not only many of our colleagues in the industry losing their businesses but has no benefit for road safety. The skills required to reverse a trailer under control are essential to towing safely as is the ability to attach and remove the trailer from the towing vehicle. There are many drivers now towing very large and heavy vehicles with no training which does not make logical sense.

The Department for Transport has put out a consultation about the removal of the minibus (D1) and small lorry (C1) and trailer (D1+E and C1+E) tests claiming that this will reduce the financial burden on small businesses and create more lorry driver opportunities. While we can see these might potentially be benefits, surely the risks of a school teacher taking a group of 16 children out in a minibus or a lorry driver driving a vehicle weighing over 7 tonnes that they have not received any training in outweighs these benefits? Why must financial cost be more important than deaths and serious injuries on the road again?

There are concerns over how other countries may view these licences. Currently anyone who passed their driving test before 1997 can drive a D1 or C1 vehicle in certain circumstances in the UK. They are not allowed to drive these vehicles in Europe in any circumstances. How will removing the need to pass a driving test in these vehicles affect driving in Europe? Will new drivers be able to? If there is no test available how will we circumnavigate this issue?

At the centres local to us we are unable to book a test at my 5 nearest test centres as the waiting list exceeds the limit of available dates on the booking system. There are new examiners being trained and reaching test centres but this isn’t happening fast enough to make much of a difference. This is leading to increased stress for instructors and increased delays and costs for our learner driver clients.

The wait for tests extends beyond the tests for learner drivers but also for the new instructors we need to help ensure that the learner drivers we teach are fully prepared for their test to increase the chance of them passing. Many of the potential driving instructors (PDIs) we work with are waiting in excess of six months for a test which is impacting their livelihoods as well as mental health due to the uncertainty of their ability to get a test date to work towards. The delays in testing new instructors are also leading to students being poorly prepared for their tests. If they fail their driving test then the backlog is increased and if they get lucky and pass then we have a poorly trained driver on the road.

At The Driving Instructor and Trainers Collective we would like to see more examiners being employed in all roles. We know there are recruitment drives taking place but the response is not sufficient to fill the available roles. We appreciate that as civil servants their pay is not set by the Driver and Vehicle Standards Agency (DVSA) but would it be possible for driving examiners to receive some kind of financial benefit to reflect the fact that they are conducting potentially dangerous work? An increase in pay or other benefits may attract more candidates who would fill these roles more quickly.

A potential solution to the backlogs would be to change the test to the model reported to be being considered in to the Republic of Ireland. In this style of test the examiner has the option to ask the test candidate questions about their performance and if they would have done anything differently if they were in the same situation again. If the test candidate gives a satisfactory answer the candidate will pass instead of failing for something that may be fairly trivial. If the candidate was to commit an egregious error than this option wouldn’t be available to the examiner which would mean that there would be minimal risk to road safety but it would mean that some candidates who get nervous and make a less serious error could turn a test fail into a pass and therefore not require an additional test that would add to the demand already being placed on the DVSA.

It has been suggested on many occasions that membership of the Official Register of Driving Instructor Trainers (ORDIT) should be mandatory for anyone conducting the training of driving instructors. As a driving instructor trainer, and a member of ORDIT, we feel this should become a reality as the standard of instructor trainers is not monitored and we see many sub standard PDIs who have paid many thousands of pounds to a training establishment only for them to receive sub standard training. This leads to multiple attempts at tests and additional training which increases the costs and stress levels of these PDIs as well as increasing the demand on the DVSA.

We are also finding that there is confusion within the DVSA as to the process for PDIs to gain their trainee licence and that our members are receiving different information every time they contact the people responsible.

We would also like Continual Professional Development to become mandatory within the industry. In the financial services industry and must complete, reflect on and log a minimum of 15 hours of CPD a year. The DVSA have mentioned this becoming mandatory but have always stopped short. Why can’t this be imposed as it is in other industries? We have several suggestions for how this could be done based on the 4 year life cycle of a driving instructors licence with DVSA.

We were founded on the belief that we, the ADIs, are responsible for achieving maximum standards. We therefore require the ability for driving instructors to anonymously raise concerns they have about their colleagues or pupils. This would have to be limited to information over action to prevent abuse or fraud but we would like to have the facility where if we have concerns they can be passed on to someone who can record them and look for patterns or supporting evidence. The DVSA has its Fraud and Integrity Team but, in our experience, they are reluctant to take any feedback from driving instructors about other driving instructors which is potentially allowing driving instructors to commit acts of fraud or sexual harassment or abuse with impunity. On the opposing side of this we would like to receive a definition of the ‘fit and proper’ to which we are all held accountable. It seems to be a catch-all statement that can cause unnecessary distress.

The Driving Instructor and Trainers Collective would also like to see greater scrutiny put on current drivers. Currently a 17 year old can pass their driving test and no one will question their ability to drive until they are 70. This is 53 years! Unless they are caught driving illegally or dangerously, or have a serious medical injury no one questions whether they are still safe. Once they turn 70 it is the responsibility of their GP, who may not even have a driving licence, to judge if they can continue to drive.

As driving licence photos have to be renewed every 10 years there is a great opportunity for each driver to have an eye test, a theory test and driving assessment as part of their application for a new photo card licence. As it is medically advised to have an eye test every 2 years there will not be any additional cost on a driver to get their eyes tested every 10 years, and in fact it may help the NHS as those who have not had a test for sometime may be able to pick up optical health issues early saving NHS treatment costs in the future.

There is already a network of theory test centres across the UK run by the private sector to conduct theory tests. This can easily be scaled up at no cost to the tax payer to cope with the demand if every driver had to retake their theory test. The current price of a theory test is £23 so there is no great cost to the driving licence holder either and as has been recently reported by the AA, 61% of drivers are unaware of the Highway Code changes from February this year. This is far too many people and a theory test on licence renewal would help encourage people to brush up on their road knowledge.

While a driving assessment may appear to increase the workload on the DVSA this could be conducted either by the private sector through the likes of the National Driver Offenders and Rehabilitation Scheme and their partners, the companies who already deliver driver training and testing, like the Royal Society for the Prevention of Accidents, the Institute of Advanced motoring or Diamond or through trusted Approved Driving Instructors (ADIs) who have received special training.

This may add an additional £100 to the cost of the renewal of a driving licence but spread over 10 years this becomes very affordable and the benefits to road safety could be substantial.

To become a lorry driver you must undergo a medical and undertake regular training every 5 years so why can’t we ask car drivers, who make up most over 80% of vehicles on the roads, to do similar?

An area of concern amongst driving instructors are the rumoured changes to the manual/automatic licence divide (Code 78). It has been mentioned that the requirement to pass your test in a manual car to gain a manual licence will be removed in the near future. This change could have massive implications for driving instructors across the country as it may require them to change their tuition vehicle. According to research by Carwow 67.11% of the new cars on sale today are available with automatic transmissions. This means that there is less demand for manual vehicles and the change in driving licences is needed. What we ask is that this can be clarified as soon as possible and that we are given enough notice of the date of implementation so that we as an industry can plan and prepare for it fully.

We would also like to state that the DVSA has delivered some excellent ideas recently. In 2014 the standards check was introduced which revolutionised the way driving instructors are examined. This was followed in 2018 by allowing learner drivers onto motorways with an ADI in a dual controlled car. The DVSA have also recently made female hygiene products available in test centres and they could improve this facility by making it obvious to users of test centres that they are there for the users to use. Most recently the ‘Ready to Pass’ campaign is being very communicative and we look forward to see if it achieves change.

As the founders of The Driving Instructor and Trainers Collective we would like to request meeting with you to discuss the contents of this letter further so that we can start to work on improving road safety with all those invested in it.

Yours Sincerely

Ian Brett and Chris Bensted
Directors and The Driving Instructor and Trainers Collective