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Public Inquiry Lessons: How Systemic Failures Lead to Operator Licence Revocation

The consequences of losing an operator licence are immediate and severe for any haulage operation. Vehicles are stopped, contracts are lost, insurance arrangements are affected, and directors and transport managers can face personal disqualification.

A recent public inquiry in the East of England, following an unsatisfactory DVSA assessment, demonstrates how quickly weak compliance control can escalate from routine enforcement to licence revocation.

This case is not unusual. It reflects what happens when core systems drift, oversight weakens, and early warning signs are ignored.

What Happened

Following a DVSA assessment that identified widespread non-compliance, a goods vehicle operator was called to public inquiry.

The Traffic Commissioner concluded that the operator no longer met the requirements of professional competence, financial standing, and good repute.

The operator licence was revoked with immediate effect. The company and its director were disqualified from holding an operator licence for 12 months, and the nominated transport manager was also disqualified for 12 months.

The decision made clear that re-entry into the industry would only be possible after significant education and demonstrable improvement.

Drivers’ Hours, Tachographs and Mileage Control

The DVSA evidence showed that driver cards were not downloaded consistently, tachograph data was not analysed, and significant mileage could not be accounted for.

Thousands of kilometres of driving were not reconciled to tachograph records. This is not a minor administrative issue. Unaccounted mileage is treated as a serious compliance risk because it may indicate undisclosed driving activity, drivers’ hours breaches, or use of vehicles outside controlled systems.

Effective control requires regular driver card and vehicle unit downloads, meaningful infringement reporting, documented follow-up actions, and reconciliation of mileage against jobs, telematics, fuel usage, and proof of delivery records.

Where mileage cannot be explained with evidence, enforcement bodies will conclude that systems are ineffective.

Vehicle Maintenance and Safety Inspections

The inquiry heard that vehicles were not inspected at the required intervals and that maintenance systems were not being followed consistently.

From a compliance perspective, maintenance failures are not a paperwork issue. They are a road safety issue. Operators are expected to demonstrate a planned inspection regime, inspections completed on time, defects reported and rectified, and records that accurately reflect vehicle use.

Any inconsistency between records and reality undermines confidence in the entire operation and weakens claims of effective control across all compliance areas.

Operator Licence Administration and Operating Centres

The operator was found to have used a vehicle that was not specified on the licence and to have parked more vehicles at an operating centre than authorised.

These are direct breaches of licence undertakings. Basic controls should prevent this, including routine reconciliation of fleet lists against the operator licence and regular checks that operating centre limits are not exceeded.

Licence compliance requires active management. It does not manage itself.

Director and Transport Manager Accountability

This case demonstrates how responsibility is assessed at public inquiry.

Directors are expected to understand their legal obligations and ensure that compliant systems are in place and properly resourced. Transport managers are expected to actively manage, monitor, and intervene where standards slip.

A transport manager who is largely absent or unable to demonstrate involvement risks the loss of good repute. Appointment as a transport manager carries personal responsibility for compliance.

Preventing Similar Outcomes: Evidence of Control

Every operator and transport manager should be able to evidence the following as a minimum:

  • Defined schedules for driver card and vehicle unit downloads

     

  • Regular review and sign-off of drivers’ hours infringements

     

  • Tachograph analysis reports including vehicle driven without the card report

     

  • A forward-planned PMI schedule that is observed

     

  • Defect reporting that is enforced and monitored

     

  • Effective VOR system

     

  • Documented driver licence checks

     

  • Routine reconciliation of fleet lists against the operator licence

     

  • Monitoring of operating centre capacity

     

  • Ongoing checks of financial standing

     

  • Clear evidence of transport manager activity and oversight

     

Transport managers should be able to produce, without delay, infringement reports with follow-up actions, maintenance schedules and inspection records, defect rectification evidence, driver licence check logs, and records of compliance reviews and interventions.

If this evidence cannot be produced quickly and confidently, enforcement bodies will conclude that control is lacking.

How the Traffic Commissioner makes the assessment of Control

At public inquiry, the focus is consistent.

Do you know what is happening in your operation?
Can you prove it with evidence?
When problems arise, do you act?

Policies and explanations carry little weight without records that demonstrate ongoing control. Where compliance relies on trust rather than evidence, or where known issues are left unresolved, enforcement action becomes a matter of when rather than if.

A proactive, evidence-led approach remains the only reliable way to protect an operator licence, professional repute, and the ability to continue trading.

 

Source: https://www.gov.uk/government/news/haulage-operator-loses-licence-following-extensive-failures