Undergoing a Driver and Vehicle Standards Agency (DVSA) Earned Recognition audit from an accredited auditor can be a complicated process. It requires meticulous preparation and a comprehensive understanding of compliance requirements, in order to ensure that your organisation is able to meet the high standards required by the scheme.

In this guide, the road transport law experts at JMW outline the essential steps and considerations required to ensure your company is fully prepared for the auditing process. By adhering to the DVSA's standards, businesses can not only improve their operational safety and efficiency, but also potentially benefit from the recognition and trust associated with this scheme.

What is the DVSA Earned Recognition scheme?

The DVSA's Earned Recognition scheme is a voluntary programme aimed at operators who consistently meet high standards in vehicle maintenance and compliance management. By participating, businesses can showcase their commitment to safety and regulatory adherence, benefiting from fewer routine DVSA inspections.

To qualify, companies must have a solid track record of compliance, robust systems for monitoring and reporting vehicle and driver standards, and the ability to share this data with the DVSA. This initiative not only acknowledges the efforts of diligent operators, but also encourages a culture of continuous improvement within the industry.

What areas does the auditing process focus on?

The audit process focuses on several key areas to ensure operators comply with transportation and safety regulations. These areas include:

• Operational compliance: reviewing operational practices for compliance with transport laws, including load security, vehicle overloading and transport documentation accuracy.
• Legal and licensing accuracy: confirming the operator's legal status matches the entity holding the operator's licence, and that all operating centres and vehicles are correctly specified.
• Vehicle maintenance and safety: ensuring vehicles are maintained to the required standards, focusing on aspects like brakes, tyres, lights and overall vehicle integrity.
• Drivers' hours and records: verifying compliance with regulations on drivers' working hours and rest periods, using tachograph data and logbooks to ensure drivers are not exceeding legal limits.
• Tachograph use and data management: assessing the correct use of tachographs, the accuracy of the data recorded, and the operator's management practices to prevent falsification and ensure accurate reporting.
• Training: ensuring that drivers and other key personnel are receiving the necessary training to meet the required standards of competency.
• Health and safety measures: examining the implementation of health and safety protocols for drivers and maintenance personnel, ensuring a safe working environment.
• Environmental compliance: checking adherence to environmental regulations, focusing on emission standards and proper waste management practices to minimise the environmental impact of operations.

This detailed examination across multiple compliance areas ensures that operators maintain high standards of safety, efficiency and regulatory adherence, thereby enhancing road safety and operational integrity.

Pre-audit preparations

Preparing for a DVSA Earned Recognition audit involves a structured and detailed approach to ensure alignment with compliance standards:

• Review compliance policies: update and fully document all compliance policies, ensuring they reflect current regulations and operational practices.
• Internal audits: conduct comprehensive audits to identify gaps in compliance, focusing on operational practices, vehicle maintenance and driver management.
• Vehicle maintenance records: maintain meticulous records of vehicle inspections, repairs and maintenance schedules to demonstrate adherence to safety standards.
• Driver documentation: organise and review driver-related documents, including licences, training records and work schedules, ensuring they are current and comprehensive.
• Tachograph data: ensure tachograph systems are accurately used and data is correctly recorded and stored, facilitating easy access for review.
• Compliance training: regularly update and provide training for all staff on Traffic Commissioner and DVSA standards and compliance requirements, ensuring a culture of compliance within the organisation.
• Action plan for identified issues: develop detailed action plans for addressing any compliance issues found during internal audits, including timelines for implementation and review.

This enhanced preparation ensures a thorough approach to compliance, addressing all key areas scrutinised in the audit, and sets a solid foundation for a successful audit outcome.

What to expect during the DVSA Earned Recognition Audit

When undergoing an audit as part of the Earned Recognition scheme, operators can anticipate a comprehensive evaluation process, broken down into distinct stages:

• Initial documentation review: auditors will first examine the operator's submitted documentation, including vehicle maintenance records, drivers' hours records and compliance reports, to assess preliminary compliance.
• Interviews with key personnel: interviews may be conducted with management and staff to gain insights into the operational practices and compliance management systems in place.
• On-site inspections: a physical inspection of vehicles and facilities to verify the condition of the fleet and the effectiveness of reported maintenance and safety protocols.
• Review of compliance systems: evaluation of the operator's systems for monitoring and reporting compliance, including the use of technology and internal audit mechanisms.
• Final assessment and feedback: the audit concludes with a final assessment, where auditors provide feedback, highlight areas of concern, and may request corrective actions or improvements.
• Report generation: a detailed report is generated, summarising the findings and outlining any recommendations for maintaining or improving compliance standards.

This structured approach ensures a thorough assessment of an operator's adherence to DVSA standards, aiming to uphold the high safety and compliance benchmarks set by the Earned Recognition scheme.

What are the potential outcomes of the audit?

The outcomes of a DVSA audit, particularly under the Earned Recognition scheme, can vary significantly depending on whether or not the necessary standards were achieved. Each outcome has specific implications for the operator, and will vary depending on whether the assessment in question was an initial audit for scheme entry or a periodic audit for ongoing compliance.

• “Standards met”: this is the ideal outcome, indicating that the operator has fully complied with all the DVSA's standards. In an initial audit, this status qualifies the operator for entry into the Earned Recognition scheme. For periodic audits, it reaffirms the operator's status within the scheme, showcasing their continued adherence to high standards of operation and safety.
• “Standards part met”: this outcome suggests that while the operator has met most of the compliance standards, there are certain areas that require improvement. During an initial audit, operators receiving this status may not qualify for the scheme until those specific issues are addressed and rectified within a given timeframe. In the context of a periodic audit, operators are typically given a corrective action plan with specified deadlines to resolve the deficiencies, failing which could affect their standing within the scheme.
• “Standards not met”: this indicates significant compliance failures, with the operator not meeting the required DVSA standards. For an initial audit, this status likely disqualifies the operator from entering the Earned Recognition scheme, necessitating substantial improvements and a re-audit for consideration. In periodic audits, this outcome could lead to the operator being suspended or removed from the scheme, highlighting the need for immediate and comprehensive corrective measures to address the shortcomings.

Understanding these potential outcomes emphasises the importance of thorough preparation and continuous compliance efforts to meet the DVSA's stringent standards.

What happens after the audit?

After the DVSA audit, the focus shifts to addressing the findings and implementing necessary improvements. Operators must carefully review the audit report, understanding areas of compliance and noting any deficiencies. Immediate acknowledgment of the findings and a structured response plan demonstrate commitment to compliance.

Developing and executing a corrective action plan for deficiencies is essential at this point. This plan should outline specific steps, responsible individuals and timelines for addressing the audit findings. Continuous improvement efforts should be integrated into daily operations, ensuring ongoing compliance and enhancements in safety and efficiency.

When non-compliance is identified during an earned recognition audit, the regulator may initiate the following actions::

• Desk-based assessment: this involves a detailed review of the operator's compliance remotely, often initiated with a request for specific information or documents to verify corrective measures. This will take into account the systems used to measure key performance indicators, specific audit failings, and information received from other sources.
• Discussion with the Earned Recognition team: operators may engage in discussions with the DVSA's team to discuss the compliance issues and how they will be addressed. The operator will proactively highlight the current problems and advise on what remedial action they will take to rectify the issues.
• Scheme manager-instigated discussion: a more formal step, where the scheme manager requests an in-depth explanation, additional information, or data directly from the operator. This is aimed at gaining a clearer picture of the issues and the operator’s capacity to address them.
• Formal improvement action plan: operators are required to develop a comprehensive action plan detailing the steps they will take to remedy the non-compliance issues. This plan may necessitate a further audit to ensure that the corrective actions have been implemented effectively and compliance has been restored.
• Removal from the scheme: if an operator fails to address the non-compliance issues satisfactorily, or if repeated breaches occur, they may face removal from the Earned Recognition scheme. This step is considered a last resort and indicates a significant failure to meet the compliance standards set by the DVSA.
• Report to the Traffic Commissioner: where the audit raises significant breaches of the operator licence undertakings, the operator may be referred to the Traffic Commissioner for contemplation of calling a public inquiry to take regulatory action against their Operator Licence.

These steps provide a clear pathway for operators to address and rectify issues of non-compliance, and underline the importance of making sure that the audit itself is followed up by concrete action to ensure that standards are being met consistently.