Commercial Vehicle Testing Review - RSA.ie Testing/CVR/CVT_Report.pdfFinal Report Commercial Vehicle Testing Review. Final Report. 2 This report has been prepared for and only for

Údarás Um Shábháilteacht Ar BhóithreRoad Safety Authority

Final Report

Commercial VehicleTesting Review

Final Report

2

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Road Safety Authority Review of Commercial Vehicle Roadworthiness Testing

Final Report 2007 Confidential 3

Contents

I Executive Summary .......................................................................................................................6Introduction ........................................................................................................................................6Current Test Arrangements ...............................................................................................................6Supervision and enforcement ............................................................................................................7Issues arising .....................................................................................................................................8Financial review .................................................................................................................................9Opportunities for improvement.........................................................................................................10Test centre operations .....................................................................................................................10IT and Management information systems........................................................................................11Scope of Testing ..............................................................................................................................11Supervisory arrangements...............................................................................................................12Enforcement.....................................................................................................................................13Operator maintenance records ........................................................................................................15ADR..................................................................................................................................................15Strategic model options ...................................................................................................................15Evaluation of strategic options .........................................................................................................16Conclusions......................................................................................................................................18

II Introduction...................................................................................................................................20Background......................................................................................................................................20

III Legal Framework Assessment .................................................................................................21European Directives on Vehicle Testing..........................................................................................21Analysis of European Directive ........................................................................................................21Legal Basis for Implementing European Directives relating to Roadworthiness Testing ................22Responsibility for Commercial Vehicle Testing in Ireland................................................................22Analysis of the European Communities (Vehicle Testing) Regulations 2004 .................................23Enforcement of Legislation in Respect of Current Testing Regime.................................................24Random Roadside Inspections of Commercial Vehicles.................................................................24

IV Current Test Arrangements ......................................................................................................26Vehicle criteria and test volumes .....................................................................................................26Test process and procedures ..........................................................................................................27Test Scope.......................................................................................................................................28Trailer Testing ..................................................................................................................................28Commercial Vehicle Testers Manual ...............................................................................................29Test centre premises .......................................................................................................................29Authorised tester licences................................................................................................................30Disciplinary Procedure .....................................................................................................................33Management information and IT systems........................................................................................33Roles & responsibilities....................................................................................................................35Roadside enforcement.....................................................................................................................36Staff training and procedures...........................................................................................................37ADR..................................................................................................................................................37

Road Haulage Operators .............................................................................................................38Potential conflicts of interest ............................................................................................................39Summary of Current Situation..........................................................................................................40

V International benchmarking study ................................................................................................42Key Findings ....................................................................................................................................42

General Observations ..................................................................................................................42Quality and Enforcement..............................................................................................................43Test centres..................................................................................................................................43Test Equipment ............................................................................................................................43Test Arrangements.......................................................................................................................44Data monitored.............................................................................................................................44



VI Customer and public consultation ............................................................................................46Customer satisfaction survey...........................................................................................................46

Booking Procedures and Communication....................................................................................46The Test Report............................................................................................................................47Overall Satisfaction with the Current System...............................................................................48

Public Consultations ........................................................................................................................49Authorised test centre review...........................................................................................................51Summary..........................................................................................................................................52

VII Financial Analysis of current model..........................................................................................53Additional Fees ................................................................................................................................54Costs ................................................................................................................................................54

VIII Opportunities for Improvement .................................................................................................55Test centre operations .....................................................................................................................55IT and Management information systems........................................................................................56Scope of Testing ..............................................................................................................................56Supervisory arrangements...............................................................................................................57Enforcement.....................................................................................................................................58Operator maintenance records ........................................................................................................60ADR..................................................................................................................................................60

IX Operational model options........................................................................................................61Option 1 – No change ......................................................................................................................61Option 2 - Improve the Current Arrangements ................................................................................61

X Evaluation of Strategic Options....................................................................................................68Methodology.....................................................................................................................................68

Quality and Consistency...............................................................................................................69Enforcement .................................................................................................................................70Improvement of management Information ...................................................................................71Impact on Test centres.................................................................................................................71Ease of Implementation................................................................................................................71Financial Assessment ..................................................................................................................72

Overall assessment .........................................................................................................................78Option 1 - ‘As Is’...............................................................................................................................78Option 2 - Improve current arrangements........................................................................................78Option 3 - Integrated network of independent private sector test providers with greater automation.........................................................................................................................................................78Option 4- Centralised supervision of the integrated network...........................................................78Option 5 Rationalisation of current test centres with central supervision. .......................................79Option 6 – A single operator with central supervision......................................................................79Option 7 – Government Agency Operations....................................................................................79

XI Conclusions and Recommendations ........................................................................................80Conclusions......................................................................................................................................80Recommendations ...........................................................................................................................81

XII Appendix 1 Pricing Structure ....................................................................................................84Appendix 2 Stakeholder Interviews .....................................................................................................85Appendix 3 Circular Letter VS 4/05 .....................................................................................................86Appendix 4 Circular letter VF10/67......................................................................................................89Appendix 5 ASC Solution Output ........................................................................................................92Appendix 6 Digital Forecourt Output ...................................................................................................93Appendix 7 International Benchmarking Survey – Country Summaries .............................................94Appendix 8 - Duties and Responsibilities of a Local Authorised Officer ...........................................105Appendix 9 Commercial Vehicle Testing Customer Satisfaction Survey..........................................107

Survey approach............................................................................................................................107Sampling.....................................................................................................................................107The Questionnaire......................................................................................................................107



Analysis ......................................................................................................................................108Key Findings: .................................................................................................................................108

Profile of Respondents ...............................................................................................................108Table 1 Length of time since Test .............................................................................................108Booking Procedures and Communication..................................................................................108Customer Service Priorities........................................................................................................111Communications and Knowledge of Complaints Procedure......................................................112Comfort, Customer Service and Professionalism ......................................................................113The Test Report..........................................................................................................................114Overall Satisfaction with the Current System.............................................................................116

Appendix 10 Financial Assessment...................................................................................................118



I Executive Summary

Introduction1.1 The scheme to test commercial vehicles in Ireland has been in existence for

approximately 25 years. During this time there have been a number of developments, although the administration of the scheme has remained relatively unchanged. Heavy goods vehicle (HGV)1 testing was initiated in 1982 and light goods vehicle (LGV)2 testing commenced in 1993.

1.2 The Road Safety Authority (RSA) has engaged PricewaterhouseCoopers (PwC) to undertake a fundamental review and evaluation of commercial vehicle roadworthiness testing policy, delivery and monitoring effectiveness and make recommendations on means of addressing any issues raised.

1.3 EU Directives dating back to the 1970s imposed various requirements on Member States to carry out roadworthiness tests on motor vehicles and their trailers. After several developments, Council Directive 1996/96, as amended by Council Directives 1999/52/EC, 2001/9/EC, 2001/11/EC and 2003/27/EC, represents current European Community law on the roadworthiness testing of motor vehicles and their trailers including commercial vehicles.

1.4 The Minister for Transport has overall responsibility at national level for vehicle testing matters. In that role the Minister is responsible for providing the legislative framework for vehicle testing either by way of sponsoring proposals for primary legislation relating to vehicle testing in the Oireachtas or by making secondary legislation.

1.5 Following the establishment of the Road Safety Authority in September 2006 and the making of the Road Safety Authority Act 2006 (Conferral of Functions) Order 2006 (S.I. No.477 of 2006), responsibility for the operation, oversight, development, quality assurance and delivery of vehicle testing arrangements is now vested in the Road Safety Authority. However, in accordance with section 4 (3) of the Road Safety Authority Act 2006 the Minister retains authority to exercise or perform any function which he has conferred on the Authority.

1.6 The European Communities (Vehicle Testing) Regulations 2004 assign responsibility to certain city and county councils to appoint, subject to requirements, “authorised testers” to carry out roadworthiness tests on motor vehicles. Each such local authority is required to appoint an “authorised officer” to supervise the conduct of “authorised testers” appointed by it

Current Test Arrangements 1.7 In 2005, there were some 286,000 registered HGVs and LGVs. Current test volumes are

difficult to estimate with accuracy since consolidated figures have not been available since 2004. The last consolidated statistics available show that in 2004 the total volume of tests was approximately 186,000. Until then LGVs were tested biennially. However, since 2005 all commercial vehicles have been tested every year. It is estimated, therefore, that the total number of tests which should take place at present, is around 230,000 per annum.

1 Heavy goods vehicles are those over 3.5 tonnes gross vehicle weight. Buses and ambulances are tested as HGVs 2 Light goods vehicles are commercial vehicles under 3.5 tonnes gross vehicle weight. These include car-derived vans.



1.8 Testing provision is fully deregulated and carried out in 158 test centres throughout the country. Of these, 51 test LGVs only, 22 test HGVs only while the remaining 85 are dual purpose. Garages apply to their relevant local authorities to be test centres provided they meet specified technical standards for premises and test equipment.

1.9 The ability of most test centres to accommodate vehicles presented for same day testing along with a general lack of activity would suggest that there is over capacity in the vehicle testing system. From the testing figures available we estimate that HGV lanes are, on average, no more than 50% utilised (based on an 8 hour day 5 days per week) and LGV lanes around 34% overall.

1.10 Over the past few years there has been a move to upgrade the test premises, a programme that is due to be completed by the end of 2008. As a result there has been significant investment on the part of many test centres, though others have yet to begin. It is anticipated that a number of centres will not meet the 2008 deadline and may withdraw, or be required to withdraw, from testing at that time.

1.11 During that time there has also been a move to improve the training of testing staff. At present, the Society of the Irish Motor Industry (SIMI) is responsible for organising training of test staff in conjunction with the Dublin Institute of Technology (DIT). Annual refresher training is also provided for all authorised testers.

Supervision and enforcement 1.12 The public bodies associated with the management of the scheme include the RSA and

29 Local Authorities (LAs). The LAs are responsible for authorising garages to provide testing services and for completing regular supervision of the authorised testers in their area. Each of the LAs has appointed a Local Authorised Officer (LAO), mostly on a part time basis, with only 2, in Dublin and Cork, working on a full time basis.

1.13 In the past, the Department of Transport employed 5-6 technical test specialists, though the number declined to one by 2006, due to retirements, with staff not being replaced. Formerly, the role of the technical specialists (now within RSA) has been to:

(a) Review and update the legislative framework for vehicle testing

(b) Prepare and update the Testers’ manual setting out standards and methods of testing

(c) Provide technical backup to LAOs on interpretation of standards, fitness of authorised testers and the like;

(d) Provide technical input to multi-agency roadside enforcement teams; and

(e) Liaise with other international testing authorities to determine changes in testing standards in line with vehicle technology developments.

1.14 RSA has begun to acquire resources in this area and has recently appointed 3 technical staff.

1.15 LAs have a significant responsibility in the appointment, supervision and delisting of Authorised Test Centres, though the delisting sanction has rarely been exercised. The function is generally given a relatively low priority by LAs and the role and responsibility of the LAOs is not consistently defined, with reporting lines that are often unclear. LAOs are from different backgrounds, and there are no common selection criteria used when appointing staff to the role.



1.16 Responsibility for roadworthiness enforcement activity lies with An Garda Síochána. To date, there has been a very limited level of enforcement, a situation acknowledged by the Gardai, who are currently in process of augmenting their traffic resources from around 450 to 1200 people. Periodically, the Gardai organise ‘multi-agency’ enforcement checks, at which vehicle test inspectors attend in an advisory capacity, but there has been a lack of technical resources to assist in this in recent years. In addition, the current tools and information that the Gardai have available to perform roadside checks are insufficient to make the process efficient and comprehensive.

Issues arising 1.17 During the course of the review we visited 18 of the test centres and interviewed a wide

range of stakeholders, including transport industry representatives. We sought the views of county managers and other LA representatives as well as conducting 3 public meetings in Dublin, Cork and Galway. In addition, interested parties could express their views by letter, email or through a website set up for the purpose. Advertisements, setting out details of the consultation opportunities were placed in the national press.

1.18 A number of concerns were identified as a result of this consultation. These included the views that:

(a) Testing standards are not applied uniformly throughout the country

(b) There is perceived inconsistency in granting of test centre licences and of applying disciplinary procedures. The disciplinary guidelines also need to be reviewed

(c) There is considerable scope for unscrupulous or careless operators or test centres not to comply with the current requirements

(d) There are considerable administrative inefficiencies in the current arrangements

(e) IT systems are inadequate, particularly in relation to integration and provision of management information, which has led directly to the inability to [provide statistics since 2004. There is also a low level of security or reasonability checking in relation to data entry and data file management.

(f) It is possible to revise test results retrospectively and to record vehicles as passing a test, even if the test was not completed in full. Inconsistent use of the category ‘pass with faults rectified’ makes national statistics on pass rates unreliable as an indicator of vehicle standards

(g) It is possible for owners to have their vehicles tested in their own test centres, giving rise to a potential conflict of interest

(h) Not all commercial vehicles using the roads are subject to testing. For example, the exemption for some agricultural vehicles gives cause for concern, given their increasing use in some areas by the construction industry. Other examples include breakdown recovery vehicles, refuse collection vehicles and the like.

(i) The frequency of testing is a concern of some, given the potential distances that can be covered over 12 months by some vehicles.

(j) HGV trailers are also liable to be tested. However, the number of such vehicles tested seems very low compared with the number of tractor units, indicating that compliance



rates are probably low in this respect. Tractor units are not required to have a trailer attached, as is the case in some other countries, when undergoing the test

(k) Not all test centres have embraced the current improvement programme. There is also objection from some that new centres must meet a higher specification (testing both HGV and LGV and meeting access standards) than existing test centres

(l) Test centre managers consider that the current training (and in particular the annual refresher course) is inadequate and needs to be reviewed

(m) Updates to the tester’s manual and technical bulletins for specific interpretations are considered to be poorly communicated

(n) LAOs consider that they have little support from their county managers in this aspect of their role

(o) Recent investigations by the Vehicle and Operator Services Agency (VOSA) in Great Britain have identified the number of faults on Irish registered vehicles to be disproportionately high in relation to UK and other foreign vehicles.

1.19 We also carried out a survey of 100 fleet operators throughout the country. Overall satisfaction with the services provided by the commercial vehicle testing centres was very high, with 94% of respondents stating that they were either ‘very’ or ‘quite’ satisfied with the service they received.

1.20 In addition we carried out a high level comparison of the current arrangements against those pertaining in 10 other countries. From this high-level assessment it was clear that Ireland, along with Denmark, monitors the least amount of information about commercial vehicle testing.

1.21 Overall, the testing arrangements in Ireland are somewhat at variance with usual practice elsewhere in Europe, particularly in relation to supervision and monitoring arrangements, independence of the test centres (i.e. not associated with repair businesses etc) and information management arrangements. In addition the service is generally more expensive than the other countries benchmarked.

Financial review 1.22 Given the distributed nature of the current operational position, the lack of volume

information across the pricing categories for HGVs and the application of varying pricing policies, the overall income for the industry are not known with certainty. Based on the assumption that 230,000 tests (60:40 LGV:HGV) per annum are charged in full, the income is in the region of €20-22m.

1.23 Based on our industry knowledge and assumptions from other similar businesses it is likely that 50-60% of the income will be taken up in staff costs, leaving around €9-11m to service capital and fixed costs. In our view this seems low and would indicate that testing services are generally being subsidised by other activities (vehicle maintenance/ sales and the like) within the test centres. In our view testing services would be loss-making on a stand-alone basis.



Opportunities for improvement 1.24 From our review we have identified a number of changes that could be made to enhance

the overall quality of the testing service and thus help improve the overall quality of the commercial fleet. They are summarised under the following headings:

(a) Test centre operations

(b) IT and management information systems

(c) Scope of testing

(d) Supervisory arrangements

(e) Enforcement

(f) Operator licensing

(g) ADR management

Test centre operations 1.25 The key to a successful test regime lies in the quality and consistency of the actual testing

process. Commercial vehicle operators and the general public must be satisfied that all necessary steps have been taken to ensure that each vehicle is tested to the required standard, irrespective of the inspector, timing or location of the test.

1.26 Improvement 1. The programme of enhancement of premises and equipment to meet the specified minimum standards should be continued. Each test centre should submit a project plan with interim milestones, in a specified format and agreed with the supervising body. Failure to progress in line with the milestones would be grounds for disciplinary action.

1.27 Improvement 2. The supervising body3 should consider further enhancements in the standards for testing facilities and equipment for the 3-5 year period beyond 2008, for implementation in the period from 2009 onwards. These should take into account developments in braking systems, light test systems and the like. This programme should involve taking into account the views of industry representatives, in an appropriate technical forum.

1.28 Improvement 3. On successful completion of the test, the test centre should be in a position to issue a Certificate of Roadworthiness (CRW) directly, or link to a central system for issuing certificates. A single composite fee would be payable to cover costs and there would be no need for operators to have to obtain a CRW separately.

1.29 Improvement 4. Introduce a system of regular assessment of authorised test persons, through independent observation of them carrying out tests. A central database of authorised testers should be held and updated with details of continuous assessment details and training course attendance.

1.30 Improvement 5. The quality and curriculum for training courses provided for authorised testing personnel should be reviewed, where possible relating them to actual problems encountered by testing personnel on a daily basis and including training in the latest

3 The RSA, or the RSA in conjunction with LAs depending on the strategic option chosen



commercial vehicle technologies. Attendance at refresher courses, which are compulsory, should be monitored and accredited.

1.31 Improvement 6. At present licences for authorised premises are issued for an indeterminate term and may only be revoked through the disciplinary process. We recommend that current licences should be time limited and all new licences issued for a fixed term of, say, 10 years. An appropriate point to introduce this change could be at the point of acceptance that existing test centres have fully complied with the current standards as per improvement 1. Future renewal of licences would take into account a review of prior performance as well as an inspection of facilities.

1.32 Improvement 7. To eliminate the potential conflict of interest, we recommend that no vehicle owner or operator should be permitted to have his vehicles tested in a test centre in which he has a management, financial or other interest.

IT and Management information systems 1.33 Improvement 8. We recommend that an integrated computer system be implemented for

the vehicle testing network. This should be procured centrally by the supervising body and licensed for use by individual test centres. It should incorporate a centralised database integrating all data from individual test centres around the country on a live basis. This would support the proposed central distribution of CRWs and accept test failure details as well as pass/fail information. Pass/ fail information could then be passed to the National Vehicle and Driver File (NVDF) to support roadside enforcement activities as required. This system could be paid for out of the fee currently charged to obtain CRWs on presentation of pass certificates.

1.34 Improvement 9. The supervisory body should use the proposed computer system to carry out statistical analyses on a national level. Comparison of information on each test centre and vehicle type would allow for a breakdown of the most common reasons for test failures. It would also support requirements of EPA, for example, for national statistics on fleet emissions etc. Such analyses could also be carried out for individual test centres and help to focus the attention of operational reviews by the supervisory body.

1.35 Improvement 10. We recommend that computer systems within the test centres should be upgraded to integrate the test lane/pit data collection within the test centre administrative system. Interfaces should be required to link automated test equipment with the system. This system should also incorporate test booking arrangements and preparation of results and failure items for onward transmission to the central database. There are a number of international examples of fully integrated systems covering also the features of Improvement 7 which should be explored. A centralised booking system is not recommended unless it is appropriate to the particular strategic option chosen.

Scope of Testing 1.36 Improvement 11. The scope of the test should be expanded to include currently exempt

vehicles that are similar to commercial vehicles and in use the public roads. The scope of testing is already expanding to include recovery vehicles and fire appliances in 2007. In particular government should consider classifying agricultural vehicles, based on type of usage and their maximum speed, only to be exempt when operating within, say,10 kilometres of the address at which they are registered, otherwise they should be subject to roadworthiness testing.

1.37 Council Directive 1996/96 (as amended) permitted an increase in the frequency of commercial vehicle testing (i.e. to more than one test per annum), which is one way to



help ensure that standards are met more of the time. In our view, such a regime would not significantly improve the overall quality of the fleet, without a significant change in enforcement activities and maintenance practices by operators. Those operators who currently comply would be faced with additional costs, while those that don’t would continue to be non-compliant. With an increase in enforcement activity (see improvement 17) the need for additional periodic testing recedes in any case.

Supervisory arrangements 1.38 In our analysis of strategic models set out later in this report, we have recommended how

best to organise effective supervisory arrangements overall for the testing service. In this section we make recommendations as to how the operation of such supervision could be improved.

1.39 Improvement 12. There is a need to focus the supervision of the Vehicle Testing Network among a smaller number of full-time staff, who are fully qualified and trained in all aspects of the service provided at the test centres. We recommend that a full-time team be appointed and based in regional locations throughout the country, accessible to the number of test centres to be visited. Supervisor staff should have access to the proposed on-line IT system identifying testing schedules, to enable them to schedule their visits more effectively.

1.40 Improvement 13. An operational audit schedule should be developed for use by supervisory staff. This should include a framework for assessment of observed tests and a weighted matrix of other criteria against which facilities, equipment, operational and administrative processes may be assessed consistently.

1.41 Improvement 14. The technical expertise should be enhanced within the aegis of RSA. This technical expertise should be capable of interacting, on an international basis, with other testing authorities at a European level and of understanding and contributing to the development of testing processes in line with developing technologies in vehicles and test equipment. RSA should be in a position to provide national leadership in determining appropriate testing standards, together with related audit and review processes.

1.42 Improvement 15. In conjunction with the technical expertise, RSA should obtain operational planning expertise to define, implement and operate a revised regime of supervision to ensure improved roadworthiness of the commercial fleet. The purpose of this would be to link roadside enforcement activity and reviews of test centres with inspection of operators’ fleet maintenance records, in an integrated regime. This would be targeted at operators of vehicles deemed most likely to offend, while continuing a ‘light-touch’ supervision on those with a good track record of compliance (see improvement 22)

1.43 Improvement 16. Warning and suspension procedures applicable to Authorised Testers are provided for in the “supervision of the vehicle testing scheme” guidelines issued by a Department of the Environment circular in 1985 (the “1985 Guidelines”) (i.e. Circular VF 10/67). We recommend that these guidelines be reviewed. Consideration should be given to introduction of a performance management system, whereby performance points could be accumulated for minor but persistent breaches as well as for major non-conformances e.g. 1 performance point could be issued against an Authorised Tester for a particular breach and when the Authorised Tester acquires a specified number of performance points, they are suspended for a certain period of time.This would make disciplining authorised test centres more objective as it would be based on a systematic approach rather than personal judgement.



Enforcement 1.44 From this review, it has been clear that a general lack of effective enforcement action has

contributed to the environment of a significant number of commercial vehicle operators being lax in ensuring the roadworthiness of their vehicles. While this does not take away from the responsibilities of operators, it seems unlikely that improvement will happen without further action in this regard.

1.45 Key to success in effective enforcement is to be able to target resources at those operators who are non-compliant, while causing minimum inconvenience to those who comply. There are a number of elements to achieving effective compliance and assurance that the overall regime of ensuring roadworthiness is effective. These are summarised in the following diagram.

Figure 8.1 A model for assuring roadworthiness compliance

1.46 In our view there are 3 strands of activity that, if carried out effectively, will ensure a much higher standard of commercial vehicle roadworthiness. Clearly the first of these is the periodic testing process and the assurance that that process is conducted impartially and correctly at all times. The elements of this have been discussed separately earlier in this section. However, on its own, this strand at best ensures that vehicles are roadworthy on a single day each year, though clearly there is a knock-on beneficial effect beyond that date. Increasing the frequency of periodic testing to 2 or more times per annum, would



have some positive impact, but it would seem to penalise normally compliant operators and those that don’t comply now would have no greater incentive to do so than at present.

1.47 To ensure compliance at other times therefore requires random checks to be carried out, normally targeted at vehicles in use by checks ‘at the roadside’. Again, on its own, this method would require significant resources to check sufficient vehicles so that it acts as a deterrent to non-compliance for the fleet as a whole. In addition, detailed roadside checks are a significant inconvenience to operators trying to meet ever tighter timetables and schedules. The third strand of enforcement activity, relating to the operators, is considered in improvement 23.

1.48 However, as part of a balanced portfolio of interventions, roadside checking with appropriate sanctions for non-compliance is very effective. To minimise the inconvenience to compliant operators, we recommend the following.

1.49 Improvement 17. The Garda Síochána, who we understand are recruiting additional resources to deal with traffic issues generally, should develop a programme of roadside checks in conjunction with the supervising body to ensure that there is sufficient expertise available to deal with technical issues (i.e. visual technical inspections on the roadside or, in certain circumstances at a local test centre) in a reasonable proportion of their activity. This would link with checks on tachographs, loading and administrative issues such as valid CRW, operator’s licence, driver’s licence, tax and insurance cover. It is important that key systems such as brakes and steering are capable of being checked

1.50 Improvement 18. To make roadside enforcement easier, we recommend that Gardai be given access to the central database of vehicles with valid CRW, either through NVDF or directly to the centralised management information system. In most cases, this would eliminate the need to follow up with drivers or operators who cannot present relevant paperwork at the roadside.

1.51 Improvement 19. As a further level of sophistication we recommend that investment in vehicle number plate recognition systems be investigated. Such systems can be used, for example on motorways or arterial routes in particular, to identify vehicles, check the database for compliance details and relay the information to a Garda checkpoint further along the route. In this way, activity can be focused on those vehicles most likely to be non-compliant. Such systems have been piloted elsewhere with VOSA in England claiming the ratio of prosecutions to the number of vehicles stopped to have increased considerably as a result. Such systems can also be integrated with ‘weigh in motion’ systems that would detect overweight vehicles in similar circumstances.

1.52 Improvement 20. To help deal with the problem of non-compliant vehicles, we recommend that a secure printed disc (similar to NCT) should be displayed on all commercial vehicles, including trailers. This would provide a ready visual check for Gardai, particularly for trailers. Care will have to be taken to minimise the risk of fraudulent transfer of discs between vehicles, by including appropriate chassis details on the disc.

1.53 Improvement 21. Overall compliance would be made easier to manage if vehicles were eligible for testing on the anniversary of their first registration date, rather than on the anniversary of the date of testing. It would also remove the incentive to ‘slip’ test dates and eliminate the anomaly of being able to tax a vehicle near the end of the period of validity of its CRW. We recommend that such a change be implemented for all new vehicles and phased in over, say, a 3-4 year period for existing vehicles.



1.54 Improvement 22. At present the penalties for offences relating to the roadworthiness of vehicles seem to fall mainly on the driver of the vehicle. The move towards fixed charge penalties, penalty points and on-the spot fines could tend to increase this. We recommend that, with the improved information available future legislation should also focus on applying sanctions to the operator.

Operator maintenance records 1.55 Improvement 23. The third strand of enforcement action that we recommend is focused

on assurance that measures are in place to maintain vehicles in a roadworthy condition at all times. To do this we recommend that, as part of the operator’s licence renewal process, there should be an obligation on the operator to maintain the vehicle in good condition and also to keep records of inspection and maintenance for review by the supervising body at any time. The programme of on-site inspection should be developed to target mainly those operators whose vehicles regularly fail during roadside or periodic inspections.

1.56 Improvement 24. A commonly held view among stakeholders interviewed is that all operators of commercial vehicles should be licensed, irrespective of whether they are used for ‘own account’ or ‘hire and reward’ activities. This is consistent with the view that all vehicles on the road should undergo regular testing. We recommend that such action be considered. Should it be inappropriate to extend the application of operator licences, we recommend that issuing a CRW should include the condition that the vehicle be maintained in a roadworthy condition and that its maintenance records are subject to inspection by the supervising body.

ADR 1.57 Improvement 25. The opportunity now exists to bring all commercial testing functions

under the control of one central body. It would be consistent to bring the ADR testing arrangements (vehicles used for the transport of dangerous goods) under the control of the same body.

Strategic model options 1.58 We have considered a number of strategic options for the future delivery of the testing

service, as follows

(a) Option 1 – No change to current arrangements. This was used as a baseline for comparison with other options

(b) Option 2 – Improve Current Arrangements. This option is based on improving the performance levels of the current system. The management structure currently in place would remain unchanged but greater emphasis would be placed on the quality of testing, enforcement and management information systems. This would lead to improved performance in testing and information produced and would require an increase in the number of full time vehicle test inspectors to carry out operational audits and quality reviews of test centres plus providing further assistance to the Gardai.

(c) Option 3 - Integrated network of independent private sector test providers with greater automation. This option includes all recommendations made in option 2. In addition, the network of independent private sector test providers would be more closely aligned using a national IT and management information system. The national MIS system would create a central commercial vehicle test database. Real time ‘live’ information on commercial vehicle testing records would also enable ‘on the spot’ to support enforcement when performing roadside checks. This option would see the



centralised issue of roadworthiness certificates and the introduction of CRW discs on trucks and trailers.

1.59 Under options 1 to 3 the current split of responsibilities between RSA and LAs would continue. For options 4-7 this is proposed to change.

(d) Option 4 – Centralised supervision of the integrated network. Under this option, in addition to the changes set out in options 2 and 3, the supervisory responsibilities would transfer entirely to a single authority, the RSA. Using this model, procedures would be streamlined and communication channels improved with greater accountability and leaving less potential for differences in interpretation. The inspection roles that are presently fulfilled by the RSA and the LAOs would be amalgamated into a team of approximately 20 vehicle test inspectors, under this management structure.

(e) Option 5 - Rationalisation of current test centres with central supervision. This is similar to Option 4. However, the number of authorised test centres would be significantly reduced based on current volumes tested by geographically location. The statistics available suggest that the majority of test centres are significantly under-utilised by at least 50% of their full potential. This would suggest that the number of test centres in Ireland could be reduced to around 80 (approximately 50% of the current 158) without loss of amenity for customers. In order to implement this option a tender would need to be run against a set of assessment criteria based on technical capability, quality, financial status and experience. Licences would then be given to the successful bidders for a fixed time period (say 8 to 10 years).

(f) Option 6 – A single operator with central supervision. This model would be similar to the NCTS model for car testing. A competition would be run for the operation of the commercial vehicle testing scheme as a whole. The number of authorised test centres would be at the discretion of the contractor. Based on previous NCT experience, which requires 90% of the population to be within 30 miles of an authorised test centre, this could result in around 30-40 test centres being made available. The contractor would be required to operate to specified performance standards and have uniform test facilities in all locations.

(g) Option 7 – Government agency operations. This is as option 6 with RSA directly running the service as the single operator. This is similar to the VOSA model in UK (currently under review) and the Driver and Vehicle Testing Agency model in Northern Ireland.

Evaluation of strategic options 1.60 We evaluated the options in relation to assessment criteria as set out in the table below.

Individual scores are out of 10 and the weightings applied as shown.



1 2 3 4 5 6 7

Quality and Consistency of test 25 2 4 6 7 8 9 9Enforcement 25 0 2 5 8 8 8 8Improvement of Management Information 20 0 2 6 7 7 8 8Impact on Test centres 15 10 9 7 6 4 2 1Ease of Implementation 15 10 7 6 7 2 4 5Total 100 22 24 30 35 29 31 31

Total with weighting 100 35 43 59 71 63 67.5 67.5

WeightingAssessment Criteria

Options

Rationalisation of current test

centres

Independent Operator (s)

Government Agency

OperationsAS IS

Improve current

arrangements

Integrated network of

independent private sector providers with

greater automation

RSA management of Integrated network of


greater automation

1.61 Options 6 and 7 scored best for the quality and consistency of testing as these options would operate using fewer test centres and it is easier to apply a common set of standards and control the quality of testing across a smaller number of test centres. In addition, having a single supervisory authority would make a significant difference in this respect

1.62 Options 4, 5, 6 and 7 all scored the same under the enforcement criterion. All of these options would have sufficient ICT improvements to ensure that the information being provided to the Gardai is up-to-date and of a reliable standard. These options would see increased use of joint task forces with the Gardai for enforcement activities.

1.63 The introduction of a central database (linked to the NVDF) automatically updated on a live basis with test results in option 3 would ensure more accurate and consistent management information. Options 6 and 7 have been given higher scores for the management information criterion because a single operator would use standard IT infrastructure and software provided through common procurement, thus providing efficiencies and further improving the consistency of information.

1.64 The relatively low scores of options 5, 6 and 7 for the impact on test centres criterion reflect the significant reduction in the number of existing test centres under these options. Options 3 and 4 score lower since they require additional IT investment by test centres.

1.65 Options 3 and 4 would see the further automation of the testing process; however, it would be easier to implement the changes needed if the scheme was solely under the control of the RSA. The scores for the ease of implementation for these options reflect this. Although options 3 and 4 require significant changes to the scheme, they could still be made relatively easily compared with the infrastructural and governance changes necessary in options 5, 6 and 7. In these options, the legal position for discontinuing current licences is not clear since these are, in effect, open-ended at present, except where there is a failure on the part of the individual test centre to provide a satisfactory service.

1.66 We have also reviewed the likely financial impact of the options, within the constraints of uncertainty of the financial information available at present. Details of this are set out in the main report but may be summarised as follows:

1.67 Options 1 and 2 will have the lowest financial impact on RSA, though each would assume recruitment of around 15 additional vehicle test inspectors. Option 3 was considered to have a low-medium financial impact, with investment in networked IT systems costing



€10-15 per test, offset by assumed income from issuing CRWs centrally. Options 4, 5 and 6 were considered to have medium financial impact. In particular, costs were assumed to increase to cover the technical supervisory team (offset in economic terms by savings in LAO costs) required for operational audit and enhanced roadside enforcement activities. For option 6 supervisory costs would be lower but setup costs higher. Option 7 was considered to have the highest financial impact.

1.68 In addition, it is possible that options 5, 6 and 7 may give rise to potential claims for compensation from those who have invested in provision of the current test lanes, particularly where this has been on foot of recent requests to upgrade facilities.

1.69 Overall the evaluation concluded that the preferred operating model is Option 4 - Centralised supervision of the integrated network. This will still present a challenge to ensure consistency of testing throughout the network, but will build on current investment by most providers. Rationalisation of the supervisory arrangements and enhancement of enforcement activities, supported by a modern IT system, will provide a much greater deterrent to non-compliance than at present.

Conclusions 1.70 Commercial vehicle testing is currently provided by 158 independent operators, using a

variety of test facilities and equipment, supervised and regulated by some 30 public bodies and with limited enforcement activity. In these circumstances it is, in our view, almost impossible to achieve consistent high quality testing and assurance that the commercial fleet is in a roadworthy condition.

1.71 The extent to which vehicles are, in fact, roadworthy relies heavily on the goodwill and integrity of the various stakeholders involved. In particular, operators need to maintain their vehicles to an appropriate standard and submit them to regular scrutiny through the testing process, with relatively few applied sanctions for non conformance. Similarly, the effectiveness of the current regime relies on the integrity and professionalism of authorised testers to ensure that testing is carried out to the required standards.

1.72 However, significant levels of anecdotal evidence, stakeholder opinion and independent checks on vehicles by other bodies such as VOSA in Great Britain, indicate that there are a significant number of Irish operators who do not keep their vehicles in a fully roadworthy condition.

1.73 The future governance of the commercial vehicle testing scheme in Ireland is crucial to its success. Currently the various bodies (RSA and LAs) have overlapping authority and, as a consequence, issues are not being efficiently managed. In our view, the organisation best placed to manage the scheme in future is the RSA.

1.74 Having reviewed the strategic options for delivery of the service and taken into account the current investment in the testing network, we have concluded that the preferred delivery model is to retain the network of test centres, but under the supervision of RSA.

1.75 There is currently excess capacity among current test providers. While this is not an issue provided quality standards are maintained, future rationalisation may be required. A single supervisory body would be better placed to monitor and influence this if required.

1.76 Advances in IT and further automation of the test process are fundamental to improving the quality and consistency of the testing process and improvements in central management information systems are vital to monitoring future performance. A single



software platform and automated lane management systems would help provide more consistent testing throughout all authorised test centres.

1.77 Enforcement activity is presently insufficient to act as a deterrent to non-compliant operators. The Gardai need to increase activity in conjunction with RSA. To be effective, they need to be provided with live and accurate information to enable them to take on-the-spot actions when performing roadside checks. Further training of Gardai to perform visual checks and the introduction of easily observable CRW discs on all commercial vehicles, including trailers would significantly benefit enforcement activities.

1.78 Overall, a programme of change must be implemented urgently. Having agreed the overall strategic direction to be adopted, the next step will be to prepare a detailed implementation plan with resources, milestones and targets identified. This will cover major strands relating to communications, procurement of IT systems, resource planning, organisation and management, operational audit, legislative change, enforcement and change management.



II Introduction

Background

2.1 The Road Safety Authority (RSA) has engaged PricewaterhouseCoopers (PwC) to undertake a fundamental review and evaluation of commercial vehicle roadworthiness testing policy, delivery and monitoring effectiveness.

2.2 The scheme to test commercial vehicles in Ireland has been in existence for approximately 25 years. During this time there have been a number of developments, although the administration of the scheme has remained relatively unchanged. Heavy goods vehicle (HGV) testing was initiated in 1982 and light goods vehicle (LGV) testing commenced in 1993.

2.3 The public bodies associated with the management of the scheme include the RSA and 29 Local Authorities (LAs), which are responsible for authorising garages to provide testing services and for completing regular supervision of the authorised testers in their area.

2.4 Garages apply to their Local Authority to become authorised test persons of vehicles. As of August 2006 there were a total of 158 approved HGV and LGV test garages. Of these 51 test LGVs only, 22 test HGVs only with the remaining 85 being dual purpose.

2.5 The review has been carried out against a background of a degree of public disquiet in relation to the roadworthiness of some public service and heavy goods vehicles involved in serious road traffic accidents. There is also some evidence that Irish registered vehicles are disproportionately failing roadside checks in UK and other countries.

2.6 The scope of this assignment was to review the commercial vehicle roadworthiness testing policy, delivery, monitoring and evaluation and make recommendations on means of addressing any issues raised.

2.7 Key steps in our approach are summarised below: -

Figure 1

Project Initiation

Legal and Policy Review

Current test arrangements

review

Consultation and

Benchmarking

Step 1 Step 2

Sum

mary and Analysis of

current situation

OptionsEvaluation

Develop ‘to be’ options

Step 3 Step 4 Step 5

FinalImplementation

Plan Design

2.8 The remainder of this report sets outs the findings of our review.



III Legal Framework Assessment

European Directives on Vehicle Testing3.1 EU Directives dating back to the 1970s imposed various requirements on Member States

to carry out roadworthiness tests on motor vehicles and their trailers. Council Directive 77/143/EEC (“CD 77/143”), which became commonly known as the “Base Council Directive”, was introduced to harmonise, as far as practicable, roadworthiness testing in the European Community by setting down the minimum frequency of roadworthiness tests for vehicles and by specifying the parts of motor vehicles which were to be tested without however prescribing how these items were to be tested.

3.2 The “Base Council Directive”, which was amended on a number of occasions in the years from 1988 to 1994, was consolidated into a single text under Council Directive 96/96/EC.

3.3 CD 1996/96, as amended by Commission Directives 1999/52/EC, 2001/9/EC, 2001/11/EC and 2003/27/EC, represents current European Community law on the roadworthiness testing of motor vehicles and their trailers including commercial vehicles.

Analysis of European Directive Responsibility for vehicle testing:

3.4 CD 1996/96 (as amended) provides that each Member State is responsible for ensuring that periodic testing of the categories of vehicles to which CD 1996/96 applies is carried out. Member States may however delegate such functions to bodies under their direct supervision. Where such delegation occurs and where establishments act both as vehicle testing centres and motor vehicle repairers, Member States are obliged to ensure objectivity and that a high quality of vehicle testing is maintained.

Measures to prove roadworthiness of vehicles:

3.5 Member States are obliged under CD 1996/96 (as amended) to take such measures as they deem necessary to make it possible to prove that a vehicle has passed a roadworthiness test complying at least with the provisions of CD 1996/96.

Recognition of proof of roadworthiness issued in other Member States:

3.6 Member States are required under CD 1996/96 to recognise proof issued in another Member State that a motor vehicle has passed a roadworthiness test.

Derogation from CD 1996/96:

3.7 Derogation is permitted from the requirements contained in CD 1996/96 (as amended) in respect of vehicles belonging to armed forces, the forces of law and order, the fire service and certain vehicles used under exceptional conditions. Ireland has derogated from CD 1996/96 in relation to vehicles which are used by the Defence Forces and the Garda Síochána.



Legal Basis for Implementing European Directives relating to Roadworthiness Testing

3.8 Section 3 of the European Communities Act 1972 gives power to a Minister of the Government to transpose, by way of regulations, instruments of the European Communities, including EU Directives, into Irish law. To date, this power has been used to transpose into Irish law the EU Directives on roadworthiness testing insofar as they relate to commercial vehicles.

3.9 In addition to section 3 of the European Communities Act 1972, another avenue has been introduced whereby the Minister for Transport may, pursuant to section 2 of the Road Traffic Act 2006, transpose and implement European Directives into Irish law under the Road Traffic Acts 1961 to 2006. The Minister may however continue to transpose and implement such European Directives under section 3 of the European Communities Act 1972.

3.10 The European Communities (Vehicle Testing) Regulations 2004 (S.I. 771 of 2004) form the current legal basis for implementing European Directives on roadworthiness testing as they relate to commercial vehicles.

Responsibility for Commercial Vehicle Testing in Ireland NATIONAL LEVEL

3.11 The Minister for Transport has overall responsibility at national level for vehicle testing matters. In that role the Minister is responsible for providing the legislative framework for vehicle testing either by way of sponsoring proposals for primary legislation relating to vehicle testing in the Oireachtas or by making secondary legislation.

3.12 Following the establishment of the Road Safety Authority in September 2006 and the making of the Road Safety Authority Act 2006 (Conferral of Functions) Order 2006 (S.I. No.477 of 2006), responsibility for the operation, oversight, development, quality assurance and delivery of vehicle testing arrangements is now vested in the Road Safety Authority. However, in accordance with section 4 (3) of the Road Safety Authority Act 2006 the Minister retains authority to exercise or perform any function which he has conferred on the Authority.

LOCAL LEVEL

3.13 The European Communities (Vehicle Testing) Regulations 2004 assign responsibility to certain city and county councils to appoint, subject to requirements, “authorised testers” to carry out roadworthiness tests on motor vehicles. Each such local authority is required to appoint an “authorised officer” to supervise the conduct of “authorised testers” appointed by it.



Analysis of the European Communities (Vehicle Testing) Regulations 2004 Application of the 2004 Regulations:

3.14. As required by CD 1996/96 (as amended), Regulation 3 of the 2004 Regulations require vehicles used for the carriage of passengers with more than 8 seats excluding the driver’s seat, goods vehicles, goods trailers and ambulances (defined in Regulation 1 of the 2004 Regulations as a mechanically propelled vehicle used for the purpose of carrying sick, injured or disabled persons) to undergo periodic vehicle testing.

Frequency of testing:

3.15 In accordance with CD 1996/96, Regulation 4 outlines the frequency with which commercial vehicles are required to undergo periodic testing.

3.16. All categories of vehicles are now subject to periodic testing on the first anniversary of when the vehicle is first registered and annually thereafter.

Responsibility for testing commercial vehicles:

3.17. The testing of motor vehicles is carried out by Authorised Testers appointed by certain local authorities. As required under the Directive where this function is delegated to establishments which also carry out repairs to vehicles, local authorities must take measures to ensure that testing is performed objectively and to the highest standards.

3.18. In considering persons for appointment as Authorised Testers, local authorities (under Regulation 6) are required to ensure that an applicant has completed the prescribed form and paid the requisite fee. In addition, local authorities are required to take into account other requirements (i.e. the person must have, or have access to, premises, trained persons and equipment to enable tests to be carried out in respect of all categories of vehicles to which the 2004 Regulations apply).

3.19. Regulation 12 (4) provides that tests may only be carried out by a person trained for that purpose and whose name is included in the register required to be maintained by the local authorities under Regulation 9. Local authorities may pursuant to Regulation 6 suspend or terminate the appointment of an Authorised Tester due to their failure to attend periodic training, to satisfactorily complete a course of periodic training or to carry out tests in a fit and proper manner.

Measures to prove roadworthiness of vehicles:

3.20. Where a commercial vehicle has undergone the requisite roadworthiness test and the Authorised Tester is satisfied as to its roadworthiness, the Authorised Tester is obliged to give the owner of the vehicle tested a pass statement.

3.21. An Authorised Tester must not give such a pass statement where the test report contains one or more items that are found not to be roadworthy or where the vehicle has not been tested in accordance with the Regulations. The local authorities may subsequently revoke such a statement under Regulation 16 where it has reasonable grounds for believing that the pass statement was not issued in accordance with the Regulations.

3.22. It is only on foot of the production of a pass statement and the appropriate fee that the local authority in its capacity as “issuing authority” is required to issue (pursuant to Regulation 15 of the Regulations) a certificate of roadworthiness (which will expire 12



months from the date of the vehicle test in respect of which the pass statement was given).

3.23. Unless a vehicle has a valid certificate of roadworthiness, Regulation 19 prohibits an individual from using the vehicle in a public place.

Enforcement of Legislation in Respect of Current Testing Regime 3.24. Authorised Officers are permitted to enter at any reasonable time the premises used or

proposed to be used by an Authorised Tester to ascertain whether the premises and test equipment are suitable for carrying out tests, whether tests are being carried out in a proper manner having regard to any direction given by the Minister, to inspect any books, documents or records relating to the testing of vehicles or to inspect any books, documents or records relating to the rectification of defects identified in vehicles in the course of a test.

3.25. A Garda may request drivers of vehicles (to which the 2004 Regulations apply) to produce certificates of roadworthiness and to stop such vehicles to establish whether they are in a roadworthy condition.

3.26. A Garda may instruct the person that a vehicle is not to be driven in a public place until the defect has been rectified or require the person to submit the vehicle for a test by a specified date.

3.27. A Garda in carrying out his/her functions under the 2004 Regulations may be accompanied by an Authorised Officer.

3.28. Authorised Officers and the Garda Síochána have powers to ensure that commercial vehicles are being tested to the standard required under CD 1996/96 (as amended) and in accordance with the 2004 Regulations.

Random Roadside Inspections of Commercial Vehicles 3.29. In addition to the annual roadworthiness testing as required by CD 1996/96 and as a

result of the increasing international nature of commercial vehicle operations, Directive 2000/30/EC of the European Parliament and of the Council of 6 June 2000 (as amended) was introduced to require Member States to supplement the annual roadworthiness tests with random roadside inspections of heavy goods vehicles and buses.

3.30. Directive 2000/30/EC recites that effective enforcement through targeted additional roadside inspection is an important measure to control the standard of maintenance of commercial vehicles on the road.

3.31. Whilst the Directive provides that technical roadside inspection shall be carried out without discrimination on grounds of nationality of driver or country of registration, it is the responsibility of Member States to determine the scale of the roadside inspection programme. The Directive does provide that the method of inspection selection should be based on a targeted approach, giving greatest effort to identifying vehicles that seem most likely to be poorly maintained.

3.32. Under the European Communities (Random Roadside Vehicle Inspection) Regulations 2003, which transposed Directive 2000/30 into Irish law, technical roadside inspections shall be conducted by the Garda Síochána (or by a person appointed by the Minister pursuant to Regulation 5 of the 2003 Regulations).



3.33. Where an Inspector is of the view that the deficiencies in the maintenance of the commercial vehicle may represent a safety risk, the vehicle may be subjected to a more elaborate test at a test centre in the vicinity.

3.34. Member States are obliged under the Directive to report to the European Commission the data collected from technical roadside inspections

3.35. The Directive has yet to be implemented in full.



IV Current Test Arrangements 4.1 This section of the report sets out the test arrangements currently in place for testing

commercial vehicles. It highlights issues observed from our assessment, in addition to views provided by relevant stakeholders interviewed as part of our review.

Vehicle criteria and test volumes4.2 Commercial vehicles may be split into 2 groups; heavy goods vehicles (HGV) over 3.5

tonnes gross vehicle weight (GVW) and light goods vehicles (LGV) under 3.5 tonnes GVW. Buses and ambulances are tested under the HGV scheme.

Table 1

Unladen Weight Total number of registered vehicles

LGV Less than 1524 kg's 110,726 HGV Greater than 1524kgs 175,821 Total 286,547

Source: 2005 Vehicle and Driver statistics – Department of Environment, Heritage and Local Government.

4.3 Table 1 shows the split between the number of registered HGVs and LGVs in Ireland. In 2005 the system for differentiating between HGVs and LGVs changed from using the unladen weight of the vehicle, to the gross design weight of the vehicle. This move resulted in a significant reallocation of commercial vehicles from the HGV to the LGV testing category. The information in the table above is the most current available but was calculated before the change of weight categorisation.

4.4 In September of 2004 the testing frequency for LGVs was changed from four years after initial registration and every two years thereafter, to one year after initial registration and every year thereafter. HGVs have always required to be tested annually from the anniversary of the first registration.

4.5 Details of the volume of vehicles tested are not readily available, as the last set of published figures relate to testing activity in 2004 (See Table 2 below). Given the change in criteria, the number of LGV tests completed in 2004 is significantly lower than we would expect for 2005 and in the future.

4.6 There were 268,082 registered goods vehicles in Ireland in 2004. Assuming that, say, 15% of these were registered in that year; this would leave approximately 228,000 vehicles (excluding trailers and semi-trailers) that would have had to have been tested under the current arrangements. However, as can be seen from the table below the actual number of tests completed was some 175,000 (excluding trailers) which is only (77% of expected level).



Table 2 - Vehicle testing result by category of vehicle

Year Ending 31st December 2004 - Actual

Vehicle category Pass (1) Pass With

Defects Rectified

(2)

Pass Total(1+2)

Fail Total Proportion of Total

Heavy Goods Vehicles 70123 27581 97704 22387 120091 64.5% Light Goods Vehicles 26784 8161 34945 9517 44462 23.9% Trailer/Semi-Trailer 6574 2991 9565 1525 11090 6.0% Bus 5669 2188 7857 1816 9673 5.2% Ambulance 540 139 679 125 804 0.4% Unknown 13 2 15 2 17 0.0% Totals 109703 41062 150765 35372 186137 100.00%

Source: Road Safety Authority

Test process and procedures 4.7 The test associated with each classification of vehicle is tailored to the type of vehicle

within the class. Once the Local Authority approves garages, using agreed guidelines published by the RSA, the individual test personnel are trained in the testing process. When training has been completed the authorised test centre can then carry out tests. The scheme does not currently operate a booking system, as it is not required to provide a specified level of customer service. No automatic prompting or reminders are sent regarding the need to get vehicles tested. It is the responsibility of the owner to ensure testing is completed as required.

4.8 Customers are required to show the vehicle registration documents at the test centre. The authorised test person matches the vehicle registration with the make and model of the vehicle. This information is then input to the Information Technology (IT) system before proceeding with the test.

4.9 The duration of the test ranges from 45 minutes to 120 minutes for HGVs depending on the type of vehicle being tested and the number of axles. LGV tests can take from 30 minute to 60 minutes to complete.

4.10 Once a vehicle is tested, either a pass or fail certificate is issued by the garage, depending on the test result. If the vehicle has passed, the driver then takes the pass certificate to the Motor Tax office where a roadworthiness certificate is issued for an additional fee. Vehicles can be tested in any county but owners must apply to the county of registration for issue of the roadworthiness certificate. The roadworthiness certificate is not displayed on the vehicle, but it must accompany the motor tax application form for a tax disc to be issued.

4.11 If a vehicle has failed and returned for testing within 21 days or has travelled fewer than 4000 kilometres since it was tested, the vehicle does not have to repeat the full test, rather it is tested only on the failure points from the first test. A re-test costs approximately



50% of the full test. The pricing structure for commercial vehicle testing is shown in Appendix 1.

4.12 It is a condition of taxing a vehicle over one year old that it has a valid certificate of roadworthiness. However, it is possible to tax a vehicle on the last day before expiry of the roadworthiness certificate, for up to 12 months. Effectively, although illegal, the vehicle may be driven for much of that time without a valid roadworthiness certificate. This practice encourages non-compliance with the testing requirement and is a cause for concern.

Test Scope 4.13 All commercial vehicles over one year old are required to undergo an annual

roadworthiness test. In the past eligible vehicles were classified in line with the corresponding motor taxation classes, which resulted in some vehicles, such as car derived vans, falling between the commercial vehicle test and the national car test schemes. Recent changes have moved to regularise this situation and to ensure that all such vehicles are now included within the commercial vehicle scheme. However, a number of other vehicle classes, such as agricultural tractors, fire tenders and the like, remain exempt from roadworthiness testing.

4.14 Stakeholder interviews highlighted the following concerns and views:-

(a) the general opinion was that if a vehicle is used on the road it should be subject to testing;

(b) There is a road safety concern over the exemption for agricultural vehicles for compulsory periodic roadworthiness testing, particularly given their increasing use in some areas by the construction industry, for towing trailers with loads of up to 25 tonnes. These concerns mainly relate to adequacy of the braking systems on these vehicles.

(c) The frequency of testing is a concern of some, given the potential distances that can be covered over 12 months by some vehicles. A change to a mileage based testing regime was mooted as a possible change.

Trailer Testing 4.15 From the last statistics available (2004), the total number of trailers tested equated to only

9% of the total number of HGV tests carried out. Based on stakeholder interviews, the majority agreed that each articulated tractor unit would have at least 3-4 trailers per unit. From the statistics available, it is not possible to break down the testing volumes between articulated and rigid units. However, the high-level test statistics suggest that the number of trailers being tested is relatively low.

4.16 Issues identified with trailer roadworthiness enforcement, through our stakeholder interviews, included:

(a) Difficulties with tracking trailer movements throughout the EU;

(b) Trailers are frequently inactive for days, weeks or longer;

(c) There is no means of recording when or where a trailer was last used or by whom (i.e. such as a tachograph for trucks); and



(d) When vehicles are stopped at roadside checks the licence details of the trailer are generally not recorded. The registration number of the tractor unit pulling the trailer is normally recorded.

4.17 Articulated vehicle tractor units are not required to have a trailer attached when being tested. In other jurisdictions this is required to enable the tractors to be tested in respect of their ability to deliver air to trailer brakes. In those circumstances it also has a beneficial effect of ensuring that a higher proportion of trailers are, in fact, tested.

Commercial Vehicle Testers Manual 4.18 Vehicle tester manuals exist for HGVs and LGVs to provide documented details of testing

requirements to vehicle owners, maintenance garages and authorised testers. Any updates to procedures are currently communicated via circulars to the authorised testers, through the county offices.

4.19 Interviews with a number of authorised test persons indicated that the testers’ manual is somewhat out of date, following various changes and updates, and the provision of circulars is not a robust mechanism to ensure that all garages are working off a single version of the rules. For example, there are concerns as to the best procedure to induce a load when testing vehicle brakes, in addition to overcoming new technology in trailer braking systems.

4.20 Authorised testers also raised an issue that instructions and standards should be more specific for certain parts of the test, particularly in relation to evolving technology and component modules such as anti lock braking systems, and that updated procedures are communicated and incorporated within ongoing training programmes.

4.21 Our review highlighted that, since a number of public bodies are involved in determination of commercial vehicle regulation, this undoubtedly complicates information flow, co-ordination of activities and release of documentation in a timely manner.

4.22 Following on from the Kyoto agreement, transport issues and their effect on the environment have taken a much higher profile. It is likely that there will in future be a greater emphasis on the environmental content of the test, particularly as fleets change from diesel engines to bio-degradable fuels. Indications from the Environmental Protection Agency (EPA) are that they will require access to statistical information on the national fleet for both cars and commercial vehicles, some of which can be provided during the testing process.

4.23 The EPA would like to see an improvement in data gathering and in particular areas such as, engine size, vehicle age, odometer readings, fuel type and more detail on reasons for test failures, particularly when these relate to emissions issues.

Test centre premises 4.24 The RSA maintains a database of authorised test centres and individual authorised test

persons. Lists of Authorised Testers are printed and circulated periodically to the Motor Tax Offices and are available on the Department of Transport website.

4.25 All authorised test centres must follow the standards laid down by the RSA in its ‘Guidelines for the Premises and Equipment required for the testing of commercial vehicles’ (2004). All test centre equipment has to have valid calibration certificates issued by the manufacturers. These must be updated, at least on an annual basis. Local



Authority Officers (LAOs) inspect calibration certificates on their inspections of authorised test centres.

4.26 These standards were agreed with the industry, prior to publication of the guidelines, in order to improve the quality of testing equipment and consistency of the testing process throughout the country. However, some existing test centres, have been given a derogation to comply, where physical limitations of existing premises make that impossible. For example, we understand that some existing centres are unable to meet the drive through and/or 22 metre inspection pit requirements for HGV testing. These have been permitted to continue pro tem and may opt to become LGV only test centres under current guidelines.

4.27 New authorised test centres need to meet the requirements for both HGV and LGV testing. This would also apply to any test centre required to relocate to new premises as a result of the physical limitations referred to above. A copy of the guidelines is included at Appendix 3.

4.28 Based on the programmed upgrade of facilities, if a test centre is unable to install the minimum requirement required by the national upgrade plan in any year, their licence is to be suspended for 3 months. If the required upgrades are made within this period their licence is reinstated. If the required upgrades are not made within the suspension period the licence is revoked. If a test centre wants to start testing again after this it must go through the entire application process again.

4.29 Compliance with the 2004 guidelines has been inconsistent throughout the network. In many cases, premises and equipment have been upgraded substantially, with significant investment, such that the overall quality of the network of test centres has improved. However, others have not yet undertaken the required investment. It is anticipated that a number of centres will not meet the 2008 deadline and may withdraw from testing at that time.

4.30 Having accepted these guidelines has shown that the industry is keen to raise the standard of testing service provided. However, the current guidelines, and the derogation provided to some existing test centres in respect of premises compliance, has led to differences in investment requirements for new and existing premises. This has led to some discontent among owners of new test centres in particular, who feel that they are not competing on a ‘level playing field’ since they see their level of investment as having been much greater than that required of existing testers.

4.31 There are currently 24 of the HGV authorised test centres licensed to conduct tests on vehicles used to carry dangerous goods (ADR). From our stakeholder interviews, customers highlighted the need for a more even geographic coverage of these specific authorised test centres throughout the country.

Authorised tester licences 4.32 Applications to become authorised testers cost €5000. As stated earlier, a licence must be

issued, if the applicant meets the necessary technical standards for his premises, equipment and staff competency. Such accreditation is a ‘one-off’ requirement, with retention of the licence automatic, unless the garage is delisted as a result of a disciplinary procedure being invoked. Delisting of authorised garages is uncommon.

4.33 From our stakeholder interviews the following issues and concerns were raised:-



(a) There is an apparent lack of consistency in the granting of test centre licences. Some County Councils attempt to control the granting of test centre licences, through the planning application process. A few Counties take the view that when a new test centre is required within the County it should be advertised and awarded on a tender basis;

(b) In the past, separate applications could be made individually for LGV and HGV licences, however, this is no longer the case, with new applicants required to provide both;

(c) Their view is that there is a lack of clear guidance from the RSA on the standards required for improvements on existing authorised garages to meet upgrade programme requirements, and in the situation where the test centre would like to continue trading as a light goods test centre only;

(d) There is Inconsistent interpretation of a circular letter sent by the DoT to all LAOs on 23rd December 2005, providing guidelines on the treatment of authorised test centres unable to comply in full with the upgrade programme (appendix 3);

4.34 There is also concern that test centres are not strategically located in relation to geographical requirement or commercial vehicle volumes. They are located wherever someone has assessed that there is a business opportunity. In future, the requirement to provide adequate facilities for both HGV and LGV testing could result in a lack of coverage in areas where demand is low.





4.35 Figure 1 shows the current geographical spread of HGV and LGV authorised test centres in Ireland.

Disciplinary Procedure 4.36 The supervision of the vehicle testing scheme which is currently in operation is based on

circular letter VF10/67 (Appendix 4) issued by the Department of the Environment on 9th

August 1985. There are warning and suspension procedures that are put into operation when exceptional circumstances prevail. If a test centre is in breach of any the rules or regulations stipulated, a warning is issued with remedial action that the test centre must take to rectify the situation. If the remedial action is not taken within a specified time span, which is variable depending on the seriousness of the offence the test centre is suspended from testing vehicles.

4.37 The enforcement of suspension is the removal of certification books from the test centre to prevent continuing testing operations. A suspension lasts for three months after which the centre is scrutinised once again. If the test centre has still not addressed the recommendations of the local authority its licence is revoked. If the test centre wants to commence testing vehicles again it needs to apply for a new licence with the Local Authority, which is currently for a HGV and LGV licence.

4.38 The following concerns and issues were highlighted through our assessment, including stakeholder interviews:-

(a) In light of the technological changes and health & safety issues over the last 21 years, the adequacy and relevance of disciplinary guidelines is questionable;

(b) There is a perceived lack of consistency with regard to applying disciplinary procedures, relevant tolerances and adherence to guidelines across all counties, as these are exercised by individual local authorities;

(c) Inadequate support from local authorities to their LAOs, with regard to enforcement issues;

(d) No clearly defined procedure and roles / responsibilities for taking action against a garage, between LAO, County Engineer or County Manager;

(e) LAOs highlighted that they have little support from their county managers and get very little exposure to them; and

(f) Poor communication between RSA, LAOs and Motor Tax Office with regard to suspensions, to ensure that any suspensions are known in all areas.

Management information and IT systems 4.39 Currently there is no cohesive ICT system for all users. There are two software systems

used by authorised test centres for collecting and processing test results, ASC and Digital Forecourt. 87% of authorised test centres use the ASC system. The two systems are considerably different in validation, security and database design. The information provided by the ASC solution is shown in appendix 5 and the information provided by the Digital Forecourt solution is shown in appendix 6. The software systems collect information from the tests and hold it on a local server within the authorised test centres. Once per month the authorised test centres are required to send a file of the passed, failed and “passed with defects rectified” test results to the RSA and copied to the LAOs (some test centres still send this information by CD-ROM).



4.40 LAOs have no standard application for storing test vehicle records and most have built their own stand alone model in Microsoft excel. We have no evidence of any sanctions being placed on authorised test centres who fail to conform to the monthly reporting requirement.

4.41 The RSA then collates this information for all the authorised test centres for its annual return. The methods used to import vehicle test records from the authorised test centres to the RSA database require significant manual intervention with the attendant risk of error in consolidation. The RSA national database was built to match the ASC system. The running order for the test was amended 2 years ago and the test centre software updated accordingly, however the software at the RSA has not yet been updated. Hence the RSA cannot interpret the information that has been coming from authorised test centres and the RSA annual return has not been completed for 2 years. Such information is key, and previously provided comparisons of individual garage ratings against the national average, that was deemed by LAOs and County Managers to be informative.

4.42 A number of issues and inefficiencies with regard to management information, were observed including:-

(a) There is no automated method of transferring readings from test equipment to the test centre computer systems. The inspector enters this data into the system manually, with human error always a risk, particularly if the vehicle is being checked in the pit and the authorised test person has to walk some distance to the computer to enter the data;

(b) There is no way to identify or share important information, such as vehicle registration numbers, owners or test records, between the authorised test centres, thus a test centre has no means of checking whether or not a vehicle has recently been presented for testing in another test centre;

(c) The software permits duplicate records to be entered for the same vehicle or owner and allows easy access to the vehicle test information, giving rise to potential data security issues;

(d) Authorised test persons are given access codes that allow them to change test results and dates and there is no encryption on files sent by the authorised test centres to the LAOs and the DoT;

(e) One major concern raised is that there are few checks on data entry of the reasonableness or completeness of data. For example, we were advised that a vehicle can be passed without a reading on the brake test result field.

4.43 In our view, the true condition of the national fleet is being obscured by inconsistent use of the category ‘pass with faults rectified’. For example one centre reported a 100% first time pass rate for the fleet that they tested, because faults detected were repaired on site and a pass certificate then issued. Thus, there is no record of any vehicles being presented in condition that was not roadworthy. Another test centre reported a 90% first time pass rate however, this included ‘passes with faults rectified’, rather than showing this as a separate category.

4.44 Through the test centre visits carried out and accompanying interviews, all authorised test centres were supportive of the need for improvement in the computer systems to provide more comprehensive support to the testing regime.



Roles & responsibilities 4.45 A number of authorities are involved in administering and supervising the testing scheme.

The Local Authorities, RSA and the Department of Transport all have a role to play.

4.46 The overall responsibility for the Goods Vehicle Testing regime lies with Vehicle Standards section, which is currently within RSA. This unit originally operated within the Department of Environment and Local Government, before transferring to the Department of Transport and then to the RSA.

4.47 The main role of the Vehicle Standards unit has been to:

(a) Review and update the legislative framework for vehicle testing

(b) Prepare and update the Testers’ manual setting out standards and methods of testing

(c) Provide technical backup to LAOs on interpretation of standards, fitness of authorised testers and the like; and

(d) Provide technical input to multi-agency roadside enforcement teams, and

(e) Liaise with other international testing authorities to determine changes in testing standards in line with vehicle technology developments.

4.48 The technical team within Vehicle Standards consisted of around 4-5 engineers. However, in recent years that number has fallen, due to retirements and staff not being replaced, with the last of the team leaving in autumn 2006. As a result, the Vehicle Standards unit has lost all of its capacity and experience and is, at present, unable to provide the technical backup that LAOs in particular require.

4.49 The RSA is currently training three experienced vehicle testers as a first step to rebuilding its capability in this respect. Their role, initially, will be to visit authorised test centres and inspect the current testing facilities and processes in conjunction with the LAOs.

4.50 Local Authorities, through the appointment of Local Authorised Officers (LAOs) have a significant role to play in the appointment, supervision and, if necessary, delisting of Authorised Test Centres. Currently there are 29 LAOs involved in the administration of the scheme, two of which are full time in the role. The number of garages under the supervision of each individual varies significantly. As a result, the provision of standard and common interpretation of guidelines and administration of those guidelines across all authorities is very difficult, if not impossible to achieve.

4.51 Although test centres in the four different local authorities in the Dublin area are overseen by one Local Authorised Officer (LAO), who is employed by Dublin City Council, no such co-operation exists throughout the rest of the country. In addition, Waterford, Galway and Limerick all use separate city and council LAOs because they have county and city vehicle registration offices.

4.52 The role and responsibility of the Local Authorised Officers (LAOs) is not consistently defined and their reporting lines are often unclear. LAOs are from different backgrounds, and there are no common selection criteria used when appointing staff to the role. Many LAOs did not go through any formal selection process; rather they inherited or were told they were taking on the role. With the exception of Dublin and Cork, the role of LAO is part-time and those appointed have many other responsibilities. Most have come from a mechanical engineering or maintenance background. They are often foremen in technical



or vehicle maintenance services who have been given this additional task. There is no standard training requirement for appointed LAOs.

4.53 County managers delegate different levels of authority to the LAO role. In some cases the LAO is unable to complete any actions without reference to a higher authority, whereas in other counties they have the full authority to suspend garages, for example. The role requires the backing of the County Manager, but we understand that this is not always secured, due to the generally low priority placed on the function. Some counties have senior Mechanical Engineers in place who can support the LAO but such support is not present in all. The presence of a Mechanical Engineer is important to provide technical backup to enforce decisions and actions made by the LAO.

4.54 From the feedback received, LAOs spend a significant amount of additional time out-of-hours on this aspect of their work, depending on the number of authorised test centres that they preside over. The role is of sufficient importance to justify specialised and dedicated staff but only Dublin and Cork having sufficient volumes for each to support a dedicated full time officer.

4.55 LAOs attempt to visit all test centres within their remit at least once per month. In some areas the resource provided restricts the number of visits that can be completed each month. Due to time pressures, the focus is mainly on paper records and equipment condition rather than on test procedures. This is exacerbated by the fact that there is often no vehicle in for testing while the LAO is present. The LAOs record the date of their visits along with the condition of the premises and any recommended actions that need to be taken.

4.56 LAOs meet monthly to discuss issues of common interest, but some consider that there is insufficient opportunity to discuss issues and support each other on a cross-county basis. Also, LAOs report having minimal support from RSA on ascertaining specific solutions to queries, particularly of a legal nature, with no clear point of reference for such information to support a standardised approach. In addition, anecdotal evidence gathered through our stakeholder interviews suggest that LAOs often find that there is little support from their County Managers when action needs to be taken.

Roadside enforcement 4.57 The Gardai is responsible for the enforcement of the roadworthiness of vehicles, although

the Minister has the power to appoint others to carry out technical assessments at the roadside. Until recently, we understand that this has not been given the priority it requires due to resource being allocated to other duties. This imbalance is now being redressed with the Gardai having recently increased their traffic corps personnel number from 530 to 805, an increase of approximately 50%. They expect to increase this further to 1200 by 2008. They currently provide 2 days of training to new recruits, on HGV enforcement duties, with one day spent in the classroom and one day practical training on the roadside.

4.58 Currently there are 14 state owned weighbridges, utilised for roadside enforcement and 60 private calibrated weighbridges (e.g. at quarries) available for enforcement purposes. The Gardai have highlighted a need to carry out more weighbridge checks for overweight vehicles, and consider that there are insufficient state weighbridges available to them.

4.59 While no specific statistics are available, anecdotal evidence gained from our discussions with Gardai, fleet operators and other agencies would indicate that there had been a relatively low level of roadside enforcement activity in the past. Such activity as there has been has been largely focused on detecting overweight vehicles and non-compliant



drivers’ hours etc, with technical assessment of vehicle condition limited to intermittent ‘multi-agency’ enforcement activities. Drivers may be asked for evidence of roadworthiness of their vehicles but have up to 10 days to produce the necessary documents. It is not clear that failure to produce such evidence is actively pursued to conviction, in many cases.

4.60 Enforcement is an international issue, since Irish registered vehicles commonly operate in UK in particular and throughout Europe generally. There are also significant numbers of foreign registered vehicles operating in Ireland. Recently, Vehicle and Operator Services Agency (VOSA) in Great Britain conducted a survey of the condition of commercial vehicles stopped between April 2005 and March 2006. The survey included vehicles originating from 12 different countries. The highest offenders, in order, were vehicles registered in Ireland, followed by Northern Ireland and Romania, with a ‘disproportionate’ number of failures compared with the number of vehicles on British roads.

4.61 Under the most recent European Directive, international co-operation in relation to enforcement is encouraged by requiring member states to notify each other of vehicles that fail to meet the standards and/ or fail to produce appropriate proof of having a valid roadworthiness certificate from the country of origin. Given the level of Irish registered vehicles that are found to be defective on British roads, VOSA are keen that the RSA work co-operatively with them to resolve this issue.

Staff training and procedures 4.62 RSA define the training content for people wishing to become Authorised Test persons. At

present, the Society of the Irish Motor Industry (SIMI) is responsible for organising training of commercial vehicle authorised test persons in conjunction with the Dublin Institute of Technology (DIT). Authorised test persons are trained to complete tests on HGV, LGV or both types of vehicles. To qualify to become a vehicle authorised test person candidates must hold a V-tec or E-tec national qualification or the equivalent with other bodies. Garages notify LAOs in respect of changes of personnel and training required so that training can be planned. When details of a new authorised test person are received, the LAOs make the necessary checks regarding mechanic’s qualifications. The training is then scheduled and the candidate must then complete 2 days of classroom based training at the DIT and 2 days of practical training at a specified location. The candidates must pass an examination before becoming an authorised test person.

4.63 Authorised test persons are required to undertake a refresher training course, at least on an annual basis, to ensure that all are up to date on procedures, test requirements and legislation. It is up to the authorised test person to book themselves on this training as the RSA does not follow this up.

4.64 The refresher course is a one day classroom based course. We have been advised that authorised test persons spend much of this time in discussion of current issues, and cases, rather than formal instruction. There is no certificate issued to confirm that authorised test persons have attended the course nor is there an exam given at the end of the course.

ADR4.65 ADR is the term used to describe the “European Agreement Concerning the International

Carriage of Dangerous Goods by Road (ADR)”. The Agreement was made under the auspices of the Inland Transport Committee of the United Nations Economic Commission for Europe.



4.66 Parties to the Agreement undertake that, subject to certain reservations, the international transport by road of dangerous goods will be permitted through their territory, provided that the goods are packed and labelled in accordance with the Agreement and are carried in vehicles which comply with the provisions of the Agreement by suitably trained and informed drivers.

4.67 As a result of the EU directives, these requirements also apply to the relevant vehicles engaged in national transport. The requirement to have an ADR vehicle examination came into force in April 2002. For the purposes of the annual technical inspection of vehicles, the Department of Transport (DoT) is the competent authority, who may appoint an Authorised Examiner to carry out these inspections. Bus Eireann has been designated the Authorised Examiner.

4.68 The complexity of ADR, training needs, consistency of testing, supervision, cost effectiveness and efficiency meant that a single body was the preferred means of implementing the arrangements.

4.69 Bus Eireann, with a regional spread of testing centres throughout the country, was identified as a suitable organisation for performing the ADR vehicle examination and certification function and agreed to act in that capacity on an informal basis. The company must carry out an annual technical examination of vehicles which are required to have a Certificate of Approval. As a prerequisite, vehicles must have undergone a roadworthiness test within the previous month. A vehicle or a trailer/semi-trailer, which has not been licensed, cannot be issued with an Approval Certificate.

Road Haulage Operators 4.70 The most significant influence on the roadworthiness of the goods vehicle fleet, and for

the standard of presentation of vehicles for testing, lies with the owners and/or operators of the vehicles. Operators have a responsibility to be in possession of a current Road Haulage Operators Licence as well as the individual CRWs for each of the vehicles. In order to meet the criteria for this licence a full time employee must possess a certificate of professional competence, be able to prove their financial standing, prove that they have access to an operating centre and an understanding of vehicle operating cost.

4.71 They must also provide, on their operators licence, details of all equipment (registration, chassis number) to be operated. However, operators are not required to keep specific records of maintenance activities, nor is any of the current enforcement activity directed towards inspection of such records.

4.72 In addition, ‘own account’ operators (keeping the vehicles for their own use rather than as a haulage service to others) escape these controls, since they are not required to hold an operators licence.

4.73 As part of this review of current arrangements, PwC conducted a survey of fleet operators as customers of the authorised test centres. Survey findings and observations are detailed in section 3 and summarised below.

4.74 Overall satisfaction with the services provided by the commercial vehicle testing centres was very high, with 94% of respondents stating that they were either ‘very’ or ‘quite’ satisfied with the service they received.

4.75 The aspects of service that customers were most satisfied with were the simplicity of the booking arrangements, the registration and payment procedures at the test centre and the professionalism, ability and helpfulness of the staff member carrying out the test. Aspects



of service with lower satisfaction ratings included the comfort and cleanliness of the waiting area, the length of time it took to get a test appointment and the length of time it took to get a retest. The findings from the survey are listed below:

(a) The majority of those vehicles which failed their first test had not been serviced prior to testing (94%) and these fails were largely seen as deserved.

(b) Waiting times for appointed tests are an issue- this element was rated as one of the top two most important aspects of customer service, but received the lowest overall satisfaction rating. The ability to turn up without booking was not deemed important.

(c) Participants awarded high satisfaction ratings for customer service, particularly the helpfulness of staff when booking tests, helpfulness and professionalism of staff carrying out the tests and the payment and registration procedures.

(d) Almost a third of respondents thought that the most important element of customer service was that the person testing the vehicle was independent from the person who had prepared it for test, and over half thought that this was in the top three.

Potential conflicts of interest 4.76 The current test arrangements rely heavily on the goodwill and integrity of the various

stakeholders involved. In particular, operators need to maintain their vehicles to an appropriate standard and submit them to regular scrutiny through the testing process, with relatively few applied sanctions for non conformance. Similarly, the effectiveness of the current regime relies on the integrity and professionalism of authorised testers to ensure that testing is carried out to the required standards.

4.77 However, there are several situations that arise under the current arrangements that could potentially give rise to a conflict of interest, in relation to ensuring that a consistent standard of testing is applied in all cases. A number of these were raised during stakeholder interviews.

4.78 The first example is that it is possible for owners to have their vehicles tested in their own workshops, where such workshops have been approved as authorised testers. While it is clearly possible to set up internal independent reporting lines and apply the standards rigorously, it is equally possible to envisage a situation arising where, due to pressures of cost or inconvenience of time off road, undue pressure is placed to provide pass certificates for vehicles that should have failed. This situation arises in particular, in respect of a number of bus companies.

4.79 Another similar concern arises when authorised test centres are associated with dealerships or where they sell second hand vehicles. It is clear that the price of a commercial vehicle is significantly increased if it is sold with a recently issued CRW. This can call the integrity of the testing process into question. For example, during stakeholder interviews it was alleged that some unscrupulous test centres are prepared to issue pass certificates for vehicles which have not been inspected.

4.80 There is also a concern that most authorised test centres provide repair services in addition to inspection services - to the same customers in many cases. This could clearly give rise to a potential conflict of interest, though this is more often seen in the context of garages doing unnecessary repair work, rather than failing to test the vehicles properly. However, since the income from testing is often a relatively small proportion of their total incomes, is possible that test centres could face withdrawal of repair business, if they are perceived as being ‘too strict’ during testing.



4.81 It is important to note that, from our survey of operators, most are comfortable with the current arrangement, whereby test centres can carry out repair work. The majority stated that they use different garages for testing their vehicles than they use to repair them, in any case. The ability for a vehicle to have faults rectified on site and for the vehicle to receive a pass certificate in a single visit, is considered to be a valuable feature of an efficient service.

Summary of Current Situation 4.82 At present there are 158 authorised test centres carrying out around 200,000 commercial

vehicle tests throughout the country each year. The test regime is supervised by LAOs from 29 local authorities, with central responsibility for technical standards and national deployment resting with RSA as an Agency of the Department of Transport.

4.83 Detailed statistical information concerning vehicle testing numbers and pass rates is not available at present, since the testing categories were changed during 2005 to bring them more in line with the European standard, resulting in the reclassification of vehicles from the HGV band into the LGV band. While individual test centres systems were changed to reflect the reclassification, the central database for consolidation of national statistics has not been updated. In addition there is no central database holding details of CRW validity and/or expiry dates, nor is the National Vehicle and Driver File updated with such information.

4.84 The commercial vehicle testing process and procedures currently in use are defined in the Vehicle Testers Manuals (2004) for LGV and HGV categories. The standards required for test centres are set out in the ‘Guidelines for the Premises and Equipment required for the testing of Commercial Vehicles (2004)’ publication by the Department of Transport.

4.85 Over the past few years the Department has encouraged garages to upgrade their facilities. There is evidence to suggest that some, but not all, are undertaking the necessary investment to meet the 2008 deadline for the upgrade to be completed. The standard set for new test centres has seen the barriers to entry into the market raised, with the requirement for a 22 metre pit and a drive-through facility that is now mandatory. There is also a requirement for new test centres to have both LGV and HGV testing facilities.

4.86 There has been a move towards common branding of authorised test centres under the name ‘Vehicle Testing Network’. However, to date this has been relatively low key.

4.87 Inconsistency in the application of vehicle testing standards is a concern for the majority of stakeholders in the process. There are a number of inherent weaknesses in the testing regime that potentially contribute to this. These include the following:

(a) There exists a large network of authorised test centres that use a variety of equipment and procedures carried out by staff who, until recently, did not have a consistent standard of training

(b) There is a heavy reliance on manual input and individual judgement in conducting tests and recording results

(c) There are inadequate IT systems to integrate the work of the testing network and to provide detailed management information on its performance and results

(d) Responsibility for the supervision of the testing network split between RSA, and 27 individual Local Authority representatives (only 2 of which are full time in the role) has



been given a relatively low priority within Local authorities and, within the Department in recent years, there has been a gradual depletion of the technical resources needed ensure the application of common standards.

(e) A limited level of roadside enforcement activity is carried out by the Gardai, with multi-Agency enforcement measures only carried out infrequently.

(f) Inadequate communications between RSA, the LAOs and Authorised Testers to ensure that all technical standards are applied equally in every location

4.88 Overall test compliance rates are impossible to estimate. However, the requirement for vehicles to have a current CRW when they are taxed provides a ‘back-stop’ in relation to compliance. Nevertheless, it is possible for a vehicle to be non-compliant by using short-term taxation renewal periods, interspersed with a 12 month period commencing close to the expiry date of the CRW.

4.89 Compliance rates for trailers and semi-trailers are a greater cause for concern since the number of trailers tested appears to be low in comparison with the estimated trailer population, based on the number of tractor units tested. Although trailers are registered when new, it seems probable that NVDF records are out of date, since trailers do not require to be taxed annually and there is little incentive on behalf of owners to notify the Vehicle Registration Unit when the vehicle details have changed.

4.90 As discussed later in this report, the economic sustainability of the current regime of testing would be difficult to achieve, should testing be carried out on a ‘stand-alone’ or independent basis, at the current number of centres. At present there are very few independent test centres and for most garages, testing is only a relatively small proportion of their business. Other activities often comprise commercial vehicle sales, repairs; road haulage or operator services (particularly buses). Operators can, therefore, end up testing their own vehicles, or vehicle repairers can test vehicles they have maintained, These are situations that could give rise to conflicts of interest in relation to the testing process.

4.91 Overall the current testing regime is very dependent on the quality of input of many stakeholders. There is evidence that many operators, authorised testers, LAOs and others working within the regime try to do a good job. However, there are also many opportunities for things to go wrong. Recent investigations by VOSA in Great Britain, which have identified the number of faults on Irish registered vehicles to be disproportionately high in relation to UK and other foreign vehicles, provides evidence that such potential problems are realised in many cases.



V International benchmarking study 5.1 A total of 22 European Countries were contacted electronically regarding commercial

vehicle testing in their country. A 40% response rate was achieved. The people approached to participate in the benchmarking exercise, were those responsible for the operation of commercial vehicle testing in their country. The sample of organisations operating commercial vehicle testing was drawn up from PwC’s industry contacts and knowledge.

5.2 Questionnaires were structured to identify how commercial vehicle testing was run and administered throughout Europe. It benchmarked, some basic and some specific issues, namely:

(a) General administration

(b) Test arrangements

(c) Test Centres

(d) Test Equipment

(e) Staff Training

(f) Customer Service

(g) Publicity and Marketing

5.3 The findings of the survey are an analysis of the responses received from the country representatives. PwC have not independently verified any details contained in the responses.

Key Findings 5.4 A brief summary of the key themes from the survey is set out below. An individual

synopsis for each country is given in appendix 7.

General Observations 5.5 In 75% of the countries involved in the survey, commercial vehicle testing is carried out by

independent test centre operators and monitored by the appropriate government department. In general, they are governed by a central body rather than individual local authorities. In 70% of the countries contacted, test centres can apply to test both cars and commercial vehicles, provided they have the capability.

5.6 In each of the countries surveyed, all classes of commercial vehicles are tested one year after the initial registration date and every year thereafter. Ireland has recently moved into line with this practice. Certificates of roadworthiness are required to be clearly displayed on commercial vehicles in 50% of the countries that participated.

5.7 All countries categorise and record faults on the test report. Apart from Hungary, the retest focuses on the specific faults identified in the original test, assuming the re-test is completed within a restricted timescale. In Hungary, a re-test is the same as a full test.

5.8 80% of countries carry out individual assessments of authorised testing personnel on a regular basis.



Quality and Enforcement 5.9 Usually the quality of testing is monitored by the central body that governs the commercial

vehicle testing scheme. Luxembourg and Hungary use independent auditors to ensure the quality of testing is kept at the required standard. Random spot checks are conducted in the majority of countries.

Test centres 5.10 The number of authorised test centres in a country is generally driven by geographical

considerations. The preferred methodology for determining the number of test centres in a county (or district) is for it to be directly dependent on the number of vehicles registered in that county (or district). In Great Britain there is also an overarching standard that no customer has to travel more than 30 miles to their nearest authorised test centre. However, in Finland authorised test centre numbers is exclusively calculated on the basis of demand, so that, in the sparsely populated north of the country, a customer may have to travel 150km to their nearest authorised testing centre. In Denmark it is entirely up to the individual operating companies to decide upon the location of testing centres.

Test Equipment 5.11 Figure 2 below illustrates the items of equipment that are required to be kept within test

centres for each country that participated in the benchmarking exercise.

Figure 2

Test Equipment

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Heavy good vehicle roller brake tester

Decelerometer

15 tonnes jacking system with appropriate extensions and saddles

Air brake pressure gauges

axle load simulator

fifth wheel measuring pin

tool for measuring trailer kingpin

test plug for checking ABS/EBS warning light system *

An instrument for checking accurately the speed setting of a speed limiter

4 post lift? (or Pit)

jacking beam

Wheel play detector

Headlamp aim tester (spec on passing)

Exhaust gas analyser

four gas exhaust emissions analyser

Diesel smoke meter (To measure opacity)

Steering side slip plate (wheel alignment) 0-20 m/km



Resonance suspension and shock absorber test (Measure performance and imbalance with the manual specifications)

Tyre tread depth gauge **

* Just visual check of ABS warning light ** Calliper used if needed

Test Arrangements 5.12 Switzerland and Denmark send reminders to customers two months prior to when their

vehicle is next due for testing. In Luxembourg the notice period is three weeks. In Poland and Finland some of the independent authorised testing centres give notification to their customers but this is on a purely voluntary basis. The remainder of the countries do not send reminders to customers when their vehicles are due for testing.

5.13 Only in Switzerland and Great Britain do all tests need to be booked. Telephone and internet booking are both available or under development in these countries.

5.14 Table 3 below displays the price of testing for the various categories of commercial vehicle in each of the countries that participated in the benchmarking survey. All prices are approximate and are shown in Euro.

Table 3

Country Heavy GoodsVehicle Re-test

LightGoodsVehicle Re-test

PublicService Vehicle Re-test

Denmark 0 0 0 0 0 0Estonia 40 20 35 15 40 20Finland Dependant on Company France*** 70/110 17 50 15 90 n/aGermany *61/104 10 43 10 45/89 10Great Britain *98 / 127 *65 / 85 78 40 **78 / 112 **52 / 74Hungary 45 45 45 Ireland *134/150 *67/75 64 32 134 63Italy*** 26/36 26/36 26/36 26/36 26/36 26/36Luxembourg 32 17 23 12 n/a n/aNorthern Ireland *72.75/90 27.75 45.75 27.75 ****62.25/97.5 ****29.25/48Poland *40 5/21 25 5/21 **55 5/21Slovakia 28 11 14 5 n/a n/aSwitzerland 100 n/a 50 n/a 100 n/a

*3 Axles/ 4 Axles, **9-22 seats/ 23+ seats, *** regional authority price/ independent garage price, ****9-16 seats/17-35 seats.

5.15 From this table it can be seen that the cost of commercial vehicle testing in Ireland is amongst the highest in Europe.

Data monitored 5.16 All the countries surveyed were asked to highlight which metrics they monitored on a

regular basis. A summary of these is shown in figure 3.



Figure 3

Monitored Notmonitored

Data Monitored

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Average test waiting times Maximum test waiting times Number of vehicles tested Pass fail rate for full tests

pass and fail rates for re-tests; reasons for failure;

Vehicles that fail to appear for test; tests cancelled by the Owner;

tests cancelled by the Contractor; number test system over-rides;

number of free tests undertaken; test time from start to finish; and

Number of Vehicles booked but not yet tested.

Vehicle test Service as a whole; Vehicle category;

Vehicle make; Vehicle model;

Vehicle age

5.17 From this high-level assessment it is clear that Ireland, along with Denmark monitor the least amount of information about commercial vehicle testing.

5.18 Overall, the testing arrangements in Ireland, is somewhat at variance with usual practice elsewhere in Europe, particularly in relation to supervision and monitoring arrangements, independence of the test centres (i.e. not associated with repair businesses etc) and information management arrangements. In addition the service is generally more expensive than the other countries benchmarked.



VI Customer and public consultation 6.1 As part of this review we carried out a survey of a cross-section of fleet operators and

conducted a series of public meetings in different parts of the country, to ensure that we had access to as wide a range of views as possible, before coming to our conclusions.

Customer satisfaction survey 6.2 A total of 103 telephone interviews were conducted with vehicle operators who had

recently had a commercial vehicle tested. A sample of around 3000 organisations operating commercial vehicles was drawn up, using publicly available data sources. The sample was then selected randomly, with approximately half of respondents within the Dublin area and half outside, to be broadly reflective of the total numbers of registered vehicles.

6.3 48% of respondents had experience of a vehicle testing centre within the Dublin area and 52% had experience of a centre located elsewhere in the country, with locations including Cork, Donegal, Waterford, Cavan, Kildare, Tipperary and Galway. Vehicle testing centres from throughout the country were included in the sample.

6.4 The majority of organisations involved in the survey operate Heavy Goods Vehicles (63%), with over half of those being in the Large Heavy Goods category (33%) and the remainder being Small Heavy Goods Vehicles (30%). Over half of respondents operate Light Goods Vehicles (52%), while a third (33%) operate Passenger Service Vehicles. Organisations involved tended to operate more than one category of vehicle.

Booking Procedures and Communication 6.5 The vast majority of respondents had booked in for a test before arriving at the test

centre- 96% overall. An analysis of the data shows that a slightly higher proportion of vehicle operators in Dublin turned up for a test without a prior appointment. Incidences of turning up without an appointment were split evenly across the categories of LGVs and PSVs, with no reports of HGVs not being booked prior to visiting the test centre.

Table 4

Booked Test No Booking

Large HGV 100% -

Small HGV 100% -

LGV 94% 6%

PSV 94% 6%

6.6 The vast majority of vehicle operators in our sample who had booked their test in advance had done so by telephone, with a small but significant proportion booking in person at the test centre, particularly in the Dublin area

6.7 Overall, satisfaction with booking procedures was very high, particularly with regard to the simplicity of booking procedures, with 91% of participants either very or quite satisfied.



There were also high satisfaction levels with the information provided on booking procedures.

6.8 However, the length of time it took to get an appointment for a test or a retest had lower satisfaction levels, with some 13% of respondents in the Dublin area very or quite dissatisfied compared to just 7% dissatisfied, for the rest of the country.

6.9 Individual comments relating to this dissatisfaction with the length of time it took to get a booking for a test suggest that owners expect a test appointment to take no more than a day or two, and that centres might operate in the evenings or at weekends.

6.10 In contrast, waiting times on arrival for test appointments was given one of the lowest satisfaction ratings, particularly in the Dublin area. This was perceived to be one of the most important aspects of customer service, with 30% of those surveyed assigning it greatest importance, and two thirds (66%) placing it in the top three most important aspects of customer service.

The Test Report 6.11 Of the vehicles that respondents had last got tested, 86% were first tests and 14% were

retests. Of those who had retested vehicles, 71% required only one retest.

6.12 We asked those respondents whose vehicle had failed its first test, or undergone a retest, whether they thought that the fail was deserved. 87% agreed that it did deserve to fail. And 94% of those whose vehicles failed the first test admitted that they had not serviced the vehicle prior to testing. The main reason given for not servicing the vehicle prior to testing was that the operator was confident it would pass (45%), although a significant proportion (20%) admitted that they wanted to find out what was wrong with it by means of the test itself.

6.13 We asked those who had serviced the vehicle prior to testing where they had gone for this service. The vast majority of those surveyed had had the vehicle tested by their own company (43%) or by a garage which was not the test centre (45%). It is also interesting to note that the pass record for vehicles which had been serviced by the operator themselves or by another garage was much higher than for vehicles which had been serviced by the garage which was the test centre itself.

Table 6

Serviced by own

company

Serviced by Test Centre

Serviced by another garage

Serviced by a Friend/family

Member

Serviced by vehicle

Dealership

PassedFirstTest

89% 67% 92% 67% 100%

Had to be

Retested

11% 33% 8% 33% -

6.14 Respondents were asked to rate their satisfaction with the test report itself. A high proportion (89%) were very or quite satisfied with the test report, but of those who were



dissatisfied and wished to comment, several individuals asked for more clarity in the test report itself. This was viewed as quite important to customers, with 47% of respondents placing a clear and easily comprehensible test report within their top three most important aspects of customer service.

Table 7

Satisfaction Level

TestingElement

Very Satisfied

QuiteSatisfied

Neither Satisfied nor Dissatisfied

QuiteDissatisfied

Very Dissatisfied

Base Number

Test report itself

51% 38% 9% 2% -

Overall Satisfaction with the Current System 6.15 We asked participating vehicle operators whether they thought that the vehicle test centre

represented good value for money.

Table 8

Very Good Quite Good Neither/Nor Quite Poor Very Poor

28% 37% 19% 7% 9%

6.16 Almost two thirds of respondents (65%) felt that the vehicle testing centres were either very or quite good value for money. Of the 16% who thought the centres represented poor value for money, the majority (63%) thought the test was simply priced too high, while the next most common answer was that “they just look for faults” (13%).

6.17 We also asked operators to rank other possible systems of testing in relation to the current arrangements.

Table 9

Preferred System

Preferred Second Choice Third Choice

Garages that also carry out

repairs (Present System)

41% 18% 20%

Independent test 40% 29% 15%



Centres

Independent Test Centres (as

NCT)

17% 29% 28%

Roadside Checks only

1% 17% 23%

6.18 In this case, most respondents’ first choice was to either continue the current system (41%), or to substitute it with a fully independent system of test centres that do not do repairs (40%). When second and third preferences are taken into account, independent test centres scored highest overall. The option of having roadside checks only as a means of enforcement received the lowest ratings

6.19 We also asked participating vehicle operators if the location of the test centre was convenient for them. Clearly, the test centres are suitably located for the majority of clients, with 80% of respondents saying they were very or quite conveniently located. Overall, 11% of respondents said that the location of the test centre was quite or very inconvenient, a figure that was 5% higher for the clients throughout the country than it was within Dublin.

6.20 Overall satisfaction with the service received was very high, with 94% of participants saying they were very or quite satisfied and just 1% saying they were very or quite dissatisfied.

6.21 A detailed version of this customer satisfaction survey can be found in the appendix.

Public Consultations 6.22 As part of the consultation process, three public meetings were held, in Dublin on the 31st

October 2006, Cork on the 1st November and Galway on the 2nd November. At the meetings, stakeholders or any member of the public had the opportunity to raise anything that was of concern or identify any potential changes that they or their representatives would like to see. In addition, interested parties could express their views by letter, email or through a website set up for the purpose. Advertisements, setting out details of the consultation opportunities were placed in the national press.

6.23 A summary of the main points raised (where these were made by more than one or two people) is set out below:

(a) The issue of existing test centres meeting current regulations was raised and in particular existing centres inability to adhere to the drive through regulation. Owners of test centres that comply consider that they are at a disadvantage to those who don’t or who have sought a derogation of this requirement

(b) A number of people suggested that administrative procedures could be improved. In particular, combining the pass statement issued by the authorized test centres with the CRW, issued by the motor tax office, was suggested. There was some resentment of the fact that customers have to go to the motor tax office after receiving a pass statement and pay an additional fee to get a CRW.



(c) The need for further computerisation was highlighted as a means of improving the administrative processes. Some participants suggested that a live and networked system, that would allow authorised test centres to recognise vehicles that had been failed at another test centre at an earlier point in time, was necessary.

(d) A number of concerns were raised at the possibility of moving to a Government operated commercial vehicle testing scheme similar to that operated in UK or equivalent to National Car Testing Scheme (NCTS). The loss of investment that many existing authorised testers have made in equipment, staff and training was cited to be the main reason.

(e) Concerns were raised regarding the impartiality of self auditing in respect of test centres that are owned by the operators of fleets of buses or trucks. Strong views were expressed on the point that fleet operators can conduct their own roadworthiness testing. It was strongly felt that this is not appropriate.

(f) Re-taxing of commercial vehicles for 12 months, on the last day of a valid roadworthiness certificate, was raised. Methods of reducing the incentive not to comply fully with the need for a valid CRW at all times were requested to be considered.

(g) A few participants suggested that vehicles should be tested at intervals of mileage rather than based on time intervals. This would mean that heavily used vehicles would be tested more often than those used only infrequently

(h) The introduction of operators needing to hold service records between tests for commercial vehicles was also suggested by some. It was commented that vehicle maintenance records should be part of the vehicle test.

(i) It was suggested that the Local Authorities, in conjunction with test centres, should have the ability to prohibit vehicles found to be defective, rather than relying solely on the Gardai to lead the enforcement activities. Test centres should be given the authority to identify ‘fail dangerous’ items as with the NCT.

(j) It was suggested that some test centres are undercutting others or not charging for re-tests if a vehicle fails it original test. A fixed test fee was proposed.

(k) The issue of the number of unregistered trailers in Ireland was introduced to the discussion. There was a general view that there were few systems in place at present to ensure compliance.

(l) A number expressed concern that the scope of commercial vehicle testing should be expanded to included agricultural vehicles, particularly those used in the construction industry. There was also some confusion around permitted legal weights on trucks and a suggestion that any vehicle that does over 30 km per hour should have a tachograph fitted.

(m) The issue of whether it should be the authorised test centre or the inspector himself who should be punished, if an error is made with a vehicle test was raised. Some people were concerned that poor inspectors could often take up positions with other authorised testers, leaving problems e.g. suspension etc for the previous test centre to deal with.

(n) The point was raised that 1 year is a long time between tests and that a lot can happen to the roadworthiness of vehicles in this time period. Blame should not be attributed to



the quality of work in the test centre if a crash happens, say 6 months after a roadworthiness test. The suggestion was made that commercial vehicles get tested every twelve to sixteen weeks.

(o) Enforcement was highlighted as the only way that road safety is going to be improved. It was suggested that if someone is found to be operating a vehicle that is not roadworthy they and their fleet should be grounded, like the UK system.

(p) The point was raised that selected test centres are reducing the quality of their test (making it easier) to increase their business. It was suggested that the profiling of vehicle test times could pick up a lot of this malpractice.

(q) It was suggested that ADR vehicle testing and speed limiters which are currently administered by other authorities should come under the scope of the RSA.

(r) The issue of balancing demand and capacity of the system was brought to the attention of the group. It is thought that there is overcapacity in some counties and under-capacity in others, though only one participant expressed difficulty in getting vehicles tested when he wanted.

(s) It was asked that the recommendations of this report are discussed with the Vehicle Testing Committee and the SIMI before anything is taken forward.

Authorised test centre review 6.24 During the course of the review we visited 18 (11%) of the authorised test centres in

different parts of the country. In addition to the findings as set out in Section IV of this report, the following paragraphs describe a number of observations based on evidence gathered through those visits and other stakeholder meetings. While the comments here are illustrative of situations observed, it should be noted that the prevalence of these situations has not been quantified statistically for the network as a whole.

6.25 There is a wide range in the quality of fit-out of test centres around the country. From our observations it is clear that most have begun to address the issue of investing in facilities and equipment to a good minimum standard. However, some have not yet begun to embrace the agreed upgrade proposals.

6.26 It was found that a new authorised test centre meeting the RSAs minimum requirements would cost approximately €1.5 m to build if located on a green field site.

6.27 We observed that most authorised test centres have sufficient capacity to deal with vehicles turning up with short lead times or on an ad-hoc basis. This mode of operation appears to work well and meets the needs of the customers without causing waiting time problems. There were mixed views around the possibility of introducing a central booking system as most authorised test centres felt that they would lose control over their customers and hence, it would detract from their business.

6.28 The ability of most test centres to accommodate vehicles presented for same day testing along with a general lack of activity would suggest that there is over capacity in the vehicle testing system. From the testing figures available we estimate that HGV lanes are, on average, no more than 50% utilised (based on 8 hour day) and LGV lanes around 34% overall.

6.29 Concerns were expressed by some test centre managers regarding the quality and consistency of testing in other places. There were reports of garages testing with



equipment that is faulty or not calibrated. While there can be significant delays between requests for calibration and the completion of the task by the calibration companies, this should not use this as an excuse. Similarly, we were cited situations where, for example, a vehicle could be passed with no reading on the brake test - an anecdotal example was cited where one test centre was issuing pass statements during a four month period when the brake testing equipment was known to be out of order. With a fully automated and integrated system this would not be possible.

6.30 There are concerns over the uniformity of enforcement by LAOs in different counties. Some counties feel that standards are not uniform throughout the country. This is resulting in vehicles that are taxed in some counties going to be tested in other places where the standards are reportedly not as stringent. Again there was anecdotal evidence of owners travelling some distance to specific test centres, perhaps bypassing other test centres on the way, with the conclusion being drawn that the test process may be less rigorous in the chosen location.

6.31 The general consensus from test centre managers is that the current training (and in particular the annual refresher course) is inadequate and needs to be reviewed. The refresher course needs to be based around commonly asked questions and issues as indicated by the RSA and LAOs. In addition, there is no record of attendance or competence kept in relation to the refresher training.

6.32 There is also concern as to the quality of communications through the vehicle testing network at present, particularly in terms of technical input to determining test content and methods. For example, there is a perception from test centre managers that concerns with regard to how to induce a load when testing vehicle brakes and overcoming new technology in braking systems, will impact on the consistency of testing procedures across the country, without improved guidance.

Summary 6.33 Overall the consultation process has served to inform this review by taking into account

the views of testing service providers, customers and other interested parties. These have highlighted a number of strengths, as well as weaknesses, in the current arrangements. These have been taken into account in identifying areas for improvement as set out in Section VIII.



VII Financial Analysis of current model 7.1 Given the distributed nature of the current operational position, the lack of volume

information across the pricing categories for HGVs and the fact that the pricing structure represents a maximum charge only, the current total industry income is not known with certainty. However, we have approximated the total income based on the most recent vehicle testing statistics available, those for year ending 31 December 2004, and this is presented as the current position.

7.2 The table below takes the 2004 volumes for LGV and HGV as published and applies the LGV test fees (€64 first test and €32 re-test, both net of VAT) and an approximated average fee for HGVs (€115 first test and €57.50 re-test, both net of VAT), based on the likely profile across HGV categories and taking account of the high volume in the >7.5kg and 2 axle category. For detail on this average fee calculation, please refer to Appendix 10, Annex 1. HGV categories include trailer / semi-trailer, bus and ambulance.

7.3 It should be noted that of the volume of 120k HGVs as published, 60k are actually LGVs and only fall into the HGV testing category when classified by unladen weight. This method of classification has been changed going forward but it is understood that the full 120k were tested as HGVs in 2004 and therefore would have attracted the HGV fee. To show the impact on income of re-classing these 60k vehicles to LGV, a further two columns have been added, setting out 2004 Adjusted Test Volumes and 2004 Adjusted Income.

7.4 Furthermore, since there have been changes in the past two years on the requirements for all LGVs to be tested annually, the LGV totals in the 2004 volumes understate the total level of LGVs that should be tested, even with the adjustment detailed above. The income that would attach to these volumes is presented in the last two columns of the table below.

RSA current position, adjusted current position and adjusted position going forward –Volumes and Income

Current Position Adjusted Current Position Adjusted Position Going Forward

2004 Test Volumes(‘000s)

2004Income

(€m)

2004Adjusted

TestVolumes

2004Adjusted Income

(€m)

Volumes(‘000s)

Income(€m)

First test LGV (€64) 44 2.8 104 6.7 138 8.8

HGV(€115)

142 16.3 82 9.4 92 10.6

Sub-total 186 19.1 186 16.1 230 19.4

Re-test LGV (€32) 9 0.3 21 0.7 32 1.0

HGV(€57.50)

26 1.5 15 0.9 21 1.2

Sub-total 36 1.8 36 1.6 53 2.2

Total 222 20.9 222 17.7 283 21.6



7.5 The table above shows that the current position and the adjusted position going forward are both in the region of €20m - €22m, with the adjusted current position at €17.7m.

Additional Fees

7.6 In addition to test and re-test fees, certificate fees are also currently collected by motor tax offices. The current rates for these are €6 for LGVs and €13 for HGVs. Across the volume scenarios above, this would give total certificate income of €2.1m for the current position, €1.7m for the adjusted current position and €2.0m for the adjusted position going forward.

Costs 7.7 Given the disaggregated nature of the current operational arrangements, the costs of

individual operators for commercial testing are not available and ultimately it is not possible to conclude upon the cost effectiveness of current arrangements.

7.8 However, in our experience of organisations in this industry, fixed costs and variable costs tend to be split fairly equally. The fixed costs are deemed to represent non labour items and would largely relate to premises and equipment. Assuming that profit is excluded and therefore the income level presents a break even position, fixed costs based on the current position and going forward would be in the region of €9m - €11m per annum. Therefore €9m - €11m would be available each year to service capital and fixed costs across the testing centres.

7.9 We estimate that there are currently approximately 242 lanes at 158 centres across the country. Premises-related and lane-related costs include building and construction costs, refurbishment costs, equipment costs, maintenance, elements of running costs and in some cases leasing / rental costs. The level of funds available from income for premises/ equipment-related costs per annum would therefore equate to some €37k - €45k per lane or €57k – €70k per centre.

7.10 Based on our industry knowledge, this seems low and in terms of complete new-build test centres recent industry experience would indicate a capital investment of €750k per lane would be required. This would mean that the opportunity to replace test centres would be limited within the current financial parameters, in a situation where many of the existing test centres would currently require at least some degree of refurbishment.

7.11 Therefore, while there is not sufficient information available to allowed detailed conclusions regarding cost effectiveness and sustainability of existing centres, there is an indication that current centres are being subsidised and it is by integration within other larger businesses that efficiencies may be obtained. In our view, test operations would be loss-making on a total cost recovery stand alone basis.



VIII Opportunities for Improvement 8.1 In the previous sections of this report we have set out details of the current testing

arrangements and the views of stakeholders in respect of these. This section takes each of the problem areas and proposes changes that could be made to enhance the overall quality of the testing service and thus help improve the overall quality of the commercial fleet. Various elements of these improvement opportunities are incorporated in the wider strategic options in the next section. They are summarised in this section under the following headings:





(e) Enforcement

(f) Operator licensing

(g) ADR management

Test centre operations 8.2 The key to a successful test regime lies in the quality and consistency of the actual testing

process. Commercial vehicle operators and the general public must be satisfied that all necessary steps have been taken to ensure that each vehicle is tested to the required standard, irrespective of the inspector, timing or location of the test.

8.3 Improvement 1. The programme of enhancement of premises and equipment to meet the specified minimum standards should be continued. Each test centre should submit a project plan with interim milestones, in a specified format and agreed with the supervising body. Failure to progress in line with the milestones would be grounds for disciplinary action.

8.4 Improvement 2. The supervising body4 should consider further enhancements in the standards for testing facilities and equipment for the 3-5 year period beyond 2008, for implementation in the period from 2009 onwards. These should take into account developments in braking systems, light test systems and the like. This programme should involve taking into account the views of industry representatives, in an appropriate technical forum.

8.5 Improvement 3. On successful completion of the test, the test centre should be in a position to issue a Certificate of Roadworthiness (CRW) directly, or link to a central system for issuing certificates. A single composite fee would be payable to cover costs and there would be no need for operators to have to obtain a CRW separately.

8.6 Improvement 4. Introduce a system of regular assessment of authorised test persons, through independent observation of them carrying out tests. A central database of

4 The RSA, or the RSA in conjunction with LAs depending on the strategic option chosen



authorised testers should be held and updated with details of continuous assessment details and training course attendance.

8.7 Improvement 5. The quality and curriculum for training courses provided for authorised testing personnel should be reviewed, where possible relating them to actual problems encountered by testing personnel on a daily basis and including training in the latest commercial vehicle technologies. Attendance at refresher courses, which are compulsory, should be monitored and accredited.

8.8 Improvement 6. At present licences for authorised premises are issued for an indeterminate term and may only be revoked through the disciplinary process. We recommend that current licences should be time limited and all new licences issued for a fixed term of, say, 10 years. An appropriate point to introduce this change could be at the point of acceptance that existing test centres have fully complied with the current standards as per improvement 1. Future renewal of licences would take into account a review of prior performance as well as an inspection of facilities.

8.9 Improvement 7. To eliminate the potential conflict of interest, we recommend that no vehicle owner or operator should be permitted to have his vehicles tested in a test centre in which he has a management, financial or other interest.

IT and Management information systems 8.10 Improvement 8. We recommend that an integrated computer system be implemented for

the vehicle testing network. This should be procured centrally by the supervising body and licensed for use by individual test centres. It should incorporate a centralised database integrating all data from individual test centres around the country on a live basis. This would support the proposed central distribution of CRWs and accept test failure details as well as pass/fail information. Pass/ fail information could then be passed to the National Vehicle and Driver File (NVDF) to support roadside enforcement activities as required. This system could be paid for out of the fee currently charged to obtain CRWs on presentation of pass certificates.

8.11 Improvement 9. The supervisory body should use the proposed computer system to carry out statistical analyses on a national level. Comparison of information on each test centre and vehicle type would allow for a breakdown of the most common reasons for test failures. It would also support requirements of EPA, for example, for national statistics on fleet emissions etc. Such analyses could also be carried out for individual test centres and help to focus the attention of operational reviews by the supervisory body.

8.12 Improvement 10. We recommend that computer systems within the test centres should be upgraded to integrate the test lane/pit data collection within the test centre administrative system. Interfaces should be required to link automated test equipment with the system. This system should also incorporate test booking arrangements and preparation of results and failure items for onward transmission to the central database. There are a number of international examples of fully integrated systems covering also the features of Improvement 7 which should be explored. A centralised booking system is not recommended unless it is appropriate to the particular strategic option chosen.

Scope of Testing 8.13 Improvement 11. The scope of the test should be expanded to include currently exempt

vehicles that are similar to commercial vehicles and in use the public roads. The scope of testing is already expanding to include recovery vehicles and fire appliances in 2007. In particular government should consider classifying agricultural vehicles, based on type of



usage and their maximum speed, only to be exempt when operating within, say,10 kilometres of the address at which they are registered, otherwise they should be subject to roadworthiness testing.

8.14 Council Directive 1996/96 (as amended) permitted an increase in the frequency of commercial vehicle testing (i.e. to more than one test per annum), which is one way to help ensure that standards are met more of the time. In our view, such a regime would not significantly improve the overall quality of the fleet, without a significant change in enforcement activities and maintenance practices by operators. Those operators who currently comply would be faced with additional costs, while those that don’t would continue to be non-compliant. With an increase in enforcement activity (see improvement 17) the need for additional periodic testing recedes in any case.

Supervisory arrangements 8.15 In our analysis of strategic models set out later in this report, we have recommended how

best to organise effective supervisory arrangements overall for the testing service. In this section we make recommendations as to how the operation of such supervision could be improved.

8.16 Improvement 12. There is a need to focus the supervision of the Vehicle Testing Network among a smaller number of full-time staff, who are fully qualified and trained in all aspects of the service provided at the test centres. We recommend that a full-time team be appointed and based in regional locations throughout the country, accessible to the number of test centres to be visited. Supervisor staff should have access to the proposed on-line IT system identifying testing schedules, to enable them to schedule their visits more effectively.

8.17 Improvement 13. An operational audit schedule should be developed for use by supervisory staff. This should include a framework for assessment of observed tests and a weighted matrix of other criteria against which facilities, equipment, operational and administrative processes may be assessed consistently.

8.18 Improvement 14. The technical expertise should be enhanced within the aegis of RSA. This technical expertise should be capable of interacting, on an international basis, with other testing authorities at a European level and of understanding and contributing to the development of testing processes in line with developing technologies in vehicles and test equipment. RSA should be in a position to provide national leadership in determining appropriate testing standards, together with related audit and review processes.

8.19 Improvement 15. In conjunction with the technical expertise, RSA should obtain operational planning expertise to define, implement and operate a revised regime of supervision to ensure improved roadworthiness of the commercial fleet. The purpose of this would be to link roadside enforcement activity and reviews of test centres with inspection of operators’ fleet maintenance records, in an integrated regime. This would be targeted at operators of vehicles deemed most likely to offend, while continuing a ‘light-touch’ supervision on those with a good track record of compliance (see improvement 22)

8.20 Improvement 16. Warning and suspension procedures applicable to Authorised Testers are provided for in the “supervision of the vehicle testing scheme” guidelines issued by a Department of the Environment circular in 1985 (the “1985 Guidelines”) (i.e. Circular VF 10/67). We recommend that these guidelines be reviewed. Consideration should be given to introduction of a performance management system, whereby performance points could be accumulated for minor but persistent breaches as well as for major non-conformances e.g. 1 performance point could be issued against an Authorised Tester for a particular



breach and when the Authorised Tester acquires a specified number of performance points, they are suspended for a certain period of time.This would make disciplining authorised test centres more objective as it would be based on a systematic approach rather than personal judgement.

Enforcement 8.21 From this review, it has been clear that a general lack of effective enforcement action has

contributed to the environment of a significant number of commercial vehicle operators being lax in ensuring the roadworthiness of their vehicles. While this does not take away from the responsibilities of operators, it seems unlikely that improvement will happen without further action in this regard.

8.22 Key to success in effective enforcement is to be able to target resources at those operators who are non-compliant, while causing minimum inconvenience to those who comply. There are a number of elements to achieving effective compliance and assurance that the overall regime of ensuring roadworthiness is effective. These are summarised in the following diagram.

Figure 8.1 A model for assuring roadworthiness compliance

8.23 In our view there are 3 strands of activity that, if carried out effectively, will ensure a much higher standard of commercial vehicle roadworthiness. Clearly the first of these is the periodic testing process and the assurance that that process is conducted impartially and



correctly at all times. The elements of this have been discussed separately earlier in this section. However, on its own, this strand at best ensures that vehicles are roadworthy on a single day each year, though clearly there is a knock-on beneficial effect beyond that date. Increasing the frequency of periodic testing to 2 or more times per annum, would have some positive impact, but it would seem to penalise normally compliant operators and those that don’t comply now would have no greater incentive to do so than at present.

8.24 To ensure compliance at other times therefore requires random checks to be carried out, normally targeted at vehicles in use by checks ‘at the roadside’. Again, on its own, this method would require significant resources to check sufficient vehicles so that it acts as a deterrent to non-compliance for the fleet as a whole. In addition, detailed roadside checks are a significant inconvenience to operators trying to meet ever tighter timetables and schedules. The third strand of enforcement activity, relating to the operators, is considered in improvement 23.

8.25 However, as part of a balanced portfolio of interventions, roadside checking with appropriate sanctions for non-compliance is very effective. To minimise the inconvenience to compliant operators, we recommend the following.

8.26 Improvement 17. The Garda Síochána, who we understand are recruiting additional resources to deal with traffic issues generally, should develop a programme of roadside checks in conjunction with the supervising body to ensure that there is sufficient expertise available to deal with technical issues (i.e. visual technical inspections on the roadside or, in certain circumstances at a local test centre) in a reasonable proportion of their activity. This would link with checks on tachographs, loading and administrative issues such as valid CRW, operator’s licence, driver’s licence, tax and insurance cover. It is important that key systems such as brakes and steering are capable of being checked

8.27 Improvement 18. To make roadside enforcement easier, we recommend that Gardai be given access to the central database of vehicles with valid CRW, either through NVDF or directly to the centralised management information system. In most cases, this would eliminate the need to follow up with drivers or operators who cannot present relevant paperwork at the roadside.

8.28 Improvement 19. As a further level of sophistication we recommend that investment in vehicle number plate recognition systems be investigated. Such systems can be used, for example on motorways or arterial routes in particular, to identify vehicles, check the database for compliance details and relay the information to a Garda checkpoint further along the route. In this way, activity can be focused on those vehicles most likely to be non-compliant. Such systems have been piloted elsewhere with VOSA in England claiming the ratio of prosecutions to the number of vehicles stopped to have increased considerably as a result. Such systems can also be integrated with ‘weigh in motion’ systems that would detect overweight vehicles in similar circumstances.

8.29 Improvement 20. To help deal with the problem of non-compliant vehicles, we recommend that a secure printed disc (similar to NCT) should be displayed on all commercial vehicles, including trailers. This would provide a ready visual check for Gardai, particularly for trailers. Care will have to be taken to minimise the risk of fraudulent transfer of discs between vehicles, by including appropriate chassis details on the disc.

8.30 Improvement 21. Overall compliance would be made easier to manage if vehicles were eligible for testing on the anniversary of their first registration date, rather than on the anniversary of the date of testing. It would also remove the incentive to ‘slip’ test dates and eliminate the anomaly of being able to tax a vehicle near the end of the period of



validity of its CRW. We recommend that such a change be implemented for all new vehicles and phased in over, say, a 3-4 year period for existing vehicles.

8.31 Improvement 22. At present the penalties for offences relating to the roadworthiness of vehicles seem to fall mainly on the driver of the vehicle. The move towards fixed charge penalties, penalty points and on-the spot fines could tend to increase this. We recommend that, with the improved information available future legislation should also focus on applying sanctions to the operator.

Operator maintenance records 8.32 Improvement 23. The third strand of enforcement action that we recommend is focused

on assurance that measures are in place to maintain vehicles in a roadworthy condition at all times. To do this we recommend that, as part of the operator’s licence renewal process, there should be an obligation on the operator to maintain the vehicle in good condition and also to keep records of inspection and maintenance for review by the supervising body at any time. The programme of on-site inspection should be developed to target mainly those operators whose vehicles regularly fail during roadside or periodic inspections.

8.33 Improvement 24. A commonly held view among stakeholders interviewed is that all operators of commercial vehicles should be licensed, irrespective of whether they are used for ‘own account’ or ‘hire and reward’ activities. This is consistent with the view that all vehicles on the road should undergo regular testing. We recommend that such action be considered. Should it be inappropriate to extend the application of operator licences, we recommend that issuing a CRW should include the condition that the vehicle be maintained in a roadworthy condition and that its maintenance records are subject to inspection by the supervising body.

ADR 8.34 Improvement 25. The opportunity now exists to bring all commercial testing functions

under the control of one central body. It would be consistent to bring the ADR testing arrangements (vehicles used for the transport of dangerous goods) under the control of the same body.

Summary

8.35 In this section we have set out recommendations for improvement that must be addressed within the preferred strategic operating model. Details of the preferred model are set out in the following section.



IX Operational model options 9.1 We have considered a number of strategic options for the future delivery of the testing

service, as set out in the following paragraphs.

Option 1 – No change 9.2 Under this option the current arrangements would remain. This option was used as a

baseline for comparison with other options. Details of the current arrangements are set out in section IV.

Option 2 - Improve the Current Arrangements

9.3 This option is based on improving the performance levels of the current system. The supervisory structure currently in place would remain unchanged but greater emphasis on the quality of testing, enforcement and management information systems would lead to improved performance in testing and information produced. This option would require an increase in the number of full time employees to carry out operational audits and quality reviews of test centres, assisting Gardai and administrative duties.

9.4 Governance would remain split between the RSA and Local Authorities but with more clearly defined roles and responsibilities. This would result in more consistent application of disciplinary measures.

9.5 It is estimated that for a sufficient level of supervision to improve testing quality to an acceptable standard, Around 15 full-time LAOs would be required, each with sufficient technical and administrative ability to review test processes as well as paperwork and administrative processes. This would enable the current 158 test centres to be visited for a day each month giving time to observe the work of vehicle testers and still leave 50% of the officers’ time available to provide input to spot checks, enforcement activities and other tasks. (Other duties listed in appendix 8).

9.6 We estimate that approximately 4 full time RSA inspectors would be required to deal with technical standards issues and conduct independent checks. This would enable them to perform at least one independent check per quarter at each test centre. Independent inspections would account for approximately 70% of their time. A senior engineer to lead the team and the development of standards in relation to international best practice would also be required.

9.7 There would be a significant increase in enforcement activity, requiring LAOs and RSA inspectors to assist the Gardai with roadside checks. LAOs would also be required to work across larger regions than at present.

9.8 A further quality assurance benefit would be achieved through delivering improvements in the training programme, ensuring that accreditation as a tester required mandatory attendance on annual courses and regular assessment of skills and knowledge to a minimum standard.

9.9 The introduction of RSA inspectors and the transition to dedicated full-time LAOs should enable communications between these bodies to be greatly improved.

9.10 With respect to ICT the following enhancements would be required:



(a) RSA would update the specification of the standard data set which must be recorded and reported for each test conducted;

(b) The software used by each of the Test Centres would be required to record this standard data set and report it back to RSA in an agreed format;

(c) Each Test Centre would be required to install a broadband link so that the results could be automatically reported by the local test systems on a daily basis

(d) The RSA would create and maintain a central database. This would accept test results and allow the RSA to manage and report on this data in order to facilitate improved quality assurance and enforcement activities.

9.11 With respect to quality improvement and assurance, an early improvement would be delivered through setting up a dedicated quality assessment team tasked with assuring the capability and quality of test facilities and staff against an agreed set of minimum standards.

9.12 No legislative changes would be required for this option, either to change the frequency or content of the supervisory activity, or to improve the level of roadside enforcement

Option 3 - Integrated network of independent private sector test providers with greater automation.

9.13 This option includes all recommendations made in option 2.

9.14 Under this option the central administration and running of the commercial vehicle testing scheme would remain as it is at present. i.e. under the control of local authorities and the RSA. The network of independent private sector operators would be more closely aligned using a national IT and MIS system. The national MIS system would create a central commercial vehicle test database. Real time ‘live’ information on commercial vehicle testing records would also be available ‘on the spot’ to support enforcement, when performing roadside checks. This option would see the centralised issue of roadworthiness certificates and the introduction of CRW discs on all vehicles.

9.15 In addition, the IT system should provide full test lane management facilities. This would include online or hand-held terminal facilities to vehicle testers while on the test lane and would interface with the automated parts of the process such as brakes, emission and light-beam testers etc. In this way the test content, standards and tolerances could be managed centrally and would reduce considerably the opportunity for local interpretation of standards and data transcription errors. It would also eliminate the possibility of failing to record the results of any part of the test.

9.16 Under this option, there would be a change to issuing discs and test certificates centrally. Using the results received by the central system from authorised test centres, road worthiness certificates (CRWs) and discs would be produced centrally and posted to the owners of the vehicles. This would help to ensure control of CRWs and reduce the risk of theft, counterfeit and fraudulent use. The authorised test centres would be responsible for collection of the roadworthiness certificate fee as part of the test fee. This would then be remitted centrally to RSA to fund payment for the IT systems. Additional benefits could include:

(a) The requirement for customers to visit the motor tax office to purchase the CRW would be removed. This would reduce the administrative burden on both customers and local authorities.



(b) Notifications could be sent to operators informing them that their vehicle is due for testing.

(c) The responsibility would be on vehicle owners to keep their registration details up to date to enable them to receive their CRWs.

9.17 The introduction of roadworthiness discs both on the windscreens of trucks and on trailers (similar to the National Car Testing Scheme) would act both as a deterrent to non-compliance and a quick visual aid to Gardai when performing roadside checks. The National MIS system would create a central database available to update NVDF. The data collected could further improve the effectiveness of roadside enforcement activities. Real time ‘live’ information on commercial vehicle testing records would also enable ‘on the spot’ enforcement actions – relating to the operator as well as the driver - when performing roadside checks.

9.18 To assure maximum benefit from this enhancement, the Gardai would need to:

(a) Continue their development and training of their traffic corps;

(b) Increase the number of roadside checks being performed. The RSA quality assurance inspectors should have sufficient capacity in their job function to assist in conducting a much greater number of checks. This would act as a deterrent to vehicle operators and achieve the objective of improving safety compliance.

9.19 With respect to ICT the following enhancements would be required:

(a) The RSA would need to update the specification of the standard data set which must be recorded and reported for each test conducted;

(b) A single software solution would be used across all test centres (managed and supported by a single systems supplier), with bookings made using NVDF data available from the central system to populate as much of the booking record as possible5, but allowing changes to be made locally and then fed electronically back up with test results, in the new standard format, to the central system;

(c) The lane management system would also be updated and fully integrated with the central system, allowing test lane equipment to automatically interface with the central system and record the date, time, relevant metric and pass/fail result of that particular element of the vehicle test6;

(d) The test lane equipment would be required to meet minimum standard interface specifications set by the RSA and also to evaluate and output results within specified tolerances;

(e) Test staff would be provided with handheld computer devices where necessary to assist them record results and the option of capturing and storing photographic evidence to assist quality assurance, reporting and enforcement activities could also be accounted for;

5 A central booking function is not anticipated. 6 This helps to ensure that minimum standards are adhered to, ensures that all re-tests are recorded and limits the opportunity for tests to be conducted in the absence of appropriately qualified staff and/or for results to be incorrectly entered into the system.



(f) The central system would hold details of the test lanes available at each of the Test Centres as well as the staff available, ensuring that resources could not be over-subscribed;

(g) The software used by the Test Centres would be required to authenticate users (possibly using biometrics to increase assurance and reduce difficulties around lost passwords) and only allow authorised testers to conduct tests;

(h) The central system would maintain an audit trail of who conducted the test and any changes to the results that had been made. Manual changes to test results outside of the system must not be possible, without proper authorisation and audit trail;

(i) Each test centre would be required to install a broadband or other type of network link so that the booking and results data could be automatically reported in real time between the central system and local test centres;

(j) The RSA would create and maintain a central commercial vehicle test database comprising data on accredited test centres and vehicle testers, the NVDF and test results;

(k) This database would:

(i) Automatically populate booking data;

(ii) Accept local test results in the agreed standard format;

(iii) Manage any update in vehicle and owner data between the local test centres, RSA and NVDF; and

(iv) Allow the RSA to manage and report on this data in order to facilitate improved quality assurance and enforcement activities; and

(v) Using the results received by the central system, road worthiness certificates and disks would be automatically produced centrally and posted to the owners of the vehicle7.

9.20 Should the integration of test lane management to the central system prove to be more complex or costly than envisaged, this could be phased in over time, with the booking elements of the ICT system being delivered earlier allowing the benefits of this infrastructure to be achieved as quickly as possible.

9.21 While various procurement options may be considered, it is likely that the preferred method for procurement of such a system would be to procure a ‘turnkey’ solution using a third party provider who could be remunerated on a ‘per test’ basis and who would be responsible for implementation, operation and maintenance of the system in the test centre. This would eliminate the need for capital investment by the garages or by government. Other development options should also be considered.

9.22 With respect to the issuing of certificates of roadworthiness by the RSA, an amending statutory instrument would be required to change the definition of "Issuing Authority" to mean the “RSA” (assuming RSA adopts this central issuing role). The format of the

7 Central production of these will help to ensure control of security paper; reduce risk of theft, counterfeit and fraudulent use; and promote economies of scale.



certificate of roadworthiness currently provided for in Schedule 4 of the 2004 Regulations may also need to be amended if this format is not what is intended going forward.

9.23 In relation firstly to the issue of increasing the fee charged by Authorised Test Centres for commercial vehicle testing, it is the Minister who is responsible for same. The Minister regulates the fees charged by way of regulations enacted for the purpose of giving effect to CD 1996/96 as amended. The Minister is also empowered under Section 18 (10) (g) of the Road Traffic Act 1961 to make regulations in relation to fees to be paid by applicants for test certificates and the disposition of such fees.

9.24 Subject to the Minister increasing the test fee, the RSA may pursuant to Section 32 (1) of the 2006 Act make such charges as it considers necessary and appropriate in consideration of (inter alia) the performance by it of its functions. This charge by the RSA is however subject to obtaining the consent of the Minister for Transport.

9.25 The requirement to display a roadworthiness disc on the front windscreen of a vehicle or the back of a trailer may be achieved by amending statutory instrument.

Option 4 – Centralised supervision of the integrated network.

9.26 This option assumes the operational and legal changes included in Option 3.

9.27 Under this option the operational monitoring and technical enforcement responsibilities would transfer entirely to a single authority. Using this model, procedures would be streamlined and communication channels would be clearer with greater accountability and there would be less potential for differences in interpretation.

9.28 The inspection roles that are presently intended to be fulfilled by the RSA and the LAOs would be amalgamated into one function under a single management structure. It is estimated that up to15 full time independent inspectors would be required to monitor the quality of testing, a staff complement of 2-3 staff less than options 2 and 3 to achieve a similar level of supervision. Within this option, it would be beneficial for the supervisory technical team to be based in a small number of regional centres, to give better access to test centres throughout the country. This would maintain a sense of being part of a team rather than working as a series of individuals.

9.29 In our view, based on current structures, the body best placed to undertake this centralised supervisory role would be the RSA, since it has a clear road safety remit and already provides a supervisory role for car testing. Under this option the RSA would expand its role to include the powers currently vested in the LAs.

9.30 The key legislative change for this option would involve changing the powers currently delegated to the LAs to the RSA by means of an amending statutory instrument.

Option 5 - Rationalisation of Current Test Centres with central supervision

9.31 In terms of supervisory, enforcement and other changes, this option assumes all of the changes incorporated in Option 4 will be included in this option.

9.32 Under this option, the number of authorised test centres would be significantly reduced. Based on current volumes tested, the available statistics suggest that the majority of test centres are significantly under-utilised by at least 50% of their full potential. This would



suggest that the number of authorised test centres could be reduced to, say, around 80 (50% of the current 158) without significant loss of amenity to customers.

9.33 This would mean that every authorised test centre would be better utilised, thus providing the following advantages:

(a) Greater efficiency through increased volumes per test centre

(b) Application of higher standards to the remaining network of test centres, with a greater incentive for those garages that are licensed, to perform to a consistently high standard. Ensuring a consistent quality of testing, generally, would be achieved more readily with the reduced number of participants;

(c) Reduced level of supervisory resources required, since there would fewer test centres to be reviewed on a regular basis. Also throughput volumes through each centre would be greater, thus making statistical analysis of the results more meaningful making problems easier to spot.

9.34 In order to implement this option a bidding process would need to be run against a set of assessment criteria based on technical capability, quality, financial status and experience. A license would then be given to the successful bidders for a fixed time period (8 to 10 years, for example).

9.35 A feature of this option would be that a large number of existing test centres would no longer be used for the purpose. Consideration of those operators who have recently made investments in upgrading their facilities would necessitate a reasonable transition period.

9.36 This option would have no specific implications for enforcement or for IT functionality, compared with the previous options.

Option 6 – A single operator with central supervision.

9.37 This model would be similar to the NCTS model for car testing. A competition would be run for the operation of the commercial vehicle testing scheme as a whole. The number of test centres proposed would be at the discretion of the contractor, provided that agreed minimum access standards are achieved. Based on previous NCT experience, which requires 90% of the population to be within 30 miles of an authorised test centre, this could result in around 30-40 test centres, with multi-lane centres in areas of greatest demand. The contractor would be required to operate to specified performance standards and have uniform test facilities in all locations.

9.38 The authorised testing centres would only be used for vehicle testing and the operator would not be permitted to engage in any other business that could give rise to a conflict of interest e.g. the sale or repair of commercial vehicles or their parts.

9.39 A significant feature of this option would be that the services of the current network of test centres would have to be discontinued, although it would be possible for a consortium of current providers to bid to provide the service. This may give rise to potential claims for compensation from those who have invested in provision of the current test lanes, particularly where this has been on foot of recent requests to upgrade facilities. In addition, the legal position for discontinuing current licences is not clear since these are, in effect, open-ended at present, except where there is a failure on the part of the individual test centre to provide a satisfactory service.



9.40 In terms of supervision, we have assumed that the number of vehicle test inspectors would be less under this option since it would be less time-consuming to provide a regular review presence in all test locations.

9.41 The single independent operator would be responsible for delivering test results in line with specified service level agreements. The systems operated would be the responsibility of the contractor, who would also be expected to provide the necessary access to the full range of management information required, to the RSA.

9.42 A strong emphasis would be placed on achieving consistent quality throughout the network, using common equipment, with customer satisfaction and operational audits of the testing operation being important performance measures.

Option 7 - Government Agency Operations

9.43 This option would be similar to option 6 with the RSA assumed to take the role of the operator of the testing service. This is similar to the VOSA model in UK (an arrangement that is currently under review) and the DoE model in Northern Ireland.

9.44 This option would involve RSA setting up and running a fully independent test centre infrastructure in 30-40 locations around the country. This would require construction of special-purpose centres, procuring the necessary test equipment and IT systems and recruiting and training an estimated 300+ staff to run the service.



X Evaluation of Strategic Options

Methodology 10.1 Below is a tabular evaluation of the 7 strategic options considered for the operation and

supervision of the commercial vehicle testing scheme.

10.2 Five key assessment criteria were used to evaluate the different strategic options. Each was given an importance weighting out of 100. Each of the options was scored out of 10 against the assessment criteria. This score was then multiplied by the relevant weighting to provide an overall ranking of the options. The total score inclusive of the weighting for each option is shown in the table below.

Table 10

1 2 3 4 5 6 7

Quality and Consistency of test 25 2 4 6 7 8 9 9Enforcement 25 0 2 5 8 8 8 8Improvement of Management Information 20 0 2 6 7 7 8 8Impact on Test centres 15 10 9 7 6 4 2 1Ease of Implementation 15 10 7 6 7 2 4 5Total 100 22 24 30 35 29 31 31

Total with weighting 100 35 43 59 71 63 67.5 67.5

WeightingAssessment Criteria

Options

Rationalisation of current test

centres

Independent Operator (s)

Government Agency

OperationsAS IS

Improve current

arrangements

Integrated network of


greater automation

RSA management of Integrated network of


greater automation

10.3 The ranges of each of the assessment criteria are given in the figure 4 (below). A detailed description of the characteristics and behaviours relating to the scoring of each criterion are given in the next section, along with the development of each criterion for all of the options.



Figure 4

High

Low

High

Low

High

Low

High

Low

High

Low

Impa

ct o

n te

st c

entre

s

Investment required by authorised test centres to improve IT systems and test lane automation. Test centres not permitted to participate in any other commercial activity. Rationalisation of the number of authorised test centres.

Small investment required by authorised test centres in IT.

Qua

lity

and

Con

sist

ency

of T

est

Clear and effective but manual business processes and procedures. Manual inputting of test results. Part time LAO's carrying out authorised test centre inspections. Mandatory annual assessment of authorised testing personnel. Audit trail of test results and manual changes made.

Significant investment required by authorised test centres in IT infrastructure and test equipment. Major reduction in the number of test centres or operators.

Defined roles and responsibilities. Introduction of consistent disciplinary procedures for non-adherent test centres. Continuous and accredited training for all authorised testing personnel. Increased in the number of operational audits. Furtherautomation of the testing procedure reducing the potential for operator error. Authentication (biometric) of authorised testingpersonnel before conducting test.

Lane management system integrated with central IT enabling fully automated testing eliminating the potential for human error. Dedicated quality assessment team carrying out independent audits. Single supplier of test equipment, that is required to meet minimum specified tolerances.

Enfo

rcem

ent

Regular joint task forces between single governing authority and Gardia to perform roadside checks. Live reliable information on commercial vehicles and owners allowing Gardai to take 'on the spot' action during roadside checks.

Increase in the number of roadside checks being performed on a monthly basis. LAO's and RSA inspectors assisting Gardai with roadside checks. Improved information to assist Gardai with roadside checks. Introduction of roadworthiness discs on trucks and trailers. Gardia trained by RSA to perform visual roadside checks.

Continuation of current training and development of traffic corps with greater involvement of LAO's at roadside checks. Improved communication between Local Councils, RSA and Gardai.

Impr

ovem

ent o

f m

anag

emen

t inf

orm

atio

n

Single software solution across all test centres managed by a single systems supplier. Test results updated on a live basis. Reliable information available to external sources.

Nationally integrated IT and MIS system. Central commercial vehicle database with a live link to the NVDF. Ability to make bookings centrally or locally.

Central commercial vehicles database. Test results updated daily. Standard data set for each test recorded.

Ease

of I

mpl

emen

tatio

n

Long-term transition period. Shift in governance of the commercial vehicle testing scheme. Changes in legislation required.

Change in management structure. Expansion of the scope of the test. Fundamental changes to testing and administration procedures. Significant increase in FTE's.

Implemented relatively quick. Simple changes to administration of the scheme. Changes in roles and responsibilities

Quality and Consistency 10.4 This criterion scored low if data input and recording of test results are heavily reliant on

manual input. The current situation received the lowest score, because the testing process relies heavily on the tester’s ability to record manually the test results, based on personal judgement and experience. At the end of the test or end of day, results have to be manually entered into a spreadsheet and e-mailed to the RSA in Dublin. This option also scores low since there is no specified layout for test centres or sequence of testing, leaving a risk of omission of certain items that would be difficult to monitor.



10.5 A high score for consistency was awarded to the options which reduced the number of locations and provided maximum standardisation of test equipment, layout and staff training. In addition, options that included vehicle test inspectors who are trained to a common standard, with effective communications between the parties involved scored higher.

10.6 Options 6 and 7 scored best for the quality and consistency of testing, as these options would operate using fewer test centres where it would be easier to apply a common set of standards. In addition they have a single management structure for both operator and supervising body which would contribute to effective application of those standards.

10.7 Option 2 would include the introduction of improved business processes, and better training, that would result in an improved quality of test. Development of the IT systems and appointment of additional staff would enable test centres to be more effectively monitored.

10.8 Option 3 would see further automation of the test process reducing the potential for human error in recording results. This, combined with an increase in the number of random operational audits would further advance the quality of testing.

10.9 Option 4 establishes the supervision of the commercial vehicle testing scheme under one body, the RSA. This would improve lines of communication and enable disciplinary procedures to be implemented consistently across the country. Inspection roles would be consolidated into full time positions under the management of the RSA. This would allow them to become highly specialised and consistent in their approach to reviewing test centres. Option 5 would see the same improvement with a reduced number of authorised test centres thus making it easier to regulate.

Enforcement 10.10 Enforcement is a requirement under EC Directive 2000/30 and is essential to maintain

high quality standards for vehicles on the roads. The current situation scores zero which reflects the fact that enforcement activity by Gardai and RSA officers been virtually non-existent in recent years. In addition, there is a lack of information available to officers to help assess compliance of vehicles when stopped. A high score against this criterion would require regular visible roadside checking of vehicles to occur with quantifiable results available on convictions and reasons for convictions. Positive aspects of good enforcement processes also include ease of enforcement for the Gardai –for example, access to good compliance information and information to help target the most likely offenders.

10.11 Options 4, 5, 6 and 7 all scored the same under the enforcement criterion. All of these options reflect sufficient ICT improvements to ensure that the information being provided to the Gardai is up-to-date and of a reliable standard. All of these options would see increased use of joint task forces between the RSA vehicle test inspectors and the Gardai for enforcement activities. The information provided would allow for on-the-spot action during roadside checks.

10.12 Option 3 was scored higher than 1 and 2, reflecting the introduction of CRW windscreen discs and investment in IT systems to provide much better centralised information, linked to NVDF. The difference between option 3 and option 4 is based on an assumption of the likely difference in the quality of test details and management information available to the enforcement teams.



Improvement of management Information 10.13 Improvement of Management Information is closely linked to the enforcement and

consistency criteria. A high score in this category indicates that an advanced IT system is assumed to manage information across the network. Ideally this would be done using a single software solution across all test centres requiring live updating of information through a fully automated lane management system. This links to the enforcement criterion by enabling the Gardai to have access to ‘live’ information for roadside checks. A centralised database would allow test centre bookings and utilisation to be monitored by the RSA and would provide reliable information on test statistics.

10.14 In option 2 the introduction of a standard data set collated by the RSA would enable more efficient reporting on a national basis. The introduction of a central database automatically updated on a live basis with test results in option 3 would ensure much more accurate and consistent information. Option 4 would give full control of this database to the RSA further reducing opportunity for error and a simplification of data distribution. Option 5 has been given a slightly higher score, to reflect the reduced size of the network and associated reduction in complexity.

10.15 Options 6 and 7 were given higher scores for this criterion because, it is assumed that the operator would use standard IT infrastructure and software throughout the network, thus providing efficiencies and further improving the consistency of information. As the service provider they would be responsible for delivering the required test information to specified standards.

Impact on Test centres 10.16 Impact on Test Centres reflects the level of change which the current network of test

centres will have to undergo to implement each of the options. A high score indicates that there will be little change to current operational activities, while a low score reflects a much higher level of change involved, or closure of some or all of the current test centres.

10.17 Option 1 has no impact on tests centres, thus, it has it has been given the maximum score for this criterion.

10.18 Option 2 requires continued upgrade of some test centres and some time improving business processes. In options 3 and 4 test centres would be expected to embrace fully the new IT systems anticipated, and to be subject to greater scrutiny than is the case at present.

10.19 The lower scores for options 5, 6 and 7 are due to the significant reduction in the number of current test centres assumed under these options. Options 6 and 7 would see the operation of the scheme by a single operator with the network of existing test centres ceasing test operations, except where a group of existing test centres was successful in winning the tender to provide the service as a consortium.

Ease of Implementation 10.20 Ease of implementation reflects the complexity of the likely programme of change and, as

appropriate, any resistance likely to be encountered from stakeholders during implementation. A high score would indicate that, in our view, an option is likely to receive general support from stakeholders and a low score indicates that the option is complex to implement or likely to be strongly resisted.

10.21 Option 1 is clearly the easiest option to implement as nothing would change and the commercial vehicle testing scheme would continue to be administered as it is today. Thus, this option received a maximum score for ease of implementation. Option 2 could be



implemented relatively quickly with straightforward changes to the administration of the scheme and some modifications to roles and responsibilities. The IT development associated with this option should also be realised fairly readily.

10.22 Options 3 and 4 would see the further development of the IT systems as well as the opportunities for improvement. We have assumed that such changes would be more straightforward to implement if the scheme was solely under the control of the RSA.

10.23 Option 5 was considered to be the most difficult to implement as the RSA would be responsible for rationalising the number of test centres over a relatively short time period. This would involve revoking the licenses for some, while ensuring that the remaining network improved both their throughput and quality. At the same time significant effort would have to be put into development of effective IT systems and the other changes set out in Section IX. Although a consistent approach would be applied, it is likely that there would be a significant reaction and criticism from the industry, particularly by those authorised test centres that had invested significant sums of money in their premises.

10.24 Options 6 and 7 require major change in the model for running the commercial vehicle testing scheme. Option 6 would see the RSA run a tender for the operation the scheme. Once the contract has been put in place the RSAs role will be to monitor the contractor and their ability to operate to the Service Level Agreement’s specified in the contract. In option 7 the RSAs function will be easier as the contractor will be a public sector body, though setting up an operation from scratch in 30-40 locations and providing sufficient staff to run it effectively would be difficult. The score given to these two options reflect this.

Financial Assessment

10.25 Each of the options within this Review has been considered from a financial perspective. Due to recent changes in testing and inadequacies in the IT systems, the future volume of tests is not known with any degree of certainty. Given the distributed nature of the current operations, the total income from testing is also unknown and the costs that individual operators incur in testing are not available. Taking account of these constraints, it is not possible to conclude accurately on the financial efficiency or value for money of the existing testing situation. However, as set out in Section VII we consider that the current situation is not cost effective on a full cost recovery basis

10.26 Therefore given the level of uncertainty regarding the financial parameters for commercial testing, the financial consequences of each option have been represented in a Financial Impact Statement. This statement considers testing and levy income as well as the key categories of costs. The statement considers the financial implications for the RSA and attributes an impact rating in the range of Low, Medium and High to each option, as referenced to the current position or As Is position. It also sets out the impact on the other key parties involved, namely Test Centre Operators, Local Authorities, the Department of Transport and the customers in order to position each option in a more holistic context. In each case, a brief description is included by cost or income type setting out the key features for that option.

10.27 The full Impact Statement is included in Appendix 10 and a summary is contained in the following pages. This shows that the financial impact for the RSA of each option against the As Is position increases incrementally between Options 2 and 7. However, the impact for Option 7 does not only represent higher costs, but also the fact that in this scenario, the RSA also receives the testing income.

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at t

he lo

cal t

ax o

ffice

s to

repr

esen

t a “l

evy”

for t

he R

SA

to re

-cou

p in

vest

men

t cos

ts.

Cur

rent

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

Cur

rent

fee

Wei

ghte

d av

erag

e €8

4 +

€5 -€

8 pe

r tes

t +

€10

-€15

per

test

+

€10

-€15

per

test

+

€6 -€

10 p

er te

st

€85-

€87

Cer

tific

ate

fee

Wei

ghte

d av

erag

e €9

Tota

lW

eigh

ted

aver

age

€93

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

74

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

Impr

ove

the

Cur

rent

A

rran

gem

ents

In

tegr

ated

Net

wor

k of

Inde

pend

ent

Priv

ate

Sect

or

Prov

ider

s w

ith

Gre

ater

Aut

omat

ion

RSA

Man

agem

ent

of In

tegr

ated

N

etw

ork

of

Inde

pend

ent

Priv

ate

Sect

or

Prov

ider

s w

ith

Gre

ater

A

utom

atio

n

Rat

iona

lisat

ion

of

Cur

rent

Tes

t C

entr

es

Inde

pend

ent

Ope

rato

r (s)

G

over

nmen

t A

genc

y O

pera

tions

RSA

Cos

ts

ICT

inve

stm

ent

(upf

ront

and

ong

oing

) In

vest

men

t in

and

mai

nten

ance

of

man

agem

ent

info

rmat

ion

syst

em

Opt

ion

2 pl

us c

osts

of

incr

ease

d IT

fu

nctio

nalit

y.

As

for O

ptio

n 3

As

for O

ptio

n 3.

A

s fo

r Opt

ion

3 O

ptio

n 3

plus

all

of th

e te

st c

entre

/ c

ompa

ny IC

T in

vest

men

t in

Opt

ion

6.

Inve

stm

ent i

n pr

emis

es a

nd te

stin

g eq

uipm

ent (

upfro

nt

and

ongo

ing)

No

finan

cial

impa

ct

iden

tifie

dN

o fin

anci

al im

pact

id

entif

ied

for R

SA

. A

s fo

r Opt

ion

3 A

s fo

r Opt

ion

3 A

s fo

r Opt

ion

3 O

ptio

n 6

for t

he

oper

ator

s no

w

RS

A c

ost.

Reg

ulat

ion

/ G

over

nanc

e N

o fin

anci

al im

pact

id

entif

ied

No

finan

cial

impa

ct

iden

tifie

dC

osts

of d

edic

ated

co

ntra

ctm

anag

emen

t tea

m.

As

for O

ptio

n 4

but

few

er te

st c

entre

s an

d op

erat

ors.

Plu

s co

sts

of a

war

ding

co

ntra

ct a

nd

issu

ing

licen

ces

All

regu

latio

n an

d go

vern

ance

by

RS

A

but m

onito

ring

2-3

com

pani

es. S

till

requ

ires

dedi

cate

d te

am. P

lus

cost

s of

te

nder

ing

proc

ess.

Sel

f-gov

erni

ng,

ther

efor

e co

st

wou

ld li

kely

be

clas

sifie

d as

a

man

agem

ent a

nd

adm

inis

trativ

e co

st.

Qua

lity

Test

ing

and

Enf

orce

men

t 1

addi

tiona

l ins

pect

or

from

cur

rent

pos

ition

. A

s fo

r Opt

ion

2 Fr

om A

s Is

, ad

ditio

nal 1

2 F/

T in

spec

tors

. Fr

om O

ptio

ns 2

an

d 3,

add

ition

al 1

1 in

spec

tors

but

No

chan

ge fr

om

Opt

ion

4 gi

ven

that

th

ere

wou

ld b

e th

e sa

me

volu

mes

of

test

s.

As

per O

ptio

n 5

All

test

ing

in-

hous

e bu

t nee

d in

tern

al q

ualit

y re

view

. Gar

dai o

r lo

cal a

utho

rity

enfo

rcem

ent.

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

75

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

repl

acin

g 15

LA

Os.

Trai

ning

Tr

aini

ng re

quire

d in

en

forc

emen

t and

te

stin

g an

d im

plem

enta

tion

of

accr

edita

tion

prog

ram

me.

As

for O

ptio

n 2

As

for O

ptio

ns 2

an

d 3

but t

o gr

eate

r ex

tent

as

all

enfo

rcem

ent a

nd

insp

ectio

n ac

tiviti

es

in-h

ouse

.

As

for O

ptio

n 4

with

po

tent

ial r

educ

tion

as n

umbe

r of

oper

ator

s re

quiri

ng

train

ing

wou

ld b

e lo

wer

.

As

for O

ptio

n 4

with

po

tent

ial r

educ

tion

as

num

ber o

f ope

rato

rs

requ

iring

ann

ual o

r ot

her t

rain

ing

wou

ld

be lo

wer

.

Add

ition

altra

inin

g co

sts

for

test

ers

but

train

ing

cost

s fo

r en

forc

emen

ts

elim

inat

ed.

Oth

er o

pera

ting

cost

s H

ighe

r adm

inis

trativ

e co

sts

As

for O

ptio

n 2,

plu

s co

sts

of p

rodu

ctio

n an

d is

sue

of d

iscs

an

d te

st c

ertif

icat

es,

and

cost

s of

issu

ing

notif

icat

ions

.

As

for O

ptio

n 3

As

for O

ptio

ns 3

an

d 4

As

for O

ptio

ns 3

and

4

As

for O

ptio

ns 3

an

d 4

plus

test

er

recr

uitm

ent c

osts

an

d m

ore

adm

inis

tratio

n co

sts.

R

SA In

com

e

Le

vyN

o im

pact

Le

vy m

ight

be

soug

ht to

re-c

oup

addi

tiona

l RSA

in

vest

men

t req

uire

d an

d if

any

volu

me

impa

ct th

is w

ould

ha

ve fo

llow

on

impa

ct fo

r lev

y in

com

e. C

ould

re

plac

e ce

rtific

ate

fee

curre

ntly

re

ceiv

ed b

y ta

x of

fice.

As

for O

ptio

n 3

(for a

ll op

tions

, lin

ked

to le

vel o

f R

SA

inve

stm

ent)

As

for O

ptio

ns 3

an

d 4

As

for O

ptio

ns 3

and

4

n/a

as fu

ll in

com

e no

w c

omin

g to

R

SA

O

vera

ll R

SA

Fina

ncia

l Im

pact

Low

Lo

w -

Med

ium

M

ediu

mM

ediu

mM

ediu

mH

igh

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

76

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

Third

Par

ties

Test

Cen

tre

Ope

rato

rs

Test

ing

Inco

me

Pot

entia

l to

re-c

oup

ICT

inve

stm

ent

thro

ugh

high

er fe

e (s

ee b

elow

)

Vol

ume

impa

ct if

hi

gher

com

plia

nce.

Opt

ion

2 w

ith

estim

ated

fee

impa

ct

of IC

T in

vest

men

t as

belo

w.

Vol

ume

impa

ct if

hi

gher

com

plia

nce.

As

for O

ptio

n 3

As

for O

ptio

ns 3

an

d 4

but s

hare

d ac

ross

few

er

oper

ator

s.P

oten

tial t

o re

duce

te

st fe

e ba

sed

on

econ

omie

s of

sca

le

and

effic

ienc

ies.

Bas

is o

f set

ting

fee

chan

ged

and

inco

me

assu

med

to s

ingl

e op

erat

or. L

ikel

y to

in

crea

se te

st fe

e w

ith

50 la

nes

for e

ach

of

LGV

and

HG

V b

ased

on

an

8 ho

ur w

orki

ng

day

(see

Ann

ex 1

, N

B p

rior t

o pr

ofit)

and

al

so u

nlik

ely

to b

e of

an

y fin

anci

al b

enef

it to

the

publ

ic, e

ven

with

40

lane

s fo

r ea

ch L

GV

and

HG

V

and

25%

long

er

open

ing

hour

s.

All

oper

atio

ns

trans

ferre

d to

RS

A.

Loss

of i

ncom

e st

ream

to a

ll cu

rrent

ope

rato

rs.

ICT

Inve

stm

ent,

inve

stm

ent i

n pr

emis

es a

nd te

stin

g eq

uipm

ent (

upfro

nt

and

ongo

ing)

ICT

inve

stm

ent a

nd

ongo

ing

cost

s w

ould

be

hig

her t

han

curre

nt

posi

tion

and

wou

ld

add

appr

oxim

atel

y €5

-€8

per

test

.

ICT

inve

stm

ent a

nd

ongo

ing

cost

s w

ould

be

hig

her t

han

in

Opt

ion

2 an

d w

ould

ad

d ap

prox

imat

ely

€10-

€15

per t

est.

As

for O

ptio

n 3

As

for O

ptio

ns 3

an

d 4

but f

or 8

0 te

st c

entre

s an

d th

eref

ore

a re

duce

d nu

mbe

r of T

est

Cen

tre O

pera

tors

. IC

T in

vest

men

t and

on

goin

g co

sts

addi

ng

appr

oxim

atel

y €6

-€1

0 pe

r tes

t.

Onl

y ap

plic

able

to 2

-3

com

pani

es a

nd fo

r lo

wer

num

ber o

f ap

prox

imat

ely

50 te

st

cent

res

to h

ave

100

lane

s to

tal.

ICT

and

equi

pmen

t (to

at l

east

th

e st

anda

rd o

f O

ptio

n 3)

, pre

mis

es

cost

s in

regi

on o

f €1

.5 m

illio

n pe

r ce

ntre

if c

reat

ing

new

ce

ntre

s.

n/a

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

77

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

Opp

ortu

nity

Cos

ts

No

impa

ct id

entif

ied

No

impa

ct id

entif

ied

No

impa

ct id

entif

ied

Opp

ortu

nity

cos

ts

from

78

test

ce

ntre

s, in

clud

ing

equi

pmen

t and

sk

ills, n

o lo

nger

re

quire

d to

test

.

Opp

ortu

nity

cos

ts

from

108

test

cen

tres,

in

clud

ing

equi

pmen

t an

d sk

ills, n

o lo

nger

re

quire

d to

test

.

Opp

ortu

nity

cos

ts

from

108

test

ce

ntre

s, in

clud

ing

equi

pmen

t and

sk

ills, n

o lo

nger

re

quire

d to

test

.

O

ther

Aut

horit

ies

Loca

l Aut

horit

ies

In to

tal a

ppro

xim

atel

y 7-

8 ad

ditio

nal F

TE’s

to

have

15

FTE

’s to

tal.

As

in O

ptio

n 2

with

: R

educ

ed

adm

inis

tratio

n co

sts

Red

uctio

ns in

ad

min

istra

tion

as in

O

ptio

n 3

but a

lso

frees

up

part

time

LAO

s.

As

per O

ptio

n 4

As

per O

ptio

n 4

As

per O

ptio

n 4

unle

ss re

sum

e ro

le

in e

nfor

cem

ent.

Dep

artm

ent o

f tra

nspo

rt N

o im

pact

iden

tifie

d N

o im

pact

iden

tifie

d Le

gal c

hang

es to

su

perv

isor

y ar

rang

emen

ts

As

for O

ptio

ns 3

an

d 4.

Plu

s in

volv

emen

t in

the

tend

er p

roce

ss a

nd

chan

ge in

law

.

As

for O

ptio

n 5.

Plu

s in

volv

emen

t in

the

tend

er p

roce

ss a

nd

chan

ge in

law

.

Pot

entia

lly m

ore

of

a go

vern

ance

role

Com

mer

cial

Veh

icle

O

wne

rs

Test

Fee

P

oten

tial i

ncre

ase

in

test

fee

P

oten

tial i

ncre

ase

in

test

fee

As

for O

ptio

n 3

May

be

som

e im

pact

on

the

test

fe

e bu

t thi

s is

like

ly

to b

e le

ss th

an

Opt

ions

3 a

nd 4

.

Like

ly s

mal

l inc

reas

e in

test

fee

Dep

ende

nt o

n R

SA

ap

proa

ch. R

SA

likel

y to

reco

ver

cost

s bu

t pro

fit

elem

ent u

nlik

ely

with

out i

ncre

ase

in

test

fee.

O

ther

fina

ncia

l im

pact

N

o im

pact

iden

tifie

d Ti

me

savi

ng /

redu

ced

burd

en o

f ha

ving

to s

epar

atel

y co

llect

cer

tific

ate.

As

for O

ptio

n 3

Add

ition

al tr

avel

tim

e / c

osts

re

quire

d fo

r som

e ve

hicl

e ow

ners

.

Add

ition

al tr

avel

tim

e / c

osts

requ

ired

for

som

e ve

hicl

e ow

ners

.

Add

ition

al tr

avel

tim

e / c

osts

re

quire

d fo

r som

e ve

hicl

e ow

ners

.

78

10.30 In summary, we consider that no option is likely to result in a reduction in the test fee and that in all options an increased investment will be required to cover improved supervisory arrangements, enforcement measures and ICT systems.

Overall assessment Option 1 - ‘As Is’

10.31 The quality and consistency of the current testing scheme is viewed as relatively poor compared to what the other options would provide. Doing nothing is not considered a viable option for the provision of an effective service in future.

Option 2 - Improve current arrangements 10.32 The quality and consistency of the tests improves slightly under this option, mainly due to

the increased level of supervision of the testing scheme. The move to full time LAOs and the introduction of independent RSA inspectors would improve the quality and consistency of testing. However, some fundamental weaknesses remain and there would still be insufficient management information available to support the targeting of supervisory and enforcement operations...

Option 3 - Integrated network of independent private sector test providers with greater automation

10.33 Under this option an improvement in Quality and Consistency of testing would be expected, due to the implementation of a single IT system across the network and associated reduction in the manual manipulation of data. The improved management information would also help focus supervisory activities.

10.34 Enforcement effectiveness would be significantly improved with this option, through the use of CRW discs on vehicles and availability of on-line information.

10.35 The impact on test centres would be significant in terms of operational efficiency and focus on quality of testing, but there would be no enforced reduction in the number of test centres as a result of adopting this option.

10.36 While this option could be relatively easily implemented there would remain a structural weakness in the split supervisory arrangements that would make it difficult to impose common standards of operation and disciplinary measures throughout the country

Option 4- Centralised supervision of the integrated network 10.37 This option should show an improvement in the quality and consistency of testing with one

body (RSA) being responsible for the entire management of the network. This would be more efficient in terms of the number of inspectors working on a full time basis which would also contribute to greater consistency in procedures and governance.

10.38 Enforcement would benefit most from this model as a result of much more open channels of communication and improved management information. One accountable body (RSA), instead of many (RSA and LAOs) should enhance these benefits further and also provide the Gardai with one point of contact for information and support. Further enforcement benefits would be realised through closer operational enforcement activities involving both RSA officers and Traffic Corps officers.



10.39 Again the impact on test centres would be significant in terms of operational process improvement, but there would be no enforced reduction in the number of test centres. This option still represents a significant challenge to bringing all test centres up to a common standard and will rely on RSA being able to influence a better regime of compliance (from both operators and test centres) through more targeted enforcement and routine checks.

Option 5 Rationalisation of current test centres with central supervision. 10.40 This option could only be achieved under central control, with one body able to consider

accessibility and quality standards on a national basis. The main advantage of this model would be a significant increase in the quality and consistency of testing with much closer monitoring of each centre possible through a reduced number of centres, operating to a higher quality threshold.

10.41 This would have a major impact on existing test centres with approximately 50% of test centres disappearing and the remaining 50% experiencing significant increases in vehicle throughput numbers. This should result in better profitability for those centres remaining. The option would reduce customer choice among fleet operators, but not affect accessibility significantly.

10.42 Implementation of this option is considered to be difficult, with particular resistance from existing testers as numbers are rationalised. As a result it may be several years before the new arrangements could be developed fully.

Option 6 – A single operator with central supervision. 10.43 The introduction of single operator would see a significant improvement in the quality and

consistency of testing, which would be continuously monitored to specified targets set by the RSA. This is a tried and tested model, with its main precedent in NCTS for car testing, where there have been impressive results. It means that testing can be totally independent of both fleet operations and also sales and repair businesses

10.44 The contractor would use standard equipment in all centres and IT infrastructure and software would be common in all locations. The service provider would be responsible for the quality of data provided through service level agreements so that it could be used by the RSA and the Gardai to improvement enforcement.

10.45 This option would have a large impact on test centres as the existing centres would cease testing operations unless part of a successful consortium bidding to provide the future independent service. It is expected that the number of centres would reduce by approximately 70-80%, to allow for an economically viable operation of the scheme.

10.46 It is likely that this option would give rise to considerable lobbying from existing test centres and potential claims for compensation, particularly where centres have invested in new facilities and equipment. There may also be resistance from operators who are generally happy with the current arrangements. As a result, implementation of this option is likely to be slow, with a stagnation of the current service likely during the implementation period.

Option 7 – Government Agency Operations 10.47 This option has similar advantages and drawbacks as option 6. However, it would also

require a substantial capital investment in new test centres as well as recruiting a large team of engineers and administrative staff to run the operation.

80

XI Conclusions and Recommendations

Conclusions 11.1 During this review we have reviewed the legal, administrative and testing processes

applicable to commercial vehicle testing. We have also sought the views of a wide cross-section of stakeholders and the public through a series of interviews, surveys and public meetings.

11.2 From our findings we have concluded that the current arrangements are inadequate in a number of respects, namely:

(a) Test processes are inconsistent, with differing standards applied. This results in an unacceptably high proportion of Irish vehicles being in an unroadworthy condition as evidenced by recent high profile cases and VOSA observations in UK.

(b) Some test centres have begun a facilities improvement programme but this is not universally in place at present

(c) It is very difficult to assess overall compliance rates, but in particular there appears to be a very small proportion of trailers tested

(d) There are a number of administrative inefficiencies in the system, including arrangements for issuing CRWs and reporting of test results

(e) The IT systems that are in place only provide basic support at test centre level. The systems have no integration across the network and have inadequate data security arrangements

(f) Training of new vehicle testers has improved in recent years , but refresher training is not considered to be adequate

(g) There are a number of situations that can give rise to conflicts of interest, potential affecting the independence of testing. In particular, vehicle owners can test their own vehicles and test centres are usually co-located with repair and/or sales operations

11.3 In addition, good governance is important for a successful test regime. In this respect we found:

(a) Supervisory responsibilities are currently split between 29 LAOs + RSA. This provides a significant challenge to achieving a consistent approach to testing throughout the country

(b) Most LAOs are part-time, with limited support within their LAs and there is a lack of dedicated resources to the supervision of testing.

(c) Linked with the inadequacy of the of IT systems, centralised management information is non-existent, to the extent that the total volume of testing has not been calculated for the past 2 years

(d) Differences in the quality of existing test centres would indicate a difficulty in achieving a consistent standard of facilities and approach in all test centres



(e) There have been few instances of disciplinary measures being applied and, in particular, very few test centres delisted over the years;

(f) There is evidence of poor communication between LAs, RSA and the test centres, particularly relating to dissemination of knowledge on testing standards and their interpretation

11.4 In addition to the weaknesses in the testing regime and supervision arrangements, there is currently very limited enforcement action by Gardai and a particularly small focus on vehicle standards (more emphasis on loading/ drivers hours etc). This has been due to the lack of resources available both within Gardai and (formerly) the Department.

11.5 While no statistics on performance are available for the condition of vehicles on the roads in Ireland, VOSA class Irish vehicles ‘bottom of the league’ for roadworthiness when observed on GB roads.

11.6 From this it is our conclusion that the current test regime relies heavily on the goodwill and professionalism of operators and testers to provide adequately presented vehicles on the roads against an environment where sanctions are unlikely. Unfortunately, in our view, a significant proportion take advantage of this situation and do not keep their vehicles adequately maintained.

Recommendations11.7 To address the weaknesses in the current regime, we have recommended a number of

improvements to the current ways of working, in the areas of:





(e) Operator maintenance records

(f) Enforcement

11.8 The aim of these recommendations is to build confidence in the quality of testing and to make it unattractive for operators not to comply. They also focus on improving the quality of vehicles throughout their time on the road, not just once per year at the time of a periodic test.

11.9 These improvements can be implemented in a number of strategic frameworks and we considered a number of options for future delivery and governance of testing.

11.10 As a result of that assessment we concluded that governance of the vehicle testing network should be solely the responsibility of the RSA, in future. This will streamline the supervisory arrangements and make it easier to assess the quality of test facilities against a common standard.

11.11 While there are attractions to reducing the number of test centres and of having a single independent testing operator, we consider that, with further investment in IT infrastructure and supervision, the current network of providers should be given the opportunity to



continue to provide the service. This is provided that, on a case by case basis, they quickly meet the facilities and testing standards required.

11.12 In implementing the proposed changes there are a number of issues that will need to be managed. In particular, the level of expectation by the industry and the public, that change must be made, will be highlighted by this report. This will put pressure on the timetable for improvement, particularly given public reaction to recent and pending accidents and court cases.

11.13 In addition, not all stakeholders may accept the findings of this report. An appropriate communications and consultation programme will be required to ensure buy-in from all key parties.

11.14 Implementation of the changes recommended constitutes a complex change programme. This programme will span the following main areas:

(a) Organisation change

(b) IT investment

(c) Test centre operational improvement

(d) Legislative change

(e) Radical change to enforcement regime

(f) Inter- departmental co-ordination

11.15 To deal with these issues we recommend that three main activities take place in the short term, namely:

(a) Implementation planning

(b) Short term improvement actions

(c) Communications programme

11.16 The purpose of the implementation planning phase will be to provide a fully costed, prioritised implementation programme which identifies the resources and skills necessary to take the individual projects forward. We would anticipate that these projects will cover the following areas:

(a) IT developments, including procurement of test lane management and MIS systems

(b) Operations improvement including facilities improvement and acceptance, training etc

(c) Supervision organisation development

(d) Enforcement. Development of targeting and enforcement programmes in conjunction with Gardai

(e) Legislation, including development of a programme of change to underpin the changes required in supervisory and testing arrangements



11.17 We recommend that RSA considers a number of short-term improvements to help bring about immediate improvements in the service provided, including:

(a) Implementation of an interim central IT database as a repository for test completion data

(b) Request and assess test centre improvement plans

(c) Provide upgraded training programmes

(d) Develop operational audit, augmenting the existing operational review criteria to cover the additional elements required

(e) Introduce revised operational audit and observed tests

(f) Establish operational links with Gardai in respect of enforcement and begin roadside checks

(g) Establish links with VOSA to focus on dealing with the specific issues of the quality of vehicles transporting through Dublin, Dun Laoghaire and Rosslare ports in particular.

11.18 Finally, we recommend that due attention be given to a programme of communication and consultation with key stakeholders, including local authorities, the transport industry, SIMI and the test centres to ensure a smooth transition to achievement of higher standards of vehicles on the roads in future.



XII Appendix 1 Pricing Structure

Reference No.(1)

Class of vehicle (2)

Full Test Fee(3)

Retest Fee

(4)

Fee for CRW (5)

1 Mechanically propelled vehicles used for the carriage of passengers with more than 8 seats, excluding the driver’s seat.

€133.64 €62.82 €13.00

2 Vehicles having a design gross weight exceeding 3,500 kilograms but not exceeding 7,500 kilograms.

€85.54 €42.77 €13.00

3 Vehicles having a design gross weight exceeding 7,500 kilograms with 2 axles.

€106.94 €53.47 €13.00

4 Vehicles having a design gross weight exceeding 7,500 kilograms with 3 axles.

€133.64 €66.82 €13.00

5 Vehicles having a design gross weight exceeding 7,500 kilograms with 4 or more axles.

€149.67 €74.83 €13.00

6 Trailers having a design gross weight exceeding 3,500 kilograms.

€96.20 €48.10 €13.00

7 Ambulances. €85.54 €42.77 €13.008 Vehicles having a design gross weight not

exceeding 3,500 kilograms. €64.13 €32.06 €6.00



Appendix 2 Stakeholder Interviews 12.1 The following table lists the stakeholders that provided input to the report.

Stakeholders

SIMI-vehicle testers committee

Up to 6 County Managers

Test Centre Visits

An Garda Síochána IRHAVOSALocal Authorised Officers workshops Road Safety Authority FTADigital Forecourt Interviews with 22 countries 3 Public Consultation Meetings Customer satisfaction survey with a sample of 100 managers/operators of HGV/LGV vehicles Representatives from 29 Local Authorities were invited to provide comments (5 Responses were received).



Appendix 3 Circular Letter VS 4/05







Appendix 4 Circular letter VF10/67







Appendix 7 International Benchmarking Survey – Country Summaries

Country

General observations

Quality and Enforcement

Test centres and staff

Test Arrangements

There are 59 commercial vehicle testing centres in Slovakia. The number of test centres is dependant on the number of vehicles in the state district. The average lead time to get a commercial vehicle test is 45 minutes. The target average queue time upon arrival at a test centre is 30 minutes. Staff are individually assessed and individual records maintained of their training and evaluation.

Slovakia

Commercial vehicle testing centres in Slovakia are agencies designated by the Ministry of Transport. The same agencies test both cars and commercial vehicles. Certificates of roadworthiness are displayed on commercial vehicles (sticker).

The Ministry of Transport in conjunction with local authorities monitor the quality and consistency of the testing process.

The vehicle test date is based on its original registration date. Reminders are not sent to vehicle owners. Tests do not need to be booked. Faults are recorded and categorised in the test results using unique identifying fault codes. A re-test only tests the specific group of faults that a vehicle failed on if completed within a month of the original test. Re-tests cannot be carried out by a different test centre from the centre that completed the original test.



Country



Test Centres and Staff

Test Arrangements

Estonia

Commercial vehicle testing in Estonia takes the form of independent testing stations under contract with Estonian Motor Vehicle Registration Centre (ARK) which links directly to the Ministry of Economic Affairs and Communications. These stations test both cars and commercial vehicles.

Test quality is monitored under the supervision of the Estonian Motor Vehicle Registration Centre. This is enforced through roadside checks by the police and customs, sometimes in co-operation with ARK.

The test date of a vehicle is based on its initial registration date. However, reminders are not sent to owners. Tests do not need to be booked. Faults are recorded and categorised in the test results. In a re-test only the specific fault that the vehicle previously failed on are tested. A re-test is approximately 50% of the cost of a full test. There is a maximum time period of 1 month between a test and re-test during which used of the particular vehicle is limited. Re-tests cannot be carried out at another centre.

There are 74 registered ‘test stations’ in Estonia. The number of the stations is dependent on the customer base. A reception with waiting room, toilets and wash rooms are all required within stations. All the normal test equipment is required. Additional a sound level meter (with electronic link to a national database) and window transparency is required as standard. Individual testing persons are assessed and these records are maintained.



Country




Test Arrangements

Finland

Commercial vehicle testing in Finland is conducted by independent inspection companies. In most cases these test centres have the facilities and permits to test cars.

Test quality is monitored by the Vehicle Administration Office who conducts random spot checks on testing establishments. Vehicle registration documents must be endorsed with a valid inspection stamp issued from a test centre.

The test date of pickups and vans is based on the first use date of the vehicle and must be tested initially in their third year and annually thereafter. Buses, trucks and trailers over 3.5 tons are based on the month of registration and tested annually. Trailers less than 3.5 tons are tested every second year. Reminders are not issued from the Vehicle Administration Office but some test centres operate a reminder system voluntarily. All vehicle taxes must be paid before testing. Pricing is set by the testing organisation. Retesting reviews only failed issues and can only happen at the original test centre.

There are 253 test centres throughout Finland. The location of the test centres is driven by geographical demand. In the sparsely populated north a customer may have to travel 150km to a test centre compared to 10km in the densely populated south. There are no requirements for facilities such as reception, waiting room and toilets. There are no standard test lane specifications. Individual testers are assessed and given annual update training all of which is recorded in training records. Several test centres offer a drive in service so no need to book.



Country




Test Arrangements

Denmark

Commercial vehicle testing in Denmark is in the form of independent testing stations governed by the Department of Transports, Road Safety and Transport Agency.

Quality is monitored by the Department of Transports, Road Safety and Transport Agency.

All commercial vehicles are tested. Vehicles and trailers need tested annually from the first year of registration. Vans are tested initially in the forth year and every second year thereafter. Reminders are sent to vehicle owners approximately 2 months before the test date. Not all tests need to be booked and the vehicle owner is free to choose a test centre. Only specific failure points require retesting within 33 days of initial test. If the failure is for documentation only then the retest can happen at any centre otherwise the owner has to return to the original test centre. It is planned for January 2007 all tests will be free.

There are 446 test centres that are operated by 107 different companies. The operating companies are free to decide the location of a test centre. There are no specific requirements for reception, waiting room, toilets or similar facilities. The Road Safety and Transport Agency do not assess individual testers but formal qualifications and training records are required. There are no standard test lane specifications.



Country




Test Arrangements

Staff are individually assessed and individual records maintained of their training and evaluation.

Switzerland

In Switzerland, commercial vehicle testing has been in place since 1969 and is run by the Department of Transport. The same agency tests both car and commercial vehicles. Similar to Ireland commercial vehicles are divided by the 3.5 tonne benchmark.

Certificates of roadworthiness need to be clearly displayed on commercial vehicles.

A vehicle’s test dates is based on its initial registration date. Reminders are sent to commercial vehicle owners 2 months prior to when their vehicle is due for testing. All commercial vehicle tests need to be booked in Switzerland. Faults are recorded and categorised in the test results. A re-test only tests the specific group of faults that a vehicle failed on in the original test. Re-tests cannot be carried out by a different test centre from the centre that completed the original test.



Country




Test Arrangements

Luxembourg

All testing in Luxembourg is controlled by the SNCT - Société nationale de Contrôle Technique which is 75% owned by the State of Luxembourg.

Quality is controlled by an independent auditor and in 2007 SNCT plan to be accredited to ISO/IEC 17020:1998, “General criteria for the operation of various types of bodies performing inspection” to complete audits. Certificates of road worthiness need to be clearly displayed. Vehicles need tested after a crash.

For vehicles under 3.5 tons they require testing every 12 months from the date of registration. For vehicles over 3.5 tons testing is required every 6 months from date of registration. All vehicles must have valid insurance and a valid tax sticker before testing. Reminders are issued 3 weeks before a test is due. Retesting focuses on specific issues if completed within 21 day otherwise a full test must be completed. Retests can be completed in another test centre.

There are 3 test centres in the country, 1 in the north, south and central regions of Luxembourg. The test centres are required to provide reception, toilets, parking, waiting rooms and first aid room. Individual testers are required to have a Masters Degree in Mechanics and are assessed by the SNCT who maintain records of staff training. SNCT standards for test lanes are adhered to. All testers must have 80% coverage in up to date training. Test centres are open 10 hours per day.



Country




Test Arrangements

There are 760 test stations in Hungary (includes test station and service providers). The quantity and location of test centres is dependent on the demand in the particular county. Staff are individually assessed and individual records maintained of their training and evaluation.

Hungary

Commercial vehicle testing has been in place since 1968 in Hungary and run through privately owned test stations. The Hungarian Transport Authority supervises the operation of the scheme. Test stations can test both cars and commercial vehicles depending on the licence that they hold.

Commercial vehicle licenses are granted after an independent assessment and audit of premises and staff. Every year test stations are audited by a team of staff from the central transport authority and the local council (‘inspectorates of transport’).

The testing of commercial vehicles is dependent on the age of the vehicle. Reminders are not sent to owners when their vehicle is due for testing. Tests do not need to be booked. Drivers are required to bring ID and registration details of the vehicle to the test. Faults are recorded and categorised in the test results using unique identifying fault codes. A re-test only tests the specific group of faults that a vehicle failed on if completed within two months of the original test. Re-tests can be carried out by a different test centre from the centre that completed the original test.



Country




Test Arrangements

Great Britain

Testing is completed by the private sector in Great Britain under the authorisation of the Vehicle and Operator Services Agency within the Department for Transport. However the agency directly tests all buses, coaches and goods vehicles greater than 3.5 tons.

Quality is ensured by a team of quality assurance and improvement officers from the agency. Test data is collected from the test centres in a data warehouse and used for targeting enforcement efforts. Roadside checks are used to spot check vehicles.

Vehicles must be tested within the first year following registration and then each year thereafter. All tests must be booked. Test pricing is based on vehicle type, number of axles, passenger capacity and test type. Retesting is completed only for those items failed originally if completed with 14 days. Retests must be completed in the original test centre.

There are around 19,000 test centres in the private sector. There are 93 in agency control for heavy commercial vehicles. Tests are also carried out by agency staff at around 400 operator premises. The centres are situated so that no operator has no further than 30 miles to travel. The agency assesses individual vehicle testers and maintains staff training records. Vehicle data must be held on VOSA database and have an identification mark prior to testing.



Country




Test Arrangements

Poland

Vehicle testing in Poland is conducted by independent inspection stations. These stations are authorised by the local administrative authority. Commercial testing includes buses, trailers and semi-trailers.

Test quality is controlled by audits from the local administrative authority.

Vehicles must be tested a year after registration and annually thereafter with the exception of full size buses which are required to be tested twice per year. All vehicles must have a registration certificate and valid technical inspection certificates for lifts and pressure tanks. Retests only focus on specific failure points but must be completed within 14 days.

There are approximately 3000 test centres in Poland. There is a national directive that governs the minimum technical standards and the requirement for premises including toilets and parking. Testing staff must have a mechanical engineering qualification and experience. They must also have completed a testing training course and attained an exam.



Country




Test Arrangements

There are approximately 5200 commercial vehicle testing centres in Italy which operate under around 100 regional authorities, which also complete vehicle tests. There are a no restrictions on the number of test centres per region and there are no guidelines as to the opening hours of test centres. All assessors are trained and accredited by the regional authorities.

Italy

Commercial vehicle testing centres are completed in Italy by independent garages and regional authorities. The garages are licensed by the regional transport agencies and test a variety of vehicle types.

The authorised independent garages are required to display their registration number and the required logo. The department of transport train and accredit all the vehicle assessors.

The vehicle test date is based on its original registration date. Reminders are not sent to vehicle owners and tests do not need to be booked.Tests can be booked in person or by phone and paid for in a variety of ways. Faults are recorded in as either minor or major and in a variety of categories. Vehicles with minor faults can used before passing completely but they must be presented again for testing within one month or be taken off the road. Vehicles with major faults are not allowed to be used until they past the test, but there is no timescale that they must be represented by. A re-test costs the same as the original test but does not need to be completed at the same test centre.



Country




Test Arrangements

There are 15 test centres in Northern Ireland for commercial vehicle testing and the location of these are determined, firstly, by geographical and then by population requirements. Test Centres adhere to specifications on facilities required and on the layout of test lanes. All vehicle assessors have been formally trained by a recognised independent body and refresher courses are also given.

Northern Ireland

A government run agency (Driver Vehicle Testing Agency) is responsible for testing all commercial and private vehicles in Northern Ireland.

The government ensures the quality of tests is maintained and standardised across the various sites through using ISO 9001/ 2000 quality management systems and through an internal quality assurance tester who supervises random tests. There is also a process in place for refresher training for staff.

The date for vehicle tests is determined by the original registration date of the vehicle except for imported vehicles when the date of manufacture is used. Reminders are sent out to customers 6-8 weeks in advance of the test. Tests can be booked by phone, fax, letter, or in person and the average waiting time for a test is 21 days with a queuing time of approximately 10 minutes at test centres. Tests can be paid for either by debit/ credit cards, cash or cheques. Vehicles with minor faults must be re-tested within two weeks of the original test.



Appendix 8 - Duties and Responsibilities of a Local Authorised Officer

12.2 Below are the duties and responsibilities of a local authorised officer as described by the National Committee of Authorised Officers for Vehicle Testing. This extract is taken from their submission to the Road Safety Authority.

Duties and Responsibilities of the Authorised Officer

1. Regular scheduled and unscheduled test centre inspections to ensure that vehicles are tested in accordance with Department of Transport guidelines

2. To carry out necessary supervision in each test centre at least twice a month and observe tests regularly on both Heavy Goods and Light Goods Vehicles.

3. To ensure that all existing vehicle test centres meet with the specifications set down in the Department’s ‘Guidelines for the Premises and Equipment required for the Testing of Commercial Vehicles within the Vehicle Testing Network 2004’

4. To attend monthly meetings with other Local Authority Authorised Officers for Vehicle Testing

5. Ensuring that all the equipment required for testing is present and that each appropriate item of equipment has a current calibration certificate.

6. Maintain a database on all tests carried out within the Local Authority area.

7. To ensure that all items of equipment are used in accordance with the specifications laid down in the Testers Manual 2004.

8. To frequently inspect the appropriate documentation for each vehicle tested.

9. Maintain a Database relating to the Certification of all the required testing equipment within the Local Authority area.

10. Maintain a Database for a register of current testers within the Local Authority area.

11. Deal with frequent calls relating to testing issues.

12. To visit various truck operators i.e. Haulage Companies regarding faults found on vehicles while operating in other European countries.

13. Liaising with the Authorised Officer in Motor Taxation regarding vehicle classification and the required inspection process.

14. Report writing relating to various testing issues for submission to Local Authority and Department of Transport Officials.

15. To liaise with An Garda Síochána regarding defective vehicles, assisting in road-side checks and the communication of any technical data when required.

16. To attend National monthly meetings of Authorised Officer Committee (Committee members only).



17. To ensure that all new Vehicle Testing legislation is implemented effectively.

18. To make appropriate recommendations in relation to vehicle testing as required.

19. To maintain standards of good practice throughout all test centres.

20. Continual training of authorised testers in relation to the introduction of new and updated legislation regarding vehicle testing

21. To interview and process all new test centre applications for vehicle testing.

22. To interview and process all new applicants for vehicle testing.

Summary of Role

Liaising, Report Writing, Supervision and Inspection, Data Collection, Standards, Training, Meetings, Recommendations, Financial and Budget responsibilities.



Appendix 9 Commercial Vehicle Testing Customer Satisfaction Survey

Survey approach 1.1 A total of 103 telephone interviews were conducted with vehicle operators who had

recently had a commercial vehicle tested. A telephone methodology was used for the following reasons:

(a) this approach yields high response rates;

(b) the interview can be controlled by a skilled interviewer, resulting in a high quality response;

(c) the sample structure can be quota controlled;

(d) interviews can be conducted in the evening, to suit customers’ availability; and

(e) This is a time efficient and cost effective approach.

Sampling1.2 A sample of organisations operating commercial vehicles was drawn up using publicly

available data sources. The sample was then selected randomly, with approximately half of respondents within the Dublin area and half outside.

The Questionnaire 1.3 The interviews were administered using a structured questionnaire dealing with the level

of importance and satisfaction with a range of issues that a commercial vehicle operator would expect to encounter in the course of testing a vehicle. The survey included questions addressing the key objectives, namely:

(a) Clarity and ease of understanding of the information regarding test procedures;

(b) efficiency of booking procedures;

(c) helpfulness of staff when booking test;

(d) length of wait for a test appointment;

(e) response times to correspondence and telephone queries;

(f) length of wait at test centre;

(g) range of facilities provided at the test centre;

(h) cleanliness and comfort of facilities;

(i) helpfulness and level of knowledge of office staff at test centre;

(j) helpfulness and level of knowledge of technical staff (if encountered);



(k) clarity of feedback on result of test e.g. reason for failure;

(l) length of wait for a retest;

(m) value for money;

(n) awareness of complaints procedures;

(o) satisfaction with the current system, and

(p) How service might be improved.

Analysis 1.4 The questionnaires were analysed using the SPSS computer statistical package, the

standard statistical package designed for the purposes of market research.

Key Findings: Profile of Respondents

1.5 Overall, 103 organisations were consulted as part of the survey, with 48% of those having experience of a vehicle testing centre within County Dublin and 52% having experience of a centre located elsewhere in the country, with locations including Cork, Donegal, Waterford, Cavan, Kildare, Tipperary and Galway. Vehicle testing centres from throughout the country were included in the sample.

1.6 The majority of organisations involved in the survey operate Heavy Goods Vehicles (63%), with over half of those being in the Large Heavy Goods category (33%) and the remainder being Small Heavy Goods Vehicles (30%). Over half of respondents operate Light Goods Vehicles (52%), while a third (33%) operate Passenger Service Vehicles. Organisations involved tended to operate more than one category of vehicle.

Table 1 Length of time since Test In the last month 46%2-3 months ago 20%3-6 months ago 19%6-12 months ago 15%

1.7 The majority of respondents had very recent experience of the vehicle testing centre, with almost half having had a vehicle tested in the last month and a total of two-thirds (66%) having had a vehicle tested in the last 3 months. Just 15% of organisations had experience of vehicle testing centres which had occurred more than 6 months before the survey. This is significant in that the majority of participants were discussing a very recent event, and as such, recall of their experience at the testing centre is likely to be highly accurate.

Booking Procedures and Communication 1.8 The vast majority of respondents had booked in for a test before arriving at the test

centre- 96% overall. An analysis of the data shows that a slightly higher proportion of vehicle operators in Dublin turned up for a test without a prior appointment.



Table 2

1.9 Incidences of turning up without an appointment were split evenly across the categories of LGVs and PSVs, with no reports of HGVs not being booked prior to visiting the test centre.

Table 3


Large HGV 100% -

Small HGV 100% -

LGV 94% 6%

PSV 94% 6%

1.10 The vast majority of vehicle operators in our sample who had booked their test in advance had done so by telephone, with a small but significant proportion booking in person at the test centre, as shown in the table below.

Table 4

BookingMethod

Telephone In Person By Post By Email

Percentage Overall

92% 5% 2% 1%

1.11 There were significant differences between booking methods utilised for Dublin test centres and those outside of Dublin. Test centres within Dublin, while still predominantly booked by telephone, were more likely to be booked by a range of other methods, as shown in the table below.


Dublin 94% 6%

Outside Dublin 98% 2%



Table 5

1.12 Overall, satisfaction with booking procedures was very high, as detailed in the table below. This general pattern of satisfaction with particular elements applied across all locations and all vehicle types. Overall satisfaction was highest with regard to the simplicity of booking procedures, with 91% of participants either very or quite satisfied. There were also high satisfaction levels with the information provided on booking procedures.

1.13 However, the length of time it took to get an appointment for a test or a retest had lower satisfaction levels, and it is interesting to note that the lowest satisfaction rating given across these elements of the service pertained to the length of time clients had to wait for a test appointment in the Dublin area-13% very or quite dissatisfied within the Dublin area compared to just 7% for the rest of the country.

Table 6

Satisfaction Level

Booking Element

Very Satisfied

QuiteSatisfied

Neither Satisfied

norDissatisfied

QuiteDissatisfied

Very Dissatisfied

Base

How straightforward it was to book test

74% 17% 6% - - 100

Informationprovided on

bookingprocedures

55% 28% 14% 2% 1% 97

Length of time client had to wait to

get a test appointment

34% 32% 21% 5% 8% 101

Length of time client had to wait

41% 33% 22% 2% 2% 70

BookingMethod

Area

Telephone In Person By Post By Email

Dublin 87% 7% 4% 2%

Outside Dublin

96% 4% - -



for retest

1.14 Individual comments relating to this dissatisfaction with the length of time it took to get a booking for a test suggest that clients would expect a test appointment to take no more than a day or two, and that centres might operate in the evenings or at weekends.

1.15 Interestingly, while straightforwardness of booking procedures was given high satisfaction ratings, respondents did not attach a high level of importance to it. When asked about a range of nine different aspects of customer service, just 17% of vehicle operators surveyed thought that clear and easy to understand booking procedures were of the greatest importance, and just 42% placed this aspect of customer service in the three most important aspects.

1.16 On the other hand, while waiting times for appointed tests had been given one of the lowest satisfaction ratings, particularly in the Dublin area, this was perceived to be one of the most important aspects of customer service, with 30% of those surveyed assigning it greatest importance, and two thirds (66%) placing it in the top three most important aspects of customer service. This is in direct contrast to the importance attached to the ability to just turn up without booking a test: considerably fewer respondents felt this was an important aspect of customer service (just 6% considered it the most important aspect of customer service and 22% placed it in their top three).

Customer Service Priorities 1.17 We asked customers to rate various aspects of customer service in terms of which they

thought were most important. Waiting times for appointed tests (an aspect which had been given low satisfaction ratings) was seen as hugely important. It was also thought important that the person who had prepared the vehicle for testing was not the individual who was testing it, although this does not necessarily mean that participants felt the maintenance and vehicle testing centres should be separate (as discussed in ‘Satisfaction with the Current System’).

Table 7

Aspect of Service Top Priority Top Three

Waiting times should be short if a test has been booked 31% 67%

The person testing the vehicle should be independent of the person who prepared it

30% 53%

Booking procedures should be clear and easy to understand 17% 32%

The test report should be clear and easy to understand 11% 47%

Should be possible to turn up and wait for a test without booking 6% 22%

The waiting area should be clean and comfortable 2% 12%

Staff should respond promptly to telephone queries 1% 19%



Staff should be helpful and courteous at all times - 23%

There should be a clear complaints procedure - 13%

Communications and Knowledge of Complaints Procedure 1.18 Participants were asked to rate their satisfaction levels with response rates to both written

and telephone queries. It was found that very few organisations submitted queries in written form, and that those who did were satisfied with response rates. In terms of telephone queries, however, there was a very high satisfaction rate with 83% of respondents stating that they were very satisfied or quite satisfied. Of those that were dissatisfied with the response time, actually making contact with the centre appeared to be the main issue.

1.19 When asked to rate various aspects of customer service in terms of importance, response times to telephone queries was rated quite low, with just 19% of respondents rating it in the top three aspects and just 1% assigning it top importance.

Table 8

Very Satisfied

QuiteSatisfied

Neither Satisfied

norDissatisfied

QuiteDissatisfied

Very Dissatisfied

Base

Length of time it took

the centre to respond to telephone

queries

52% 31% 13% 3% 1% 84

1.20 We assessed participants’ awareness of the current complaints procedure by asking them if they would know how to make a complaint about the testing service. Just over half of participants (51%) felt that they had no idea how they would go about this. However, of the 49% who felt they did know how to proceed with a complaint, just 2% would have contacted the Road safety Authority, all of whom by telephone. A fifth (20%) would have contacted the Department of Transport. More than three quarters of respondents (78%) would have taken their complaint back to the garage or the tester, indicating that the Road Safety Authority may not be notified of problems arising in the test process/system.

Table 9

Telephone Garage that tested the vehicle 60%

Telephone Department of Transport 14%

Write to the Garage that tested the vehicle 12%

Visit the garage that tested the vehicle 6%

Write to the Department of Transport 6%



Talk to the Tester 6%

Telephone Local Authority 4%

Telephone Roads Safety Authority 2%

Others 8%

Comfort, Customer Service and Professionalism 1.21 Participants were asked to rate their satisfaction levels with various aspects of customer

service at the vehicle testing centres. Overall, registration and payment procedures were the aspects to which participants assigned the highest satisfaction ratings, with 95% of respondents either very or quite satisfied, and none dissatisfied in any way. Helpfulness of staff in booking a test was also given high satisfaction ratings, with 94% of respondents either very or quite satisfied, and none dissatisfied.

1.22 Likewise, staff members conducting the test itself were viewed very positively, with a total of 90% of respondents being very or quite satisfied with this aspect of customer service. These ratings however, should be viewed in light of the importance attached to this aspect of customer service: courteous staff were viewed as much less important than other aspects of customer service, such as short waiting times, with no respondents assigning it top importance and just 23% placing it in their top three. In contrast, the comfort and cleanliness of the waiting area at the testing centres were given lower satisfaction ratings (73% and 79% respectively), and higher dissatisfaction ratings. A total of 11% of respondents were very or quite dissatisfied with the comfort of the waiting area, and the majority of comments on this issue related to the lack of such facilities as vending machines and enough seats. In terms of priority, respondents viewed other elements of customer service as much more important, with just 12% placing comfort and cleanliness in their top three and only 2% assigning this aspect top importance.

Table 10

Satisfaction Level

BookingElement

Very Satisfied

QuiteSatisfied


QuiteDissatisfied

Very Dissatisfied

Base

The helpfulness of staff you

spoke to when booking your

test

68% 26% 6% - - 98

Registration and payment procedures at the test centre

62% 33% 5% - - 100

Helpfulness of the member of

58% 32% 10% - - 91



staff who carried out the

test

Helpfulness of the staff on

reception at the test centre

60% 28% 11% 1% - 101

Length of time client had to

wait at the test centre

37% 36% 23% 2% 2% 94

Cleanliness of the waiting area

49% 30% 14% 7% - 89

Comfort of the waiting area

32% 41% 16% 9% 2% 89

1.23 We asked respondents to rate their satisfaction with various elements of customer service relating to the standard of testing they experienced in the vehicle testing centres.

Table 11

Satisfaction Level

Testing Element

Very Satisfied

QuiteSatisfied


QuiteDissatisfied

Very Dissatisfied

Base

Ability to carry out test professionally

69% 26% 3% - 2% 96

Ability to answer questions on test result

62% 30% 7% 1% - 86

Test report itself 51% 38% 9% 2% - 98

1.24 The highest satisfaction rating for this element of the service was for the ability of vehicle testing centres to conduct the vehicle test professionally- 95% of respondents were either very or quite satisfied with this element.

The Test Report 1.25 Of the vehicles that respondents had last got tested, 86% were first tests and 14% were

retests. This figure was largely similar for both geographical areas surveyed, although a



slightly higher rate of Small HGVs were retests- 22%. Of those who had retested vehicles, 71% required only one retest.

1.26 We asked those respondents whose vehicle had failed its first test or undergone a retest whether they thought that the fail was deserved. Eighty-seven percent agreed that it did indeed deserve to fail. And 94% of those whose vehicles failed the first test admitted that they had not serviced the vehicle prior to testing. The main reason given for not servicing the vehicle prior to testing was that the operator was confident it would pass (45%), although a significant proportion (20%) admitted that they wanted to find out what was wrong with it by means of the test itself. Those who thought the fail was undeserved were asked why they held this view. Just one respondent felt that the fail was petty and gave no mechanical reason. Whether the vehicle was serviced in the garage where the test took place or at another garage was not seen to affect the pass rate significantly.

1.27 We asked those who had serviced the vehicle prior to testing where they had gone for this service. The vast majority of those surveyed had had the vehicle tested by their own company (43%) or by a garage which was not the test centre (45%). It is also interesting to note that the pass record for vehicles which had been serviced by the operator themselves or by another garage was much higher than for vehicles which had been serviced by the garage which was the test centre itself.

Table 12

Serviced by own

company

Serviced by Test Centre

Serviced by another garage

Serviced by a Friend/family

Member

Serviced by vehicle

Dealership

PassedFirstTest

89% 67% 92% 67% 100%

Had to be

Retested

11% 33% 8% 33% -

1.28 Respondents were asked to rate their satisfaction with the test report itself. A high proportion (89%) were very or quite satisfied with the test report, but of those who were dissatisfied and wished to comment, several individuals asked for more clarity in the test report itself. This was viewed as quite important to clients, with 47% of respondents placing a clear and easily comprehensible test report within their top three most important aspects of customer service.



Table 13

Satisfaction Level

TestingElement

Very Satisfied

QuiteSatisfied


QuiteDissatisfied

Very Dissatisfied

Base Number

Test report itself

51% 38% 9% 2% -

Overall Satisfaction with the Current System 1.29 We asked participating vehicle operators whether they thought that the vehicle test centre

represented good value for money.

Table 14

Very Good Quite Good Neither/Nor Quite Poor Very Poor

28% 37% 19% 7% 9%

1.30 Almost two thirds of respondents (65%) felt that the vehicle testing centres were either very or quite good value for money. This rating was largely similar for respondents within Dublin and throughout the country, and for all vehicle types tested. Of the 16% who thought the centres represented quite or very poor value for money, the majority (63%) thought the test was simply priced too high, while the next most common answer was that “they just look for faults” (13%).

Table 15

Preferred System

Preferred Second Choice Third Choice

Garages that also carry out

repairs (Present System)

41% 18% 20%

Independent test Centres

40% 29% 15%

Independent Test Centres (as

NCT)

17% 29% 28%

Roadside Checks only

1% 17% 23%



1.31 We also asked participating vehicle operators if the location of the test centre was convenient for them. Clearly, the test centres are suitably located for the majority of clients, with 80% of respondents saying they were very or quite conveniently located. Overall, 11% of respondents said that the location of the test centre was quite or very inconvenient, a figure that was 5% higher for the clients throughout the country than it was within Dublin.

Table 16

Very Convenient

QuiteConvenient

Neither/Nor Quite Inconvenient

Not at all convenient

52% 28% 9% 9% 2%

1.32 S o

Table 17

Satisfaction Level Very Satisfied

QuiteSatisfied


QuiteDissatisfied

Very Dissatisfied

Overall Satisfaction with Service received

54% 40% 5% - 1%

118

Appendix 10 Financial Assessment

119

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

Impr

ove

the

Cur

rent

A

rran

gem

ents

In

tegr

ated

Net

wor

k of

Inde

pend

ent

Priv

ate

Sect

or

Prov

ider

s w

ith

Gre

ater

Aut

omat

ion

RSA

Man

agem

ent

of In

tegr

ated

N

etw

ork

of

Inde

pend

ent

Priv

ate

Sect

or

Prov

ider

s w

ith

Gre

ater

A

utom

atio

n

Rat

iona

lisat

ion

of

Cur

rent

Tes

t C

entr

es

Inde

pend

ent

Ope

rato

r (s)

G

over

nmen

t A

genc

y O

pera

tions

RSA

Cos

ts

ICT

inve

stm

ent

(upf

ront

and

ong

oing

) In

vest

men

t in

man

agem

ent

info

rmat

ion

syst

em,

spec

ifica

tion

of

stan

dard

dat

a se

t and

cr

eatin

g an

d m

aint

aini

ng te

st

data

base

. Upf

ront

in

vest

men

t and

on

goin

g m

aint

enan

ce

cost

s.

ICT

inve

stm

ent f

or th

is

optio

n is

mai

nly

at th

e te

st c

entre

s.

See

test

ope

rato

r se

ctio

n be

low

for

deta

ils o

f est

imat

ed

incr

ease

to fe

e as

a

resu

lt of

incr

ease

d in

vest

men

t.

Inve

stm

ent i

n m

anag

emen

t in

form

atio

n sy

stem

an

d na

tiona

l IT

syst

em, s

peci

ficat

ion

of s

tand

ard

data

set

an

d cr

eatin

g an

d m

aint

aini

ng te

st

data

base

. Dat

abas

e w

ould

hav

e in

crea

sed

func

tiona

lity

from

O

ptio

n 2.

Upf

ront

inve

stm

ent

and

ongo

ing

mai

nten

ance

cos

ts.

Sin

gle

syst

ems

supp

lier a

nd

softw

are

solu

tion

to

allo

w s

ome

book

ing

info

rmat

ion

to b

e po

pula

ted

cent

rally

As

for O

ptio

n 3

As

for O

ptio

n 3.

See

test

ope

rato

r se

ctio

n be

low

for

deta

ils o

f est

imat

ed

incr

ease

to fe

e as

a

resu

lt of

incr

ease

d in

vest

men

t.

As

for O

ptio

n 3

As

for O

ptio

n 3

but a

lso

with

all

of th

e te

st c

entre

/ c

ompa

ny IC

T in

vest

men

t in

Opt

ion

6.

Like

ly to

incl

ude

cent

ralis

edbo

okin

g sy

stem

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

120

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

but b

ooki

ng m

ade

loca

lly. B

ooki

ng

info

rmat

ion

and

test

re

sults

to b

e fe

d fro

m

cent

res

to c

entra

l sy

stem

.

Cen

tral s

yste

m to

in

terfa

ce w

ith la

ne

man

agem

ent s

yste

m

and

hold

test

lane

da

ta, a

s w

ell a

s au

dit

trail

of te

st re

sults

.

Cap

acity

to b

e bu

ilt

in to

sys

tem

to

prod

uce

disc

s /

certi

ficat

es a

nd to

be

in n

otifi

catio

n /

rem

inde

r fu

nctio

nalit

y.

See

test

ope

rato

r se

ctio

n be

low

for

deta

ils o

f est

imat

ed

incr

ease

to fe

e as

a

resu

lt of

incr

ease

d in

vest

men

t. In

vest

men

t in

prem

ises

and

test

ing

equi

pmen

t (up

front

an

d on

goin

g)

No

finan

cial

impa

ct

iden

tifie

dN

o fin

anci

al im

pact

id

entif

ied

for R

SA

. S

ome

test

lane

eq

uipm

ent

inve

stm

ent b

ut b

y

As

for O

ptio

n 3

As

for O

ptio

n 3

As

for O

ptio

n 3

As

per O

ptio

n 6

for o

pera

tors

as

deta

iled

belo

w

but n

ow R

SA

co

st. S

ame

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

121

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

Test

ing

Ope

rato

rs

(incl

uded

bel

ow).

pote

ntia

l to

reac

h ag

reem

ent w

ith

exis

ting

oper

ator

s re

gard

ing

prem

ises

and

eq

uipm

ent,

if tra

nsfe

rabl

e.

Reg

ulat

ion

/ G

over

nanc

e N

o fin

anci

al im

pact

id

entif

ied

No

finan

cial

impa

ct

iden

tifie

dC

osts

ass

ocia

ted

with

man

agin

g an

d m

onito

ring

oper

atio

ns o

f the

pr

ivat

e se

ctor

pr

ovid

ers

and

a de

dica

ted

cont

ract

m

onito

ring

team

w

ill be

requ

ired.

C

osts

exp

ecte

d to

be

a m

ix o

f sta

ff re

late

d or

pr

ofes

sion

al fe

es.

As

for O

ptio

n 4

but

low

er n

umbe

r of

test

cen

tres

and

oper

ator

s bu

t stil

l lik

ely

to re

quire

a

dedi

cate

d co

ntra

ct

man

agem

ent t

eam

.

Plu

s co

sts

of

runn

ing

tend

er

com

petit

ion

(and

se

ekin

g ch

ange

in

law

) to

issu

e lic

ence

s. L

ikel

y to

re

quire

hig

her l

evel

of

ong

oing

m

onito

ring

as

oppo

rtuni

ty to

at

tach

con

ditio

ns /

stan

dard

s to

lic

ence

but

this

co

uld

brin

g be

nefit

of

ince

ntiv

e to

pe

rform

wel

l for

lic

ense

d op

erat

ors.

In

itial

ass

ignm

ent

All

regu

latio

n an

d go

vern

ance

by

RS

A

but o

nly

mon

itorin

g 2-

3 co

mpa

nies

.

How

ever

wou

ld s

till

requ

ire a

ded

icat

ed

team

to m

anag

e th

e co

ntra

ct a

s co

ntra

ct

likel

y to

bui

ld in

pr

ovis

ions

rega

rdin

g st

anda

rds

of s

ervi

ce -

as fo

r Opt

ion

5 th

is

has

adde

d po

tent

ial

bene

fit o

f inc

entiv

e fo

r com

pani

es to

pe

rform

wel

l.

Pot

entia

l to

adop

t the

su

perv

isio

n m

odel

for

NC

TS a

lso

in fo

rm o

f su

pple

men

ting

in-

hous

e re

sour

ces

with

ex

tern

al re

sour

ces.

Plu

s co

sts

of ru

nnin

g

Sel

f-gov

erni

ng,

ther

efor

e co

st

wou

ld li

kely

be

clas

sifie

d as

a

man

agem

ent a

nd

adm

inis

trativ

e co

st (s

ee

oper

atin

g co

sts

belo

w).

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

122

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

of li

cenc

es a

nd

qual

ity a

ssur

ance

lik

ely

to re

quire

2

FTE

s fo

r 1 y

ear.

tend

er c

ompe

titio

n (a

nd s

eeki

ng c

hang

e in

law

) to

awar

d co

ntra

cts.

Q

ualit

y Te

stin

g an

d E

nfor

cem

ent

Hig

her l

evel

of

enfo

rcem

ent

invo

lvem

ent f

or R

SA

of

ficer

s. A

dditi

onal

FT

Es

requ

ired

perfo

rm o

pera

tiona

l au

dits

and

qua

lity

revi

ews.

A

ppro

xim

atel

y 4

full

time

RS

A in

spec

tors

in

tota

l, w

hich

is 1

ad

ditio

nal i

nspe

ctor

fro

m c

urre

nt p

ositi

on.

As

for O

ptio

n 2

From

As

Is, a

n ad

ditio

nal 1

2 fu

ll tim

e in

spec

tors

for

inde

pend

ent

insp

ectio

n an

d en

forc

emen

t. Fr

om O

ptio

ns 2

an

d 3,

an

addi

tiona

l 11

insp

ecto

rs b

ut to

re

plac

e 15

LAO

s al

so.

Ove

rall,

acr

oss

all

parti

es, r

educ

tion

of

4 FT

E’s

from

O

ptio

ns 2

and

3

whi

ch w

ould

refle

ct

antic

ipat

ed

econ

omie

s of

sca

le

with

in a

sin

gle

orga

nisa

tion

with

gr

eate

r m

anag

emen

t ca

paci

ty a

nd

cons

iste

ncy

unde

rtaki

ng th

is

activ

ity.

No

chan

ge fr

om

Opt

ion

4 gi

ven

that

th

ere

wou

ld b

e th

e sa

me

volu

mes

of

test

s.

Cou

ld b

e so

me

redu

ctio

n gi

ven

that

hi

gher

sta

ndar

ds

coul

d be

atta

ched

as

con

ditio

ns to

lic

ence

but

unl

ikel

y to

hav

e si

gnifi

cant

im

pact

on

requ

irem

ent t

o te

st

and

enfo

rce

qual

ity.

As

per O

ptio

n 5

All

test

ing

in-

hous

e bu

t stil

l ne

ed in

tern

al

qual

ity re

view

an

d as

sura

nce,

as

wel

l as

enfo

rcem

ent.

Giv

enin

depe

nden

ce

issu

e,en

forc

emen

t co

uld

be

perfo

rmed

by

Gar

dai o

r cou

ld

reve

rt to

loca

l au

thor

ities

.

Trai

ning

Tr

aini

ng re

quire

d in

en

forc

emen

t and

te

stin

g an

d

As

for O

ptio

n 2

As

for O

ptio

ns 2

an

d 3

but t

o gr

eate

r ex

tent

as

all

As

for O

ptio

n 4

with

po

tent

ial r

educ

tion

as n

umbe

r of

As

for O

ptio

n 4

with

po

tent

ial r

educ

tion

as

num

ber o

f ope

rato

rs

Add

ition

altra

inin

g co

sts

from

cur

rent

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

123

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

impl

emen

tatio

n of

ac

cred

itatio

n pr

ogra

mm

e.

enfo

rcem

ent a

nd

insp

ectio

n ac

tiviti

es

in-h

ouse

.

oper

ator

s re

quiri

ng

annu

al o

r oth

er

train

ing

wou

ld b

e lo

wer

.

requ

iring

ann

ual o

r ot

her t

rain

ing

wou

ld

be lo

wer

.

posi

tion

for

test

ers

as

brin

ging

in n

ew

stan

dard

ised

pr

oced

ures

but

as

enf

orce

men

t no

t lik

ely

to b

e in

ho

use

this

el

imin

ates

train

ing

cost

s fo

r th

is e

lem

ent.

Oth

er o

pera

ting

cost

s H

ighe

r adm

inis

trativ

e co

sts

As

for O

ptio

n 2,

plu

s co

sts

of p

rodu

ctio

n an

d is

sue

of d

iscs

an

d te

st c

ertif

icat

es

and

cost

s as

soci

ated

w

ith is

suin

g no

tific

atio

ns to

cu

stom

ers.

The

se

cost

s ar

e lik

ely

to b

e st

aff c

osts

for

adm

inis

tratio

n an

d st

atio

nery

cos

ts.

How

ever

eco

nom

ies

of s

cale

wou

ld b

e ex

pect

ed o

ver

curre

nt c

osts

for

issu

ing

disc

/ ce

rtific

ates

.

As

for O

ptio

n 3

As

for O

ptio

ns 3

an

d 4

As

for O

ptio

ns 3

and

4

As

for O

ptio

ns 3

an

d 4

but a

lso

recr

uitm

ent c

osts

fo

r tes

ters

and

m

ore

adm

inis

tratio

n co

sts

as

man

agin

g ra

ther

th

an re

gula

ting,

al

so b

ooki

ng a

ll in

-hou

se.

Cos

ts o

f im

plem

entin

g ne

w s

tand

ardi

sed

proc

esse

s fo

r te

stin

g an

d ad

min

istra

tion.

RSA

Inco

me

Levy

Levy

mig

ht b

e so

ught

to

re-c

oup

addi

tiona

l A

s fo

r Opt

ion

2 pl

us

pote

ntia

lly s

ome

As

for O

ptio

n 3

(for a

ll op

tions

, A

s fo

r Opt

ions

3

and

4 A

s fo

r Opt

ions

3 a

nd

4n/

a as

full

inco

me

now

com

ing

to

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

124

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

RS

A in

vest

men

t re

quire

d –

coul

d re

plac

e C

ertif

icat

e fe

e.

This

wou

ld n

eed

to b

e pr

ofile

d ov

er th

e pe

riod

of u

sefu

l life

of

inve

stm

ent a

nd a

cros

s th

e vo

lum

e of

firs

t te

sts.

One

pot

entia

l w

ay o

f allo

catin

g le

vy

to fi

rst t

est f

ees

coul

d be

to a

pply

a m

ark

up

perc

enta

ge

repr

esen

ting

tota

l in

vest

men

t div

ided

by

fore

cast

tota

l inc

ome

from

firs

t tes

ts fo

r the

us

eful

life

per

iod.

If an

y vo

lum

e im

pact

(s

ee O

pera

tors

in

com

e be

low

), th

is

wou

ld a

lso

impa

ct fo

r le

vy in

com

e.

follo

w o

n if

volu

me

impa

ct if

incr

ease

d co

ntro

l ove

r dis

c an

d ce

rtific

ate

issu

e re

duce

s fra

udul

ent

use,

cou

nter

feit

or

thef

t and

in tu

rn

lead

s to

gre

ater

co

mpl

ianc

e

linke

d to

leve

l of

RS

A in

vest

men

t) R

SA

– a

ppro

ach

to fe

e se

tting

lik

ely

to b

e bo

ttom

up

as p

er

Opt

ion

6 w

ith

RS

A s

eeki

ng to

re

cove

r its

cos

ts

and

be s

elf-

fund

ing.

How

ever

, no

prof

it el

emen

t ex

pect

ed.

Ove

rall

RSA

Fi

nanc

ial I

mpa

ctLo

w

Low

- M

ediu

m

Med

ium

Med

ium

Med

ium

Hig

h

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

125

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

Third

Par

ties

Test

Cen

tre

Ope

rato

rs

Test

ing

Inco

me

Pot

entia

l to

re-c

oup

ICT

inve

stm

ent

thro

ugh

high

er fe

e (s

ee b

elow

)

This

wou

ld n

eed

to b

e pr

ofile

d ov

er th

e pe

riod

of u

sefu

l life

of

inve

stm

ent a

nd a

cros

s th

e vo

lum

e of

firs

t te

sts.

One

pot

entia

l w

ay o

f inc

reas

ing

first

te

st fe

es c

ould

be

to

appl

y a

mar

k up

pe

rcen

tage

re

pres

entin

g to

tal

inve

stm

ent d

ivid

ed b

y fo

reca

st to

tal i

ncom

e fro

m fi

rst t

ests

for t

he

usef

ul li

fe p

erio

d.

Cou

ld b

e so

me

volu

me

impa

ct if

en

forc

emen

t and

re

gula

tion

activ

ities

en

cour

age

high

er

com

plia

nce

with

re

quire

men

t for

te

stin

g, o

r if a

ny

chan

ge to

the

prof

ile

Opt

ion

2 w

ith

estim

ated

fee

impa

ct

of IC

T in

vest

men

t as

belo

w.

Pot

entia

lly s

ome

volu

me

impa

ct if

in

crea

sed

cont

rol

over

dis

c an

d ce

rtific

ate

issu

e re

duce

s fra

udul

ent

use,

cou

nter

feit

or

thef

t and

in tu

rn

lead

s to

gre

ater

co

mpl

ianc

e.

As

for O

ptio

n 3

No

chan

ge in

ov

eral

l inc

ome

expe

cted

from

O

ptio

ns 3

and

4 b

ut

ther

e w

ould

be

a ch

ange

in w

ho

rece

ives

the

inco

me

– sh

ared

ac

ross

a s

mal

ler

num

ber o

f op

erat

ors.

Los

s of

te

stin

g in

com

e st

ream

to 7

8 op

erat

ors.

Arg

umen

t for

a

redu

ced

test

fee

base

d on

ec

onom

ies

of s

cale

an

d ef

ficie

ncie

s at

re

mai

ning

cen

tres

as te

stin

g m

ore

at

each

whi

ch s

houl

d re

duce

cos

ts p

er

test

, eve

n ta

king

in

to a

ccou

nt lo

nger

op

enin

g ho

urs

/ ad

ditio

nal t

estin

g st

aff r

equi

red.

Com

plet

e ch

ange

to

the

basi

s of

set

ting

fee

and

inco

me

only

sp

read

acr

oss

2-3

oper

ator

s /

com

pani

es. L

oss

of

test

ing

inco

me

stre

am to

a

sign

ifica

nt n

umbe

r of

oper

ator

s.

Like

ly “b

otto

m u

p”

appr

oach

with

co

mpa

nies

see

king

to

reco

ver c

osts

(with

a

high

er c

ost b

asis

th

an c

urre

nt

oper

atio

ns) w

ith a

co

ntra

cted

pro

fit /

retu

rn. O

pera

tions

m

ay e

nd u

p m

ore

prof

itabl

e th

an th

e cu

rren

t pos

ition

for

oper

ator

s, p

oten

tial

for f

ull e

ffici

ency

and

va

lue

for m

oney

th

roug

h co

mpe

titio

n re

stric

ted

due

to

geog

raph

ical

co

nstra

ints

, whi

le

All

oper

atio

ns

trans

ferre

d to

R

SA

.

Loss

of i

ncom

e st

ream

to a

ll cu

rrent

ope

rato

rs.

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

126

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

of fi

rst t

ests

. so

me

oppo

rtuni

ties

for e

cono

mie

s of

sc

ale.

Bas

is o

f set

ting

fee

chan

ged

and

depe

nden

t on

com

mer

cial

app

roac

h of

com

pani

es a

nd

inco

me

only

spr

ead

acro

ss 2

-3 o

pera

tors

. B

ased

on

prel

imin

ary

wor

king

s w

ithin

the

cont

ext o

f spe

cifie

d pa

ram

eter

s, s

ingl

e op

erat

or o

ptio

n lik

ely

to in

crea

se th

e te

st

fee

base

d on

50

lane

s fo

r eac

h of

LG

V

and

HG

V a

nd o

n an

8

hour

wor

king

day

. A

lso

unlik

ely

to b

e of

an

y fin

anci

al b

enef

it to

the

publ

ic e

ven

with

40

lane

s fo

r ea

ch L

GV

and

HG

V

and

25%

long

er

open

ing

hour

s. (R

efer

to

Ann

ex 1

for d

etai

l. P

leas

e no

te th

at th

is

anal

ysis

exc

lude

s pr

ofit

assu

mpt

ions

)

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

127

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

If 2

or 3

com

pani

es

this

cou

ld b

e di

fficu

lt to

man

age

in te

rms

of

havi

ng a

fixe

d fe

e an

d qu

ality

sta

ndar

d th

roug

hout

the

coun

try /

mar

ket.

Sep

arat

e co

mpa

nies

w

ould

intro

duce

be

tter c

ompe

titio

n bu

t so

me

fee

and

qual

ity

stan

dard

isat

ion

wou

ld

be re

quire

d to

m

anag

e th

e m

arke

t. IC

T In

vest

men

t, in

vest

men

t in

prem

ises

and

test

ing

equi

pmen

t (up

front

an

d on

goin

g)

ICT

inve

stm

ent

requ

ired

at e

ach

test

ce

ntre

for s

oftw

are

to

reco

rd a

nd s

ubm

it st

anda

rd d

ata,

plu

s in

stal

latio

n of

br

oadb

and

link

ICT

inve

stm

ent a

nd

ongo

ing

cost

s w

ould

be

hig

her t

han

curre

nt

posi

tion

and

wou

ld

add

appr

oxim

atel

y €5

-€8

per

test

from

cu

rrent

cos

ts b

ased

on

230

,000

vol

ume

per a

nnum

(bas

ed o

n an

ave

rage

cos

t per

te

st a

nd n

ot

Inve

stm

ent r

equi

red

in la

ne m

anag

emen

t sy

stem

and

test

lane

eq

uipm

ent t

o in

terfa

ce w

ith c

entra

l sy

stem

. In

vest

men

t req

uire

d in

han

dhel

d co

mpu

ter d

evic

es

and

user

au

then

ticat

ion

softw

are.

A

s in

Opt

ion

2, IC

T in

vest

men

t req

uire

d at

eac

h te

st c

entre

fo

r sof

twar

e to

reco

rd

and

subm

it st

anda

rd

data

, plu

s in

stal

latio

n of

bro

adba

nd li

nk.

As

for O

ptio

n 3

As

for O

ptio

ns 3

an

d 4

but f

or a

lo

wer

num

ber o

f te

st c

entre

s (a

ppro

xim

atel

y 80

) an

d th

eref

ore

a re

duce

d nu

mbe

r of

Test

Cen

tre

Ope

rato

rs.

ICT

inve

stm

ent a

nd

ongo

ing

cost

s w

ould

be

high

er

than

cur

rent

po

sitio

n an

d w

ould

ad

d ap

prox

imat

ely

€6-€

10 p

er te

st

from

cur

rent

cos

ts

base

d on

230

,000

Onl

y ap

plic

able

to 2

-3

com

pani

es a

nd fo

r a

low

er n

umbe

r of

appr

oxim

atel

y 50

test

ce

ntre

s, a

nd

appr

oxim

atel

y 10

0 la

nes,

50

each

for

LGV

and

HG

V.

Abi

lity

to re

-cou

p in

vest

men

t in

prem

ises

, IC

T an

d eq

uipm

ent (

to a

t lea

st

the

stan

dard

of

Opt

ion

3 pl

us li

kely

to

be c

entra

lised

bo

okin

g sy

stem

) ove

r a

long

term

con

tract

. H

ighe

r ini

tial

inve

stm

ent p

oten

tially

n/a

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

128

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

diffe

rent

iatin

g be

twee

n te

st

cate

gorie

s). T

his

is

the

estim

ated

tota

l co

st im

pact

from

the

addi

tiona

l inv

estm

ent

requ

ired

from

RS

A

and

the

test

cen

tre

oper

ator

s.

ICT

inve

stm

ent a

nd

ongo

ing

cost

s w

ould

be

hig

her t

han

in

Opt

ion

2 an

d w

ould

ad

d ap

prox

imat

ely

€10-

€15

per t

est

from

cur

rent

cos

ts

base

d on

230

,000

vo

lum

e pe

r ann

um

(bas

ed o

n an

av

erag

e co

st p

er te

st

and

not

diffe

rent

iatin

g be

twee

n te

st

cate

gorie

s). T

his

is

the

estim

ated

tota

l co

st im

pact

from

the

addi

tiona

l inv

estm

ent

requ

ired

from

RS

A

and

the

test

cen

tre

oper

ator

s.

volu

me

per a

nnum

(b

ased

on

an

aver

age

cost

per

te

st a

nd n

ot

diffe

rent

iatin

g be

twee

n te

st

cate

gorie

s) b

ut

taki

ng a

ccou

nt o

f th

e lo

wer

num

ber

of te

st c

entre

s fro

m

Opt

ion

3. T

his

is

the

estim

ated

tota

l co

st im

pact

from

th

e ad

ditio

nal

inve

stm

ent r

equi

red

from

RS

A a

nd th

e te

st c

entre

op

erat

ors.

requ

ired

from

the

succ

essf

ul

com

pani

es, i

n re

gion

of

€1.

5 m

illio

n pe

r ce

ntre

if c

reat

ing

new

ce

ntre

s. P

oten

tial f

or

com

pani

es to

reac

h ag

reem

ent w

ith

owne

rs o

f exi

stin

g te

st c

entre

s re

tra

nsfe

r of p

rem

ises

or

equ

ipm

ent o

r to

assu

me

exis

ting

leas

es in

som

e ca

ses

whe

re th

ese

are

sepa

rabl

e fro

m

exis

ting

oper

ator

s’

core

bus

ines

ses

– ex

act m

ix o

f new

ce

ntre

s to

use

of

exis

ting

cent

res

unce

rtain

.O

ppor

tuni

ty C

osts

N

o im

pact

iden

tifie

d N

o im

pact

iden

tifie

d N

o im

pact

iden

tifie

d O

ppor

tuni

ty c

osts

re

sult

from

the

78

test

cen

tres

that

w

ould

no

long

er b

e re

quire

d to

per

form

co

mm

erci

al v

ehic

le

test

ing.

Cen

tres

may

not

hav

e al

tern

ativ

e us

e an

d te

st e

quip

men

t w

ould

not

be

used

.

Opp

ortu

nity

cos

ts

resu

lt fro

m th

e 10

8 te

st c

entre

s th

at

wou

ld n

o lo

nger

be

perfo

rmin

g co

mm

erci

al v

ehic

le

test

ing,

to th

e ex

tent

th

at p

rem

ises

and

eq

uipm

ent a

re n

ot

trans

fera

ble

to n

ew

redu

ced

num

ber o

f

Opp

ortu

nity

cos

ts

resu

lt fro

m th

e 10

8 te

st c

entre

s th

at w

ould

no

long

er b

e pe

rform

ing

com

mer

cial

ve

hicl

e te

stin

g, to

th

e ex

tent

that

pr

emis

es a

nd

equi

pmen

t are

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

129

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

Loss

of s

kills

et o

f nu

mbe

r of t

estin

g op

erat

ors.

prov

ider

s.

Thes

e ce

ntre

s m

ay

not h

ave

alte

rnat

ive

use

and

test

eq

uipm

ent w

ould

not

be

use

d.Lo

ss o

f ski

llset

of

num

ber o

f tes

ting

oper

ator

s to

ext

ent

not t

aken

on

by

succ

essf

ul

com

pani

es.

not t

rans

fera

ble

to R

SA

.Th

ese

cent

res

may

not

hav

e al

tern

ativ

e us

e an

d te

st

equi

pmen

t wou

ld

not b

e us

ed.

Loss

of s

kills

et o

f nu

mbe

r of t

estin

g op

erat

ors

to

exte

nt n

ot

trans

ferri

ng to

R

SA

.

O

ther

Aut

horit

ies

Loca

l Aut

horit

ies

Impa

ct o

n LA

Os

in

assi

stin

g w

ith

road

side

che

cks

and

unde

rtaki

ng g

reat

er

degr

ee o

f qua

lity

chec

ks b

ut p

ossi

bly

re-o

rgan

ised

for

grea

ter e

ffici

ency

, e.g

. 1

pers

on fu

ll tim

e ac

ross

a fe

w c

ount

ies

as o

ppos

ed to

mor

e pe

ople

par

t-tim

e.

In to

tal a

ppro

xim

atel

y 7-

8 ad

ditio

nal F

TE’s

to

have

15

FTE

’s to

tal.

Pot

entia

l los

s of

ce

rtific

ate

fee

if

As

in O

ptio

n 2

with

: R

educ

ed

adm

inis

tratio

n co

sts

and

upda

te to

sy

stem

at t

ax o

ffice

s as

road

wor

thin

ess

certi

ficat

e to

be

prod

uced

and

issu

ed

cent

rally

.

No

rem

aini

ng

invo

lvem

ent.

Red

uctio

ns in

ad

min

istra

tion

as

per O

ptio

n 3

but

also

rem

ovin

g re

quire

men

t for

the

15 L

AO

s, w

hich

fre

es u

p re

sour

ces

for t

he L

ocal

A

utho

ritie

s.

As

per O

ptio

n 4

As

per O

ptio

n 4

As

per O

ptio

n 4

unle

ss re

sum

e ro

le in

en

forc

emen

t.

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

130

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

inco

rpor

ated

into

levy

. C

entra

l Dep

artm

ent

(abo

ve a

nd b

eyon

d R

SA

)

No

impa

ct id

entif

ied

No

impa

ct id

entif

ied

As

for O

ptio

n 3

A

s fo

r Opt

ions

3

and

4.

Plu

s po

tent

ially

so

me

invo

lvem

ent

in th

e te

nder

pr

oces

s an

d ch

ange

in la

w.

As

for O

ptio

n 5.

Plu

s po

tent

ially

som

e in

volv

emen

t in

the

tend

er p

roce

ss a

nd

chan

ge in

law

.

Pot

entia

lly m

ore

of a

gov

erna

nce

role

Com

mer

cial

Veh

icle

O

wne

rs

Test

Fee

P

oten

tial i

ncre

ase

in

test

fee

resu

lting

from

in

crea

ses

to p

ass

thro

ugh

ICT

inve

stm

ent a

nd /

or

RS

A le

vy in

crea

ses.

Pot

entia

l inc

reas

e in

te

st fe

e re

sulti

ng

from

incr

ease

s to

pa

ss th

roug

h IC

T in

vest

men

t and

/ or

R

SA

levy

incr

ease

s.

As

for O

ptio

n 3

Bui

ldin

g on

Opt

ion

4, ta

king

into

ac

coun

t the

ad

ditio

nal

inve

stm

ent r

equi

red

by o

pera

tors

at 8

0 ce

ntre

s an

d th

e po

tent

ial a

dditi

onal

le

vy b

ut a

lso

the

effic

ienc

ies

that

w

ould

be

expe

cted

–

ther

e m

ay b

e so

me

impa

ct o

n th

e te

st fe

e bu

t thi

s is

lik

ely

to b

e le

ss

than

Opt

ions

3 a

nd

4.

Dep

ende

nt o

n co

mm

erci

al a

ppro

ach

of c

ompa

nies

, mar

ket

man

agem

ent f

or

qual

ity a

nd p

rice

and

appr

oach

to le

vy.

From

ana

lysi

s in

A

nnex

1 (p

leas

e no

te, t

his

anal

ysis

ex

clud

es p

rofit

as

sum

ptio

ns),

test

fe

e m

ay in

crea

se if

th

is o

ptio

n is

se

lect

ed.

Dep

ende

nt o

n R

SA

app

roac

h to

fe

e se

tting

.

Sim

ilar t

o le

vy

conc

ept,

RSA

lik

ely

to re

cove

r co

sts

with

in fe

e bu

t pro

fit e

lem

ent

unlik

ely.

Roa

d S

afet

y A

utho

rity

R

evie

w o

f Com

mer

cial

Veh

icle

Roa

dwor

thin

ess

Test

ing

Fina

l Rep

ort 2

007

Con

fiden

tial

131

Impa

ct o

n A

s Is

Pos

ition

: O

ptio

n 2

Opt

ion

3 O

ptio

n 4

Opt

ion

5 O

ptio

n 6

Opt

ion

7

Oth

er fi

nanc

ial i

mpa

ct

No

impa

ct id

entif

ied

Tim

e sa

ving

/ re

duce

d bu

rden

of

havi

ng to

mak

e se

para

te v

isit

to

mot

or o

ffice

to c

olle

ct

road

wor

thin

ess

certi

ficat

e.

As

for O

ptio

n 3

Add

ition

al tr

avel

tim

e / c

osts

re

quire

d fo

r som

e ve

hicl

e ow

ners

w

here

clo

sest

test

ce

ntre

is n

ot

awar

ded

a lic

ence

.

Add

ition

al tr

avel

tim

e / c

osts

requ

ired

for

som

e ve

hicl

e ow

ners

as

few

er c

entre

s ac

ross

the

coun

try

(with

in 3

0 m

ile

cond

ition

).

Add

ition

al tr

avel

tim

e / c

osts

re

quire

d fo

r som

e ve

hicl

e ow

ners

as

few

er c

entre

s ac

ross

the

coun

try (w

ithin

30

mile

con

ditio

n).

132

Annex 1

Single Operator Fee Rationale – using NCTS as a benchmark

Underlying information:

NCTS Full Test statistics

625,000 full tests in 2005 @ €40 net of VAT = €25m income

The test statistics and full test fee information have been extracted from publicly available published information. The tests are delivered from approximately 80 lanes.

Assumptions of profit have been excluded from workings and 50% (€12.5m) fixed costs and 50% (€12.5m) variable costs have been assumed. Non-labour costs are assumed to be mainly fixed or semi-fixed.

RSA volumes expressed as NCTS equivalents

The split between HGV and LGV is assumed to be 138,000 (60%) LGV and 92,000 (40%) HGV based on RSA guidance of 60:40 mix and 230,000 total volumes.

LGV: 184,000 Equivalent Car Tests [based on 1.33 car tests equating to 1 LGV test – see additional example below]

HGV: 230,000 Equivalent Car Tests [based on 2.5 car tests equating to 1 HGV test – see additional example below]

LGV and HGV therefore represent approximately 29% and 37% respectively of the total NCTS capacity and in total operations across RSA volumes would approximate to 66% of NCTS levels.

Based on the estimated minimum number of lanes, assuming an 8 hour working day, and taking account of the fact that different lanes are required for testing LGVs and HGVs, approximately 50 lanes would be required for each which gives 100 lanes in total.

Given that there would be around 100 test lanes required, fixed costs are taken to be in the range of €13 m - €18m (initial guide based on €12.5m * 125% = €15.6m, but the actual number depends on a balance of achieving efficiencies and the fact that HGV lanes are expected to be more expensive to run).

For variable costs, based on the working assumption that NCTS would approximate to 50:50 fixed and variable, this would have €12.5m variable costs for 625k tests and RSA equivalent car tests are approximately 66% of NCTS test volumes, giving €8.3m for RSA variable costs. Again a range would be more prudent, particularly as there are more lanes and this could increase the level of semi variable costs, and therefore an assumption of €7m - €10m is used. Any difference in labour intensity in LGV test and HGV test is already taken account of in the volumes.

Assuming profit is again excluded would give total costs in the range of €20m - €28m.

Splitting this across the real volume of 230k RSA tests gives an indicative average price per first / full test of €87 - €121.75 (mid-range = €104.5).



Comparison with current RSA first test fees:

LGV fee (pre VAT): €64

HGV fees (pre VAT):

€149.67 > 7.5kg and 4 axle €133.64 > 7.5kg and 3 axle €106.94 > 7.5kg and 2 axle €85.54 3.5kg – 7.5kg

A straight mathematical average of the 4 HGV categories would be €119. However, from our experience of the likely mix of categories (in particular the high volume of vehicles in the >7.5kg and 2 axle category), an approximate average HGV fee is assumed to be €115.

Based on the 60:40 LGV to HGV test volumes, this would give income of:

138k tests at €64 = €8.8m 92k tests at €115 = €10.6mTotal income €19.4m Average test fee (/ 230k tests) €84

Conclusion: No financial benefit to the industry is indicated by the Single Operator option against the current first test fees and in fact it is estimated that the test fees may increase.

However it is important to bear in mind the unknown factors at this stage of analysis, most notably in terms of volumes and current operator costs.

In addition, the assumed number of lanes required is a key assumption in this example.

By reducing the number of lanes, this would reduce the extent of the likely price increase. For example, by reducing the number of lanes to 80 (40 for LGV and 40 for HGV) but increasing the opening hours by 25% to ensure sufficient testing capacity that the volume of tests can be delivered, this would result in a likely split of 45 : 55 between fixed and variable costs respectively and the test fee range would be reduced to €70.50 - €105.50 with a mid point in that range of €88. While this mitigates the potential for higher test fees it is unlikely that the test fee would go below the current fee level.



Additional worked example:

LGV: 138k Equivalent Car Tests [based on 1 LGV test equating to 1 car test]

HGV: 251k Equivalent Tests [based on 1 HGV test equating to 2.73 car tests]

LGVs and HGVs therefore represent approximately 22% and 40% respectively of the total NCTS capacity respectively and in total operations across RSA volumes would approximate 62% of NCTS levels.

Based on the estimated minimum number of lanes, assuming an 8 hour working day, and taking account of the fact that different lanes are required for testing LGVs and HGVs, approximately 50 lanes would be required for each which gives 100 lanes in total.

Given that there would be 20 (25%) more lanes than NCTS currently operate, fixed costs are taken to be in the range of €13m - €18m (initial guide based on €12.5m * 125% = €15.6m, but the actual number depends on a balance of achieving efficiencies and the fact that HGV lanes are expected to be slightly more expensive to run).

For variable costs, based on the working assumption that NCTS would approximate to 50:50 fixed and variable, this would have €12.5m for 625k tests and RSA equivalent car tests are approximately 62% of NCTS test volumes, giving €7.8m variable costs. Again, a range would be more prudent, particularly as there are more lanes and this could increase the level of semi variable costs, and therefore an assumption of €6.5m - €9.5m is used. Any difference in labour intensity in LGV test and HGV test is already taken account of in the volumes.

Assuming profit is again excluded would give total costs in the range of €19.5m - €27.5m.

Splitting this across the real volume of 230k RSA tests gives an indicative average price per first / full test of €84.75 - €119.50 (mid-range = €102).

Therefore as under this example lane numbers would again be 100 in total and RSA volumes would be approximately 62% (previously estimated at 66%), this gives rise to no significant difference to the conclusion in the first example, which is that the Single Operator option does not indicate any financial benefit to the industry and would actually be likely to result in a fee increase, when compared against current first test fees. Again, this example is based on a number of key assumptions as specified throughout.

Údarás Um Shábháilteacht Ar BhóithreRoad Safety Authority

Teach Chluain Fearta, Sráid Bhríde, Baile Locha Riach,Co. na Gaillimhe.Clonfert House, Bride Street, Loughrea, Co. Galway.tel: (091) 872 600 fax: (091) 872 660email: [email protected] website: www.rsa.ie

Workin

g To Save Lives

Documents

Commercial Vehicle Testing Review - RSA.ie Testing/CVR/CVT_Report.pdfFinal Report Commercial Vehicle Testing Review. Final Report. 2 This report has been prepared for and only for