Driver Hours/WTD

As far as I can see the specific issue questioned was whether a day spent just driving a van would mean the daily duty limit of 11 hours would apply. Personally I believe that it would.

I believe the 11 hours is duty only. This would presumably mean that if you accumulated breaks these wouldn’t count. I don’t know how far that can be pushed. The summaries of the domestic rules generally don’t go that far in explaining the minutae. Reference to the original legislation would probably be required, which I believe goes back as far as the Transport Act 1968 (and subsequent amendments).

Effectively if driving under EU rules in the same week, this means that the start and finish times of the domestic driving day are relevant. If putting in a manual entry for the day it will most likely be analysed against RT(WTR), so making the breaks compatible with this would probably be advisable. Whether or not RT(WTR) or the normal WTR apply for the domestic day is a moot point.

Disclaimer: As before I am happy to be corrected, as this is just my understanding based on the limitations both in terms of time and expertise that I possess.