Vehicle licence and tacho advice

I keep finding conflicting information so i’m hoping someone on here can help me out

I’m working with a new client who has some converted vehciles all being used without tacho’s as follows:

  • Converted double decker coach which is now a Motorhome with 8 seats, it is used commercially to transfer staff to events who then stay in the motorhome for around 4 days, this is driven by someone with a Class 2 licence.

  • Converted 7.5t truck which is now a food catering vehcile, this is driven without a tacho by someone with a C1 entitlement who also works in the catering unit.

The business have no O licence in place as they were advised that they don’t need one. Can anyone share their thoughts I normally only deal with HGV haulage clients

for what its worth on the info given in relation to the O licence …
the PSV is less than the magical NINE or more passengers required to make it a PSV so exempt.
The catering vehicle is effectively engineering plant or the goods it carries are for use in and of the vehicle so carries no goods for hire or reward as such would seem to be exempt as well.
The licences seem okay for what they are being used for.

From your description of the set up it would appear that you are in some way responsible for the operation of these vehicles. Elderly PSV used as employee transport raises sufficient concern among maintenance contractors to have seen some terminate the agreement with immediate effect over safety concerns.

The use of the motorhome raises an issue which you should consider in relation to best practice. This is probably not a vehicle in the first flush of youth but regardless of daily mileage run or even its actual age, the passengers have the right to expect that it is maintained to the standards appropriate to its original design. Therefore you would be advised to submit this vehicle for PMI to a contractor on the same schedule (8 weeks) used by the Class 6 PSV wedding hire operators. Clearly the vehicle is not a PSV nor does it have sufficient seats to be classed as a Class V heavy, but the latter is possibly the nearest fit to an appropriate inspection regime - seats, emergency exit etc . It would also be advisable to include items from a Class 6 inspection :step and interior lighting, fire extinguisher and first aid box. You should discuss with your contractor what is appropriate rather than what is legally required. This is going to end up as a mix and match between classes 4, 5 and 6.

Best practice would also apply the 10 year tyre age conditions to both vehicles and also ensure that the driver of each vehicle will not be expected to exceed any of the time limits relating to driving, breaks, rest or working time. Typical example being meal break 12.00- 1300 work till 16.00 drive everyone back until 20.00. Peer pressure from the 8 to finish early requiring the driver to work until the last minute before packing up to go home is common. Over the years there have been tragedies following this practice.

Is the catering vehicle used in conjunction with the motorhome to provide facilities for the workers or are there catering facilities in the Motorhome? In addition there are other issues to consider: passenger consumption of alcohol on the move. This is more than a motorhome, it is mobile accommodation for employees so there are likely to be fire safety and health and safety aspects as well.

Thanks to you both, very informative