In my job i might drive a hgv for 3 days but do other work for 2 days for the same company (which involves driving a company van in work time to get to the location to do this other work) I currently record the 2 days as other work including all breaks taken as breaks. My question is, do i need to record these breaks or do i just need to record the 2 shifts as ‘other work’ as a whole?
As I understand it those days of work off the tacho must be recorded on the back of a tacho roll:
Start time…duty time…break times…and end time.
The work must comply with the (EU) relevant rules regarding breaks etc, so you will need to record the breaks taken to prove you are complying with the law.
Thats not exactly true, I know that they can, and must be recorded on your card by way of a manual entry.
Quote from Drivers’ hours and tachographs: goods vehicles - 4. Tachograph rules - Guidance - GOV.UK
"When a tachograph is not available to record data in real time, the only permitted methods for drivers to make a manual entry are to:
- make a manual entry on an analogue tachograph record sheet
- make a manual entry on digital printout paper
- retrospectively use the manual input facility on a digital tachograph when the card is next inserted"
So, 3 methods seem acceptable. If records are made on tacho roll or disc, then there is no need to do a manual entry when a tacho is next used.
I’d do a manual entry personally
A manual entry has to be done on my card next time I insert it.
If you have done work when no tachograph was available?
The law requires either written (on tacho roll or disc) records or a manual entry on tacho when available.
Your company may well insist or require as part of your contract of employment, on a tacho manual entry.
On days that you do not drive in-scope of EU regulations you do not legally need to use a tachograph and therefore do not legally need to manually input the work record into a tachograph.
The records for none HGV driving days can be manually written on tachograph printout paper with all work time recorded as other work.
To answer the original question about recording breaks on none HGV driving days, my understanding is that as you’re working for the same company as when you’re driving in-scope vehicles you should record breaks in order to keep your working time down bellow the maximum average of 48 hours per week during the reference period.
Having said that, your company is within their rights to insist on you entering none HGV driving days work into a tachograph but it's not legally required.
3.4 Records (Mixed assimilated or AETR and Great Britain domestic driving)
What you should do, and what you do do are two different things lol,
just remember an honest man cannot live in this country anymore.