Here you go, I found the results of the trials:
Digital Tachographs — Advantages and Challenges
Summary
The introduction of the digital tachograph, available from 2004 and mandated for
newly-registered trucks from spring 2006, has provided advantages for both
drivers and operators; it has also posed challenges to some operators and
uncertainties that required clarification.
A VOSA/RHA trial demonstrated that in some operations, where a driver has
been using most of his allowed hours, there may be an impact, including on the
cost and the organisation of driver shifts when the regime of the digital
tachograph is compared to accepted custom and practice with analogues.
Criticisms of the efficiency of the device are justified in terms of the ‘rounding-up’
issue but the impact of that in practical terms can be largely dismissed, based on
current extensive evidence and enforcement practice.
The ‘15-minute’ discretionary concession worked out in Brussels in late 2007
makes little if any practical difference in the UK, where a case-by-case discretion
is already applied.
The practical impact of off-road driving being included in driver’s hours records
must be borne in mind. If there is evidence that queuing practice needs to be
tightened, the RHA can highlight this issue to members and customers.
Advantages
Record keeping can be greatly simplified. Waxed paper charts are replaced by a
digital smart card and it is easier to carry, store and produce records.
Generally speaking, the driver smart card is a more robust storage medium than
the previous charts.
Centre field entries have been eliminated due to the details being transferred
automatically between card and the vehicle unit upon card insertion and
withdrawal.
Data can be rapidly analysed and compliance reports generated by either
operator-hosted software or internet-based analysis. These have been
developed to allow individuals to view their own data remotely at a time that suits
them.
Compliance with both drivers’ hour’s rules and the Road Transport Directive on
working time can be checked more rapidly, with immediate availability of the
information. Data may be transmitted electronically; most charts continue to rely
on the postal service.
Record-keeping on the vehicle unit is available for the first time with the digital
tachograph, allowing verification of driver data, both by the operator and
enforcement agencies.
Digital tachograph services have developed since introduction. The latest
generation devices allow for remote card and vehicle unit downloading via either
GPRS or WLAN, ensuring accurate data is received by the operator, despite the
vehicle being away from base for protracted periods.
Challenges
Anecdotal evidence suggested that there was considerable variance between
digital and analogue tachographs, with the digital recording significantly more
driving time. Operators reported that vehicles were running in tandem on
journeys and substantially different driving times being recorded by the two
equipment types.
Unfortunately, the records had no scientific value as there were too many
variables involved. VOSA sought to establish scientific data and the challenge
was picked up by the RHA, which identified two haulier members who were
happy to establish a trial and to open their records to inspection.
VOSA commissioned a trial involving both analogue and digital recording
equipment being fitted to a truck at two haulage firms. The trial lasted for four
weeks.
The conclusions from the trial were;
- The digital equipment was recording exactly as the EU legislation
intended.
- There was a variance in recorded driving time. This amounted in most
cases to at most 10-to-15 minutes during a working day, although on
some runs the difference was as high as 30 minutes. The longer periods
of variance were found on journeys that involved periods of ‘stop / start’
driving, with short stationary periods, or where the truck was queuing on a
motorway. A key reason for the difference is not variances in the way
driving time is recorded; more the ■■■■■■■■■■ impact of the way analogue
charts are often ‘cautiously’ analysed, with small movements being
ignored.
- The impact on individual operations could be significant, where drivers
were running close to their 90-hour fortnightly maximum, to the extent of
losing one driver shift, or having to put a long-distance driver on local work
for a reduced shift, where the work is available. This was especially true
when the impact of the inclusion off-road driving in 561/2006 was factored
into the driving record.
- There was a recognition by the hauliers involved in the trial that the rules
has been tightened; and a recognition that the industry could be
considered to have been “getting away with” some additional driving in the
past.
The VOSA trial, arranged in partnership with the RHA, generated data comparing
analogue and digital recording that was reliable and verifiable. In practice, it
threw up few if any surprises to VOSA but it did confirm what VOSA suspected to
be the case and strengthened confidence in understanding of the application and
impact of the digital tachograph in practice. VOSA has expressed its appreciation
and thanks to the RHA and to the members involved.
How the digital tachograph records
The digital tachograph assigns a calendar minute to ‘driving’ when vehicle
movement is detected in that minute. If the vehicle unit detects signals from the
motion sensor for more than five consecutive seconds, it will record ‘driving.’
Detection of impulses is discreet rather than ■■■■■■■■■■■ In other words, a vehicle
could move a number of times in a calendar minute, each one for five seconds or
less and the digital tachograph would not record ‘driving’.
On the other hand, programming rules result in a calendar minute that is
stationary, being recorded as ‘driving’ if the calendar minutes either side of the
stationary minute are recorded as ‘driving.’ At first glance this may appear to be
perverse. However, if we consider what the action of driving actually involves,
especially in the light of R. v MacDonagh [1974] Q.B. 448 where it was ruled that
‘driving’ was the activity of sitting behind the steering wheel in order to control the
movement of the vehicle, the storage rule makes sense in the vast majority of
cases. In other words, the court was stating that we have to break the mindset
that ‘driving’ means that the vehicle is moving.
By contrast, the analogue will actually record slightly more driving time than the
digital. It will, for example, mark movements of only a second or so. In practice,
such records will usually only be taken into account in ultra-detailed forensic
analysis.
There is little difference between the analogue and digital devices in terms of
switching to record ‘other work’ when the engine is running — for example at a
customer’s premises or in a traffic jam — where there is no movement for several
minutes.
Where a driver is going over his hours unexpectedly, for example due to an
exceptional hold-up on a motorway, he should make a note that an enforcement
officer can inspect at a future time. This relates to Article 12 of 561/2006, finding
a safe place to park, not to the digital tachograph.
The 15-minute tolerance
Enforcement guidance from Brussels suggests that it is possible for the
enforcement authorities of a Member State to apply a discretionary tolerance to
the driving period of 15 minutes. The guidance makes particular reference to
vehicles involved in multi-drop operations and the 4.5-hour ■■■■■■■■■■ driving
period, where the driver can demonstrate that he has been involved in such
activity. Further, it should be borne in mind that the EU guidance states that
occasional and not frequent breaches will be permitted and only where evidence
of multi-drop operation is determined.
VOSA already applied a discretionary tolerance to the analysis of all driving and
break / rest periods. It is felt that the current arrangements cater for the tolerance
discussed in the guidance. For this reason, the Brussels guidance note makes
little or no practical change to the enforcement position in the UK.
VOSA notes that a driver of a vehicle fitted with digital recording equipment has
the capability to check their current accumulated driving time; in reality there is
little or no excuse for them breaching the legislative limits. There was a problem
with the displays on early Stoneridge tachographs, which could show a variance
with the recorded driving time; that problem has been rectified on models from
late 2007.
Minimising recorded driving time
It is possible for drivers to minimise their driving time, especially when involved in
queuing. The main action is not to continually creep forward in slow moving
traffic. If they remain stationary and then cover the distance between their vehicle
and the one in front, the ‘driving’ record will be interrupted by periods of other
activity, usually ‘work’. Council Regulation 561/2006 defines driving as the ‘period
recorded automatically or semi-automatically by the equipment’. An enforcement
officer would sum only the periods shown as ‘driving’ and discount those periods
recorded as another activity. The RHA strongly recommends to members and
drivers that queuing behaviour on-site be adjusted accordingly.
courtesy RHA
It seems that with analogue, minor movements such as backing under a trailer from just infront of it, are discarded. With digi, if it crosses a calender minute change point it will record 2 minutes.
Manouevring for 1 minute 10 seconds, could clock 3 minutes.
Anybody care to try and work out how many minutes would be used up by following H & S recommended coupling procedure to the letter? i.e. stop infront of trailer, apply park brake, stop engine, take keys out, get out & look at heights, etc. etc.
However, by my understanding, driving the unit from its parking place, accross to the office, then maybe twice round the yard looking for the right trailer and then coupling to it, is not part of the road journey & could therefor legitimately be recorded as out of scope. Though i would think very few drivers, myself included, would bother to do this
