Driving a van and tacho usage

So I’ve got to drive a van for 2 weeks, which obviously has no tacho machine.

I’m keeping a written record of my hours for driving the van in case I get stopped but I’m not sure what to do once I return to the wagon in a couple.of weeks time.

When my card goes in its going to ask me to account for the 2 weeks gap in the tacho records. I can’t just put it as rest because that’s not true. Am I expected to spend an hour painstakingly making a massive list of manual entries?

No need to record anything for the tacho :smiley:
If not got official domestic regs record book for the van work then perhaps do a manual printout for the two weeks of van work just to keep the records on track :bulb:
A diary of the van work record is also ok

Legally your records for the van work should be on printouts or charts, or log sheets if you’re using them which presumably you’re not, there appears to be some doubt as to whether or not the DVSA will still accept records kept in a notebook, I’m not saying they won’t accept them I’m just saying there seems to be some doubt.
For the van work you only need to record the start and finish times, if the van work is for a transport company you normally work for you will need to record the breaks but not the driving times.

When you insert your driver card in the tachograph after the 2 weeks van driving mark the time between tachograph shifts with the ? symbol.

Although it legally allowed under no circumstances should you try to input 2 weeks work manually into the tachograph, it will be time consuming and you’re likely to make mistakes, apart from that it’s not legally required.

Silverz:
.

When my card goes in its going to ask me to account for the 2 weeks gap in the tacho records.

Just checking you know that there’s a “?” symbol that you can select instead of rest that will mean that you have manual records to account for your time.

stu675:

Silverz:
.

When my card goes in its going to ask me to account for the 2 weeks gap in the tacho records.

Just checking you know that there’s a “?” symbol that you can select instead of rest that will mean that you have manual records to account for your time.

The “?” is no longer acceptable to DVSA, you can get fined for that. Easiest answer is a tacho printout showing the tacho card details on the front, on the back write what he was doing in the van.
For example: Mon 1st to Friday 5th, 8am to 5pm, other work, break 12:00 to 12:30. Then the same for the second week.

Or, he could use an Attestation Letter, but that needs to be the official DVSA style version. Chances are his company won’t know about this or have a copy available.

When the OP returns to using a tachograph after the 2 weeks van driving he will need to use the ? symbol for the time from the end of the last shift when the tachograph was used to the start of the current shift, there is no other symbol that would be legal.
He cannot legally use the rest symbol because he’s been driving a van, he cannot use POA because he hasn’t been on POA he’s been working, he cannot record all the time as other work because there has been times when he’s been on rest, so he must use the ? symbol to show that the time cannot legally be accounted for on the driver card.

tachograph:
Legally your records for the van work should be on printouts or charts, or log sheets if you’re using them which presumably you’re not, there appears to be some doubt as to whether or not the DVSA will still accept records kept in a notebook, I’m not saying they won’t accept them I’m just saying there seems to be some doubt.
For the van work you only need to record the start and finish times, if the van work is for a transport company you normally work for you will need to record the breaks but not the driving times.

.

Are you sure? The DVSA template shows driving hours is required, but a daily total, not in fine detail.

Zac_A:

stu675:

Silverz:
.

When my card goes in its going to ask me to account for the 2 weeks gap in the tacho records.

Just checking you know that there’s a “?” symbol that you can select instead of rest that will mean that you have manual records to account for your time.

The “?” is no longer acceptable to DVSA, you can get fined for that. Easiest answer is a tacho printout showing the tacho card details on the front, on the back write what he was doing in the van.
For example: Mon 1st to Friday 5th, 8am to 5pm, other work, break 12:00 to 12:30. Then the same for the second week.

Or, he could use an Attestation Letter, but that needs to be the official DVSA style version. Chances are his company won’t know about this or have a copy available.

You don’t understand.

Yes the “?” is not acceptable on its own, but it is required on your digital tacho card record. The only other choices being driving, work, rest or poa. So if you’re not saying rest until now because you’ve been working, you absolutely have to use a symbol to cover that time. Are you suggesting you should not use “?” ?

stu675:

Zac_A:

stu675:

Silverz:
.

When my card goes in its going to ask me to account for the 2 weeks gap in the tacho records.

Just checking you know that there’s a “?” symbol that you can select instead of rest that will mean that you have manual records to account for your time.

The “?” is no longer acceptable to DVSA, you can get fined for that. Easiest answer is a tacho printout showing the tacho card details on the front, on the back write what he was doing in the van.
For example: Mon 1st to Friday 5th, 8am to 5pm, other work, break 12:00 to 12:30. Then the same for the second week.

Or, he could use an Attestation Letter, but that needs to be the official DVSA style version. Chances are his company won’t know about this or have a copy available.

You don’t understand.

Yes the “?” is not acceptable on its own, but it is required on your digital tacho card record. The only other choices being driving, work, rest or poa. So if you’re not saying rest until now because you’ve been working, you absolutely have to use a symbol to cover that time. Are you suggesting you should not use “?” ?

Before questioning someone and suggesting they don’t understand, who knows a lot more about this subject than you and me, understand who you are arguing with. Just a suggestion as Zac is very knowledgeable about a lot of stuff, and I could be wrong but I am fairly sure he holds a TM qualification.

I have no reason to disbelieve Zac, I was told weeks back maybe a month or that there were impending changes by DVSA, and one of those things was ? Will no longer be allowed to be used, the other was that even the shunters are going to have to record all their hours by inserting their card into a digital tacho each day and do manual entries for each shift. That the changes mean they cannot use ? and neither can we and they have to have a proper record of their working hours whether they drive on the road or not.

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With effect from 20 August 2020, the following changes were made to the retained Regulation (EC) 561/2006 (EU drivers’ hours rules) and retained Regulation (EU) 165/2014 (tachograph rules)[footnote 1].

Article 6(5) of retained Regulation (EC) 561/2006) requires manual records to be kept of all work (including out of scope driving and any other work) and periods of availability, using either the manual inputs on a digital/smart tachograph or by making a manual record on a record sheet (from analogue tachographs) or on printout paper (from digital tachographs).

Article 34(5)(b)(iv) of retained Regulation (EU) 165/2014 requires periods of annual leave and sick leave, as well as breaks and rest to be recorded on the tachograph.

Along with other parts of the regulations in place before August 2020, the changes mean that all drivers (including occasional drivers) must keep a full set of records of their activities for the current day and the previous 28 days. The records must cover their:

driving

other work

periods of availability

breaks

rest

annual leave and sick leave

The detailed guidance on the drivers’ hours and tachograph rules for drivers of goods vehicles and passenger vehicles was updated on 20 August 2020 to cover the above and other changes to the rules. You can view it at

Some reading on changes already brought in.

gov.uk/government/publicati … other-work

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simcor:

stu675:

Zac_A:

stu675:

Silverz:
.

When my card goes in its going to ask me to account for the 2 weeks gap in the tacho records.

Just checking you know that there’s a “?” symbol that you can select instead of rest that will mean that you have manual records to account for your time.

The “?” is no longer acceptable to DVSA, you can get fined for that. Easiest answer is a tacho printout showing the tacho card details on the front, on the back write what he was doing in the van.
For example: Mon 1st to Friday 5th, 8am to 5pm, other work, break 12:00 to 12:30. Then the same for the second week.

Or, he could use an Attestation Letter, but that needs to be the official DVSA style version. Chances are his company won’t know about this or have a copy available.

You don’t understand.

Yes the “?” is not acceptable on its own, but it is required on your digital tacho card record. The only other choices being driving, work, rest or poa. So if you’re not saying rest until now because you’ve been working, you absolutely have to use a symbol to cover that time. Are you suggesting you should not use “?” ?

Before questioning someone and suggesting they don’t understand, who knows a lot more about this subject than you and me, understand who you are arguing with. Just a suggestion as Zac is very knowledgeable about a lot of stuff, and I could be wrong but I am fairly sure he holds a TM qualification.

I have no reason to disbelieve Zac, I was told weeks back maybe a month or that there were impending changes by DVSA, and one of those things was ? Will no longer be allowed to be used, the other was that even the shunters are going to have to record all their hours by inserting their card into a digital tacho each day and do manual entries for each shift. That the changes mean they cannot use ? and neither can we and they have to have a proper record of their working hours whether they drive on the road or not.

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Let’s see what he has to say for himself.

simcor:
With effect from 20 August 2020, the following changes were made to the retained Regulation (EC) 561/2006 (EU drivers’ hours rules) and retained Regulation (EU) 165/2014 (tachograph rules)[footnote 1].

Article 6(5) of retained Regulation (EC) 561/2006) requires manual records to be kept of all work (including out of scope driving and any other work) and periods of availability, using either the manual inputs on a digital/smart tachograph or by making a manual record on a record sheet (from analogue tachographs) or on printout paper (from digital tachographs).

Article 34(5)(b)(iv) of retained Regulation (EU) 165/2014 requires periods of annual leave and sick leave, as well as breaks and rest to be recorded on the tachograph.

Along with other parts of the regulations in place before August 2020, the changes mean that all drivers (including occasional drivers) must keep a full set of records of their activities for the current day and the previous 28 days. The records must cover their:

driving

other work

periods of availability

breaks

rest

annual leave and sick leave

The detailed guidance on the drivers’ hours and tachograph rules for drivers of goods vehicles and passenger vehicles was updated on 20 August 2020 to cover the above and other changes to the rules. You can view it at

Some reading on changes already brought in.

gov.uk/government/publicati … other-work

Sent from my CPH2173 using Tapatalk

Thanks for typing all that out. Which confirms that you must record ? on your digital tacho card record if you have supplementary manual records.

tachograph:
When you insert your driver card in the tachograph after the 2 weeks van driving mark the time between tachograph shifts with the ? symbol.

Although it legally allowed under no circumstances should you try to input 2 weeks work manually into the tachograph, it will be time consuming and you’re likely to make mistakes, apart from that it’s not legally required.

This.

I have no idea if it is legal or not but it is what everyone does.

I’ve had plenty of arguments with I think Zac and others about this but basically the DVSA are ■■■■■ and have very convoluted rules and this is a particular area that the DVSA are pretty bad on. In so far as what is required is not clear. All I know is as long as you keep written records of your work activity while not driving you will be fine. I have yet to see anyone at work get fined.

stu675:

simcor:
With effect from 20 August 2020, the following changes were made to the retained Regulation (EC) 561/2006 (EU drivers’ hours rules) and retained Regulation (EU) 165/2014 (tachograph rules)[footnote 1].

Article 6(5) of retained Regulation (EC) 561/2006) requires manual records to be kept of all work (including out of scope driving and any other work) and periods of availability, using either the manual inputs on a digital/smart tachograph or by making a manual record on a record sheet (from analogue tachographs) or on printout paper (from digital tachographs).

Article 34(5)(b)(iv) of retained Regulation (EU) 165/2014 requires periods of annual leave and sick leave, as well as breaks and rest to be recorded on the tachograph.

Along with other parts of the regulations in place before August 2020, the changes mean that all drivers (including occasional drivers) must keep a full set of records of their activities for the current day and the previous 28 days. The records must cover their:

driving

other work

periods of availability

breaks

rest

annual leave and sick leave

The detailed guidance on the drivers’ hours and tachograph rules for drivers of goods vehicles and passenger vehicles was updated on 20 August 2020 to cover the above and other changes to the rules. You can view it at

Some reading on changes already brought in.

gov.uk/government/publicati … other-work

Sent from my CPH2173 using Tapatalk

Thanks for typing all that out. Which confirms that you must record ? on your digital tacho card record if you have supplementary manual records.

I copied and pasted in including the link from the official source it was taken from.

Where does it state you can use question mark for entries? It doesn’t. It states records must have the following recorded:

The records must cover their:

driving

other work

periods of availability

breaks

rest

annual leave and sick leave

No mention of unknown time which I what the question mark refers to, they are asking for a full record of all time even including sickness and annual leave.

I’d bet a pound to a dollar there is not a single driver recording their sick leave or annual holidays on the card or in any other form.

The DVSA are very good at making changes to legislation but not publicising it very well if at all. Companies are also no good at publicising or making sure drivers are aware of these changes.

Like I said one of our driver trainers told me there were a lot of changes coming in soon and ? Will not be allowed to be used anymore. And for compliance sake even the shunters will be advised to use their card in a truck each day to make manual entries for that day on a dialt basis to ensure that records are being kept. Even if they do nothing but shunt and only ever occasionally go out in a vehicle under scope.

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I am fairly sure the old version of GV262 it was written about ? as unknown time.

The current version which is online and somewhat different format to the old GV262 unless I mistaken shows only pictograms for driving, POA, other work and rest. No mention of ? anymore. No mention of unknown time in wording.

I can’t actually find a download of the older GV262 for comparison and never have had a printed book version.

That image is the only copy of drivers hours rules I can find like the old GV262 downloadable file not in html format. Agai. It mention nothing about the ? on a tacho anymore.

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simcor:
I am fairly sure the old version of GV262 it was written about ? as unknown time.

The current version which is online and somewhat different format to the old GV262 unless I mistaken shows only pictograms for driving, POA, other work and rest. No mention of ? anymore. No mention of unknown time in wording.

I can’t actually find a download of the older GV262 for comparison and never have had a printed book version.

That image is the only copy of drivers hours rules I can find like the old GV262 downloadable file not in html format. Agai. It mention nothing about the ? on a tacho anymore.

Ok, correct me if I’m wrong, I believe that every digital tacho card in existence has a symbol recorded for every minute of every day 24-7, 365 for the up to 5 years of its validity.

With me so far?

Which symbol do you suggest the op uses for the couple of weeks in question?

dont over analyse the dvsa rules and regs… unless you are a TM lol.
Just use the ? symbol like 99.9% of drivers do.

Even if it is technically wrong until we hear DVSA starting to fine drivers due to it I would not worry. But yea, keep a written log of your hours worked in the van.

the ‘?’ symbol means or meant unaccounted time. Now if you want to say you cant use the ? symbol then please explain why all modern digital tachos still have that as an option :grimacing:

stu675:

Zac_A:

stu675:

Silverz:
.

When my card goes in its going to ask me to account for the 2 weeks gap in the tacho records.

Just checking you know that there’s a “?” symbol that you can select instead of rest that will mean that you have manual records to account for your time.

The “?” is no longer acceptable to DVSA, you can get fined for that. Easiest answer is a tacho printout showing the tacho card details on the front, on the back write what he was doing in the van.
For example: Mon 1st to Friday 5th, 8am to 5pm, other work, break 12:00 to 12:30. Then the same for the second week.

Or, he could use an Attestation Letter, but that needs to be the official DVSA style version. Chances are his company won’t know about this or have a copy available.

You don’t understand.

Sorry Stu, but it’s you who doesn’t understand: “?” means nothing to DVSA these days - not since mid-2022 when they started enforcing something they had previously let slide.

EU 2020/1054 made it a legal requirement for drivers to keep “full records” of all activities, “?” is not a “full record”

It’s been discussed widely on these boards that there are four ways to satisfy the “full records” requirement

  1. Detailed manual entries (no good here, too prone to error)
  2. Details on the back of an analogue chart (rarely can you lay your hands on them these days, so not the go-to choice for our purposes)
  3. Digicard printout (showing your card number), with the non-card-recorded activties laid out on the back, in a “block format” as I described already
  4. An official standard Attestation Letter, (DVSA template is available, see screenshot) preferably filled in on a computer, printed off and signed

Anything not compliant with that list has the potential to result in a financial penalty for the driver, unless the DVSA Officer/Plod who’s looking at your tacho card is in an uncharacteristically understanding, chilled-out mood.
If my drivers were swapping between out-of-scope and in-scope vehicles (they don’t do this) I’d expect them to do an ME for Other Work (crossed hammers), then fill in the blanks using option 3 above, as this is the simplest option.

I won’t bore you with the details, but a couple of months back I was asked to show a card-carrying DVSA operative what information I gave my drivers about “requirements to keep driver records” and he was satisfied with what I’ve written here.

I have a vested interest in keeping my own drivers comfortably on the right side of the law and not getting unnecessarily fined. But anyone who wants to go with Adam’s approach (below) is free to do that, as long as they don’t complain if they get fined.

What does the law say? The law says… Recording other work
Any work-related activity can impact on a driver’s fatigue levels. The EU regulation defines any work activity as being ‘other work’. This includes work that falls outside of the scope of EU drivers’ hours rules. For example, a part time driver who has a second job working in a bar, must count the bar work as ‘other work’ regardless of when that work takes place.

Drivers must keep records of time spent carrying out other work.

adam277:
I have no idea if it is legal or not but it is what everyone does.

:laughing: DVSA (like all authorities) don’t care what you think of them, and just because a number of people generically don’t do what is required of them, will not stop an authority person dishing out a penalty