Is my jet patcher exempt?

Hi, new here. I’ve was working for a tar spraying company which spray a combination of hot pitch and emulsion to seal the new road surface to the old base after its been planed. It was a daf 55 18 tonner chassis. Now these vehicles are exempt from a shed full of rules… Basically we ran them on red diesel, no tacho or log book recording our hours, there’s no operators licence required (plant) therefore no domestic hours, they’re mot and 6 weekly check exempt and you don’t even need your hgv therefore no need for cpc. The reason being they are considered specialist mobile plant.

nidirect.gov.uk/driving-larg … ng-licence

Exempted large goods vehicles hgv licence
road construction vehicles used or kept on the road solely for the conveyance of built-in road construction machinery, (with/without articles or materials used for the purpose of that machinery)

Article 4(6) of E.C. Regulation 3820/85
Exemptions - eu driving hours
6. vehicles used in connection with the sewerage, flood protection, water, gas and electricity services, highway maintenance and control, refuse collection and disposal, telegraph and telephone services, carriage of postal articles, radio and television transmitters or receivers ;

gov.uk/government/uploads/s … europe.pdf

Does the driver drive a vehicle that is in the scope of operator licensing on this day? No…therefore, No records are required by law for that day

gov.uk/government/uploads/s … _Guide.pdf

Other exemptions from Operator Licensing
a vehicle with equipment permanently attached to it for the life of that vehicle. Examples of such equipment include permanently fixed machines or appliances. Additionally, the only other goods or burden that such vehicles are allowed to carry are those essential for use in connection with that fixed equipment.Â

customs.hmrc.gov.uk/channelsPort … _CL_000164

Exemptions from fuel duty
8.18 Tar Sprayer
To qualify in this category, the tar sprayer must be constructed or permanently adapted, and used solely for spraying tar on to the road or for proceeding to and from the place where it is to be or has been used for that purpose.

Now we’ve all been stopped by vosa and as soon as you mention tar sprayer, mobile plant, the colour drains out of them and they let you on your way.

The question I’m asking here is not about the above but I’ve started a new job operating a jet sprayer. You can see one here

youtube.com/watch?v=EEocO2PXIpk

They say emulsion in the video but it is still ‘tar’ based similar to that which we use on the spray bar to bond the layers and the 6mm stone Chipping’s are mixed on site like the volumetric cement mix lorries, then as you can see ‘sprayed’ onto the road albeit mixed with Chipping’s. I was wondering if this comes under the same category as the tar sprayer above, with all it’s exemptions?Â

I wouyld think so, but the law is currently being looked at to bring concrete batch mixers into ‘normal’ truck operating and licencinglaw