The recent siege at a training broker’s offices suggests to me that this may be the right time for a campaign to make the provision of LGV and PCV training a regulated matter.
Unfortunately, the current government is pursuing an aggressive campaign of reducing regulation, supposedly in the interests of business competitiveness. However, I believe that the current situation with LGV training brokers acts very much against the public interest, allowing these companies to make considerable profit for providing often unsatisfactory training (or no training at all if they go bust before paying the training provider).
I would hope any campaign can focus on the following issues.
Any instructor providing practical tuition on driving LGVs or PCVs (including being paid by an employer to teach in-house) should have to be on the DSA’s LGV or PCV register
Anyone teaching car driving for payment has to be a registered Approved Driving Instructor. ADIs have to:* pass qualifying tests: a theory test, an advanced driving test and a test of instructional ability
- display their ADI badge in the windscreen during lessons
- submit to periodic ‘check tests’ of their instructional ability where a DSA examiner acts as a simulated learner and grades them on their instructional ability
- be monitored by DSA on the practical test performance of candidates they taught
Those providing on-road tuition to qualified car drivers for payment also have to be ADIs, even if they don’t teach learners. Unless the law has changed recently, civilian police driving instructors have to be ADIs.
There is no direct equivalent of the ADI scheme for motorcycle tuition, though approval is required to run Certificate of Basic Training courses and to supervise Direct Access learners on larger bikes. The only on-road training that instructors without either of these approvals can provide is to learners on bikes of 125cc or less.
In mid-January 2013, the law around motorcycle licenses will get tougher as the UK implements the Third Driving Licence Directive. Once these changes come into effect, the restricted motorcycle entitlement gained by taking a test on a 125cc bike will not be automatically upgraded to unrestricted motorcycle entitlement after two years. It could well be that a much greater proportion of learner bikers who are entitled to use the Direct Access route take their test on a 600cc or larger bike (600cc is the minimum for Direct Access from 2013), making the Direct Access instructor’s qualification a de-facto ADI qualification for professional motorcycle instructors.
The DSA register for LGV and PCV driving instructors is voluntary - a fact that I am sure will surprise most members of the public, including many prospective LGV and PCV learners. An LGV or PCV driving instructor merely has to satisfy the requirements to supervise a learner, which is:* hold the relevant licence for three years, or
- hold the relevant licence for one year and the corresponding licence from the ‘other’ family for three years - for example, a driver holding category D for three years and category C for one year can supervise a category C learner
An LGV instructor never has to have driven an LGV since his or her test!
Even competent drivers do not necessarily make good instructors because teaching involves far more than being good at doing something yourself. A good instructor:* has excellent communication skills, including the ability to explain themselves in multiple different ways
- has good inter-personal skills
- is patient
- can rapidly analyse a learner’s training needs and diagnose their faults
- has the ability to analyse a learner’s progress and plan their tuition
- remains appropriately self-critical at all times, and
- recognises that they never stop learning themselves
Training and developing a professional instructor takes considerable time and money. Unfortunately, the general public do not know that LGV and PCV instruction is unregulated - they may well shop around for the lowest price without realising the DSA’s supervision of instructors is purely voluntary. It isn’t that expensive to get a flashy web site and put some vinyl graphics on a lorry - exactly the sort of things that ■■■■ many prospective learners in.
Bad instructors cost candidates more in the end. After all, it’s in a bad instructor’s interests for a candidate to fail, as they can make more money training the candidate for a retest. “You’ve come so far, it would be a shame to throw it away for the sake of a few hundred quid” is a powerful lever to opening the wallet of an increasingly frustrated learner.
However, the current situation also has road safety implications. Driving tests are only a snapshot of driving ability, but especially with larger vehicles, it should not be enough for a poorly trained candidate to scrape through their test after several failures whilst still being far from competent. Many countries require a minimum number of hours of tuition with a registered instructor before taking a practical driving test. The UK doesn’t even require this, even for vocational categories.
DSA have no leverage against bad LGV and PCV training providers. The pass rate of car test candidates for each ADI is monitored and I believe that poorly performing instructors have to take an early check test. DSA cannot take any action against bad LGV and PCV training providers; the poor providers are most unlikely to be DSA approved.
If the standard of preparation of test candidates improved, the damage and accident records of newly-qualified drivers may also improve. This, in turn, may lead to insurers being a little less harsh on newly-qualified drivers, improving their work prospects and therefore the value of their newly acquired licence (though, of course, there is no shortage of qualified LGV drivers in many areas at present).
Any driving school offering LGV or PCV training to members of the public should be required to be DSA approved
At the moment, LGV and PCV driving schools are exempt from operator licensing as their vehicles are not carrying goods for commercial purposes or passengers. I believe DSA approval of the training company should be looked on as a mandatory operator’s licence to provide training services to the public.
This would allow VOSA to holding training companies to the same requirements as those holders of restricted operator’s licences in terms of the maintenance and similar. However, I believe this should go further. The Traffic Commissioner can consider the repute of a transport manager listed against a standard operator’s licence. I believe that the Traffic Commissioner should be empowered to consider the repute of the head of an LGV or driving school - and that repute in this context should cover instructional matters as well as other operator’s licensing matters.
I would suggest that those holding an operator’s licence who only train their own employees do not need to be DSA approved but merely have to use registered instructors. The maintenance of vehicles is covered by the existing operator’s licence regime, and no employer will stand for sub-standard training that doesn’t get their employees through their tests quickly. When you are paying both instructor and candidate, you need results!
Consideration should be given to requiring that only DSA approved LGV and PCV training providers can accept money for LGV and PCV driving courses
Once brokers have to use DSA registered providers, it would be illegal to pass trainees on to a cheapskate operation run by someone who:* passed his rigid LGV test three years ago but has barely driven an LGV since
- has no instructional training
- never took his initial DCPC test, even though he’s preparing candidates for initial DCPC
- uses a tired old lorry he bought for a few thousand pounds
- parks his lorry outside his house and only takes to a fitter if it breaks down or fails the MoT (as there’s no O licence required), and
- carries out reversing training on some tired piece of concrete he borrows from a landowner
At the moment, a broker can charge the going rate for LGV training and make considerable profit by passing the candidate on to this sort of cheap provider. DSA approved providers can’t hope to compete with these cheap providers - their overheads are going to be much greater.
A mandatory approval requirement will likely remove much of the commercial incentive that keeps the brokers in operation. However, if brokers continue to rip off the public by taking money for training that they don’t then deliver, it would be a straightforward change in the law to forbid any organisation that was not DSA approved from accepting money from the public for LGV and PCV training.
Even with this change in the law, it would be possible for umbrella organisations to market themselves nationally, along the lines of InjuryLawyers4u. Unlike many of the firms selling personal injury claim services to the public, InjuryLawyers4u acts as an introducer to member companies who are all regulated solicitors’ practices. The member companies pay fees to InjuryLawyers4u for each lead, the public have a brand to turn to - though I would still argue that anyone who is injured in an accident is better served by going direct to a firm of specialist personal injury solicitors.
If mandatory DSA approval of training providers failed to stamp out the problem of unscrupulous brokers, it would be a small extension to the law to prohibit any organisation from taking money for LGV and PCV training unless they were DSA approved. The brokers could continue as introduction services paid by the training providers, but the individual trainee’s contract would be with a DSA approved provider against whom DSA could impose sanctions for malpractice.
What do people think? I don’t have the time or energy to drive this forward, but others do. Is Rikki able to bring this up with his employers - magazine coverage would certainly help. Is there any way to get the RHA and FTA interested? What about organisations like RoSPA and Brake? Are people willing to lobby their MPs and write to the Secretary of State for Transport? Are operators and existing training providers willing to get involved? Can we do anything with existing contacts with Watchdog and similar consumer programmes who have run stories on the brokers?
I firmly believe the existing situation helps nobody other the cheapskate training providers and brokers who line their pockets at others’ expense. LGV and PCV licences are supposed to be vocational licences, indicating the ability to drive large commercial vehicles. Surely the drivers of these vehicles should be trained to professional standards.
