Are you a red, amber, green ............or perhaps grey operator?
The Vehicle and Operator Services Agency (VOSA) Operator Compliance Risk Score (OCRS) has now been in operation for six years and a series of updates and amendments to the existing system will be introduced from Monday 1st October 2012 It is to be hoped by VOSA that the changes will make the scoring system more representative and fair right across the board, irrespective of the size of authorised operation in terms of specified vehicles.
VOSA have acknowledged that many operators have not been entered onto the OCRS system through spot encounters and have therefore been given a predictive score, which is in effect a disadvantage to them when the OCRS has been calculated.
Predictive scoring ......... fact or fiction?
This situation has arisen because of the 'predictive score' way of banding operators. What this means is that operators who simply have not had their vehicles stopped in spot encounters have not gained a roadside score. So, VOSA have come up with a prediction that has been made on what it is believed there levels of compliance would be if they had been stopped.........
Clear spot encounters ...... are yours recorded?
A further issue that has led to a distortion of the OCRS problem is that there is widespread evidence of VOSA examiners failing to record clear encounters when vehicles and their drivers have been checked. Unfortunately this is something that the VOSA Policy Department have failed to accept or address, putting it down to the 'sifting' process that is utilised when a large number of vehicles are stopped at the roadside. Sadly this organisation is regularly made aware by clients of their vehicles being throughly checked by vehicle examiners and found to be clear and yet a 'clear encounter' is not recorded against the OCRS score.
If these clear encounters were recorded, as they should be, they would help the operator move up the traffic light system.
Hopefully the change in the OCRS will force examiners to folow the correct procedures in future, as it will defeat the object of the 'grey fleet' if every check is not recorded.
Operator roadside check procedures
Truck UK strongly recommend that every operator implement their own system of recording every roadside encounter, irrespective of whether VOSA provide documentary evidence or not. This will ensure that, should the need ever occur, the operator can provide his or her own evidence of when vehicles have been stopped and checked by the authorities. Even 'sift' stops, where the vehicle and/or records are not physically checked should be recorded and stored by the operator. This provides you with a comprehensive record of your fleet and may pay dividends should you need to prove your compliance to the Traffic Commissioner.
No score banding .... the 'grey fleet'
Although many in the industry will have got used to the term 'grey fleet' covering vehicles that are not owned by a company, but used by them - i.e. a salesmans own car - VOSA have decided to add a 'grey fleet' band to the OCRS system.
So, as soon as the changes are implemented predictive scores will be replaced with a 'no score' band, to be known as the ‘grey fleet’ marking. This will show that VOSA has no data with which to rate that operator’s risk.
OCRS to be calculated on three years of data
Furthermore, to allegedly make the OCRS more robust, more accurate and more up-to-date, VOSA have stated that they will move from a rolling two-year dataset, that calculates the OCRS from the end of the previous month to a rolling three-year dataset, starting from October 2009, which will calculate the OCRS from the end of the previous week.
The OCRS Points system
VOSA have admitted that many operators have commented that it is not easy to understand how points received for a defect or offence will impact on their OCRS. To try and address this, VOSA have agreed to move
point allocations for traffic offences to the same system as
for mechanical defects - graduated - based on the severity of the offence. So, rather than different points for each defect or offence, they will be moving to a set number of points based upon the seriousness of the defect or offence.
For example, an immediate prohibition for brakes or tyres will receive more points than one for defective bodywork, which is obviously a positive move when considering the seriousness of any defect.
Defects found at annual test will be treated in a similar way to those found at roadside. ‘S’-marked defects will incur double points.
Hopefully, if this change is taken on board and used correctly it will be possible for both the authorities and operators' to look at a more realistic situation with regard to compliance and the seriousness of offences. While every offence is serious and safety is always paramount it is nonetheless a fact that an OCRS score and the computer generated prohibition notices that relate to an operator can give a wholly distorted picture of the levels of compliance of that operator if some useful examiner notes are not added.
Graduated Fixed Penalties
The Graduated Fixed Penalty and deposit bandings will apply to all offences detected at the roadside. OCRS points will also be applied when VOSA issues a prohibition for Hazchem offences. Something that is often apprent when this orgainisation carries out independent systems audits of operators is that a large number are failing to comply with the obligation they have to notify the Traffic Commissioner if a driver is issued with a graduated fixed penalty. While the penalty is definitely against the driver it is nonetheless essential that the operator carries out an investigation into why the penalty was issued and then the Traffic Commissioner is notified. This is not an optional procedure, it is a legal obligation of holding an operator's licence.
Furthermore, rather than allocating a score when VOSA sends the paperwork to a court to issue a summons, points for a prosecution will in future only be added in the instance of a conviction. This again should make the system far more realistic and will hopefully assist everyone involved, including the Traffic Commissioner's, to get a better picture of the situation when considering any further action against an operator.
An OCRS age related sliding scale .............
VOSA state that they have also recognised that the existing system has had a detrimental impact on operators who are attempting to move from amber to green, which it must be stated yet again has not been helped by a reluctance by some examiners at the roadside to enter clear encounters onto the system.
So, VOSA have stated that soon all points will be weighted by age. More recent defects / offences will be given more points than older ones. As the incident becomes older, so the points will reduce and the operator’s score will become greener – giving operators the chance to improve their score, even without a clear encounter with VOSA being reported.
However, some events will trigger an operator’s status being changed to red, whatever their underlying score. For example, a conviction will move an operator to red for a 12 month period, after which the operator will revert to the status merited by their baseline score.
If as the result of a roadside inspection an operator
receives a Most Serious Infringement (MSI) as defined in Regulation (EC) 1071/2009, their status will move to red for six months. If another MSI is issued in this time, the six months will start again. However, if no further points are received, at the end of six months the operator will revert to their baseline score status.
VOSA is also looking to move from 10 bands, each
containing a fixed percentage of operators, to a system
where operators are rated as Red, Amber or Green (RAG) depending on their baseline score.
This means that an operator will only move between bands as either the result of a vehicle inspection or the result of the weighting factor reducing the OCRS Score.
VOSA’s inspection priorities will be based upon this new
banding, with red rated operators being the first priority, followed by grey fleet, then amber, then green. This is aimed at ensuring that VOSA target those vehicles most at risk of non-compliance and also get to know all those operators who have not established their own score. It is essential that operators have a procedure laid down that ensures that every driver makes a note of any spot roadside encounter, so that a failure to record the encounter by VOSA can at least be recorded by the operator and used as evidence if required.
OCRS sign up not ideal...but essential
It is essential that every operator registers to enable them to gain access to their OCRS score. While the registration system is far from ideal and the process is, in the opinion of this organisation, unhelpful and difficult to access and complete, it is nonetheless something that the Traffic Commissioners will expect you to be regularly checking.
PLEASE NOTE: All the factual information contained in this news article was sourced from the VOSA publication 'Moving On' - March 2012 edition and the revised date for implementation of 1st October 2012 was provided by VOSA on 1st August 2012. All comments regarding the changes are the opinion of Steve Williams and not necessarily the company opinion of Truck (UK) Limited.
Steve Williams / August 2012