13 Dec Beyond the Red Tape – Ian Smith Talks

With a constantly changing legislative framework, these changes are creating more questions than providing answers to the post Brexit world of Type Approval, carbon reduction targets and indeed our operating licence compliance requirements.

As a manufacturer, operator and representative of the industry in several forums, it is noticeable that the burden of change is ever increasing.

In this juggling act, the hot potatoes are the European Commission’s introduction of the Vehicle Energy Consumption Tool (you may have heard the term “VECTO” being brandished about), General Safety Regulation 2 (known as GSR2),– what should be included in the GB Type Approval framework and closer to home, the additional text which appears in the 2024 Guide to Maintaining Roadworthiness in regard to periodic preventative maintenance brake performance assessments  – we won’t  mention railroading the introduction of Smart Tachograph 2, despite the “system” being  not even close to satisfactory for roll out, but hey lets just load the expense and burden onto operators in any case with an “interim” fix.

So, lets jump into the 2024 Guide to Maintaining Roadworthiness, and particularly the requirements around brake performance monitoring at every mandatory periodic safety inspection.

This in itself is not a new requirement, so there is not an increased frequency of brake performance monitoring, as some may have interpreted, what is new and effective from April 2025, is the focus around brake performance assessments in particular the use of Electronic Brake Performance Systems and where that sits in regard to the alternative methods of assessment that have been in use such as Roller Brake Test (RBT) and decelerometers.

The guide is written in such a way that, in my opinion, leads the reader along the path that EBPMS is the preferred method of monitoring brake performance, even though, in the case of an articulated combination, the “system” cannot distinguish between a tractor or trailer fault. When a deterioration of the parameters is noted, further investigation is required and inevitably, again in my opinion, that will lead to a foundation brake assessment including assessing brake force effort using a RBT.

However, it is the very fact, that a deterioration of performance data is noted in service, rather than waiting until a safety inspection draws the attention to a defective brake, that makes the system a winner.

EBPMS allows for continuously monitoring brake performance, why would you not want to do that (I ask myself with a fleet engineering head on?).

Where EBPMS is not used, the guide goes on to say that the expectation (read as must do), is that a minimum of 4 laden brake tests spread evenly across the year are carried out (including the RBT check at MoT).

Now, if your inspection frequency based on mileage, age, nature of operation (to name but a few considerations), dictates that this is undertaken at 12-week intervals, each inspection requires a laden brake test. If your inspection frequencies are 6 weeks, you’ll undertake 8 safety inspections, 8 brake tests, 4 of which must be laden. (Every second inspection to maintain an even spread throughout the year). The thing here is that to have a meaningful assessment of brake performance, in my opinion, every safety inspection should wherever possible be conducted with the vehicle or trailer in a laden condition.

I hear the groans, about the impact on service delivery additional cost and that sometimes this is just impracticable, that’s why the guide also gives a little breathing space, vehicles can have their laden RBT brake test up to 14 days before the scheduled mandatory safety inspection

With the last paragraph in mind, it is therefore, again in my opinion, no change to what I believe should be happening, regarding planned safety inspections and in particular brake condition monitoring.

I’m sure you’ll agree that we all want to ensure the highest of standards when it comes to the safe operation of our fleets, this is another step in the right direction.

Check out the details by reading the 2024 Guide to Maintaining Roadworthiness for full details, available on the gov.uk website (it’s always worth a refresher).