Causing or
Permitting Driver's Hours Offences
In order for a Haulier
to be prosecuted for Drivers Hours Offences it must be
proved that the Haulier caused or permitted
those offences. Below
are extracts from the Transport Act 1968 and Regulation
561/2006 which may provide a defence to such charges.
To prevent prosecution
for permitting offences, Hauliers should follow our
simple advice.
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Download data from
analogue charts, driver cards and vehicle units and
have it properly analysed using our software for the
analysis of analogue and digital data.
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Utilise our
Complete Tachograph Data Management Service
to ensure that
your digital data has been checked by people who
have the relevant knowledge, edited and assigned
where necessary.
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Regularly print
driver reports and working time directive reports.
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Assign a member of
staff to go through these reports with the drivers
and have the drivers sign the reports.
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Give proper
training to drivers who regularly commit breaches of
the legislation.
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Have in place a
discipline policy for habitual offenders.
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Abandon paper
records such as worksheets and use the full
capabilities of our software.
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If you insist on
using outdated paper records, make sure that these
are checked against data downloaded from driver
cards and vehicle units and that the driver is
recording all of the time that he is on duty on his
card. The same applies to clock cards.
If you fail to follow
these instructions you will leave yourself open to
prosecution. You should view the fines that can be
imposed for breaches of Section 96 11(A) in
this document.
Guidance
to CPS on Traffic Offences.
Link
http://www.cps.gov.uk/legal/p_to_r/road_traffic_offences/index.html#P48_1556
Tachograph Cases and Public Interest Criteria
You should
consider the following factors, whether you are
prosecuting drivers' hours, breaches or falsifications:
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assessment of the role played by each person in the
company/operator in the case of large scale
prosecutions;
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whether
there has been systematic flouting of the law
resulting in widespread falsification of records
endorsed by management. In serious cases a
conspiracy charge should be considered;
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consider
using as witnesses persons who might be guilty of
the offence or offences such as office staff and
drivers where they have been threatened with the
sack unless they continue to act illegally. It
should, however, be remembered that the driver is
the "person at the wheel;
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falsification of records usually takes place to
enable more journeys to be undertaken than would be
possible during lawful working hours, thereby
jeopardising road safety.
The
Transport Act 1968
Offences
in Contravention of the Regulations - Section 96:
Charging Practice
Section
96(11) TA creates offences for breach of the domestic
drivers' hours code, while section 96(11)(A) TA creates
offences for breaches of the European Community
Regulations. In the great majority of cases the offence
will fall within the second of these provisions.
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Liability for these offences falls upon the "Driver"
(for the Domestic Rules) or the "Offender" (for the
European Community Rules).
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Under
section 96(11)(b) TA liability also falls upon "any
other person (being that driver's offender's
employer or a person to whose order the
driver/offender was subject) who caused or permitted
the contravention".
In
Skills Motor
Coaches Ltd, Farmer, Burley and Denman (Case C-297/99),
the European Court of Justice
The
Court held that driving time spent performing a
transport service also constituted a period when the
driver was actually engaged in activities liable to have
a bearing on driving, during which he did not freely
dispose of his time. A transcript of the judgement is
available.
Sections 96 and 97(1) create absolute offences for the
driver/offender. This is not the case so far as the
employers or persons in authority are concerned. There
must be evidence upon which a Court can properly infer
that an employer gave a positive mandate or some other
sufficient act to 'cause' the offence to occur. Mere
passive acquiescence is not enough - see
Redhead Freight Ltd v Shulman [1989] RTR 1.
Other recent cases on drivers' hours include
Vehicle Inspectorate v Southern Coaches and Others
[2000] RTR 165
and
Vehicle Inspectorate v Nuttall [1999] Crim LR 674.
In the
latter case the House of Lords held that the Community
rules placed a responsibility on employers to use
tachograph records to prevent contraventions and to
promote road safety.
Although the offence was not one of strict liability,
'permitting' in section 96(11A) was to be given a wide
meaning of failing to take reasonable steps to prevent
contraventions, to be governed by the objective
standards of a responsible employer. Nothing less than
wilfulness or recklessness would suffice. See also
Yorkshire Traction Co Ltd v Vehicle Inspectorate [2001]
RTR 518.
In Vehicle
Inspectorate v Blakes Chilled Distribution Ltd [2002]
166 JP Jo.118, the Administrative Court held that the
intent necessary to prove vicarious liability was
established where it could be proved that an employer
had failed to take reasonable steps to prevent
contraventions by drivers, provided that such failure
was not due to honest mistake or accident. Knowledge
that an operating system was defective, and that that
deficiency could lead to the commission of offences, was
the only knowledge required of an employer as a basis
for vicarious liability.
Under Section 99ZE 3(f) of the Transport Act 1968
A person
commits an offence :-
3 (f) if he fails without reasonable excuse to record
any data on recording equipment or on a driver card, or
causes or permits such a failure.
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For the
purposes of this section, a person shall be taken to
permit an act or omission if he is, or ought
reasonably to be, aware of the act or omission, or
of it being a likelihood, and takes no steps to
prevent it.
Under
section 96 it states:
(11A) Where, in the case of a driver of a motor vehicle,
there is a contravention of any requirement of the
applicable Community rules as to periods of driving or
distance driven, or periods on or off duty, then the
offender and the offender’s employer, and any other
person to whose orders the offender was subject shall be
liable on summary conviction to a fine not exceeding
level 4 on the standard scale.
(11B) But a
person shall not be liable to be convicted under
subsection (11A) if :-
(a) he
proves the matters specified in paragraph (i) of
subsection (11); or
(b) being
charged as the offender’s employer or a person to whose
orders the offender was subject, he proves the matter
specified in paragraph (ii) of that subsection;
or
(c) being charged as mentioned
in paragraph (b), he proves—
(i) that at the time of the
contravention he was complying with Article 10(1)
(distance-related payments etc) and Article 10(2)
(organisation of drivers’ work etc) of the Community
Drivers’ Hours Regulation; and
REGULATION (EC) No 561/2006 OF THE EUROPEAN PARLIAMENT
AND OF THE COUNCIL of 15 March 2006 on the
harmonisation of certain social legislation relating to
road transport and amending Council Regulations (EEC) No
3821/85 and (EC) No 2135/98 and repealing Council
Regulation (EEC) No 3820/8
CHAPTER III
of the above regulation states
LIABILITY OF
TRANSPORT UNDERTAKINGS
Article 10
1. A
transport undertaking shall not give drivers it employs
or who are put at its disposal any payment, even in the
form of a bonus or wage supplement, related to distances
travelled and/or the amount of goods carried if that
payment is of such a kind as to endanger road safety
and/or encourages infringement of this Regulation.
2. A
transport undertaking shall organise the work of drivers
referred to in paragraph 1 in such a way that the
drivers are able to comply with Regulation (EEC) No
3821/85 and Chapter II of this Regulation. The transport
undertaking shall properly instruct the driver and shall
make regular checks to ensure that Regulation (EEC) No
3821/85 and Chapter II of this Regulation are complied
with.
3. A
transport undertaking shall be liable for infringements
committed by drivers of the undertaking, even if the
infringement was committed on the territory of another
Member State or a third country.
Without prejudice to the right of Member States to hold
transport undertakings fully liable, Member States may
make this liability conditional on the undertaking's
infringement of paragraphs 1 and 2. Member
States may consider any evidence that the transport
undertaking cannot reasonably be held responsible for
the infringement committed.
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