Desk Based Assessments – How to Tackle the Beast
By CET Carolyn Evans
Desk Based Assessments have become the remote tool of choice for the DVSA since COVID.
Have they become a stick to beat operators with or a fair assessment of an operator’s compliance systems?
What is a DBA?
A Desk Based Assessment is a remote Audit which began during COVID and has continued unabated ever since. The assessment can be on the traffic or maintenance side of the business (or both). The operator is asked to produce a sample of their records in order that a DVSA officer can assess the systems to assess whether they meet current good practice and legal requirements.
What triggers a DBA?
- Roadside check - prohibition
- Application to Increase OL
- TC Request
What does it involve?
The DVSA make an initial request allowing 14 days to supply the documentary evidence in a soft copy format.
They supply a Guidance document with the initial request which sets out:
- What will amount to sufficient / Insufficient Information
- How to send the records
- Which documents to send
- What will happen in the event of non compliance
At the end of the request letter is a section titled ‘IMPORTANT’ which just explains that the request is a formal one and should be responded to by the Transport Manager or Director (if the licence is restricted).
My advice is to read both the letter and the Guidance document carefully. It sounds like an obvious point, but you may not be surprised to learn that a lot of the errors which crop up later could have been remedied by a simple reading of the initial request letter and accompanying guidance.
Complete the DBAQ
After reading the guidance documents carefully, make sure the Desk Based Assessment Questionnaire (or ‘DBAQ’) is fully completed. In each section you must include a detailed explanation of your system and produce accompanying evidence in support.
I attended a hearing recently where there had been some criticism of the operator for failing to describe his documented process for investigating MOT failures when he had not previously had a vehicle fail at MOT!
Another classic issue is not including images of the maintenance facility. In addition to describing the facilities available (decelerometer, roller brake tester, pit, headlamp alignment) you must provide evidence of the facilities. This request generally causes some consternation at the contractors’ premises. You may have to re-assure them that the reason for the request is in order to satisfy the DVSA that your contractor has the equipment available in order to adequately maintain your fleet, not to remotely assess their capability.
When complete, it is a good idea to supply an index and check the attachments before they are sent so that you can be sure you have sent everything you intended and can PROVE you sent everything required. A common error is to find that only e mails 1,2, and 4 ‘got through’.
Tools to Help
There is a reasonable amount of information available online which you can use alongside the Guidance Document and checklist provided.
Although some Transport Consultants will assist with the preparation of material and completion of the DBAQ, ultimately the Transport manager / Operator has to sign this off in circumstances where they are content that all of the elements have been completed satisfactorily.
We have produced a short video which you can also watch (if you are having trouble sleeping) which can be found here Invergold’s West Midlands Transport Conference 2023 - Presentation: Carolyn Evans (youtube.com)
What Happens Next?
When you have lodged the DBAQ and accompanying material you will be sent a ‘Request for Further Evidence’ (or RFE). This is a final opportunity for you to provide supporting information.
In my view, anything you provide at this stage is less impactful. It is unlikely to change the initial scoring and the best you can hope for is that the author / assessor will add the material in an addendum. In other words, the damage is already done.
Your final response is then graded as satisfactory or unsatisfactory and may result in a warning, further assessment or a report to OTC.
4 Categories
We have put the DBAQ responses into 4 general categories or ‘buckets’ to give you an idea of the common pitfalls.
The first response bucket is just ‘inadequate’. This is where the operator has provided evidence of their systems but what they have in place does not meet the current standard. The operator may simply fail to respond at all in these circumstances citing fire / theft / memory loss / pressure of work, etc.
The second response bucket is ‘descriptions too short’. This is where the answers provided in the DBAQ were too short and so the auditor was unable to ascertain whether the systems met the criteria.
Number three on our list is a ‘lack of evidence’ bucket. This is where the operator has given fairly detailed information in the DBAQ but has not provided proof of the system they are describing.
Finally – and most commonly – we have the ‘Basic not Best’ bucket. This is where the operator has all of the basic systems in place but has failed to keep up with the constantly changing standards and requirements. A common example is where the operator is having the vehicles serviced and maintained but does not have a VOR procedure, recall and defect recall checking system or driver training.
There is of course a fifth category of ‘meets the standard’ which we hope you will all reach after reading this!
Our Advice
Approximately 50% of our cases which end up at a Public Inquiry started with a desk based assessment.
If you are planning to increase your fleet size, have been the subject of a roadside prohibition or have an issue with OTC you may be required to participate in one of these assessments.
It is good advice to have an external audit of your systems to identify any shortcomings so that you can remedy those issues prior to the DVSA letter dropping on your mat.
The DBAQ completion can be tricky so if you are not satisfied that you can do this adequately then draft in some assistance or professional advice.
Finally, use all of the publicly available material to guide you through the process and follow the checklist provided.
Good luck!