In my personal opinion' having dealt with this area on a number of occasions' the Road Transport Legislation does not stand up to scrutiny for much of H&S law and are not designed to do so The kit is PUWER which ever way you look at it with all that it implies but suppliers/manufacturers do not, in my personal view, understand the areas at all so it can be an up hill fight especially if your procurement are not on the ball as they will just take the suppliers side especially if it has already been procured! Update yourself again to be on the safe side and move from there to educate your procurers; and I, without updating myself [from memory] would side with your interpretation noting that U will have a lot of education to do with your own procurers It also depends on how deep your pockets are as suppliers listen if you are looking to part with lots of £ but if its a low cost one off situation they may not move from their current position Overall if its low risk bit of kit in all its operation modes then move on as the argument will not get you far