I was wondering if anyone else in IOSH with minibus responsibilities was aware that on Thursday 08th February, the UK Government’s Department for Transport launched a consultation on the use of section 19 and 22 permits. This consultation sets out how it intends to change its guidance following a reinterpretation of how certain EU regulations on passenger transport and driver licencing should be applied in England, Wales and Scotland.
I work for a school, as such we are classed as a ‘not-for-profit transport service’ and so we operate under a section 19/22 permit, rather than having to apply for a commercial operator’s licence. This means like local authorities and charities we use MiDAS training and 10 weekly vehicle inspections, to ensure our transport services are safe and legal.
The crux of the matter is, following a challenge from a group of commercial bus operators, the Department for Transport has recently proposed changes to eligibility for section 19/22 permits. The changes are an attempt to clarify how European Union regulations regarding passenger transport and driver licencing should apply.
As a result of the proposed changes, all schools, charities, local authorities (or any other non-profits) running a 9 seat or more minibus on a section 19/22, may need to do so under Public Service Vehicle Operator’s Licence (PSV O licence) in the future.
As a school and looking the information provided by the Community Transport Association (see below), we will not have to apply for a full PSV O Licence. However, the consultation may also mean that if the organisation uses any paid member of staff (regardless of their job role) to drive a minibus they will require a Driver CPC qualification.
We are a large school with 85 MiDAS trained staff, most of them teachers, some of who (the younger ones) only have a class B driving licence. In this eventuality, as a worst case scenario, in order to get all staff to be D1 licence holders and through their CPC will cost the school in the region of £55,000 and up to 295 lost working days. That’s a lot of teaching time!!
If you need more information the Community Transport Association, has a lot more information. https://ctablog.org/2018/04/13/help-us-protect-community-transport/
I would however be interested to hear from anyone else who is in similar boat to us, who would like to try and lobby against this becoming law. These changes will have severe impact on our school’s educational visits and sporting fixtures, just so that some commercial transport companies can make some more money.
Let me know if you want direct contact details
Thank you
Philip