Alice in Transportland"
Page 48
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Your recent editorial on driving hours and record keeping was most timely but I would go much further, I would rather see a stricter act with harsher penalties if only it were 100 per cent clear and 10 times as simple.
No one in our firm is clear on the rules (from the managing director to individual drivers) and apart from which it takes a very practised eye a long time to determine if a record sheet is correctly filled in {even if one knew what was correct).
Referring to your Q and A (CM January 1,
1971) on the 60-hour limit last week we seem to disagree with you. In the booklet issued by the MoT, "A Guide to Vehicle Drivers' Hours and Records", page 8 "Exemptions" there is a paragraph headed "Non Driving Days". This says:—
"On days when a goods vehicle driver does not drive, the rules regarding permitted daily duty . . . and breaks for rest and refreshment will not apply to him during that day. Any excess of duty over the limit of 11 hours of duty generally permitted in each working day is not counted towards the 60 hours limit on weekly duty." Section 96 18).
We take this to mean that if a man works away from his vehicle for 20 hours on any day then, so long as he has his 11 hours of rest before starting driving he only counts 11 of these -on duty" hours towards his 60..
Also in appendix 3 (page 21) of the same book it is clearly stated that drivers not driving on any day, {off duty, or on duty but not driving) are exempt from all requirements to carry record books and to make entries in such a book. They are also exempt from recording the end of their last duty period and exempt from keeping a full record of hours of duty, driving and rest for the day.
If Lewis Carroll were alive today he would have already written "Alice in Transportland" —and he would have had no need to invent or twist anything to do it!