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New regulations: counting the cost

A large fleet user concludes his assessment of the likely effect of new legislation on commercial vehicle operating costs

Par-t2 THE REDUCTION in the maximum driving period of from 11 hours to nine is approximately 18 per cent of a driving day. This is a point made by Mr. L. G. Reed, managing director, United Builders Merchants Transport Ltd., Bristol, in a discussion on the effect of new legislation on operating costs.

We moved on to this point after dealing with quality and quantity licensing and the introduction of the transport manager's licence— which I wrote about in this series last week.

The reduction in drivers' hours means an equivalent reduction in the work of each vehicle, unless additional drivers are employed, says Mr. Reed. And because of the relatively short "effective delivery time" in any one day, extra drivers will be the only solution for operators in some industries. A further option is to use an additional one in five lorries and drivers.

As it is still permissible to work an extra two hours in connection with the vehicle or its load, it is clear that the proposal to cut the day's driving time to nine hours is aimed at the long-distance haul as opposed to relatively local work, Mr. Reed contends that, together with the 100-mile limit on the operation of vehicles over 16 tons gross weight, this could ultimately mean the end of most long-distance heavy road transport.

The reduction of the spread-over period from 14 to 11 hours will considerably restrict flexibility of operation, particularly for the own-account operators. In many instances the driver has a function which involves more than just delivering the goods, and this feature will be impaired by this hours reduction.

It may be necessary in some trades to have to follow these delivery vehicles round with another employee to complete the service aspect which at present is fulfilled by the lorry driver. In that event the effect on cost will be grave.

The introduction of a 22-hour period, says Mr. Reed, is going to complicate still further the completion and checking of records. This continuing process of extending and making returns more involved can only result in making the necessary clerical work more exacting and expensive.

In many cases the requirement in the proposals for a driver to have one day off per week will not complicate current working arrangements as economic necessity already does not warrant the premium rates of pay which are normally payable for the seventh day. But if this becomes a legal provision flexibility will be once again impaired.

These circumstances are most likely to involve the delivery roundsmen and service engineer operating the smaller vehicles for which it is proposed that records of hours of work should be abolished. But while it is universally agreed that this latter proposal is long overdue, little overall advance will be made if the abolished records of hours of work are to be replaced by records of days of work.

The new provisions concerning brakes, plating and testing embodied in the C and U Regulations 1966 and the Road Safety Bill 1967 will have far reaching effects on costs. This, in fact, is generally recognized. The additional expense to which an operator will be committed by braking standards will depend on the standard he maintained in the past.

But as with other aspects of legislation few standards have been laid down in the past relative to the engineering side of velicle operation. So generally speaking the law was satisfied if safe working was observed.

Now, however, minimum performance figures are laid down for brakes which must be met at all times. Assuming an operator has maintained his fleet so far to a high standard further expenditure will, nevertheless, be required to brake gear to ensure that the "in service" level is higher than the minimum demanded.

The scarcity and high cost of garage labour will mean that brake lining and other wearing parts will in most cases be replaced before they reach the end of their economic life because no chances can afford to be taken in the future. Laudable though this decision may be, Mr. Reed contends that it can only result in heavier costs.

Tapley checks

By far the greatest proportion of operators will not have access to roller brake testers and will therefore have to depend on the Tapley meter type of check. This will mean loading with test weights and taking a lorry to a stretch of road where sufficient speed can be attained and brake application made safely.

Depending on local circumstances such tests must inevitably be tune consuming and half a day's work—with attendant loss of use—would not be over-estimating the cost of a simple brake check. Where vehicles were engaged on exacting work involving high mileage it would not be unrealistic to consider that one check a fortnight would be necessary.

But even if one check a month was sufficient, six days work a year per vehicle would be lost to which must be added six days fitter's labour.

Mr. Reed claims that plating proposals to specify both the maximum gross weight and specific axle loading will demand a complete reappraisal of loading bay practice. If it is necessary for an operator to approach closely to the maximum permitted gross weight it may be necessary to have more than one check-weigh while loading and possibly a re-arrangement of goods on the platform so as to get the balance between individual axles correct. Moreover, the resulting longer periods at the loading bay could necessitate additional loading space.

Constant check-weighing would mean a completely new expenditure for many fleet operators. The use of public weighbridges once a day by a 100-vehicle fleet could cost £6,250 a year.

Admittedly, if all vehicles operated from one base it would pay to install one's own weighbridge but often traders' fleets in particular are split into groups of, say, eight to 10 units when the facility of a public weighbridge provides the only economic solution.

The biggest single factor affecting costs resulting from plating will vary from fleet to fleet and in some instances would not arise at all.

Where full capacity loads are carried as a regular practice careful consideration will have to be given to the type of vehicle at present used. As a result of plating and minimum braking standards many lorries may not be able to carry the same tonnage in future.

A typical example of this is the popular two-axle rigid normally rated as a 7/8 tonner which, with a kerb weight of 4+ tons, can carry a 9-i-ton load under the present legislation. A similar vehicle designed to meet the 1966 C and U Regulations will have a legal gross rating of 11+ tons.

In this particular example seven plated vehicles would be needed to do the work of five operating on the old basis. But whatever the individual circumstances, careful assessment will be needed by every operator to establish whether there is need for any change of plan, whether vehicles will have to be down-rated and the number increased so as to carry the same amount of tratic or whether certain sections of the fleet will need to be prematurely replaced.

Mr. Reed considers that the cost of annual inspection of goods vehicles can be fairly accurately estimated although few operators would have the same set of circumstances. A typical estimate of the cost of a vehicle attending a test centre is as follows: driver/mechanic (say 20 miles return trip and three hours attendance)—£1 10s; vehicle running cost for 20 miles—£1; MoT fee—£5; chassis cleaning—£10; additional pre-inspection work—£10; loss of vehicle earnings—£9; total—£36 10s.

This estimate could be less for some fleets--but in many cases it is likely to be more, Mr. Reed argues. Particularly would this apply where preparation and steam-cleaning facilities are only provided at base and travelling time and mileage to and from the outlying depot have to be added to the estimate already made together with the cost of the vehicle's temporary replacement. In the latter circumstances additional vehicles needed as a result of the MoT tests could be in the ratio of one to 50. But this proportion might be conditioned by the decision reached on the method of calling up vehicles to the test station.

The most expensive item of test equipment needed would be a roller tester costing about £2,000. Obviously it could only be justified where there was a concentration of vehicles. The alternative is a decelerometer at about £25.

However, it's complicated by the fact that straight and level stretches of road with little traffic are needed to carry out tests safely. This, Mr. Reed points out, may mean travelling some distance from base with the attendant additional expenditure.

Realism To assess brake test results satisfactorily it is necessary to load the vehicle with test weights and also provide facilities to mount and demount the load, all of which would add to the cost. Public garages are gearing up to the demand for the necessary services from small operators, but until details of requirements are clearer the costs of such tests are not yet generally available.

If the proposed changes in legislation regarding compulsory regular vehicle inspection and maintenance become effective this aspect will be of paramount importance to operators. Every operator will have to face the fact that the standard of maintenance and —entirely separately—the standard of inspection of his fleet will become the main yardstick in determining his qualification to hold a licence.

Standards of maintenance and resulting cost can be calculated without much difficulty because such figures are already known. But the cost of the necessary inspection, when considered as a separate entity, introduces a new factor for most operators.

Again the geographical location and disposition of a vehicle fleet will determine the number of vehicle inspections required. As to the cost of providing an inspector, this is likely to be approximately £2,400 a year when all expenses are included.

Schemes such as the TRTA inspection scheme, as national coverage continues to expand, will be of value to both large and small operators. But whether one does one's own inspection or not a new cost will be added to the repairs bill.

Because of the need to keep maintenance and inspection records as statutory documents, more clerical staff will have to be employed. Although the form and amount of detail required is not yet known, Mr. Reed believes that this task could be very complicated and expensive unless some flexibility is permitted.

Finally the effect of the increase in the maximum penalties from £50 to £200 is bound to be salutory. Moreover the new regulations provide many more ways in which the law could be broken while the number of people involved is also extended. To put an annual cost on this item must be speculative, Mr. Reed admits, even though the prudent operator would hope that no item of expense would occur in this category.