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Page 53
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ADY a few adept operators will have ick to their Licensing Authority the en application form devised by the -y of Transport as part of a pilot for quality licensing. They have ;urprised to find how seriously the y takes the responsibility of deciding 3" existing licence holders should be to continue.
a time the idea was encouraged or at ot strongly contradicted that operateady in business could with very few Loris expect to be granted a quality almost automatically. The tone was long ago as November 1967 in the Paper on the transport of freight ted by Mrs. Barbara Castle.
assurance was given to existing operthat most of them had the sort of which would enable them to "be d a licence with the minimum of gation". At the same time there was a ig that some operators could "expect ast searching inquiries to be made". ad been regarded as a saving clause ver an exceptional case where an or with a notoriously bad record himself left out in the cold.
ring an illusion?
some extent the Transport Act 1968 d the illusion. The established operais put in an apparently privileged n. He was required to satisfy the ing Authority only on some of the laid down and he was to be exempt ibjections at least to his first applica tainly, if 200,000 quality licences are ssued within a period of from four to mths the Licensing Authorities will ye much time in which to make up ninds on individual cases. This fact lay have strengthened the impression le first grants would be little more formality.
reflection it must be plain that the s cannot exactly follow the precef the caucus race in Alice in Wonder/here everybody must win and everymust have a prize. In these circum s the application form for a replacelicence would have been in the St terms. There would have been no lar the pilot scheme in which about operators have been asked to take
:ording to the Ministry the scheme is ed to test the suitability of the forms he point of view of both operators and nd to test the efficiency of office procein the traffic areas. Sensible operators lave not received the dummy form be well advised to obtain a copy. It elp them to assess in advance how rorn organization will stand up to the and searching inquiries that it con
way in which some of the questions vorded may produce incongruous ; in the mind. It is not known whether spect of the pilot scheme was the t of comment by the Freight TranAssociation and the Road Haulage Association who have given the scheme their support. They may have been more concerned with the content of the form than with the phraseology which they no doubt accepted was best left to the civil servants.
Perhaps it is in accordance with established drafting procedure that the second section is headed "Past History". The operator may easily have been misled into supposing that completion of this part of the form would be a pleasure rather than a hardship.
One can imagine the typical operator setting himself for a congenial task which he is usually discouraged from performing. Here at last is a kindly LA who actually wants to know the detailed story of how the applicant's father founded the business after the First World War, how it was sold to the British Transport Commission shortly after the second and how the present licence holder bought it back a few years later for half the price he had been paid in compensation. When the 1933 Act became law....
At this stage the operator may begin to wonder where on the form he is to put down the facts that are so readily assembling themselves in his mind. A glance at the actual questions in the section with such an inviting title will at once show that he has been thinking along the wrong lines.
Obsession with past misdeeds The questions relate almost obsessively to his past misdeeds or those of his company. The attitude of the Ministry towards history leaves no room for sentiment and strips the chronicle down to a mere catalogue of crimes.
Revocations, suspensions and convictions are the items in his past history that the operator would prefer to forget They are also the items that the LA is most likely to have on his records. The operator will find them branded in his memory by the time he has finished. The experience will be very much like going into the witness box on oath.
If the operator has depots in various parts of the country he may find himself repeating the experience again and again as in a dream or in a form of penance that schoolboys used to describe as an imposition. A separate application has to be made in each traffic area where there is an operating centre and the questions make it clear that the list of misdeeds will have to be repeated on each occasion.
There is more than a touch of the school examination room about the form. The operator with a bad record may well consider that he has failed in History or at best has scraped through with a pass. The next subject is headed "Maintenance"; the first question reads "At what intervals are your vehicles inspected for defects?"; an explanatory note gives the stern injunction "All applicants must answer this question".
Answers obligatory This is the very tone of the examination paper and it may kindle the faint hope that there are other questions the applicant need not answer if they are embarrassing. There are no such options except where questions have to be duplicated to suit different circumstances. Otherwise answers seem obligatory and in most cases the point is reinforced with the peremptory injunction "Answer YES or NO".
This procedure not only forces the operator's hand. It leaves no room for explanations or excuses. It faces the unsatisfactory applicant with a dilemma. To the question "Do you provide for regular reporting of defects by vehicle drivers?" he knows well enough what answer will gain full marks and he knows equally well that the opposite answer is the correct one.
He should be relieved if not grateful that he has seen the questions in advance—a privilege not usually accorded to examination candidates. If he does not already provide for the regular reporting of defects by his drivers here is a clear warning that he should institute the procedure at once:
There are other questions of the same type. The operator has to say whether, when defects which affect the safety of a vehicle are discovered as a result of inspections, the defective vehicle is immediately taken out of service for repair. He has to say whether records are kept of inspections and work carried out on each of his vehicles and how long he keeps the records.
In any case where these elementary items are not a commonplace to an operator he should act at once. There are much stronger reasons for doing this than the desirability of providing an honest affirmative answer when the time comes to complete the application form in earnest.
He may not find it so easy to make good any deficiencies in his maintenance system. He can at least use the form as a guide in bringing about what improvements are possible in the time at his disposal. There is nothing he can do in advance to make a better showing on the historical questions which are concerned with the five years that have already passed. All that he can hope is that the LA, having refrained from revoking his licence for his earlier faults, will be equally considerate in granting an operator's licence to enable him to move forward into the future.