Mechanic using a Digital card

Can anyone give me advice on wether I need to use a digital card for road testing, and also for the presentation of a vehicle for MOT.

I went for a test last week and the tester as part of the test printed off the vehicle data to check the K factor, he then
told me under data protection that I should not have inserted my card as my details are on the print out, well that suits me
fine I thought, so next time I put the tacho out of scope, and on test I was told by a different examiner that I was committing
an offence by not using a digital card, I only drive vehicles for transporting goods purposes occasionaly.

Dave…

dave docwra:
Can anyone give me advice on wether I need to use a digital card for road testing, and also for the presentation of a vehicle for MOT.

I went for a test last week and the tester as part of the test printed off the vehicle data to check the K factor, he then
told me under data protection that I should not have inserted my card as my details are on the print out, well that suits me
fine I thought, so next time I put the tacho out of scope, and on test I was told by a different examiner that I was committing
an offence by not using a digital card, I only drive vehicles for transporting goods purposes occasionaly.

Dave…

I know I’m in France, but all our fitters have there own digi-cards for the above purpose. I’m sure it’s the same in the UK.

gov.uk/drivers-hours
“…Some types of vehicle are exempt from EU rules. This means they come under GB domestic rules in the UK.
…vehicles undergoing road tests for technical development, repair or maintenance purposes,…”

So, if you are under GB Domestic rules:

“You must record your hours on a weekly record sheet or on a tachograph.”
You can choose to record hours on a Tacho Card or in a Log Book.

But again:
“Exemptions to the GB domestic rules
The GB Domestic rules do not apply if you:
drive for less than 4 hours in any day”

Keeping a record will show if you are under 4hrs a day.

BUT if you are mixing the above with delivering goods, then you will be under EU rules for that work:

“Driving under both EU and GB domestic rules
If you work partly under EU/AETR rules and partly under GB domestic rules during a day or a week you need to know the following:
driving under EU rules counts towards the driving and duty limits under GB domestic rules
on any days you drive under EU rules you must take EU daily rest periods, as well as a weekly rest period
you cannot count the time you spend driving under EU rules as an off-duty period under GB domestic rules
driving and other duty under GB domestic rules count as ‘attendance at work’, not as a break or rest period under EU rules”

If all your driving is done “on the card” it is easy to keep accurate records.
Can`t see anywhere that using a tacho card is in any way wrong.

dave docwra:
Can anyone give me advice on wether I need to use a digital card for road testing, and also for the presentation of a vehicle for MOT.

I went for a test last week and the tester as part of the test printed off the vehicle data to check the K factor, he then
told me under data protection that I should not have inserted my card as my details are on the print out, well that suits me
fine I thought, so next time I put the tacho out of scope, and on test I was told by a different examiner that I was committing
an offence by not using a digital card, I only drive vehicles for transporting goods purposes occasionaly.

Dave…

On days that you’re not carrying goods and only driving on public roads to road test vehicles or deliver a vehicle to a test station I’d say you do not need to use a driver card.

Here’s a link to the guide written by the EU commission on this very subject

It may be worth checking with the DVSA that they comply with this EU guide though, they’re not obliged to but I’d be surprised if they don’t.

I can’t find the relevant Gov UK advice page quickly, it was there once but they seem to vanish when you want them. I looked at this carefully a while ago since I am in the same ‘boat’. If you are not employed as a driver but as a mechanic you do not need to insert a digicard if you fulfill all the conditions. Driving is not the main activity of your employment, You do not exceed 100 km from base, you do not drive for more than 4 hours on the relevant day, and the purpose of the driving is solely to road test the vehicle or take it for a pre booked MOT appointment or Brake Test which is at a recognised ATF. However the vehicle is ‘supposed’ to be unladen which is the stupidest stipulation going since it probably needs to be laden for both purposes… So that becomes ‘Test Weights’. You are exempt from the DCPC as well unless you drive the vehicle in other circumstances.

Since you are under Domestic rules I set the tacho to ‘out of scope’ and do a vehicle print out afterwards as a record. Since I do not want to have to be bothered with recording any other days for that week and I make sure I do not drive ‘commercially’ during that week.

As I understand it,
Road test no if under 60 miles total
Mot present no again if under 60 miles total
Take a truck out to swap for a broken down one, yes need card
Drive truck back becasue driver ran out of hours yes need card
If you put the card in for any reason then you have to do it for the following 5 days on other work I think.

Quite a few mechs have their hgv but no digi card.

Would the easy solution not be to drive the vehicle to the test centre with your card in once the test is about to begin remove the card and then re-insert once the test is over.

That would mean you would have to make a manual entry for the missing time, the vehicle would flag up having moved during that time and one can guarantee that the entires would not tally exactly to the minute, but more of a nuisance you would have to keep a record of all your working hours for that entire week…a pain if it is a Monday meaning you have to do it for the rest of the week. Even more of a pain if it is a Friday and you have to start trying to remember Monday to Thursday and account for a weekly rest period at the start of the week. Not too bad I suppose if you do it every week because you will be recording as a matter of habit, but doing what is correctly out of scope exempt driving once every few weeks is a different matter.

Having had another trawl through Gov UK the only one I can find is 2013, which says exactly the opposite, because as usual HMG have not updated what appears to ensure that the post 2017 revision of the regs to make this exempt is what a search engine comes up with.

Or when next at testing station ask the tester, as most of them do roadside too.

biggriffin:
Or when next at testing station ask the tester, as most of them do roadside too.

If you check the first post, this arose because one tester says “Yes” , and t’other says “No”.

Franglais:

biggriffin:
Or when next at testing station ask the tester, as most of them do roadside too.

If you check the first post, this arose because one tester says “Yes” , and t’other says “No”.

Absolutely, and as the tester blamed HIS GDPR upon the driver, makes you realise how disconnected they are. It looks like the OP has had a fairly good answer and the Gov website gives similar responses as well for mechanics.
About the only thing to be cautious of, is taking a laden vehicle to PMI so later it can be picked up laden by the driver for onward journey and that may be seen as driving for hire & reward rather than being incidental to the business

Acorn:
About the only thing to be cautious of, is taking a laden vehicle to PMI so later it can be picked up laden by the driver for onward journey and that may be seen as driving for hire & reward rather than being incidental to the business

Thanks for all the responses.
Problem with testing now is, that virtually everything has to be loaded.

Dave…

Franglais:

biggriffin:
Or when next at testing station ask the tester, as most of them do roadside too.

If you check the first post, this arose because one tester says “Yes” , and t’other says “No”.

I did with my glasses on, does help… So classic case of left and right, different rules. We expect no less from those who make the rules.

dave docwra:

Acorn:
About the only thing to be cautious of, is taking a laden vehicle to PMI so later it can be picked up laden by the driver for onward journey and that may be seen as driving for hire & reward rather than being incidental to the business

Thanks for all the responses.
Problem with testing now is, that virtually everything has to be loaded.

Dave…

Did you see the subtle difference… take out laden and return to yard laden = good.
Take out laden and allow driver to take it onward to deliver = not good. Not a problem taking to test, it’s how it’s managed on the second part of the journey

Acorn:

dave docwra:

Acorn:
About the only thing to be cautious of, is taking a laden vehicle to PMI so later it can be picked up laden by the driver for onward journey and that may be seen as driving for hire & reward rather than being incidental to the business

Thanks for all the responses.
Problem with testing now is, that virtually everything has to be loaded.

Dave…

Did you see the subtle difference… take out laden and return to yard laden = good.
Take out laden and allow driver to take it onward to deliver = not good. Not a problem taking to test, it’s how it’s managed on the second part of the journey

I am going to and from the MOT ATF loaded, I never get involved in collecting for PMI purposes.

Dave…

If you never carry goods or passengers in that employment, then you can take empty vehicles to test out of scope of the EU regs

But if you do or it’s loaded, then you’re in scope of the EU regs

gov.uk/guidance/drivers-hou … vers-hours

And as a driver I’ve taken a few vehicles for test with my card in, there’s never been an issue, if he didn’t want your card in for his printout, he should have got you to eject it and reinsert it once he’d done it

Trickydick:
As I understand it,
Road test no if under 60 miles total
Mot present no again if under 60 miles total
Take a truck out to swap for a broken down one, yes need card
Drive truck back becasue driver ran out of hours yes need card
If you put the card in for any reason then you have to do it for the following 5 days on other work I think.

Quite a few mechs have their hgv but no digi card.

Or DCPC