I am self employed in the UK as a welder/fabricator making bits for race cars. In a previous life, I worked for European race teams and did some HGV driving when the team required. My licence is still valid/ I have CPC and I have the chance of some work in Germany and the rest of Europe this summer which I am interested in doing. Laws have changed and I have some concerns so I am looking for some knowledgeable answers.
The company who want my services are based in Japan and they want me to drive a truck which is leased to their European arm of the company. Now I don’t know if they are actually operating legally. Hence I won’t name them. They have 2 trucks, German registered, and they are leased so they are good trucks with all the correct documentation. But I can’t seem to find out if they have the German equivalent of an O licence. There isn’t a transport manager. There obviously wasn’t an issue with leasing the trucks from the truck company but I am not sure if you need an O licence to lease a truck in Germany. I am pretty sure that you would have to in the UK?..or maybe not.
These trucks are used periodically for moving cars around but the drivers just seem to be agency guys who they employ on a very occasional basis. These guys have a had a few speeding offences last year so this company have had communications with the German police. I would like to get involved this year but I don’t want to be driving around illegally. I know from past experience that race trucks don’t attract the police attention so easily but I don’t want to risk the chance of any wrong doing.
My other concern is letters of attestation, or lack of them. I can’t see how I can account for my non driving periods. As there isn’t a transport manager to be found, how can I approach the attestation letter situation? Can I just fill out a logbook/diary as my work will only be 2-3 days a month and then I go back to the UK. Also, the trucks are based at a workshop which is 300km from this companies main office so I wouldn’t be able to get someone of any sort of company boss to print and sign one for me.
So if anyone has any thoughts on German truck laws and the above situation, I’m listening.
Can’t really help with the German O license situation, there’s a member on here called Insellafe who’s German based, sure if he spots this thread he’ll fill in the details for you.
I’d be very surprised if the company has had recent dealings with the police and not been picked up for having no O license though.
Attestation letters are no longer required in the EU so a log/diary recording your non-driving days would be acceptable.
German police tend to be pretty clued up so shouldn’t be surprised a race team driver isn’t driving every day, just make sure you comply with daily/weekly rest requirements etc.
Having worked in European motorsport since about a week ago, I wouldn’t be overly worried about the trucks if they look well maintained and legal and especially if it’s operating on behalf of major sponsor. Most race teams in the UK only operate on a restricted licence, so don’t actually have a qualified TM, so having no TM should be nothing new.
I found letters of attestation useful and was stopped in Spain a couple of years ago and asked for them to account for days not covered on the tacho.
But as they’re gone and trying to do a manual entry for a weeks work is bloody difficult without losing track. What we do is keep the tacho running at the circuit if the truck is behind the garage, except circuits like Spa you remove the unit and park it out of the way, so it’s card out and either not worry or have a time sheet, I haven’t been stopped using either option yet, but hopefully sense will prevail. I know other who just leave it on rest for the week.
Personally I wouldn’t worry to much about it, I’ve been stopped many times running round Europe with race trucks and rarely had anything to do with tacho checks, just make sure you have plenty of caps an t’shirts. 
The German BAG enforcement are hot on load security, it was due to the large infux of Eastern European drivers transiting the country and loosing their loads in accidents, shutting motorways all day to clean up the mess.
Another issue is the authorities may have put a marker on the trucks for unpaid fines or court orders .
If they are leasing the trucks I’m sure the lease company will have ensured the paper work will have been in order before releasing the trucks