Shunting

Hi

Where i work the company has two yards , connected by a max of 50 foot of single highway on an industrial estate. During the loading operation on a nightly basis trucks are often moved up and down the road to each yard to facilitate loading arrangements. Currently the company does not employ a full time shunter , however the movement is always carried out by a hgv driver. This can involve 15 plus vehicles per night going up and down that 50 foot of road between yards. Currently the drivers do not put a tacho card in when they shunt the vehicles.

My question is do they need to put a card in for each seperate shunt they do between the yards ,and if so is there any maximum number of shunts that they can do per night using the card.

I know I’m brand new to commercial driving but have just done all the studying and tests. If I remember rightly drivers reg’s don’t apply if the whole journey is started and completed off road, Ie not on a public highway. If the industrial estate is not maintained by the local council then it should be exempt as far as I can see. What do you think?

Tom.