Isn’t a 17 seater fine because 1 driver + 16 passenger?
No, a 17 seater is the maximum number of possible
passengers, it doesn’t include the driver.
A 17 seater with just 12 passengers is still a 17 seater.
Someone in our Wing got busted as they were driving and empty bus and tried to argue the fact it wasn’t being used as a bus but as a van…6 points and a hefty fine.
I think your confusing permit 19 with D1 (or adding to the confusion)
If you have the ford transit minibus it is 16 passengers + driver. It’s a minibus but you need to have a permit 19 AND D1 on your license.
I think what you are referring to is driving a 12 - 16 seater on a class b under purely a permit 19 which was always the grey area.
You can do this BUT you have to physically remove the seats. If you leave the seats in you are in breach, leave them out then you are using it as van / crew van
Why would you need a Permit 19 if you already have D1?
The P19 is to enable someone who doesn’t have D1 entitlement to drive a Minibus (upto 3500kg).
Not so, the Section 19 Permit allows you to operate without a PCV as it’s not “hire or reward”
4 Likes
yes, some Wings have a Wing MT Officer
My quick read is that there isn’t anything new in this that we shouldn’t already have been doing. (Un)happy to be prove wrong though.
What I have taken away from it is that we can now use an SOV for Hire & Reward. Although this was always allowed under a Section 19 Permit, RAFAC rules said otherwise - this means we can now ‘officially’ charge cadets for transport costs as long as it isn’t for profit. Also, whilst the requirement for a Daily Walkaround Inspection was always there, it now details what specifically has to be checked and provided a form. There is also the Administrative Check Form to be completed prior to each use. Basically more paperwork.
Although it’s not more paperwork as this should be happening already. It’s just now HQ are giving you a sample of what they want. They’re not even saying you need to use their version.
It’s arguably less paperwork as now you don’t need to create your own check list!
1 Like
Generally this would be true for us. But twice a year we have a request for our SOV to be used on a camp of 300 cadets, with 50 or so staff. Due to commitments our OC cant attend, so would be unable to vet any of the potential 50 staff that might want to use the minibus during the week camp.
They are basically used as taxi’s, and unless the competency of ever potential driver was checked, by my OC, then how can the OC and / or civcom fulfil their responsibilities as per this ACLI?
C
Exactly that & the way we use to do it were the potential drivers came to the Sqn several weeks/months before the camp to do the paperwork & approval.
Having said that I would be very wary of the SOV being used on camp with no Sqn staff attending.
4 Likes
there is an argument that if not used on the public roads does the paragraph in question apply?
i am not suggesting that a 17 year old Cdt FS who has a B licence should drive a bus full of cadets between the Cadet block and the mess saving a 15 minute walk, but if not being used on the public highway and limited to “on station” which typically have 15/20mph limits to taxi the troops from A, to B, to C and back to A in a day (all on station) then while i would still expect the driver to be a D1 holder the insurance is not valid as it is “off the public highway” so from a DVLA/DVSA/Police legal standpoint does it matter if the driver is even insured (ie named driver)?
taking a stricter viewpoint, the paragraph in question indicates that drivers are:
checked for competence (D1 holder)
driver training (D1 Holder)
licence details (Driver licence number?)
only qualified (D1 holder)
Responsible (CFAV?)
competent (D1 holder)
None of that is hard to prove or share. thus as an OC, i could ask the Camp MT officer* the list of drivers and photocopies of their DL.
in return issue SOV SOP - which states there is a vehicle log book which is completed at the start of the day/start with a “first parade” inspection of the vehicle, and at the start of each drivers “shift” (ie Flt Lt Bloggs does the breakfast run, and as first use of the day full inspection completed, and then signed to confirm completed, with start time and mileage recorded. When FS Smith does the lunchtime run, they only need to record they are driving that stint with start time and mileage as the first parade has been completed that day) and then state only those drivers listed have permission to use the SOV. (where the list indicates those Drivers identified who have shared their details)
This way the boxes are ticked. I have put in place a practical system to assure competence, training…etc to the CivCom.
It is much like the RAF system without the training or FamDrive. A bit of a paperwork exercise, but without too much ballache of seeing every driver drive.
As OC i have the list of Drivers, and have recorded their competence, training, and have their licence details. the expectations in the paragraph are met.
perhaps I am trying to apply KISS to readily, but why make it harder than it needs to be? by banning the use of a SOV which was likely used to get the Squadron Cadets and staff there simply because the OC is not following the vehicle to the point of use?
*and this is a grand title for whoever is sorting out MT, which could be the CampCom
1 Like
You’re correct that on base things like the RTA wouldn’t apply. But as far as best practice is concerned from us as a youth organization we should be applying the same basic rules whether were on public roads or otherwise.
Our MT Orders, that applied to all self drive travel, so not just a minibus but also transporting cadets in your private car, had the following in relation to drivers being authorised.
Authorised Drivers – All Vehicles
5. OC 1234 has a duty to safeguard the young people who are members of 1324 and in order to assure individual drivers a DVLA Check Code and the last 8 characters of the Driver Licence are required to complete a licence check, this is to be completed annually by the Adjutant.
- The presence of any of the following endorsement codes will result in the individual not being authorised to drive with any Cadet passengers:
a. Any BA Code
b. CD40 thru CD90
c. Any DD code
d. Any DR code
e. Any DG Code
- The annual review authorised drivers is to be documented and recorded within Annex A of this document by the Adjutant at point of review, in event of their unavailability the Dep OC Sqn and OC Sqn are also authorised to complete these checks.
There is then a separate section in relation to the use of the Minibus.
1234 (Anytown) Squadron owns and operates a Squadron Minibus, this is primarily for the benefit of 1234Cadets, but is also available to support other RAFAC Units if not in use by 1234. Non 1234 use of this vehicle are still to comply with these orders and need to ensure that their Risk Assessment also complies.
In accordance with Ref C (IBN 45/2020 now superceded by these ACLIs), the 1234 SOV is operated with a valid Section 19 Permit issued by the Traffic Commissioner and responsibility for the management of the SOV rests with the Civilian Committee.
All drivers of the SOV are to be authorised, this authorisation is detailed within Annex A and is only done following the individual licence check which assures the following additional elements that relate to the driving of a vehicle being operated with a Section 19 Permit.
a. The driver is over the age of 21
b. Licence issued before 1 Jan 1997
- D1 Entitlement
c. Licence issued after 1 Jan 1997
- Held a category B car licence for at least 2 years
- for drivers aged 70 or over, that they don’t have any medical conditions which would disqualify them from eligibility for a D1 licence
Useful link in terms of what is allowed by the use of the Section 19 Permit, there seems to remain a lot of confusion still (Drive minibus on B licence for example) Drivers of Permit Vehicles (Gov.uk)
1 Like
i agree - i was simply looking at it from both sides.
1 - does it really apply
2 - if it does, and OC isn’t attending, how can it be met
1 Like
I mean, if someone has any of those on their license I’d question their position as a CFAV.
I’ve not got the correct crypto fill for this message, anyone care to decode?
1 Like
Surely ant CD code should indicate an issue, especially if points are tallied.
You can get CD10, 20 and 30 for pretty silly things. A single CD10, 20 or 30 is really not indictive of someone dangerous.
1 Like