Now that schools are closed, except for key worker’s children, it might be the perfect opportunity to look at your minibuses and spend some time updating or creating a robust safety system. Chris Maynard, Managing Director of Castle Minibus gives us his recommendations.
A responsible person
If you make a profit from your school transportation you will need to hold an Operator’s licence that requires a transport manager to be appointed. If you are a charity or operate not-for-profit, running your vehicles at cost, then schools can operate under a Section 19 Permit. Regardless of the profit factor every school needs to appoint someone responsible for their minibuses. This person needs to be aware of their responsibilities under the Section 19 Permit and have a job description and contract in writing. If you don’t know much about the legal responsibilities in having a minibus, then use this time to check if you are compliant and can prove that you operate your minibuses safely because effective and continuous fleet management is required more than ever.
Suggested Action: Draft a job description for a school transport manager (STM)
Policies and procedures
Under a Section 19 Permit there are a range of requirements including ‘drivers are suitably trained and correctly licensed, drivers take appropriate breaks and your vehicles satisfy the appropriate construction and use requirements e.g. Fire extinguisher/first aid kit etc. and are maintained in a safe and roadworthy condition.’ www.gov.uk/government/publications/section-19-and-22-permits-not-for-profit-passenger-transport/section-19-and-22-permits-not-for-profit-passenger-transport
Management and administration of vehicles and drivers is the main responsibility of the STM but it requires the understanding and cooperation of other members of staff such as heads, governors, teachers and drivers. Therefore, agreed policies and procedures need to be in place and signed by the relevant staff.
Advice on several of the issues required under the Section 19 Permit such as driver fatigue, mobile phones and safer journey planning are available from RoSPA (Royal Society for the Prevention of Accidents). www.rospa.com/Road-Safety/Resources/Free#employers/
Suggested Actions: Write procedures for the STM, drivers, journeys and minibus operation and use. Prepare the relevant policies for staff who drive the minibuses.
Documentation and evidence
The Section 19 Permit requires the demonstration of several factors. If there is an incident it is not only the parents, heads and governors who’ll be interested but possibly the police, your insurance company, the DVSA and/or the traffic commissioner (they issue the Section 19 Permits). Therefore, it is important that you are evidencing and documenting your minibus activities as part of a safety system. In this way you can prove you did everything you could to run a safe and legal fleet.
Driver training and vehicle checks are the most obvious areas of ongoing evidence that the STM needs to manage.
For the drivers; Annual eye checks (from 20m), termly licence checks to remain aware of penalty points, driver risk assessments and driver training
For the vehicles: Daily, weekly and 10-week vehicle inspections as well as regular services and MOTs.
Regular vehicle checks are just as important now, when vehicles may not be being used regularly, to identify problems of inactivity such as rodent damage or rust.
There are several tools available to help STMs manage checks which could be researched and put into place if necessary.
- The Licence Bureau (licencebureau.co.uk) provides a number of Driver Licence Checking services
- STRIDA is a free app that allows STMs to manage a dashboard of weekly and daily checks on all their vehicles by all their drivers.
- Records should be kept of professional inspections such as 10-week safety inspections, services and MOTs.
Suggested Actions: Complete a calendar plan of vehicle services, MOTs and 10-week inspections – this is a specific requirement under a Section 19 Permit. You could also add annual eye checks, weekly inspections and termly licence checks.
It is the opinion of Castle Minibus, several county councils and the NASWUT that teachers should not be driving any minibuses (regardless of weight) on a standard B car licence. ‘The NASUWT strongly asserts that, particularly but not exclusively due to the ambiguity around the hire/reward status, the full D1 licence is the minimum requirement, and a car licence is insufficient in all circumstances’
Having the correct driver’s licence and continual training is imperative to safe minibus operation even for those with D1 (101) entitlement.
- MiDAS or minibus assessment training is recommended to be completed every 4 years.
- For more frequent risks assessments there are online driver assessments like CODA an online platform that enables schools to risk assess their drivers and offer training modules.
The combination of physical and online driver assessments and ongoing driver training will greatly enhance the safety of a school’s minibus operation.
Suggested Action: Document and diarise you past driver training and schedule/book trainings and assessments for the future – add to your calendar of vehicle checks and inspections (see above).
Fundamentals of a robust safety minibus safety system
In normal circumstances Castle Minibus deliver a day long minibus compliance course (MCC), and while we are working to get this valuable resource online, we want to encourage schools to be utilising any down time to really get to grips with what’s required to run the safest minibus fleet possible.
- Appointing a school transport manager
- Policies and procedures for minibus use and management
- Evidencing and documentation
Many of the schools we’ve worked with through the MCC are unwittingly placing their pupils, staff and reputations at risk, should the worst happen, because they do not have the basics required by a Section 19 Permit. A RoSPA inspector told us ‘the most dangerous thing a school can do is take children out on the public highway’ so we want to make sure you’ll be ready and able to do so safely and fully compliant when your minibus fleet is up and running again.