MOT Workshop 60 – DVSA, DfT and the MOT

MOT Testing – a big project

There are now 23,000 MOT Testing Stations and about 60,000 active MOT Testers. So the MOT Testing scheme probably involves up to 90,000 people in small businesses. This excludes Civil Servants at DVSA or DfT, and those involved in manufacturing and servicing MOT equipment, or more recently, those involved in MOT Training since it was privatised. Compare that with other large organisations:

Testing Stations carried out over 29.5 million MOT inspections last year generating £1.33 billion (approx) in MOT fees alone, and probably a further £60M in consequent MOT repairs – nearly £2billion altogether.

MOT rules and regulations – monitoring and control

DVSA are responsible, for setting the MOT rules and regulations in the MOT inspection Manuals, and the MOT Guide. Then, quite separately DVSA staff monitor and control adherence to those rules by MOT Testing businesses; the policies adopted, and how Vehicle Examiners are directed when visiting Testing Stations.

The Guide covers issues like disciplinary action, equipment requirements, administrative procedures and so on. In practice, developing the Guide probably involves more people within DVSA than for the Manual – and is subject to wider internal consultation before finalisation.

On both the Guide and the Manuals the MOT Trade are consulted at joint meetings between senior DVSA staff and a wide range of MOT trade representatives; trade body officials, executives from large ‘fast-fit’ businesses and smaller Testing Stations as well as other businesses affected by the MOT rules.

Operations and enforcement

This is about how DVSA ensure Testers and AEs comply with the rules. In terms of ‘head count’ it’s the biggest part of DVSA’s MOT activities. Here’s where DVSA’s ‘foot soldiers’ are to be found visiting MOT Testing Stations carrying out a range of different MOT activities. Yet they also do work unrelated to the MOT – roadside checks, inspecting Heavy Goods and Public Service vehicles and so on. They are based regionally at Area Offices throughout the country. Altogether the equivalent of about 130 full time VEs and SVEs are involved in MOT Testing drawn from a total of about 450 Vehicle Examiners and Senior Vehicle Examiners. Here’s what they do:

Routine Operations

• Carrying out ‘risk-assessment’ visits
• Conducting observed Tests for new Testers
• Visits to ‘check-out’ new Testing Stations and/or ‘approve’ new equipment
• Enforcement activities
• Compliance visits to red and amber garages to re-test previously tested vehicles (six and nine monthly respectively)
• Random compliance visits to green Testing Stations, both ‘mystery shopper’, and re-testing previously tested vehicles
• ‘Survey’ compliance visits to Testing Stations to measure MOT quality by re-inspecting previously tested vehicles
• Targeted ‘mystery shopper’ visits to Testing Stations.

These VEs and SVEs check out new MOT bays, new Testers, or maybe re-inspect cars you’ve just tested, to make sure the Tester got it right! They also trigger disciplinary action if an MOT hasn’t been done properly. The local area office also used to be a place to call if there was a problem with an MOT inspection, where a VE would be available to discuss the issue and provide assistance.

These days, however, the areas are in decline with many offices being closed – and the ‘help line’ is the main support facility to use.

The disciplinary process

All disciplinary cases go directly to a ‘Case Review Team’ (CRT) at DVSA’s head office. They examine the VE’s evidence following a disciplinary visit, together with the submissions from the Tester and AE, and decide the disciplinary outcome. There’s also a final Appeal process available at DVSA head office, but located in a different Directorate to ensure impartiality.

DVSA also have an, ‘Intelligence’ section investigating Testing Stations suspected of systematic fraudulent activity. They might ‘stake out’ a Testing Station observing and timing vehicles coming and going, and compare them with MOT certificates issued.

DVSA’s ‘Head Office’

A great deal of MOT work takes place at DVSA’s two head offices in Bristol and Nottingham. Both the CRT and the team working on the Manual are ‘Head Office’ activities. There’s a section delivering ‘Digital Services and Technology’. Part of this section does the IT ‘magic’ – (or black magic when it goes wrong!) for the MOT computer, working with another team to co-ordinate what the technicians are doing to meet the needs of the users – Testers, AEs, and motorists.

The MOT Testing Service Management Team, headed by Neil Barlow has the greatest influence on day-to-day MOT Testing. A section headed up by Danny Charles – a highly experienced SVE, works on improving the practicalities of the MOT computer, so it’s increasingly ‘user friendly’ for Testers.
In Barlow’s own words, “…whilst we aren’t responsible for 100% of everything we do aim to facilitate the right outcome… we do a lot of close working with Enforcement Operations to help deal with problems and fix longer term issues…”

Finally, there is at Head Office a ‘Service Management Group’ (SMG) over which Neil Barlow has control. The SMG has a co-ordinating function for all DVSA’s day-to-day MOT activities – excluding strategic planning, which involves DVSA’s Board of Directors, the DfT and the Minister himself, Andrew Jones.

Strategic planning

MOT strategy is decided between DVSA and the DfT. On some issues the DfT have the final say – MOT fees, MOT frequency, as well as MOT exemptions, like historic vehicles. Yet day-to-day the DVSA Board do have control. They can either increase or decrease MOT funding as compared to their other activities in the merged Agency. So HGV Testing, a key DVSA responsibility, could gain, for example, to the detriment of the MOT Scheme – which has happened in recent years.

Strangely, despite the significant size of the MOT Trade, as primary ‘stakeholders’ they are uninvolved in MOT Testing’s strategic planning. The recent ‘five year plan’ (see DVSA and DfT Matters) was compiled without any formal consultation with the Trade. Perhaps that’s because the MOT is superficially a minority segment within DVSA creating just 16% of DVSA’s total income. Yet in DVSA’s last accounts for 2015/16, the MOT made DVSA’s biggest surplus at £12.278M – without which the Agency would have been in deficit!

MOT Trade ‘Out in the cold’…?

When it comes to strategic planning, the MOT Trade is very much out in the cold. But should that be a problem? DVSA/DfT decide what needs to happen, and then work with the MOT Trade deciding how best to make it happen – what’s wrong with that? Well, nothing if the Scheme operated perfectly – but it doesn’t.

The risk assessment system, the very crux of DVSA’s enforcement, isn’t working. There’s poor correlation between bad Testing and whether or not a garage is red, amber or green. That doesn’t mean the system is wrong; it’s under-resourced – a strategic issue. MOT quality, deemed unacceptable by DVSA, hasn’t significantly improved for nearly a decade.

Surely that’s no surprise with only the equivalent of 130 VEs nationwide to monitor and control 60,0000 Testers and 23,000 Test Stations? No matter how smart your data analysis or operating systems – you still need enough people to do the job properly – and VEs aren’t permanent staff working only on MOT issues. They are drawn from a pool of about 450 VEs who do other DVSA work, and when called on for the MOT Scheme may not be available. How can DVSA’s managers cope when staff may suddenly be prioritised elsewhere? It must be ‘mission impossible’!

How strange that the MOT Scheme is under-staffed but making over £12M profit? Surely Neil Barlow could improve things if he could invest that money in the MOT Scheme, instead of it being used to prop-up DVSA’s shaky finances.

Better engagement

If the MOT industry were fully engaged in strategic planning on a genuine partnership basis with both DfT and DVSA, wherein the MOT fee, and how the Scheme operates became an integral part of joint strategic planning, then motorists would get better service and quality from MOT Testing. With more VEs quality would improve and with appropriate fees VTSs could be expected by DVSA to use the most up-to-date equipment with increased productivity, and road safety would also improve. Dream on…

Growth and development of the MOT Scheme

Reduced VE productivity

It’s rumoured that VE productivity has reduced since 2005. So we’ve shown this as the number of ‘effective VEs’ available for enforcement activities as compared to the 130 VEs in 2005.

Risk Assessment visits

We asked DVSA how up-to-date they were with their risk assessment visits – the foundation of their VTS quality management:

19,221 green VTSs
• 795 overdue by more than 6 months,
• 2,259 by over one year,
• 1,614 over two years.
1,679 amber VTSs
• 77 overdue 6 months,
• 436 over a year
497 red VTSs
• 3 over three months,
• 47 over 6 months.

Under-resourced

These figures show that DVSA are under-resourced compared to VOSA in 2005.
The slippage in ‘risk assessment’ visits clearly illustrates the point.

DVSA’s MOT staffing

Here are the various MOT activities, together with an approximation of the number of staff in ‘person/years’ involved, and what they do:

MOT Enforcement: This involves 130 Vehicle Examiners from a pool of about 450 VEs. About 30% is ‘on demand’ work like checking new equipment, new Testers, and so on. The rest do risk assessments, ‘mystery shopper’ activities and ‘intelligence led’ enforcement.

Specialist investigations: This team of 25 people spend about 20% of their time on MOT work, prioritised as to the road safety risk prompting such investigations.

The intelligence team: This team operates across the whole of the DVSA. Acting on information received, they investigate serious infringements like covert surveillance of Testing Stations suspected of carrying out systemic MOT fraud. About 15% of their time is on MOT issues.

Central Review Team: This small team – mainly VEs, and admin staff work across the whole of DVSA including MOT disciplinary issues – they also consider appeals.

MOT Testing Service Management team: This team, led by Neil Barlow does operational strategy and planning. Here’s where what happens day-to-day is decided. Prioritising what’s ‘next up’ on the computer. Risk assessment and training policies – and specifically how DVSA interact directly with Testing Stations.

The ‘digital’ team: It’s what it says on the tin – the MOT computer, as well as DVSA’s own internal IT requirements. These are the guys who sweat behind the scenes when the computer goes down!

(The above figures applied at the original time of publication in MOT Testing Magazine)

This article originally appeared in MOT Testing Magazine.
MOT regulations analysis, news and equipment reviews appear in MOT Testing Magazine every quarter. Subscribe for only £30 a year at www.motester.co.uk/subscriptions.