Whilst we wait to learn the outcome of the Department for Transport (DfT)’s consultation about the future of Driver CPC, RTITB shares our views. We look back at the introduction of Driver CPC in 2009, and at how driver training has evolved over the years. We also share our thoughts on the reform, as well as our own findings from talking to driver training companies, employers, and LGV/HGV, truck, bus, and coach drivers.
Appetite for reform
RTITB welcomed the introduction of Driver CPC (DCPC) in 2009 as a way towards our vision that all professional drivers receive relevant, structured training throughout their working lives in order to be safe on the roads. We saw and still see DCPC as a key part of efforts to professionalise the occupations of truck, bus and coach drivers.
As the operator of one of the largest Driver CPC consortiums, we work with nearly 200 companies to support the training of 20,000 drivers each year. This gives us privileged insight into the impact of DCPC on those businesses and insights into ways to make the Driver CPC Periodic Training regime more efficient and effective. We fully concur with the overall finding of the recent Department for Transport review, set out in the consultation document, that current DCPC arrangements can be reformed to better engage drivers and reduce complexity for transport businesses.
In preparing our response to the consultation (which was conducted during Aoril 2023) we talked to companies and drivers. They shared our appetite to reform DCPC. Only 23% of the road haulage operators we surveyed are content with current DCPC arrangement, however 63% seek reform. Only 14% called for the abolition of Driver CPC. Among the drivers we surveyed, only 27% are content with the current scheme, with 49% calling for reform.
Training in the road transport industry
Training in the sector is needed and will continue, even in the very unlikely event that the statutory DCPC training requirement is removed. Legally compliant employers and transport businesses need to satisfy, among others, the Traffic Commissioners and bodies responsible for workplace safety that they have provided appropriate training for those who operate and work around their vehicles. As commercial businesses, transport companies make large investments, for example in alternatively fuelled vehicle fleets and recognise that their drivers need to be given the knowledge and skills to achieve efficient operation. At the same time, increased awareness of staff well-being sees responsible companies providing training to their drivers with regard to their physical and mental health.
Routes to DCPC qualification
It is clear that transport businesses operating internationally will need to follow the I-DCPC route and we will continue to support these businesses. Our own research confirms the comment in the consultation that 80% of transport businesses operate solely in the UK and so we support the creation of new approaches to N-DCPC to better meet the needs of these businesses. We set our below the response we submitted to the main proposals for reforms to N- DCPC.
Reformed Training
This is our preferred route for N-DCPC. Our experience and the feedback from our consultations around the proposals is that drivers benefit from in-person training and gaining new knowledge in a structured setting.
Specifically, we strongly support the removal of the requirement for courses to be a minimum of seven hours and linked to that, ending the requirement that courses that are split into two parts (of 3.5 hours) that must be completed across two consecutive days. This addresses the persistent complaint from drivers (and trainers) that sessions are too long. This will also give employers more scope to deliver training at the end of shifts or at weekends, for example with one- hour sessions spread over several weeks.
E-learning
We welcome the recognition of the increasing value and use of e-learning in the sector. We support the proposals to remove the requirement to complete a split course, containing e-learning, over 2 consecutive days and remove the requirement that only 2 hours of e-learning can be taken for every trainer led course. We see no case for setting an arbitrary time limit between completion of the trainer-led course and corresponding e-learning. Furthermore we suggest that some topics can be covered entirely by e-learning with no requirement for a ‘corresponding’ trainer-led session.
Periodic Test
We do not support this option for N-DCPC. The ‘test-based’ model was widely debated in the industry in the discussions prior to 2009 and the reasons not to adopt this model then remain valid. Our main concern is that such a test is by its nature pass/fail, so it brings the prospect of qualified drivers losing their entitlement to drive because they do not perform well in a multiple choice test. Many drivers confide that they do not perform well in examination situations and have real fears that this might lead to loss of their livelihood. This same factor may also lead some drivers to leave the industry, which was one reason the ‘test route’ was not followed in 2009.
There is also evidence that a test-based route will mean that training will default to ‘training to the test’. This will lose one of the key benefits of the training route, which is that employers can provide training on topics of specific relevance to their business and that drivers can engage with the training without the fear of an ‘end-test’. A standard periodic test may well result in a need for training to cover subjects that are of no relevance to the sub-sector in which a driver works or the type of driving (e.g. urban or rural) they do.
Proposals for returning drivers
RTITB support the intention to facilitate the return to the sector of qualified drivers with a lapsed DCPC. We believe that this is best done through the proposed specific ‘return to driving’ training module as described in the consultation. It is important that this module is developed with employer input to ensure it covers and updates driver knowledge on matters such as drivers’ hours and health & safety.
Changes to allow for short term extensions and exemptions in exceptional circumstances
RTITB support the proposals to grant extensions and exemptions, but only in the case of highly exceptional circumstances. We do not believe it is appropriate to pre-set generic minimum and maximum periods for such extensions or exemptions as proposed in the consultation. Taking the example of the complex circumstances which emerged during the waves of the COVID pandemic, it is clear that each ‘force majeure’ case will need to be handled and judged as it evolves.
Recognition of non-UK qualifications
We support both the development of arrangements and powers to allow exchange or recognition to be agreed and the intention for UK government to continue to recognise DCPCs obtained anywhere within the EU and other specified countries.
Electronic Driver Qualification Cards (DQC)
Our survey among LGV drivers showed that 51% want to retain a physical card, with only 25.4% supporting an electronic alternative. On that basis, even when an electronic version is introduced, we ask that the physical card is retained.