The following is taken from a letter circular we at TMC Assist will shortly be sending out to our clients, concerning a growing enforcement trend within both the DVSA and Uk Tarrfic Police:

We at TMC Assist have become aware of a growing and shifting trend within both DVSA and Police enforcement regarding manual records and periods of ‘Other Work’, which we feel you should be made aware of.

At a number of recent public inquiries to which TMC Assist have been involved as in, we have observed that both the Traffic Commissioner and DVSA Enforcement Officers are paying greater attention to reported periods of inactivity, where the possibility of additional or ‘Other Work’, outside the purview of the Tachograph Recording Regulations may have occurred.

Specifically, there is growing interest and/or concern that drivers are not accurately measuring their activity under the Working Time Directive, as they are not reporting periods during which they are performing ‘Other Work’ or driving activities which do not necessitate the use of a tachograph unit directly.

An example would be a scaffolder who drives an HGV most days, then drives a rescue/repair vehicle on others. As the second vehicle is not covered by the tachograph regulations, some operators and drivers are not recording this activity at all. However, this activity is monitored under the Working Time Directive and as such, must be recorded on the tachograph as a manual entry at a later point.

In the event that you have workers who perform work both within and outside the Tachograph Recording Regulations, you must ensure that ALL their activity is recorded on to the tachograph recording device in the form of manual records.

Additionally, in the event that a driver is required to take a day off for sick leave, holiday, or unforeseen events; it is good practice to also record these activities as a manual record as well

If you have any questions related to this article, tachograph regulations, manual entries; or just wish to discuss this matter with us in more detail; please do not hesitate to contact our offices either by Phone (01634 731310) or email (

Leave a comment