Tachograph: downloads, infringements and the follow-up nobody does

A tachograph records driving time, other work, availability and rest for drivers subject to drivers’ hours rules. Modern vehicles use digital tachographs with a driver card and a vehicle unit, and the data has to be downloaded, stored, analysed and retained — the recording itself is only the first step of the obligation.

The compliance failures that turn up at inspection are rarely about drivers concealing hours. They are about operators who record everything and act on nothing: downloads late, data stored but never analysed, infringements listed but never discussed, and no evidence that anything changed as a result.

What the operator has to do with tachograph data

• Download vehicle unit data and driver card data within the required intervals — the two have different deadlines.
• Store the data for the retention period, in a form that can be produced on request.
• Analyse it for infringements against drivers’ hours and working time limits.
• Discuss infringements with the driver, record the discussion, and keep the record signed.
• Track repeat infringements and escalate them through a defined process.
• Keep records for periods when a driver was absent or the vehicle was out of scope, so the gaps are explained.

That fourth point is the one examiners test hardest. An infringement report with no evidence of a conversation shows the operator knew about a breach and did nothing — which is worse, from an enforcement perspective, than not having looked.

The rules the data is checked against

1. Daily driving limits, with the permitted extensions and how often they may be used.
2. Weekly and fortnightly driving limits.
3. Break requirements during driving periods.
4. Daily and weekly rest, including reduced rest and how it must be compensated.
5. Working time rules, which are separate from drivers’ hours and often forgotten.
6. Manual entries for other work, so periods off the card are accounted for rather than blank.

Missing mileage — a gap between where one card record ends and the next begins — is treated as unrecorded driving unless it is explained. Manual entries and printouts exist for exactly this, and a policy that requires them is cheaper than defending the gaps later.

Making the routine survive holidays

The most common cause of late downloads is a single person doing them, going on leave, and nobody noticing until the interval has passed. Put the schedule somewhere with dates and an owner, name a deputy, and check the completeness of the data rather than trusting that the routine ran.

Ettex Records holds the download schedule, the completed downloads and the infringement discussions with their dates and signatures against each driver and vehicle, so the operator licence undertaking on drivers’ hours is evidenced by the same records that manage it. Analysis software and the tachograph equipment itself are separate specialist tools — this is the file that proves the process ran, not a replacement for the analysis.