Managing Drivers

Managing Drivers

Any business with employees who drive for work has duties that go beyond the vehicle itself - duties around the people who drive. Who is authorised to drive? Are their licences valid? Do they have the right category for the vehicle? Have they acknowledged the driving policy? Are their eyesight and medical fitness current? Who is checking?

This is one of the most common audit findings, and not just in ISO audits. Insurance providers, the Driver and Vehicle Standards Agency (DVSA), and corporate risk reviews all look for the same thing: documented evidence that the organisation knows who is driving on its behalf and that those drivers are authorised and checked. A policy alone is not enough - the evidence of what has been done matters.

This article covers the workforce management side of drivers. The H&S angle of the act of driving itself - fatigue, mobile phones, route planning, incident response - is covered in the companion article on Driving for Work.

What is Expected of Employers

There is no single UK regulation for "managing drivers" as such. The duties come from several sources:

The Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999 - the general duty to manage risks from work activities, including driving.
The Road Traffic Act 1988 and regulations made under it - the driver must hold a current valid licence for the vehicle category, and must notify DVLA of relevant medical conditions.
Common law and insurance conditions - employers have a duty of care to their employees and other road users, and motor insurance cover usually depends on declared drivers meeting specific standards.

HSE guidance INDG382 sets out that employers need a system for managing drivers that covers authorisation, competence, fitness and ongoing review. This is not optional: ISO 45001 auditors treat driver management as part of Clause 8 operational control, and failures to manage drivers are a common source of non-conformities.

Authorisation to Drive

Before an employee drives for work, there should be a documented process that confirms they are authorised. The elements typically include:

Driver declaration - a signed statement by the driver confirming they hold a valid licence, are fit to drive, will notify the employer of changes, and accept the terms of the driving policy.
Licence verification - original licence seen, copy taken, validity confirmed against the DVLA check service.
Health declaration - confirming that the driver has no medical condition or medication that would affect their ability to drive.
Categories and restrictions - confirming the driver holds the right categories (cars, LGV, PCV, trailer) and that any restrictions (for example, eyesight codes) are understood and met.
Policy acknowledgement - the driver has received, read and accepted the driving policy, drivers handbook and any safe-driving guidance.

Authorisation should be recorded against the individual driver and held on file. Agency drivers, contractors and visitors driving company vehicles need to go through the same process before they are allowed to drive.

Licence Checks

Licence checking is where many organisations fall short. The baseline expectation is that licences are checked both when a driver is first authorised and at regular intervals thereafter. Frequency should be based on risk:

0 points - annual check is sufficient for most drivers.
3 points - six-monthly check.
6 points - three-monthly check.
9 points - monthly check.
New endorsement or conviction - immediate check and review of authorisation.

DVLA provides an online check service for employers, which requires the driver's consent (via a check code the driver generates). For larger fleets, third-party licence checking services automate the process and alert the employer to changes. Either way, records should show what was checked, when, by whom and what the result was.

Paper driving licences were abolished in the UK in 2015 - the counterpart is no longer issued. Employers should not rely on paper counterparts as evidence of current status; DVLA online is the authoritative source.

Eyesight Checks

The legal standard is that a driver must be able to read a vehicle number plate (font to current specification) from 20.5 metres in good daylight, with any corrective eyewear normally worn. Failing this is a criminal offence if the driver continues to drive.

The employer has a duty under H&S law to make sure drivers are fit to drive, which includes eyesight. A simple number-plate test carried out regularly (every six months is a practical default) is acceptable evidence. For higher-risk drivers or those in specific vehicle categories (LGV, PCV), more formal medical eyesight testing is appropriate.

Results should be recorded on an eyesight check register. Where a driver fails the test, they should not drive until vision has been corrected.

Medical Fitness and Declarations

Drivers have a legal duty to notify DVLA of relevant medical conditions that could affect their ability to drive - diabetes, heart conditions, epilepsy, certain eye conditions, sleep disorders, and others listed in DVLA's "At a glance" guide. The employer's role is to make the driver aware of this duty and to require drivers to report to the employer any condition, medication or change that could affect driving.

A health declaration form - completed at authorisation and refreshed periodically (typically annually) - is the usual mechanism. The form covers current medical conditions, current medications, and a commitment to report changes. Where a driver reports a condition that could affect driving, the employer should review their authorisation and may need to pause driving until the condition is reviewed or DVLA confirmation is obtained.

Endorsements, Convictions and Incident Reporting

Drivers have an obligation to report to their employer any conviction, endorsement, fine or incident affecting their driving - not just those that happen at work. The reporting should cover:

Road traffic offences and endorsements.
Fixed penalty notices.
Collisions or incidents, whether at work or in private use, where a company vehicle is involved or the driver's licence status is affected.
Disqualification (full or interim).
Changes to medical fitness or eyesight.

The employer's response depends on the circumstances but typically includes updating the driver's file, reviewing authorisation, re-checking the licence, and in serious cases suspending driving authorisation until the matter is resolved. Repeated or serious breaches are disciplinary matters and, where holding a valid licence is a condition of employment, may lead to dismissal.

Managing drivers is an area where I have seen real improvements from quite modest process changes. We moved from ad-hoc licence checks to a quarterly batch process using an external checking service - took the admin burden off our HR team and caught a couple of endorsements we would have missed otherwise. Insurance premium came down at the next renewal because we could demonstrate a documented system.

The other thing that made a difference was a single "driver file" per employee - licence copy, declarations, eyesight checks, training records, endorsements - all in one place rather than scattered across HR, H&S and fleet. Makes audit time much easier, but it also means the person doing the periodic review can actually see the whole picture.

Managing drivers is a standing audit finding and it is almost always the same pattern: the policy is in place, the forms exist as templates, but the records do not add up to a running system. I ask for five random driver files and want to see a current licence check, a signed declaration, a recent eyesight check, and evidence that any endorsements have been reviewed. If three out of five are missing something, it is a non-conformity.

The other common finding is agency drivers and contractors. The permanent workforce has a managed driver process; temporary or contracted drivers do not. They are doing the same driving, often in the same vehicles, but the organisation has no record of their authorisation. Under ISO 45001 and HSWA, the duty extends to them too.

Driver management sits under Clause 7.2 (competence) and Clause 8 (operational control) in ISO 45001, and under the same clauses in ISO 9001 where driving is part of the service delivery. The expectation is not that you have a specific "driver management" procedure - it is that driving is managed through the same process as any other competence-based activity: identify who needs to do it, assess their competence, authorise them, keep the evidence, review periodically.

The link to Clause 9.1 performance monitoring is also worth making. Driver endorsements, collision data, licence check results are all indicators of how well the management system is working, and should feed into management review.

Practical Compliance Guidance

Section 3.1 of the IMS1 Manual covers the management of staff and company personnel, including competence and authorisation. Driver management sits within this framework, linked to the driving policy and procedure in Section 7.

The alphaZ documents below cover the driver management process - the policy set, declaration forms, eyesight and health checks, and the drivers toolkit that brings the administrative pack together.

alphaZ document	How to use it
ISO 9001 14001 45001 IMS Toolkit	The full integrated toolkit for ISO 9001, 14001 and 45001. Contains the procedural documents, forms and guidance needed to set up and run a compliant management system including driver management arrangements.
Drivers Toolkit	The consolidated administrative pack for managing drivers - brings together the policies, declaration forms, licence check process, eyesight checks and driver handbook in one place. Use as the starting point for setting up a driver management system.
PP-1-01 Driving and Use of Vehicles Policy Procedure	The policy-procedure document covering driving for work, competence to drive, licence checks and the full set of driver responsibilities. Use as the primary written procedure for driver management.
P-9 Driving Policy	Sets out the organisation's high-level commitment on driving and driver management. Issue to all drivers as part of their authorisation pack alongside the policy-procedure.
P-62 Driving Own Vehicles Policy	Policy covering employees who use their own vehicles for business purposes (grey fleet). Covers insurance requirements, roadworthiness and the checks needed before authorising own-vehicle use.
P-63 Company Vehicles Driving Policy	Policy specifically for drivers of company-owned vehicles. Covers pre-use checks, responsibilities, permitted use and reporting requirements.
F-HS35 Driver Declaration	Declaration form signed by the driver at authorisation and periodically thereafter. Covers licence validity, fitness to drive and acceptance of the driving policy.
F-HR2 Driving Company Vehicles Declaration	Declaration specific to drivers of company vehicles, covering licence consent for checking and acceptance of the company vehicle policy. Use alongside F-HS35 for company vehicle drivers.
F-HS33 Driver Health Declaration	Health declaration covering medical conditions and medications that could affect driving. Completed at authorisation and refreshed annually (or on any relevant change).
F-HS34 Driver Collision Declaration	Form used when a driver reports a collision or incident - whether at work or privately - to capture the details and feed into the authorisation review.
F-HS17 Driver Eyesight Check	Eyesight check register used to record number-plate reading tests for drivers. Use every six months as a practical default for lower-risk drivers; more often where risk warrants.

Note - all the above files can be downloaded with an alphaZ subscription.

Frequently Asked Questions

How often should we check driving licences?

Frequency should be based on risk. For drivers with no endorsements, annual checks are usually sufficient. For those with 3 points, six-monthly; 6 points, three-monthly; 9 points, monthly. New endorsements or convictions should trigger an immediate check. Use the DVLA online check service with the driver's consent (via check code) - this is the authoritative current status. Paper counterparts were abolished in 2015 and are no longer valid evidence.

Do we need to manage drivers who use their own vehicles for work?

Yes - often more carefully than company vehicle drivers. Grey fleet drivers (those using their own vehicles for business) must be authorised in the same way, with the addition of insurance checks (many personal policies exclude business use unless specifically added), MOT status confirmation and vehicle roadworthiness declarations. The H&S duty under HSWA applies regardless of who owns the vehicle. Many organisations find their grey fleet exposure is larger than their company fleet and less well controlled.

What about agency drivers and contractors?

The organisation that controls the work has the H&S duty under HSWA, regardless of who employs the driver. Agency drivers and contractors driving on your behalf, or in your vehicles, need the same authorisation process - licence check, declaration, eyesight, policy acknowledgement. For agency staff the agency should hold primary records, but the organisation using them should have evidence of the checks before allowing them to drive. Audit findings in this area are common and material.

A driver has just got points on their licence - do they have to tell us?

Yes, if the driving policy requires them to report endorsements and convictions - which it should. Drivers have no legal duty to notify their employer of points as such, but your authorisation to drive on business should be conditional on holding a clean enough licence for your risk appetite. The policy should make clear that endorsements, fixed penalties and convictions must be reported within a short window (typically a few working days), and that failure to do so is itself a disciplinary matter. Some employers set an automatic suspension threshold (for example, 9 points triggers review of authorisation) to make the consequences clear in advance.

UK Legislation

The following UK legislation is directly relevant to managing drivers. Organisations outside the UK should identify the equivalent legislation applicable in their jurisdiction.

Further Resources