Minibus Compliance and Health & Safety
Safe Vehicles, Safe Drivers and Safe Journeys
Published in the October edition of the Independent School’s Magazine this article was written following a conversation between John Peterson of Rivervale Minibus and Pearson Webb Consulting, health & safety and fire safety consultants for the education and charity sectors. Pearson Webb were keen to understand and clarify some of the health and safety issues surrounding minibuses for their ‘Safer Schools Podcast’.
The episode (released on 4th October 2024 ) highlights the importance of minbus compliance and comprehensive minibus management, not just from a compliance point of view but from a health and safety perspective. Michelle Pearson who has over 20 years’ experience in the education H&S sector gives her recommendations on what she would be looking for if she inspected a school - and combine these requirements with what organisations need to be doing under a Section 19 Permit.
Any organisation running minibuses must either operate under a Section 19 Permit or a PSV’s Operator’s licence. Section 19 Permits can be obtained from the DVSA website and cost around £11. You require one for each of your minibus and they can not be used by another organisation. If you are lending your minibus to another organisation they need to have their own permits. It’s advisable to have some spares for when you maybe borrowing of hiring and extra vehicle.
Safe Vehicles
Ensuring that your vehicle is safe and roadworthy is not only an obvious safety issue it is a requirement of a Section 19 Permit. As well as regular services and annual MOTs (from year one) you need to have a qualified engineer complete a minibus safety inspections every 6-10 weeks, depending on the age of the vehicle, and ensure drivers/staff are completing daily and weekly walk around checks.
Michelle recommends that organisations have a comprehensive maintenance planning schedule in place. The Section 19 Permit also requires 6 month maintenance planning and records to be kept for at least 15 months. Ideally records should be kept separately for each vehicle rather than just having all paperwork/details in one file.
It is recommended that you use different engineers for your safety inspections than the company that completed the MOT and services – this is so they are not checking their own work. Rivervale Minibus has a fleet of engineers that will come to your premises to complete minibus safety checks so you don’t need to worry about pick ups and drop offs.
You staff can complete the daily or pre-journey vehicle checks, to ensure they are happy the vehicle is fit to take on the road. They need to know that any issue should be immediately reported and records of any actions/repairs are a H&S must and should be included in the maintenance log of each vehicle, as detailed earlier.
It is important that your staff/drivers understand that, as the driver, they are liable to fines and penalty points if a defect is found on their vehicle so checks maybe inconvenient for them, but they are protecting themselves. A bald tyre could cost them £2500 and 3 penalty points.
The use of a free app like myminibusmanager.com, means checks can easily be completed and the results easily managed and recorded. There is a 12 point daily check and a 40 point weekly check which includes checks under the bonnet.
Safe Drivers
There is still a lot of confusion around driver training and who can drive a minibus. There are two types of licence you can drive a minibus with under a Section 19 Permit: a standard B1 car licence (conditions apply) and a D1 licence.
- If you passed you driving test after Jan 1997 you can only drive a vehicle 3.5 tonnes or under (4.25 tonnes with specialist equipment) and not for hire or reward – other conditions apply.
- If you are driving a minibus with a GVW over 3.5 tonnes you will need D1 entitlement.
- If you passed your driving test before January 1st 1997 you will have D1(101) entitlement on your standard B1 car licence, this mean you can drive a minibus not for hire or reward.
- If you are being paid to drive you need the full D1 licence.
Being able to drive on a car licence or this D1 entitlement means that some drivers might not have ever driven a minibus, three/four times the size and weight of your average hatchback, or received any additional training before they take up-to 16 passengers out on the road. Therefore, it is recommended that some training is given before this happened.
MiDAS is a nationally recognised minibus course including an online theory and practical assessment, but it is only required every 4 years. From a H&S angle, Michelle would be keen to see schools providing training before the first drive, and more frequent training such as an online assessment and online training.
When looking for MiDAS practical training please be sure to check it is being delivered by qualified driving instructors. Rivervale Minibus only use Advance Driving instructor for both D1 driver training, and MiDAS. We also have an Online Driver Assessment programme for organisations to risk assess their drivers and provide additional online refresher training.
Among Michelle’s recommendations is that schools keep an up to date ‘Approved Drivers List’ that details the licence each driver holds, their training history, and the vehicles they can drive. Licences should be checked via the DVSA for any changes and endorsements at least annually.
In addition, vehicle keys need to be held securely held so that drivers can’t help themselves and take unplanned journeys or unwittingly drive the wrong weight of vehicle.
Safe Journeys
Planning for your journey can make all the difference in terms of safety, not only to ensure the trip runs smoothly but that should something unexpected happen the driver is prepared. Simple things like ensuring the minibus contains breakdown contact information, a cradle for any mobile phones being used for sat nav, and checking weather, traffic and any height and weight restrictions in advance are often forgotten, but will make a huge difference.
Supervision is also another area that needs attention. What policies and procedures are in place for having an additional driver, taking breaks to avoid driver fatigue, refuelling, toilet stops and medical or emergency situations. Do staff know how to evacuate 16 children on the side of a motorway safely? What provisions are in the minibus for emergency situations in extreme weather or at night?
Risk assessments are often carried out for trips and one-off journeys, and will hopefully cover off al the above, but home-to-school drop off and pick up points need to also be risk assessed to ensure the safety of the pupil.
Seatbelts and passenger safety need to be considered, as children under the height of 1.35m are more at risk of injury when wearing an adult seatbelt so booster seats maybe required or you need to ensure seats are wide enough and suitable for car chairs if necessary.
In Summary
One of the most dangerous things a school can do is take their pupils on the road. Rivervale Minibus provide the services and support that not only satisfy the conditions of a Section 19 Permit, but tick many H&S boxes. Michelle’s recommendations include:
- Drivers confirming in writing they have read and understand all minibus Risk Assessments and policies
- Spot checks of minibus operations, like the drivers daily checks are regularly completed
- An auditable paper trail for vehicle maintenance, driver training and journey planning is maintained and can be made available for inspection at any time.
If you’re interested to find out more about how Rivervale Minibus can help you with vehicles, driver training, safety inspections or minibus management including an online Minibus Management Course then please visit Rivervale.co.uk/minibus.
More information on PearsonWebb Consulting and their podcast series can be found through via pearsonwebb.co.uk.