When a driver uses their own vehicle for work, they are still under the responsibility of the employer, and this presents a real challenge for managing associated work related road safety risk. Employers may think that it is easier to manage employees using their own cars for work, instead of a company car fleet. However once all of the considerations are taken into account this may not be the case.
This guide has been produced to help organisations review and improve grey fleet management, with a specific focus on safety concerns. It will explain the legal responsibilities as well as the business benefits of an effective grey fleet management policy. It will also explain how grey fleet road risks can be reduced through risk assessment, and stress the importance of integrating grey fleet policy in company procedures and management responsibilities.
Grey Fleet definitions
- privately owned vehicles
- hired vehicles used for work
- vehicles obtained through an Employee Car Ownership (ECO) scheme
UK Grey Fleet, The Data shows;
- 9 million vehicles used for business journeys on a regular basis
- 40% of work vehicles are grey fleet
- 62% of private car use is for work-related activity
- 14 million grey fleet vehicles are in use
- 57% of public sector distance driven in grey fleet
Grey Fleet, The typical vehicle profiles;
- Often older than average company car
- Greater carbon footprint
- Less well maintained
- Lower safety rating
- Missing safety features
- Older safety features
- Less safe on average
Grey Fleet, Is this your typical company culture?
- Grey fleet perceived as cheaper option for employer
- Not doing enough mileage to get company car
- Not management grades to get a company car
- Driving not a primary activity just use your own car
- Occasional business use, easier to pay the employee for the miles used
- The provision of company car not economically viable
- Employee is deemed to be responsible for vehicle
- Less administration for employer, no company cars needed
- Cost per mile travelled is cheaper if employee uses their own vehicle
- Just pay an annual payment towards upkeep of car
Grey Fleet, Why manage it?
- Firstly it is law, Safe driving for work https://eguides.osha.europa.eu/vehicle-safety/legislation
- Reduced running costs such as fuel consumption and vehicle maintenance through better driving standards
- Fewer working days lost due to injury
- Reduced risk of work-related ill health
- Reduced stress and improved morale/job satisfaction
- Less need for investigation and paperwork
- Less time lost to work rescheduling
- Loss of reputation
- Fewer vehicles off the road for repair
- Fewer missed orders and business opportunities, reduced risk of losing the goodwill of customers
- Less chance of key employees being banned from driving.
Grey Fleet, What is the Key Risk Management Steps?
- Do I have responsibilities?
- Business risk inventory
- Pay attention to ‘Big Data’ on work related road risk
- Claims and cost profile
- Driving for Work risk assessment
- Driver profile
- Vehicle profile
- Journey profile
- Suitable controls and procedures for key risks
- Set Key performance indicators
- Review performance
Grey Fleet, How are you managing your drivers?
- Clear unequivocal rules for work tasks
- Fit to drive on a daily basis
- No Intoxicants [drugs and alcohol]
- Collision/incident /near miss reporting
- Prevent Fatigue
- No Distractions
- Use Safety equipment
- Safe driving behaviour
Grey Fleet, Driver Risk Factors
- Length of time employed
- Type of vehicle driven
- Types of journey undertaken
- Annual mileage
- Previous driving history
- Acquisition of penalty points
- Health status
- Incident involvement
Grey Fleet, Risk assessment of personal vehicles used for work
Typically, risk assessment of personal cars used for work, should ask the following questions:
- What journeys have to be taken?
- Which modes would represent the lowest risk?
- What kinds of vehicles make up the fleet?
- Who are the vehicles driven by?
- Where are they driven?
- What type of drivers do you have?
- How long do they have to drive?
- How long have they been driving?
- (Ensure you have the correct driving licence checks in place with DriverCheck)
- What are they being asked to do, apart from driving?
Grey Fleet, Recommendations to employers
- Take responsibility for managing your grey fleet
- Adopt a clear policy setting out the organisation’s commitment to managing grey fleet use
- Identify clear roles for implementing this policy
- Promote a safety culture as an integral part of the policy implementation
- Include grey fleet use in your Work Related Road Risk (WRRR) programme
Grey Fleet, It’s the Law
Duty of care, occupational health and safety and road safety compliance are legal requirements in all EU Member States. The European Framework Directive 89/391/EEC on the health and safety of workers requires that every employer in Europe undertakes a risk assessment according to the principles of prevention. This should include employees travelling for work and cover all aspects of that travel, including grey fleet.
The fact that employees use their own vehicle for business purposes does not absolve the employer from ‘duty of care’ responsibilities. The law is clear: an organisation has a legal duty of care to an employee, regardless of vehicle ownership, therefore the grey fleet needs to be managed as diligently as company-owned or leased vehicles.
Some European Member States have supplementary legislation detailing employers’ obligations for reducing the risks related to driving for work. Member States have also developed specific guidance on applying the Framework Directive to work related road safety. Employers are responsible for ensuring that they are compliant with this EU and national level legislation. In this context, the employer is responsible for answering questions such as:
- Does the driver have the right skills?
- Is the driver’s licence valid? Is the vehicle suitable for the task?
- Is the vehicle well maintained and insured for business travel?
Keeping an audit trail of these requirements is crucial, especially if a collision occurs. This will be covered in more detail in part 4 of this report. In some countries, it is an offence under road traffic law to ‘cause or permit’ a person to drive without a valid licence or third party insurance or to drive a vehicle that is in a dangerous condition.
No matter the mileage, any grey fleet vehicles should be ‘fit for the task’.
Managing grey fleet safety