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?

Vetting
Induction
Authorisation
Training
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

Age
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
competence

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