This is a copy of a submission by the PSU (Examiners Union) on the state and the effectiveness of the dvsa to the House of Commons. It details a litany of failure, incompetence and just about any other adjective to describe failure that one could think of. I would dearly love to know what the dvsa's response was, does anyone know? Many thanks to the Guardian newspaper for bringing this to my attention. Written submission from PCS (DTA0017) Introduction: PCS (Public and Commercial Services Union) is the biggest public service union for civil servants. We have a very strong membership in DVSA, and the vast majority of driving examiners and their line managers are in PCS. PCS reps and full-time officers have engaged with DVSA Ex-Co throughout the Driving Services Recovery Project. We have faced, and continue to face, challenges working with DVSA, particularly the Driver Operations division, who are responsible for the Driver Services Recovery Project. When we have challenged decisions or asked for information, there has been a delay in responding, we have been rebuffed and our reps have, at times, been subject to aggressive behaviour from some senior executives in driver operations division. DVSA Driver Operations have refrained from consulting with PCS at appropriate points in the project. This has led to two incidences of industrial dispute in the last four years over the driver services recovery project. Both were resolved without PCS members having to take industrial action, but these two disputes evidence how reticent DVSA are to work collaboratively with PCS to find workable solutions to resolve the driving test back log . There has been a concerted effort from those involved with the Driver Services Recovery Project to keep pertinent information regarding the project away from PCS. In this report we will refer to the Driver Services Recovery Project business case and subsequent workplace exception documents. These only became available to us on the 23rd of October this year. (2024) We are submitting evidence because PCS has concerns regarding the ability for DVSA to reach the targets is has set in the Driver Services Recovery Project and its subsequent Workplace Exception Reports. We also have serious concerns regarding DVSA’s ability to act as an objective regulator of driving tests at this time and we are concerned regarding the long term sustainability of the organisation as DVSA Ex-Co continue follow the route of degrading terms and conditions of Driving Examiners in a bid to achieve Driver service recovery targets, despite all evidence showing this is not an effective resolution. Summary of Report: • The new cluster contract with degraded terms and conditions, is failing to attract driving examiners of the correct calibre, and DVSA is unable to reach the recruitment targets it has set, which the success of the project is dependent on. • Reports from driving examiners that they are being pressurised by more senior DVSA employees to inflate pass rates and take out unroadworthy vehicles. our members have witnessed examiners turn away cars with tyres so bald the canvas is showing, loose exhausts, brake lights not working, no tax or insurance. • Increasing attrition rates for driving examiners because of the culture in the organisation. • The initial plan for growing the training team to successfully manage the number of new driving examiner recruits has failed. The solution to overload LDTMs is ill thought out. Proper investment and long terms solutions are needed. • Report from an HGV driving examiner that tolerances are being adjusted on the manoeuvres on an HGV test at a certain training site, and preferential leasing of the site on reduced rate is causing incidences being overlooked to enable HGV tests to continue. • DVSA have not taken decisive enough action regarding the reduction of the number of tests third party sites can book using a singular driving licence number. a huge concern from our members as has been highlighted repeatedly in our blogs • There have been critical errors and a coordinated mis-management of the driver services recovery project by a cadre of individuals in DVSA Driver Operations which have resulted in unachievable targets for the project. • There has been mis-management by DVSA Ex-Co in allowing the iterations of Workplace Exception Reports to be passed, continuing the Driver Service Recovery Project without proper and robust analysis of content and targets. • There has been a co-ordinated effort from DVSA Driver Operations to frustrate the consultation and negotiation process with trade unions Operations to hide the issues in the Driver Services Recovery Project. • DVSA are unable to function appropriately as a regulatory body at this point. What possible solutions are there for reducing waiting times and preventing slots being blocked out by automated bookings: 1)Abolish the new ‘cluster contract’ terms and conditions for new driving examiner employees and return to previous driving examiner terms and conditions to encourage recruitment and retention of the number and calibre of driving examiners needed to fill the vacancies. PCS has always been opposed to the terms and conditions of the ‘cluster contract’, first billed by DVSA as a temporary, short-term contract for driving examiners recruited to meet the increased demand for tests after Covid. This contract offers poorer terms and conditions than the substantive contracts for existing driving examiners, including, but not limited to - regular weekend working expected as part of the working week on basic rate, with no additional overtime. Increased travel to and from work, as those on new ‘cluster contracts’ will be attached to a number of driving test centres across a geographical area, as opposed to just one, and are unable to claim comparative terms and conditions to those on the previously existing contract. It is important to note that PCS has continually challenged the imposition of these contracts and moved to a position of industrial dispute with DVSA in October 2023 over elements of the contracts. PCS won some significant gains for those driving examiners on the ‘cluster contract’, including a reduction in the frequency of weekend working, and improved subsistence and mileage allowances, as well as a shrinking of the geographical areas driving examiners on ‘cluster contracts’ would cover, but PCS reps have continually warned DVSA Ex-Co members that this contract is not sufficient to attract enough examiners of the appropriate calibre to the role. DVSA Ex-Co have always maintained in meetings with PCS that attrition rates of existing Driving Examiners are not increasing, and that recruitment of driving examiners was going well. On 23rd October 2024, after PCS continually asked for project documents (with requests always being evaded), PCS received from the Driver Services Recovery SRO, the Project plan documentation and successive Workplace Exception Reports which identify changes in the project when key targets are not met. These documents have never been discussed with PCS. These documents show a continual pattern of recruitment and retention of driving examiners falling well below the targets required to meet the successive deadlines of the initial project plan and the workplace exception iterations thereafter. There is, in the documents, acknowledgement that the resolutions suggested will not meet the targets. The initial Driving Test Recovery Business Case, states: “To deliver a reduction in the current waiting time for driving tests to single figures (in terms of weeks) by the end of February 2023. Based on the recommended option, this is to be achieved by: Direct Recruitment of Additional Driving Examiners A net increase of up to 300 additional DEs will be recruited, trained, and on-boarded into DVSA. They will be employed on fixed-term contracts, maximum duration of 2 years. Successful candidates will be allocated into test centre ‘clusters’ so that demand in particular areas can be met by having a flexible pool of resource that is able to be allocated to different local Driving Test Centres (DTCs) as and when required.” This cluster contract was first billed to the trade unions as a temporary contract to be used short term to resolve the immediate issue of the Covid back up of driving tests. When it became clear that DVSA would not achieve the initial target of reduction of driving tests to a 7 week wait by March 2023, DVSA Driver Operations created their first Workplace Exception Report which details the strategy to get the driver services recovery project on target. DVSA have produced four of these that PCS has seen, in February 2022, March 2023, Feb 2024 and July 2024. The first exception report was primarily focused on the roll out on an 8-test working day, but did note that overall project success was dependent on: “There are 3 financial risks associated with the revised model: a) The model assumes very high numbers of successful new entrants and low attrition. Project risk DRRE RIS 016 refers.” Indicating awareness that poor recruitment and increased attrition would affect the success of the project. The next Workplace Exception report that PCS has had sight of is from Feb 2023 and states: “ 2.3 Since the autumn factors above, there have also been other factors that have impacted the ability of the Project to meet the Feb 2022 delivery target date: • Failure to attract as many Driving Examiners as possible in the expected period planned. • Attrition rate of Driving Examiners being higher than historically.” The Exception Report in Feb 2024 states that the project has been delayed and not reached number of targets in the project because of several reasons, inclusive of: “Fewer new entrant Driving Examiners than planned and higher than expected attrition which has impacted test delivery over the period – the volume of new Driving Examiners that we planned to recruit between October 2023 and January 2024 was lower than anticipated and attrition was higher than expected.” The risk profile section of the Feb 2024 Exception Report states the ability to recruit sufficient driving examiners, as one of three risks, to the success of the project, with an overall risk factor of twelve, a medium risk score. The most recent Workplace Exception Report that PCS has seen was dated July 2024 and covered two specific areas of scope: 1.2 Context: This exception relates to scope and time as summarised below: • Scope exception – the project will need to recruit and train around 450 additional Driving Examiners (DE) in this financial year to deliver the 7week waiting time target by the end of March 2025 (this aligns with the Business Plan), which adds additional scope to the project. • Time exception – the current baselined delivery date is September 2024, so the project requires an extension of nine months from October 2024 to the end of June 2025 to enable delivery of the target and time to close down the project. A 7 week waiting list by July 2025 is the latest proposal/ dream of the dvsa - you have to have a good laugh here. The report goes on to describe the reasons for the inability to meet targets set in previous Exception Report, and states: “2. Description of the cause of a deviation from Plan Fewer new entrant Driving Examiners than planned which has impacted test delivery over the period – the volume of new Driving Examiners that we planned to recruit between October 2023 and January 2024 was lower than anticipated.” In section 3.6 of this report, the Risk Profile shows an increase to the risk profile of the risk: “Ability to recruit sufficient DE [Driving Examiner] numbers to service increased demand.” This risk factor has more than doubled from Feb 2024’s Exception Report and is marked as twenty-five, the maximum rating a risk factor can achieve in DVSA risk assessment model. This report lists under the assumptions that: “5. Assumptions (this is a peach) 1. Recruitment of new Driving Examiners will be delivered in line with the forecast. 2. Attrition of Driving Examiners remains in line with the forecast.” It is clear from the Business Case and the subsequent Workplace Exception Reports that DVSA is unable to fill the driving examiner vacancies at a volume required to ensure the project’s success. PCS has campaigned consistently that the poor terms and conditions of the ‘cluster contract’ are a significant contributor to the lack of interest in candidates of the correct calibre. DVSA have stuck resolutely to this ideology and it is without success. I note that DVSA is currently in it’s fourth extension to the project and at a recent meeting when PCS asked how far into the current target of recruiting and retaining driving examiners DVSA were, they were unable to tell us. The most recent advertisement had borne 19 candidates, of which 9 were successful after the initial training. DVSA mentioned vaguely that there were ’previous candidates’ that contributed to the most recent Workplace Exception target of 300 but were unable to offer any clear parameters of how many driving examiners had applied, been retained and from which wave of recruitment. PCS is gravely concerned at the management by Driver Services of the project. ( Ecactly what we have been saying consistently through our blogs.) T he litany of missed targets regarding recruitment over the lifetime of the project, and the narrowing of scope for resolution from DVSA as the project continues and enters its fourth extension, reflects errors in the management of the project at every level, inclusive of those who have been involved in the development and signing off of targets and given credence to these extensions without objectively questioning the validity of the resolutions within. 2). Immediate Cessation of ‘third party’ driving test providers to buy and sell multiple tests using learners’ driving licence numbers with automatic bookings. The ability for third party companies to buy and sell on driving test times has been a significant contributing factor to the ongoing difficulty in learner driers being able to book practical driving tests. PCS has raised concerns regarding this with DVSA Drivee Operations senior management several times over the past few years. When PCS called into question the ethics of the third party organisations being able to use learner drivers driving licence numbers to book repeated tests on the system, and why this can’t be curtailed to ‘one driving licence number, one booking’ the answers from Driver Operations were evasive, with PCS being told ‘it’s just not that easy’. PCS were told by senior staff in Driver Operations that progress had been made in that that the numbers of tests third party organisations are able to book with one driving licence number (without the learner driver’s knowledge) has been reduced from twenty driving tests from one licence number to five. PCS has been led to believe from ‘off the record’ conversations with senior management in DVSA that repealing the third party buying and selling of tests is difficult as this was brought in without the correct legislative process being undertaken, and therefore admission of the problem would reveal this significant error. The impact of allowing the continuation of third-party organisations being able to book up multiple tests to then sell them on at a profit means an evercontinuing cycle of delays for those learners awaiting driving tests. 3) Review into the narrowing of resolutions for increasing first time test pass and potentially for un-regulatory conduct. In the initial Driver Recovery Business Case one of the outputs of the Driver Service recovery outputs is: “Launch communications ‘Ready to Pass’ campaign that will contribute towards a range of initiatives leading to better preparedness for tests, ideally with positive impact on the pass rate, and reduce the number of learner drivers who will need to take a retest.” With a target of the project being: “Undertake a behavioural change campaign which aims to improve learner drivers’ readiness to take their test and encourages them only to take their practical car driving test when they are ready.” Two of the key methods for delivering the element of the campaign to engage with learner drivers and increase likelihood of passing first time are listed in the initial Business Case as: “Keep learner drivers and driving instructors updated with our progress on GOV.UK, by email and by using social media……Launch the recovery campaign with a pro-active national media announcement, publish the new campaign platform on GOV.UK and relaunch our Instagram channel with tailored social media content aimed at learner drivers.” The second Workplace Exception Report in Feb 2023 states: “And maintain the trust our people, stakeholders and customers have in our services, whilst encouraging learners of the importance of being properly prepared for their test.” With the target of a “1% increase in pass rate per year” and “1500 reduction in [test] demand per month” and an expectation this target will be achieved by: “Benefit realisation forecast is expected in Jan 2023.” It is clear from DVSA’s Instagram account that there was a considerable piece of work undertaken between July 2022 and October 2023, reaching out to Learner Drivers with the Ready to Pass communications, however, from October 2023 this proactive campaigning stops abruptly on social media (although its worth noting the internet pages are still in place). This is a shame as there is obviously investment into relevant content that could have been recycled through re-posting at no extra cost to the organisation. In the third Workplace Exception Report (Feb 2024) this project output is reduced to: “Improve and maintain the trust and confidence that our people, stakeholders and customers have in our services.” But retains the same target of: “1% increase in pass rate per year.” With the method of achieving this detailed as the target “Increase in slot availability up to 45% (currently 21% as at February 2024).” It is important to note the move of the focus on this target is away from the Ready to Pass Campaign, to slot availability. In the fourth Workplace Exception Report in July 2024, the target is noted again as a “1% increase in the pass rate per year”, but with the revised benefit noting that the target “Increase in slot availability up to 45% progress” is moving further away from the target in this quarter: “(currently 18.31% as at July 2024).” It was in Spring 2024 our PCS reps began to hear of key changes in the rhetoric from Driver Operations: PCS has been led to believe that during a meeting of driving examiner line managers in May 2024 there was a discussion around ‘utilisation’ (a phrase encapsulating the ideology of making sure every booked test is productive). PCS has been told that senior managers encouraged leniency in the running of tests in ‘private runners’ (cars owned by individuals and not by approved driving instructors) that were not in a roadworthy condition or did not have a current MOT. During that meeting managers were also introduced to using Power Bi, DVSA’s project management tool that charts the pass rates of different test routes and of driving examiners, to identify specifically those routes and examiners with low test pass rates. Since then, PCS has received a number of contacts from driving examiners in the organisation who have felt pressured and bullied by managers further on in their chain of command to increase test pass rates. Additionally, driving examiner line managers have also been asked to start completing new documentation which analyses performance based on examiners with low pass rates and routes with low pass rates. This is a marked difference to previous assessment which takes a broader view of both high and low pass rates on routes and from examiners. Several PCS members have begun the whistleblowing process to report these incidences but there is a reluctance among the driving examiners and their line managers to report these incidences as they report an organised and coordinated strategy from senior management in Driver Operations from SEO to senior Ex-Co to comply with this analysis and rhetoric. 4) Invest and develop a long-term plan to increase in the number of learning and development trainers, future proofing DVSA training provisions moving forward. Recently, DVSA has moved the responsibility of the first few weeks training for new driving examiners from the qualified and experienced training team to driving examiner line managers, who are expected to undertake this duty alongside their other line and centre management responsibilities. PCS have been against this idea from the start and wrote to DVSA in June to express our concerns and the potential for industrial dispute regarding this decision. DVSA’s decision is detailed in the fourth workplace Exception Report (July 2024), but it sits at odds with the initial business plan and previous iterations of workplace reception reports. In the initial business case, the plan for training was: • Improve the training resource to allow us to onboard and start more DEs every month by doubling the size of the training team. · Speeding up the Recruitment and Training of New DEs · This is to improve the training resource to allow us to onboard and start more DEs every month by doubling the size of the training team. In the short term, this will limit the number of new examiners we can train, but from February 2022 doubles the number of new entrants who can be trained concurrently. · To support the increase in training, up to 29 LTDMs [driving examiner line managers] will be trained as trainers and required to train new entrants for a period of up to 12 months. Operations has requested that these posts are backfilled and, therefore, up to an additional 29 LTDM posts will be required.” By the time the project reaches it second extension and workplace exception report (Feb 2023), DVSA recognises the roll out of this initial plan for training has been unsuccessful: “5. DRRE RIS 057 “Attrition rate of L&D Trainers available to train new entrant DEs”. We experience an attrition rate of trainers that significantly impacts training plans and new entrants start dates. We are monitoring BAU trainer departure attrition and move trainers from other training activities over to deliver Driving Tests. DVSA also continues to recruit new trainers as BAU activity. We plan to reduce Trainee cohorts to match current resource from February 2023 - April 2023. This also supports the delegates who are in the recruitment pipeline as there are insufficient numbers to meet original planned cohorts. Plan is to increase LGV delegated courses which will reduce DVSA LGV demand to diverting those examiners to deliver car tests.” and has resulted in a high number of leavers from the training team. The expectation now from DVSA, is that driving examiner line managers, without a background in training, many of whom are undertaking 6 month, temporary, Career Development Opportunity (CDO) posts, can now successfully manage this considerable piece of work in addition to their substantive post, is unrealistic. Driving Examiner Line Managers (known in DVSA as LDTMs: Local Driving Test Managers) have borne the brunt of the changes at DVSA; in previous iterations of the project, they were moved from their substantive posts to work full time on driving tests in an attempt to relieve the backlog. Consistently throughout all the business case and workplace exception documents, the same concern is flagged regarding driving examiner line managers: “Will require a longer period of support activity than that which was originally planned for. Risk of burn out, stress, reduced morale, reduced effort provided, as the period of work support extends beyond originally planned.” Workplace Exception Report Feb 2023, Feb 2024, July 2024. DVSA’s decision that a workable solution to a successful training programme for new driving examiner recruits is to task driving examiner line managers with this responsibility, given the evidence that earlier attempts in the project failed, when DVSA employed a larger, experienced team of specialist trainers and a number of fully trained driving examiner line managers, seems particularly reckless. This decision runs the risk of pushing up the number of leavers in the manager post and reduces the likelihood of producing driving examiner candidates that can move on from successfully from their initial training into the further development stage. DVSA Driver Operations have ignored PCS’s representations on this matter and instead attempted to foster a position that LDTM line mangers can handle the pressure as they are doing nothing out of the ordinary. This is stark contrast to the concerns highlighted in their own exception reports outlined above. PCS is currently reaching out to communicate with LDTM line manager members affected by this change with a view to surveying what impact this change has had on them. How the scarcity of HGV driving tests has affected industry? PCS understands the importance of candidates being able to attain HGV driving licences, however it is important that in providing the test, the validity of the test is not degraded to obtain false positive pass results, with the safety of road users compromised. PCS can report that we have had a PCS rep that raised concerns in October 2022 regarding practices in a test centre which held Entry to Employment courses, with the HGV test included, and where DVSA rent space for testing, where the tolerances on manoeuvres were being changed to make the manoeuvres easier to the candidate and increase the chance of the candidate passing. The rep reported this to the SRO for the Driver Services Recovery Programme at a Directors Live event, and he was then contacted to give a full description of his concerns. After this, the rep in question was investigated for a 17-point complaint from the test site owner. None of the points had a case to answer, but since then the rep has been told he has to move sites at the behest of this third-party site owner, which DVSA has complied with, to a site significantly further away (it is pertinent to note here that this examiner has a visible, physical disability, which makes commuting more challenging). On raising a complaint regarding this, PCS has been told that the third-party site owner does retain the right to say which DVSA employees can work on the site. PCS questioned the right of the site owner to make this decision and requested to see the contract between DVSA and the site to see where this right was written into the contract. We were told no contract existed between the site owner and DVSA. PCS has concerns that this site has offered DVSA a very beneficial rate to hire the land, enabling DVSA to undertake HGV testing at this site, and in doing so, this third-party organisation is utilising this leverage to control which DVSA employees can work at the site and is thus, undermining DVSA’s regulatory duties in ensuring testing is carried out in a legitimate manner PCS is aware that this is not a direct response to the evidence requested regarding the impact of the scarcity of tests but we feel this is such a significant situation it cannot be overlooked, PCS has brought this to the attention of ExCo a number of times but there has not been any investigation regarding this by DVSA Driver Operations Ex-Co. This calls into question DVSA’s ability to serve properly as a regulatory body when the division responsible for regulating the testing, Driver Operations, is also the division in charge of managing the Driver Servies Recovery Project: this is a dangerous conflict of interest. Summary of PCS’s recommendations to enable DVSA to reduce waiting time and prevent blocking out tests by automated bookings. 1) Immediate cessation of the use of the ‘cluster contract’ as the standard contract for new driving examiners, with a return to using the substantive contract in place for driving examiners prior to the Driver Test Recovery Programme, and a move for all those on the ‘cluster contract’ to pre -Driver Services Recovery Programme contract to enable a more attractive employment offer to potential new driving examiners and reduction in attrition of existing driving examiners. 2) Immediate cessation of any potential research or projects into the changes/harmonisation of the driving examiner terms and conditions on the pre–Recovery Programme contract to reduce examiner attrition. PCS are aware the Supporting Future Services Programme is looking at changes to contracts which could affect driving examiners. 3)Training of new driving examiners by LDTMS to be voluntary with proper training and remuneration for LDTMS undertaking this work. An increased budget for the training team to refresh and allow for new leadership. Increase in the number of learning and development trainers to invest in future proofing the training provisions moving forward. 4) Full investigation into the Driver Operations directorate who have managed the recovery project. 5) Move the regulatory function of DVSA to outside of the Driver Operations directorate, to enable an effective, unbiased regulatory system. 6) Repeal the ability for third party organisations to be able to retain learner drivers’ licence numbers and utilise them to book multiple numbers of tests. 7) An increase in pay across the department. DfT has one of the lowest rates of pay for EOs (the driving examiner grade), with new starter’s salary at £29,525 p.a. (Nationally) and £33, 864 p.a. (London). An increase in pay would attract a wider and higher calibre of suitable candidates. 8) Proper investment into long-term solutions and a commitment to a robust project review framework to ensure DVSA can successfully continue in its role in setting road safety standard and regulating driving tests. November PCS Public and Commercial services Union DVSA Driver and Vehicle Standards Agency DFT Dept for Transport EO Executive Officer LDTMS Local Driving Test Centre Managers DTC Driving Test Centre DE Driving Examiner HGV Heavy Goods Vehicle LGV Light Goods Vehicle

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AADI advising the dvsa, and they are at last listening.

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We are all Ambassadors for our chosen profession