I recently spent an enjoyable morning (online of course) with the UK Metal Decking Association.

For anyone unfamiliar with this organisation, the UKMDA was formed by leading companies in the Metal Decking and Studwelding industry in response to a demand from the construction industry for authoritative guidance, training and qualifications in this specialist area. Besides setting high standards, and levels of quality and good practice within the industry, their objective is to create a safe (accident-free) environment.

Which is where I came in.

I led a presentation on the issue of what constitutes ‘engineering plant’. In case you were wondering whether or not this was a purely academic exercise, there’s a very good reason for asking this question.

This is because engineering plant - vehicles which are designed and/or modified to undertake engineering operations - are exempt from many of the regulations associated with Large Goods Vehicles. This includes the requirement to hold a Class-C licence, tachographs and driver hours regulations – so some pretty fundamental exemptions there.

You can now understand why operators try to make life easier for themselves, and shoehorn their vehicles into this classification. The analogy that comes to mind here are the Step-Sisters trying on Cinderella’s glass slipper…

Unsurprisingly, the law attempts to restrict the definition of engineering plant to avoid a situation of these sorts of loop-holes occurring which, unchecked, can have fatal consequences.   

For the record, so there can be absolutely no ambiguity in the regulations around definition of Engineering plant, the following must apply:

1. 'Movable plant or equipment being a motor vehicle or trailer specially designed and constructed for the special purposes of engineering operations and which cannot, owing to the requirements of those purposes, comply with all the requirements of these regulations and which is not constructed primarily to carry a load other than a load being either excavated materials raised from the ground by apparatus on the motor vehicle or trailer or materials which the vehicle or trailer is specially designed to treat while carried thereon;
2. A mobile crane which does not comply in all respects with the requirements of these regulations.'

The point is that exemption doesn’t mean exemption from safe practice.

As with many areas of transport regulation though, it’s a grey area and understandably something of a compliance minefield for companies knowing they could be at risk of falling foul of the law. Which is why I was speaking with the UKMDA, helping their members to minimise how much was open to interpretation and offering some insight into how a regulatory officer may stand on these matters.

It’s a presentation I’d be happy to share again, so if you’d like advice on this or any other aspect of staying on the right side of transport regulation, please call 01275 390001 or email admin@transportmanagersolutions.co.uk.