Managing Hired HGVs and Trailers: A Compliance Checklist for Operators

First-use inspection before the hired asset works

The Guide to Maintaining Roadworthiness requires operators to conduct a first-use inspection before using a newly acquired vehicle on the public highway, to satisfy themselves that the equipment is roadworthy. First-use inspections are essential for operators who lease, hire or borrow vehicles — especially where vehicles and trailers have been off the road for some time. A first-use inspection must not be confused with a driver’s daily walkaround check.

In some instances a first-use inspection is not required where sufficient evidence shows the equipment has already been subject to a safety inspection. That evidence has to be on your file before the wheels turn, not assumed because the hire desk said the vehicle was fine.

Operator licence and specification

The goods vehicle operator licensing guide expects vehicles used under the licence to be properly authorised. Temporary and hired vehicles still need a place in your authorisation and disc arrangements. Leaving a hired vehicle on the licence after it has gone back can affect repute and paperwork. Notify changes within the timescales the licensing guide requires.

• Confirm the vehicle or trailer is within your authorised numbers and centres
• Display the correct disc arrangements for the period of use
• Know when the hire ends and remove or update licence details promptly
• Keep hire agreements with the maintenance file for that period

Hired and third-party trailers

Where trailers are changed during the day, each trailer that is used should be checked on the walkaround. The guide expects a contract or written agreement with the trailer owner covering safety inspection details, frequency and defect rectification where that arrangement is needed to keep roadworthiness acceptable. Providing evidence that first-use and safety inspections have been done and there are no defects is part of that relationship.

Prohibitions issued to a trailer at the roadside are allocated to the vehicle pulling it for OCRS purposes. A “not my trailer” argument does not remove the combination from scrutiny while you are using it.

Safety inspections and defects while on hire

Operators are responsible for the condition of vehicles and trailers that are inspected and/or maintained for them by agents, contractors or hire companies. Agree who does the safety inspection, at what interval, and how defects are rectified before return to service. Recording the maintenance of hired or temporary vehicles is called out in the roadworthiness guide — the history from the days the asset was yours to run still belongs in your file.

How inspections work is in HGV PMI inspections. How intervals are declared is in HGV PMI inspection intervals. Hire company sheets do not excuse a gap against the interval you rely on for that period of use.

Records after off-hire

Safety inspection and defect records are kept for at least 15 months, including for vehicles no longer on the licence. Handing the keys back does not hand the duty to produce the history from the days you operated the asset. Electronic copies count if you can find them by vehicle and date.

Common questions

Does the hire company own the compliance duty?

They may do the work under contract. You remain responsible for the condition of vehicles and trailers maintained for you, and for producing records for the period of use.

Is a hire desk “passed MOT” enough?

An annual test pass is not a first-use inspection and not a substitute for the safety inspections during the hire. Ask for evidence, then keep it.

Do I walk around a third-party trailer?

Yes when you use it. Each trailer in a day of swaps should be checked.