Quality street

Ian Gillgrass looks at how the recent MOT changes mean a Quality Management System is essential

Published:  25 July, 2018

The MOT has gone through change over the past few years. There have been changes in the way the MOT tester and the MOT Centre Manager become eligible to operate a Vehicle Testing Station (VTS) through the qualifications that are available through various national and local training organisations,  through to the MOT tester having to manage their own Annual Training and the Annual Assessment.

In combination with the revised MOT Inspection Manual (aligning to the European Directive) being implemented during May 2018, some confusion may exist in this ever changing sector.

The VTS has several people roles that exist, one major role; the Authorised Examiner (AE) or Authorised Examiner Designated Manager (AEDM) being the person having the ultimate responsibility within the business.

A new VTS and those  changing their approved status will need an AE/AEDM to hold the Level 3 Award in MOT Test Centre Management prior to the VTS becoming approved by DVSA. Most training providers will deliver the MOT Centre Manager qualification. Part of the qualification is that the person understands how to operate a Quality Management System (QMS) for the purposes of the VTS. This has been identified as an area that most people struggle with within the qualification.

To implement an effective QMS program, the business must initially internally agree the standards that they set. The results are then collected and reported into the QMS. Any problem should have a corrective action. This should be written with an indication the people responsible to carry out the action along with a completion date. If the same problem repeats, then a plan should be developed to improve the situation, and put into action.

The following highlights a few areas that where the QMS needs to focus.

Training
The AE should ensure all staff (employees and contractors) fully understand their responsibilities. This enables them to carry out their job accurately and remain compliant with the necessary requirements.

The MOT tester should ensure that they meet the requirements of the MOT tester Annual Training and Annual Assessment. This year the annual training includes updating their knowledge of the MOT Inspection Manual which was introduced in May 2018. Most MOT testers will be familiar with the revisions and updates to the MOT Inspection Manual, either through specific training prior to the changes or reviewing the Inspection Manual during its implementation stages.

The AE should also ensure that the MOT testers that carry out tests at the VTS, are compliant with the requirements. Failure to do so will result in the MOT tester unable to test vehicles. It should be noted that some MOT testers that have not met the requirements have taken many weeks to become reinstated as an MOT tester as a result of non compliance which could reduce business income.

At present there is no requirement for the MOT Centre Manager to comply with the updating of their MOT knowledge but this could change in the near future.

Procedures
The AE should ensure that everyone involved in the MOT testing process within their business has access to key information, especially focusing on MOT test logs and MOT Test Quality Information (TQI).

TQI can be accessed by both the AE and also the MOT tester, reviewing the MOT test data applicable to their role. The data can indicate both strengths and weaknesses with the MOT testers and the VTS, it is therefore important that this data is regularly reviewed to identify any anomalies within the data and implement an ‘action plan’ to correct any deficiencies, therefore both the MOT tester and the AE have a responsibility in this area.

MOT TQI was highlighted as a requirement for the MOT tester annual training/annual assessment. It is therefore suggested that the MOT Centre Manager also updates their knowledge on Test Quality Information (TQI) and also MOT test logs.

The AE should ensure that the relevant people know procedures for the reporting of equipment defects/problems, the equipment maintenance and any equipment calibration requirements within the specified dates as indicated by the MOT Testing Guide. The AE must ensure that any appropriate records (calibration certificates) are kept and the records are held securely.
The AE should always ensure that the equipment is maintained and calibrated correctly, if a problem is detected (yes things do go wrong) preferable before a breakdown occurs then a clear process should be identified and the rectification of the equipment recorded.

Assurance
The MOT tests which are carried out at the VTS must always have the correct result, the security of data, information and passwords are maintained which will lead to the reduction in risk of MOT fraudulent activity. The protection of data used in the MOT process needs to comply with the General Data Protection Regulation (GDPR) which was also introduced in May 2018 replacing the Data Protect Action (DPA) that previously covered the data. The AE has a duty to ensure this has been complied with.
The process should also include a Quality Control process of the MOT tester to ensure that they produce satisfactory results, and to identify any future weaknesses in their MOT test procedures.

The MOT Testing Guide (updated earlier this year) indicates that a QC check needs to be performed on an MOT tester every two months. Best practice would indicate that the QC process is completed on each MOT tester more frequently such as every month. The QC check should be recorded and kept in-line with the requirements. The QC report should indicate the strengths and weaknesses of each individual (not just indicating the MOT tester is OK) with an ‘action plan’ (further training etc) on how to reduce the weaknesses. The next month Quality Control report should then indicate how the MOT tester has performed against the ‘action plan’. This could help to reduce the VTS risk score, improving MOT tester performance but also increase business performance.
Performing and recording quality control checks within an MOT business can be time consuming and often gets forgotten. The person carrying out the MOT QC must be carried out by an approved DVSA MOT tester. The QC can be achieved within the MOT testing team providing more than one MOT tester is engaged (one MOT Tester is nominated as the QC) or alternatively a service that an outside agency could provide. A Vehicle Testing Station with only one MOT tester could have a reciprocal arrangement with a nearby similar business by carrying out the QC check on each other.

Improvement
An effective QMS used within the VTS should identify any weaknesses that could put the station at risk. Once a weakness has been identified the business should develop an action plan to improve within the area of weakness. This will typically lead to an improvement.

All these points will help to achieve a low VTS risk score. The MOT centre manager should read and understand the various documents provided free by the DVSA on how to carry out a VTS risk assessment and to hopefully reduce the VTS risk score.
The AE can find out more on the qualification by contacting a recognised training provider delivering the MOT Centre Manager Qualification, this will help them better understand the requirements of a Vehicle Testing Station and the various MOT Testing documents and standards associated with MOT testing. Many of these requirements have been revised over the last few years, and it is a requirement for the AE to constantly update their knowledge to remain current. Remember the MOT Testing Guide was revised in early 2018 and many AEs do not have knowledge of the new requirements.

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