Sample policy · Patient transport

Vehicle defect, MOT and roadworthiness policy (patient transport)

Statutory anchor: Regulation 12 (safe care and treatment) and Regulation 15 (premises and equipment), Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (SI 2014/2936). The primary source for vehicle roadworthiness is the Road Traffic Act 1988 and DVSA roadworthiness guidance; this template quotes the engaged CQC regulations because the Road Traffic Act is not in the Verivius guidance manifest. · primary source

1. What the regulation says

Care and treatment must be provided in a safe way for service users. (Reg 12(1) (the headline duty))

assessing the risks to the health and safety of service users of receiving the care or treatment, (Reg 12(2)(a) (risk assessment))

doing all that is reasonably practicable to mitigate any such risks, (Reg 12(2)(b) (risk mitigation))

ensuring that the premises used by the service provider are safe to use for their intended purpose and are used in a safe way, (Reg 12(2)(d) (premises safety))

ensuring that the equipment used by the service provider for providing care or treatment to a service user is safe for such use and is used in a safe way, (Reg 12(2)(e) (equipment safety))

Regulation 15 adds the premises-and-equipment duty that this policy operationalises:

All premises and equipment used by the service provider must be ... clean, secure, suitable for the purpose for which they are being used, properly used, properly maintained, and appropriately located for the purpose for which they are being used. (Reg 15(1): the six criteria)

The full text is at https://www.legislation.gov.uk/uksi/2014/2936/regulation/12 and https://www.legislation.gov.uk/uksi/2014/2936/regulation/15. Where this policy and the regulation diverge, the regulation wins.

2. Plain-English summary

Care and treatment must be provided in a safe way. The regulation lists the areas a provider must address, including risk assessment, risk mitigation, staff competence, safe premises, safe equipment, sufficient equipment and medicines, medicines safety, infection prevention and shared-care planning. Regulation 12 is central to CQC's safety expectations. Premises and equipment, including patient transport vehicles and the patient-handling equipment carried on them, must also be clean, secure, suitable for purpose, properly used, properly maintained and appropriately located under Regulation 15.

3. Purpose

This policy sets out how the Service keeps patient transport vehicles roadworthy, records pre-shift checks, manages defects and tracks MOT, tax, insurance and patient-handling equipment.

The Service must verify this policy against current Road Traffic Act, MOT, DVSA and CQC source material before adoption. The policy is written for non-emergency patient transport services where each job depends on a safe vehicle, suitable equipment and a crew member who knows the defect process.

4. Sources to verify before adoption

5. Scope

This policy applies to:

This policy does not replace the manufacturer's instructions, MOT requirements, insurance terms or any operator-licence duties that apply to the Service.

6. Vehicle roadworthiness process

The Service keeps a live vehicle register and uses it to plan, check and evidence roadworthiness.

6.1 Vehicle register

The Fleet Lead maintains a register for each vehicle.

The register records:

The Fleet Lead checks the register before allocating a vehicle to the rota.

6.2 Pre-shift defect check

Crew complete a pre-shift vehicle check before the vehicle leaves the operating base.

The check covers:

Crew record the check against the vehicle, shift, date, time and checker. The platform records the check as an assurance task. Staff record an incident only when the check fails or a defect creates a patient-safety, staff-safety or service-continuity risk.

6.3 Defect grading

The Service grades each defect before the vehicle is used.

Crew do not override a critical defect because a job is delayed. The Operations Manager arranges a replacement vehicle, subcontracted transport where approved or a safe rebooking route.

6.4 Defect repair and release back to service

The Fleet Lead keeps a repair record for each defect.

The record includes:

The vehicle returns to service only when the Fleet Lead or delegated competent person records that the defect has been corrected or controlled.

6.5 Patient-handling equipment on vehicles

The Service treats patient-handling equipment as part of vehicle readiness.

Staff check that:

The Service does not dispatch a vehicle where essential patient-handling equipment is missing, damaged, out of service date or unsuitable for the planned patient.

7. MOT, service, insurance and tax control

The Fleet Lead keeps expiry-date control for each statutory and service record.

The Service records:

The Service does not allocate a vehicle where MOT, insurance or tax evidence is missing, expired or uncertain. Staff use GOV.UK check routes and the Service's own records to verify the position before a vehicle is dispatched.

8. Response to an unfit vehicle dispatched

If Staff identify that a vehicle was dispatched while unfit for use, they record an incident immediately.

The Registered Manager or Fleet Lead:

The review checks whether the defect was visible during pre-shift check, whether records were complete and whether rota pressure affected the decision to dispatch.

The Service does not set a fixed DVSA reporting threshold in this template. The Fleet Lead checks current DVSA source material, insurance terms and commissioner terms before reporting or ruling out external notification.

9. Responsibilities

9.1 Training and competence

Crew must be trained and assessed as competent before completing vehicle checks without supervision. The assessment covers the vehicle class and conversion they use, the local check sequence, defect reporting, stop-use decisions and the patient-handling equipment carried on that vehicle.

The Service records:

Only the Fleet Lead or another person whose maintenance competence and authority have been recorded may assess a defect, authorise a repair or release a vehicle back to service. The training matrix must show who may check, assess, repair and release each vehicle type.

10. Recording requirements

The Service keeps the following records:

Records are kept in the Service governance records and are available for internal review, CQC review, commissioner review and external review where required.

11. Audit cadence

The Service uses the following Verivius default audit rhythm unless current DVSA, MOT, CQC, insurance, commissioner or local source material requires a different rhythm:

Audit findings are recorded as improvement actions with an owner and review date.

12. Version control and review date

The Service keeps a controlled copy of this policy. The footer or document-control table records:

13. Related policies and records

Review cadence: annual or on regulatory change, whichever sooner. Owner: Registered Manager.

14. Sources and further reading

This template is based on CQC's guidance for providers and managers, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and other topic-specific legislation and guidance listed below. It is a starting point for adaptation, not a substitute for legal, clinical, HR, safeguarding or specialist professional advice.

15. When to seek further advice

Seek specialist advice where the issue involves serious harm, safeguarding, deprivation of liberty, restraint, children, professional misconduct, controlled drugs, radiation, termination of pregnancy, infection outbreak, water safety, employment dismissal, DBS barring referral, or regulatory enforcement.

16. Document control

Version Date Author Changes
v1 2026-06-10 Verivius (sample) Initial sample template, conformed to the Verivius policy standard.
v1.1 2026-07-21 Verivius (sample) Added role-based roadworthiness competence controls and linked companion policies.

This sample policy template was issued by Verivius. It is a template, not a substitute for legal advice or the tenant's own policy-development process. Where this template and live law or regulator guidance diverge, the live source wins.

What good looks like here

Written from an ex-CQC inspector's chair, but the point is safe, well-led care your team can stand behind. Each row shows what strong evidence looks like, what thin evidence looks like, and where the expectation comes from.

Patient transport is planned work, and that is exactly where the risk hides. Every non-emergency journey is booked in advance against a named patient with a known need: a stretcher, a bariatric transfer, oxygen for a long run, an end-of-life move that has to go right first time. The vehicle and its patient-handling equipment are not incidental to the job, they are the job, and the person being carried is usually frail or unwell enough that they cannot brace, cannot get themselves out, and did not choose the vehicle. That is why a tail-lift outside its thorough-examination date, a worn restraint anchorage or a brake fault carried through one more booked run is a clinical risk rather than a garage matter. The live register and an honest defect trail are what let an operations manager decline a job at six in the morning when cover is thin and arrange a replacement, an approved subcontractor or a safe rebooking, instead of leaving a crew to judge at the patient's door whether a fault will hold for one more journey. Good records show vehicles taken off the road and jobs moved. An unbroken run of clean checks almost always means the checking stopped, not that the fleet is sound.

  1. The pre-shift vehicle check is a real inspection that catches faults before the wheels move, recorded against the vehicle, shift, date, time and a named checker, rather than a block of ticks signed off after the vehicle has already left base.

    Strong evidence: The pre-shift vehicle check crew record against the vehicle, shift, date, time and checker, running from lights, tyres, brakes and dashboard alerts through to the stretcher, carry chair, wheelchair restraints, tail-lift, ramp and oxygen fixtures, logged by the platform as an assurance task with an incident raised only where the check fails or a defect creates a risk (Sections 6.2 and 11).

    Weak evidence: Months of shifts with every line ticked in the same pen, no comment box ever used and not one failed check, which reads as a signature rather than an inspection. Checks timed after the vehicle had already left base, a checker recorded as 'crew' or 'day shift' rather than a named person, or a workshop invoice for a fault that appears nowhere in the check record.

    Our recommended baseline. Not a legal or regulatory requirement, but a sensible standard we suggest where the rules leave the detail to you. Adapt it to your service.

  2. A critical defect takes the vehicle off the road at once, so no patient travels in it, rather than the fault being carried through one more booked job because the rota is tight.

    Strong evidence: The defect grading record showing a critical defect removes the vehicle from service immediately until the Fleet Lead confirms repair and release, alongside the replacement vehicle, approved subcontracted transport or safe rebooking the Operations Manager arranged instead, and the policy bar on crew overriding a critical defect because a job is delayed (Sections 6.3 and 6.4).

    Weak evidence: A brake warning light or tyre fault logged at the morning check and the same registration still on the afternoon rota with the removed-from-service field blank. A critical defect quietly regraded to major with no reason recorded and no name against the decision, or a grading timestamp that lands after the job was completed, so the call was made on the road and written up afterwards to fit.

    A legal duty. This comes from legislation that applies to your service, so meeting it is not optional. The exact provision is cited beneath the badge.

    Road Traffic Act 1988 s.40A (using a vehicle in a dangerous condition); Road Vehicles (Construction and Use) Regulations 1986 reg 100(1); Provision and Use of Work Equipment Regulations 1998 reg 5(1)

  3. The statutory roadworthiness test applicable to each vehicle's class is current: the Class 3, 4, 5 or 7 MOT for light and private passenger vehicles, or the separate DVSA annual test for buses, coaches and heavier vehicles within the public service vehicle or goods-vehicle regime. The service records which test applies to each vehicle rather than assuming the MOT covers the whole fleet.

    Strong evidence: The roadworthiness test, service, insurance and tax control record (test-certificate expiry date and certificate, whether the standard MOT or the annual test that applies to the vehicle class, insurance certificate and renewal date, vehicle excise duty status), verified through GOV.UK check routes and the Service's own register before allocation, with hired, leased and loaned replacement vehicles held on the same register (Sections 6.1 and 7).

    Weak evidence: A folder of certificate scans with no expiry-date control, so nobody can say which vehicle falls out of test cover next month without opening every file. The clearest tell is sequencing: the vehicle is allocated first and the GOV.UK check is pulled afterwards. Replacement vehicles missing from the register altogether, or an insurance renewal tracked only in one manager's personal calendar.

    What the regulator expects to see. Not a law in itself, but CQC judges you against it, so an inspector will look for it and expect a reason where you depart from it.

  4. Patient-handling equipment is in service date and matched to the person actually booked, so a stretcher, bariatric or oxygen-dependent journey is confirmed against the equipment before acceptance, not discovered at the patient's door.

    Strong evidence: The patient-handling equipment record (stretchers, carry chairs, ramps and tail-lifts within service date, wheelchair restraints and tracking clean, complete and functional, bariatric equipment where the booking requires it, oxygen fixtures secured to the local process), with the policy barring dispatch where essential equipment is missing, out of service date or unsuitable for the planned patient (Section 6.5).

    Weak evidence: A stretcher, carry chair or ramp on the vehicle inventory with no service date beside it, and tail-lift thorough-examination certificates held by the leasing company that the Service has never seen. Bariatric capacity assumed from the booking rather than confirmed against the equipment's stated safe working load, and no record anywhere of a job stood down because the equipment did not suit the person.

    A legal duty. This comes from legislation that applies to your service, so meeting it is not optional. The exact provision is cited beneath the badge.

    Lifting Operations and Lifting Equipment Regulations 1998 reg 5 (lifting equipment for lifting persons), reg 7 (marking of safe working load) and reg 9(3) (thorough examination); Provision and Use of Work Equipment Regulations 1998 reg 4(1) (suitability)

  5. Each defect carries a repair record and a named person authorising release back to service, so the next crew knows the vehicle is genuinely fixed rather than quietly back on the rota.

    Strong evidence: The repair record (defect description, whether the vehicle was removed from service, repair provider, repair completion evidence and the person who authorised release), with only the Fleet Lead or a named delegated competent person permitted to assess a defect, authorise a repair or release the vehicle back to service (Sections 6.4 and 9.1).

    Weak evidence: A garage invoice filed as the repair record, reading 'fixed' or 'serviced' with nothing describing which of the reported faults was corrected. A blank release-back-to-service line, a release signed by whoever happened to be in the office rather than the Fleet Lead or a named competent person, or an unexplained gap between the repair date and the date the vehicle carried its next patient.

    Our recommended baseline. Not a legal or regulatory requirement, but a sensible standard we suggest where the rules leave the detail to you. Adapt it to your service.

  6. An unfit vehicle reaching the road is opened as an incident and its root cause examined, testing whether the defect was visible at the pre-shift check and whether rota pressure drove the decision, not written off as a one-off.

    Strong evidence: The unfit-vehicle-dispatched incident record and review (whether the defect was visible at pre-shift check, whether records were complete, whether rota pressure affected the decision to dispatch), which separately considers whether the Regulation 20 duty of candour is owed to the person affected, and whether external notification advice from the Driver and Vehicle Standards Agency (DVSA), insurer, commissioner or CQC is needed (Section 8).

    Weak evidence: No incident at all, because the crew swapped vehicles and got the patient there, so the near miss never reached the register. Where an incident does exist, a closure line reading 'crew reminded to complete checks' with no test of whether the defect was catchable earlier, nothing recorded about the effect on the person transported, no separate reasoning on whether the Regulation 20 duty of candour threshold was reached, and the same registration appearing across several reports with no pattern review.

    What the regulator expects to see. Not a law in itself, but CQC judges you against it, so an inspector will look for it and expect a reason where you depart from it.

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Last verified 23 July 2026

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Last reviewed 21 July 2026