ALL THINGS LICENSING
authorities should require taxi and private hire vehicle drivers to undertake training and/or assessment on driving proficiency, focused on attitudes and behaviours at both first application and renewal. The rationale for this is that as professional drivers, the licensed trade should display a higher degree of driving aptitude and diligence than a private motorist, and that this is considered appropriate and proportionate and is consistent with other elements of taxi and private hire vehicle driver licensing.
Elsewhere in the BPG there is some suggestion about what other training could be included, such as training around health and safety responsibility, personal safety/security and training on emergency equipment where it is required.
The updated BPG also reinforces the position of the Statutory Standards in respect of language proficiency, and concludes that good communications skills will bring wider passenger benefits in terms of the driver’s ability to demonstrate an understanding of the desired destination, an estimation of the time taken to get there and other common passenger requests and for the driver to provide a legibly written receipt upon request.
As far as knowledge testing is concerned, for hackney carriage drivers the position of the previous BPG is maintained, in that taxi drivers should undertake a topographical assessment based upon the local area.
However, for private hire drivers, clearly advances in technology and app-based services have lead to a position in the updated BPG that operators should gather sufficient information from the passenger to identify the collection and drop-off points, which in turn will enable the driver to check the details of a route before starting a journey and plan or enter it in a navigation system. In addition, given the availability, reliability and ease of use of sat nav systems, licensing authorities should not require any topographical knowledge or navigational tests for PHV drivers. This is a movement from the position in the previous BPG which indicated private hire drivers should have a knowledge of major roads and destinations.
To conclude
It is clear that the most recent BPG, when read in conjunction with the Statutory Standards 2020 and the Taxis and Private Hire Vehicles (Disabled Persons) Act 2022, requires driver training in respect of wider disability awareness, safeguarding and driver proficiency.
PHTM MARCH 2024
In addition, it is perhaps unthinkable for any other regulated profession, such as a teacher, doctor, lawyer etc. to be able to embark upon their chosen profession without some form of vocational and competency based assessment, the BPG appears to only initially require proportionate topographical knowledge for hackney carriage drivers.
However, whilst the BPG has moved away from formal vocational training, it does set a higher standard for those mandatory subjects above and does indicate a need for drivers to receive updated training periodically during their careers.
As I said previously, whilst CPD in any professional role is to be welcomed, unfortunately any further content or interval for such assessment will likely relate to emerging issues and needs to be set out in further guidance to ensure consistency between authorities. Otherwise, further training will likely be as a result of an enforcement issue where a particular deficiency has been identified, again perhaps undermining the intended preventative nature of the licensing regime.
As for private hire drivers, clearly advances in technology have lead to a reduction in assessment, although there obviously remains some debate about how much time a private hire driver operating on an on-demand platform has to plan their route and the benefits of local knowledge in the event of a road closure or navigation failure; but this is the position intended to be best practice.
However, despite any recommended position in the BPG, we are still left with the situation where there is likely to be considerable variation in training requirements based upon local needs and decision making, and without a defined national standard there is also a risk of a race to the bottom with authorities nervous about setting high standards for the fear of licence shopping.
So, as we continue to examine the updated Best Practice Guidance, there is no more important time to be ‘in the know’ about licensing issues affecting the industry and I would again encourage members of the trade to join the Institute of Licensing where the guidance is likely to be the subject of many events and publications this year.
Full details are available at:
www.instituteoflicensing.org
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