The maintenance investigation for goods vehicle operators. Trailers count, and section 9 is about the load.

By Scott Woodfield, who builds HGVault. Last checked 7 November 2026.

When a DVSA examiner comes to look at a goods operator’s maintenance, the questions they work through are public. DVSA publishes the whole set, with what each question requires and how each answer is marked, and its roadworthiness guide encourages operators to use it to assess their own systems. On a goods licence the same questions read differently, because the yard is full of trailers and the loads are the operator’s problem too.

In brief

• DVSA combined its separate HGV and PSV investigation guides on 1 April 2022. The questions were last updated on 4 May 2023.
• On the report form, vehicle means vehicles and trailers, so 3 lorries and 6 trailers make a fleet of 9.
• Section 9 on a goods licence covers load security arrangements and the training of everyone who loads, carries and unloads.
• An unsatisfactory fleet assessment adds 50 roadworthiness points to your OCRS, or 100 if DVSA reports it to the traffic commissioner.

How the visit is marked

Each question section ends in one of up to four outcomes. Satisfactory needs no action, and mostly satisfactory brings advice. Unsatisfactory needs your explanation of what you’ll do about it, after which DVSA may close the case, run later checks through its Remote Enforcement Office or send the report to the traffic commissioner. Report to the Traffic Commissioners means the report goes to them with your explanation attached, whatever it says.

The visit report has fourteen question sections, from the legal entity on your licence to the transport manager, and two of them are split by licence type. Question 4g, on incident reporting with the PSV112 form, is for operators with PSVs only and drops out of a goods operator’s visit. Section 9 changes completely, and on a goods licence it’s about load security.

Trailers count as vehicles

The questions put it in one line. On the maintenance investigation report form, the word vehicle refers to vehicles and trailers. Trailers go into the fleet size, and DVSA’s own example is an operating centre with 3 vehicles and 6 trailers treated as a fleet of 9. The recommended minimum the examiner inspects at the fleet check goes by that number.

Take a yard with 14 tractor units, 3 rigids and 22 trailers. That’s 39 in possession, so the examiner should inspect at least 3, chosen where possible across different types and ages and at different points in their inspection and test cycle. The trailer that’s sat in the corner since August is as likely a pick as the newest unit. Third-party trailers can go into the fleet check too, where you’re responsible for one at the time of the visit.

The record sample counts the same way. With no prohibitions in the last 15 months, the examiner analyses 12 months of records and checks at least 4 files for a fleet of 39. With prohibitions it’s 15 months and at least 5 files, plus every prohibition file they can get to. A file is every maintenance document for one vehicle or trailer. The sample should take in articulated and rigid vehicles and semi and drawbar trailers, and it grows if the first files turn up problems. The analysis runs on DVSA’s safety inspection period calculator and analysis tool, SIPCAT.

Brake tests on lorries and trailers

Question 4b wants every safety inspection to assess the braking performance of the vehicle or trailer, with the inspector recording how it was done. It lists three ways. One is a laden roller brake test, with a recommended minimum of 3 a year on top of the one at the MOT. Another is a decelerometer test with brake temperatures, for rigid vehicles. The third is an assessment from an electronic braking performance monitoring system, EBPMS. A road test on its own isn’t enough.

The Guide to maintaining roadworthiness comes at it from the other side, expecting at least four laden tests a year spread evenly where EBPMS isn’t used, the annual test included. It also says decelerometers can’t be used for trailer brakes at all. One difference between the two documents is worth knowing. Since May 2023 the questions allow EBPMS for any vehicle, while the guide, updated in 2025, still says EBPMS is at present only available for use on trailers.

Laden is the awkward word for a curtainsider that comes back empty most nights. The guide lets a vehicle be roller tested up to 14 days before its inspection, so the laden test can be done during normal work. The facilities question also expects arrangements for loading vehicles and trailers for brake tests, so the examiner will ask how yours get loaded.

What section 9 asks a haulier

Whether your load security arrangements work, and whether the people involved are trained for them. Question 9a expects everyone in the transport chain to know the rules in the Department for Transport code of practice on the safety of loads on vehicles. The arrangements it lists include:

• up to date risk assessments
• responsibilities for loading, transport and unloading set out in contracts of work
• drivers involved in loading where possible
• supervision and quality checks
• a reporting procedure, with action taken, when a load shifts
• vehicles that suit the load, and load security equipment that’s checked regularly and fit for purpose
• loading plans used consistently

Question 9b covers training for drivers and anyone else who loads, carries or unloads, on your loads, your securing systems and your vehicles. It names the restraining equipment, loading and unloading procedures, load plans, load weight and distribution, and load security risk assessments. DVSA’s load securing guidance is the place to start on all of it.

Load security equipment that’s inappropriate or in poor condition is a listed reason for unsatisfactory, so the bin of frayed ratchet straps at the back of the shed counts against you. It goes to the traffic commissioner on clear evidence of deliberately inappropriate load security instructions or policy, or of training records that are false or don’t exist.

Prohibitions on trailers you don’t maintain

Section 10 looks at every roadworthiness prohibition in the sample period. That period starts from whichever is most recent of the last public inquiry that considered roadworthiness prohibitions, the last maintenance investigation fleet check, or three years ago. Each defect is marked S for a significant failure of roadworthiness compliance, X where it’s no reflection on your maintenance system, or left blank where it can’t be told either way.

Goods operators get one extra test. Where you weren’t responsible for a third-party trailer’s safety inspection, the examiner checks whether your driver could have known about the defect from a walkaround, a system warning or simply towing it. A flat tyre or a hanging marker lamp that was there to see in the yard at five in the morning points straight at your walkaround system, and our guide to HGV walkaround checks covers what the driver should be looking at.

One more line in section 10 matters. An investigation generated by a roadworthiness most serious infringement must be reported to the traffic commissioner whatever the outcome of the visit. That infringement is a penalty or conviction for using a vehicle with a dangerous defect on its brakes, steering, wheels, tyres or suspension, and a category 1 S marked prohibition sets one off.

Trailer prohibitions reach your OCRS too. One issued at the roadside is allocated to the vehicle pulling the trailer. Trailer MOT results aren’t counted in the roadworthiness score, but a prohibition issued to a trailer at its MOT is.

After the visit

If anything is unsatisfactory or reportable you’ll get a request for explanation. The reply should reach DVSA within 14 days of the report being given to you, and a further 7 days can be allowed only in exceptional cases, with the examiner writing the reason on the report. A signed maintenance contract or the missing inspection sheet carries more weight than a promise. Where a fix takes longer, a firm commitment can be accepted, such as a laden roller brake test at every inspection confirmed by the maintenance provider. A good reply won’t undo a recommendation to report you to the traffic commissioner, though. That stands either way.

The visit also lands on your OCRS as a fleet assessment. On the roadworthiness side, unsatisfactory adds 50 points and unsatisfactory with a report to the traffic commissioner adds 100. On the traffic side, which covers offences such as drivers’ hours, the figures are 100 and 250. A satisfactory or mostly satisfactory visit adds nothing. This is general information, and the questions themselves are the place to check anything your licence depends on.

Marking your own files first

Pull a trailer file at random and read it the way an examiner would. Is there a brake result behind every inspection, and does the sheet say how it was done and whether the trailer was laden? Then ask for the paperwork on the last customer trailer your drivers pulled on traction-only work, because it sits in someone else’s office until you ask for it. Have a look in the strap bin while you’re at it. Our page on what it checks sets out the records HGVault reads for you, and our guide to trailer safety inspections covers what a trailer file needs.

HGVault’s maintenance investigation self-check works through DVSA’s questions in the HGV form against your own records. It fills in what the records show for each question and suggests an answer with the reason, and the office confirms or changes each one before signing it off. SIPCAT figures come from the same records. The walkthrough has a made-up haulier to try it on.

Sources

• GOV.UK (DVSA), Maintenance investigations, questions
• GOV.UK (DVSA), Vehicle operator maintenance investigations
• GOV.UK (DVSA), Guide to maintaining roadworthiness
• GOV.UK (DVSA), Use the operator compliance risk score (OCRS) system
• GOV.UK (DVSA), Securing loads on HGVs and goods vehicles, responsibility for load security