Salvage Code of Practice Soft Launch.


Well readers, the revised salvage code of practice had its "soft launch" yesterday so that industry can be "ready for it"....Ready for what I ask myself, a non legislative gentleman's agreement that is dangerous to the industry financially and just dangerous (Potentially) to the public. Written by the Insurers for the insurers totally ignoring all previous owners of the code. 

Not supported by the BVSF, MVDA, MCIA to name a few.

The BVSF has received an "offer of dialogue" with the co-writers in the last 24 hours but, to be honest if they have soft launched a document will they really want to substantially alter it in an attempt to gain some support from the industry it affects...I think probably not although I would add that we would happily meet with them if the meeting was considered worthwhile. 

In the light of this announcement the BVSF have prepared a media pack showing what the ill conceived, poorly written document really means for both industry and the public alike.and this will be issued to the media in the month leading up to the alleged launch date of 1st October. (A number of print houses have already requested the information)

Furthermore the Federation will be offering any member a Categorisation confirmation checking service, totally free of charge in the instance of a suspicion of "commercial categorisation".


Full report in the up and coming magazine

The BVSF have recently received information via email from the EA concerning the cessation of OPRA and the introduction of Performance Based Regulation. Obviously BVSF will feed into the consultation when we are able. However, should any individual companies wish to comment then may I respectfully suggest that these comments are forwarded to the BVSF offices in the first instance so that they can be collated into one cohesive document.

 Click Here to go to the informal consultation


Secretary General






Performance based regulation 


 Environmental Permitting Regulations


Performance bands                   The Plan                   How to get involved                 Feedback



Our future approach to regulation.



We are seeking to evolve our existing approach to regulation, to take forward our proposals in  Regulating for People the Environment and Growth (link below) and also to deliver the six key principles of our regulatory strategy:


  1. Protecting people, the environment and responsible business through proportionate regulation
  2. Enabling business to develop, supporting growth
  3. Being customer focussed
  4. Maintaining public and business confidence in us as a regulator
  5. Working in partnership to maximise outcomes
  6. Our charges are sustainable and recover our costs


Working collaboratively, we aim to develop an approach that is fairer to industry, that supports growth, and that protects our environment and local communities, as shown in the graphic representation on the right. We want to make a system that not only describes an operator’s performance more accurately, but is also more reflective of the regulatory effort we have to apply.


Some regulators, including the Civil Aviation Authority are already in the process of transitioning their approach from compliance to performance in order to realise a range of benefits and opportunities for their customers, and similar approaches are also proposed in the recently published Regulatory Futures Review.










Performance band proposals



Moving to a performance based approach would enable us to better focus our regulation at sites regulated under the Environmental Permitting Regulations (EPR) on outcomes (rather than rules), we could use innovation to realise step changes in improved environmental standards and economic efficiencies. It would help to drive social, environmental and economic benefits by recognising positive and socially responsible behaviours.


For business it would further support a level playing field, and we could recognise and reward those that voluntarily go beyond compliance.

For local communities it recognises the importance of positive public engagement, making them feel better protected, informed and reassured.

Operator behaviour, and specifically negative behaviour is something which impacts on legitimate businesses within a sector, the local community and also the health, safety and wellbeing of our staff.  A performance based framework gives us an opportunity to clearly set out expectations of operator behaviour, and would also enable us to recognise positive behaviours.

Our proposals include moving to four descriptive bands:




We will support all permitted sites to meet the Expected level of performance through concise, accessible and reliable advice and guidance. We will encourage self-reporting and recognise positive operator behaviours in addressing minor incidents.


However, if an operator displays unresponsive, obstructive, abusive or hostile behaviour, such as poor complaint handling, persistent non-payment of fees, unsatisfactory community engagement or unwillingness to comply, then this would lead to the site being in one of the two Improvement Needed bands.

A site in an improvement band could expect to be the focus of our regulatory effort; in many cases we will take enforcement or remediation action to reduce unacceptable risks.


Exemplary will be for operators  whose behaviour and compliance record provides verification that we can reduce our regulatory effort and will include a form of regulated self-assurance.






The plan for performance bands



We have been working internal colleagues from across the Environment Agency to create initial proposals for what performance based regulation may look like. We recognise that it is vital to engage with those who regulate and those who represent them to gain feedback and comment on these initial proposals.  


We will aim to formally consult on performance band proposals in Summer 2017. We are considering implementation for performance based regulation for Waste and Installations permits (including Intensive Farming) in April 2018, with other EPR regimes likely to follow in 2020 - 2021




Innovative Regulation industry workshop 


As part of our informal engagement we ran an industry workshop on 26 April, attendees were representatives from trade associations across the EPR regimes.We received some really useful feedback on our initial proposals, which will help shape and inform them for formal consultation.


Thank you again  to those that came along and contributed. Unfortunately workshop places were limited, however the information shared on the day is available to all, how to access this information is highlighted in the article below.











How to get involved



We are running an informal engagement  on these proposals via our consultation hub.  You can access this at the link below, the site contains questions on our initial proposals that we would like your views and feedback on.


The comments and feedback we gain from this informal engagement will help shape and inform the proposals. The site below will be open from 28 April 2017 until 26 May 2017.


 We will use future e-bulletins to provide key updates around the work on performance bands as well as highlighting opportunities for further engagement.




From Sunday 1st January 2017,

You must send technical applications for the HGV, PSV, trailer and Carriage of Dangerous Goods by Road (ADR)  through GOV.UK

Any applications sent by email from 1 January 2017 won’t be processed.

Applying online should speed up the whole process for you.

Read the recent blog post about changes for submitting technical applications to find out how to:

  • apply for an Individual Vehicle Approval tests
  • apply for a test certificate for a lorry or trailer
  • apply for a test certificate for a bus or coach
  • tell us about a change to a bus or coach 

 Insurance Consultation.

The BVSF have been advised of a Consultation that is running until late March this year relating to.... 
broadening the UK definition of a motor vehicle and extending the insurance requirement beyond roads and other public places. This could mean users of motor vehicles (including trailers) would be required to have third party insurance on private land.
This consultation has been brought about due to an incident elsewhere in the EU and the subsequent actions of the commission. Of course, the UK is leaving the EU but we have to abide by decisions made until we actually leave unfortunately. Had this incident occurred in the UK it would have been covered under the Public Liability section of members insurance policy so in theory at least it wouldn't have been a problem 
Currently as it stands members of the BVSF do not need to separately insure their fork lift trucks or similar machinery as they have cover for these vehicles on their private land via the public liability insurance they have in place The only time they need to insure items such as fork lift trucks or other machinery would be if they were used on roads or public places such as their car parks To separately insure every "vehicle" as is one of the options being considered on site would not be practical for our members and financially would be potentially crippling and almost impossible to police.


It is clear that a great deal of thought needs to be applied to the answer to this consultation and rest assured that this will be done. We can't sadly just say "we don't agree" and hope the problem goes away !!!



Roger West AMIMI
Secretary General
01303 814325



Keeping You Informed - The Insurance Act 2015


From time to time various acts of legislation appear that can be of significant importance to merit discussion.


One of these is The Insurance Act 2015

The legislation is seeking to create a new and fairer balance between policyholder and insurer. The main provisions of the Act give effect, with some modifications, to the recommendations made in July 2014 by the Law Commission and Scottish Law Commission.

The changes will have a significant impact on how insureds and insurers approach policies, creating new duties for insurers and policyholders to comply with.

The Act deals with:

·         Duty of disclosure, both before a contract incepts and when amended

·         Warranties (including basis of contract clauses)

·         Terms not relevant to the actual loss

·         Fraudulent claims by insureds

·         Good faith

·         Amendments to the Third Parties (Rights Against Insurers) Act 20101

Please click here to find a CCRS briefing document which will provide some clarity. If you wish to discuss the document further, please do not hesitate to contact our office where we will be happy to help.



CCRS Vision: Partnership, Understanding, Value and Extraordinary Service

Main Telephone: 0141 212 8820