Updated requirements for Laden Brake Testing – April 2025

Ensuring commercial vehicles are roadworthy is a vital duty for operators and transport managers. A key aspect of this responsibility is brake testing, which has been highlighted in the latest updates to the "Guide to Maintaining Roadworthiness," effective from April 2025.

What is expected?

To follow best practice and comply with legislation there is an expectation that every safety inspection will include a brake performance assessment. Conducting a laden brake test using a calibrated roller brake tester is the most effective method of measuring individual and overall braking performances.

There is an expectation, where EBPMS is not used, for a minimum of four Laden Brake Tests per year. If you operate on a 13 week inspection cycle, this means a Laden Brake Test on every safety inspection. If you are on a more frequent inspection cycle, every inspection should have a minimum of a brake performance assessment with a risk assessment, completed by a competent person, detailing why a laden roller brake test was not completed.

The use of an EBPMS system is deemed as an acceptable alternative to Laden Brake Testing and would not require a risk assessment to be completed.

Operators must satisfy themselves that the methods used to assess brake performance are sufficient to meet the requirements of Regulation 18 of The Road Vehicle (Construction and Use) Regulations 1986.

What is a brake performance assessment?

A brake performance assessment could be any of:

• A Roller Brake Test

• An Electronic Brake Performance Monitoring System

• A Decelerometer test with individual temperature readings

Exemptions? Where is the detail?

Details of the exemptions from these requirements found in the Guide to Maintaining Roadworthiness include:

• Unladen Tri-axle Semi-Trailer (ULTAST) – Trailers where under normal operating conditions (more than 70% of the time) run at less than 65% of the permitted axle weights.

• Vehicles where under normal operating conditions (more than 70% of the time) run at less than 65% of the permitted axle weights. This may include car transporters where they are designed for that specific task.

• ADR – Only when the load is considered dangerous and specialist facilities are not available.

• Livestock carriers – Where other means of loading are not possible.

• Noxious load carriers – Only when designed and constructed for this purpose.

• Furniture removal vehicles – Only when designed and constructed as a furniture removal vehicle.

• Vehicles operating at 50% or more of permitted axle weights when unladen – This could include fixed plant, mobile libraries, compactor vehicles, exhibition type vehicles, bullion vehicles

• PSV – Includes prisoner transfer vehicles.

• Where the construction or weight prevent the use of an RBT - This could include vehicles where their load compartment consists of racking, the design of the floor compartment cannot withstand the necessary load that would need to be imposed on it, the load compartment is used for carrying food products and simulated loads would cause contamination of the compartment

Although this list is not exhaustive, it would be the responsibility of the operator, in conjunction with the maintenance provider, to assess the risk involved using the Risk Assessment. There is an expectation that every attempt must be made to conduct a laden roller brake test.

Who is competent?

The risk assessment process will vary depending on the operator and maintenance provider.

The basis of the Risk Assessment would require input from both the operator, who understands if the operation of the vehicle meets one of the exemptions, and from the maintenance provider to ensure a form of assessment is carried out.

The guide to maintaining roadworthiness details the competent person must have a working knowledge of braking systems and components.

Communication between each element will be key, as even if using EBPMS, there are details which the operator would be required to share with the maintenance provider.

Conclusion

The updated guide to maintaining roadworthiness has prompted a lot of operators to look at alternatives to laden roller brake tests. While best practice will be to complete a laden brake test on every inspection, EBPMS is a viable alternative to operators wishing to stay complaint.

The allowance of brake performance assessments with risk assessment give some flexibility to operators on higher frequency inspection cycles, but may not be an option for all.

Understanding your operations, and working closely with your maintenance provider will be key to staying compliant.

Training:

With the expected increase in required Laden Brake Test capacity, the RHA have partnered with Prestige Transport Compliance and Blyth Auto Solutions, to offer a Roller Brake Testing IMI accredited programme. The programme is designed to increase the number of ‘competent persons’ as required within the Guide to Maintaining Roadworthiness. This programme will establish that the candidate has the knowledge and competency to undertake a rolling road brake test on heavy goods vehicles, heavy trailers coaches and buses, understand the importance of a good brake test result and how that effects road safety and the operators responsibilities.

For further information on this training course, please contact our national helpdesk on 01274 863100