Fleet duty of care is sometimes treated as a compliance exercise. Check driving licences. Confirm vehicles have an MOT. Record servicing. Issue a driver handbook. Keep the relevant documentation on file. All of those things can form part of a responsible fleet operation, but they do not in themselves demonstrate that work-related road risk is being effectively managed.
The Health and Safety Executive (HSE) says employers must manage health and safety risks to people who drive or ride as part of their work, just as they would manage risks arising from activities at a fixed workplace. Importantly, its guidance applies to both company vehicles and employees’ own vehicles used for business journeys – the grey fleet.
The HSE’s approach centres on three areas: the journey, the driver or rider and the vehicle.
That provides fleet managers with a useful framework of their own: safe driver → safe vehicle → safe journey
Effective duty of care means being able to understand and manage all three continuously, rather than proving once a year that the correct paperwork existed.
Start with Who Actually Drives for Work
Before an organisation can manage occupational road risk, it needs to know who is exposed to it.
That population may be considerably larger than the employees traditionally considered “fleet drivers”.
It can include employees driving company cars and vans, cash-allowance drivers, occasional business drivers, employees using their own cars for work, temporary workers and other people driving as part of their role.
The HSE explicitly includes grey fleet vehicles within its work-related road safety guidance and defines these as vehicles owned and driven by workers for business purposes, including vehicles used under cash-allowance schemes.
The first practical question is therefore not: How many fleet vehicles do we operate?
It is: How many people drive on behalf of our organisation?
That distinction can expose gaps in duty-of-care processes very quickly.
Check Driver Eligibility, and Keep Checking It
An employee having a valid licence when they join an organisation does not guarantee that nothing subsequently changes.
Fleet managers need an appropriate process for confirming that employees remain legally entitled and suitable to drive the vehicles required for their work.
HSE guidance says employers should consider drivers’ experience, attitude, driving record, fitness and competence as part of risk assessment, as well as ensuring licences, insurance and MOTs remain legal and up to date.
Technology can help organisations move away from fragmented spreadsheets and periodic manual administration.
FleetCheck, for example, provides fleet-management software covering areas including driver management, vehicle compliance, licence checking, maintenance and associated fleet records.
SambaSafety specialises in driver risk management and monitoring, bringing together driver-record information, telematics and risk data to help organisations identify drivers who may require intervention.
The important capability is not simply performing a check.
It is recognising when the result of that check means something needs to happen.
Move from Compliance Data to Driver Risk
A driving licence provides useful information.
It does not provide a complete picture of how somebody drives.
That is where additional data can strengthen fleet risk management.
Telematics can potentially highlight patterns such as speeding, harsh braking, acceleration and other behaviours. Camera technology can provide additional context around incidents and risk, while driver-monitoring systems can help organisations identify behaviours requiring coaching or intervention.
HSE guidance specifically says telematics can be used to audit performance and notes that any system should be straightforward for drivers and coaches to use and interpret. It also stresses that technology should sit within documented policies and a wider risk-management approach.
ORBCOMM provides fleet telematics and vehicle-management technology capable of giving operators visibility of vehicles, journeys and driver activity.
SambaSafety combines driver and telematics data to build driver risk profiles and support targeted intervention.
Exeros Technologies specialises in vehicle camera and safety technology, including systems designed to improve driver visibility and provide evidence and insight around road incidents.
The value of these technologies is not the amount of data they generate.
It is whether that data results in safer behaviour.
Turn Driver Data into Intervention
A common danger with fleet technology is collecting considerably more information than anybody has the capacity to act upon.
Hundreds of speeding events or harsh-braking alerts do not automatically create a safer fleet.
Fleet managers need to determine which behaviours indicate meaningful risk, which drivers require attention and what intervention should follow.
That might include:
- A conversation with the driver
- Targeted coaching
- Online training
- Practical driver training
- Route or workload review
- More frequent monitoring
- Formal escalation where necessary
The HSE recommends prioritising training towards higher-risk drivers and riders, including those with high mileage, poor collision records or other vulnerabilities.
The useful operational cycle becomes: identify → understand → intervene → monitor → improve
This is more valuable than simply producing a monthly driver score.
Manage the Vehicle, Not Just the Driver
Duty of care cannot be addressed through driver monitoring alone.
Vehicles themselves must be safe and fit for use.
HSE guidance says employers should ensure vehicles are maintained in a safe and fit condition and that workers understand that unsafe vehicles must not be driven. Privately owned vehicles used for work must also be safe, appropriately serviced and covered by valid insurance and MOT requirements.
A fleet-management system can help centralise records for servicing, MOTs, inspections, defects and other compliance requirements.
FleetCheck provides tools for areas including vehicle maintenance, driver checks and fleet compliance, helping organisations build a clearer record of whether required actions have been completed.
But systems should support a live process rather than simply create an electronic filing cabinet.
If a driver reports a serious vehicle defect, for example, fleet managers need confidence that the issue is escalated, the vehicle is prevented from inappropriate use and the repair is recorded.
The question is not only whether the organisation can demonstrate compliance afterwards.
It is whether the process prevents an unsafe vehicle going onto the road in the first place.
Don’t Forget Grey Fleet
Grey fleet can be one of the most easily overlooked duty-of-care risks.
An employee using their own vehicle for a business journey may not feel like part of the fleet operation at all.
From a work-related road-risk perspective, however, that distinction is important.
The HSE makes clear that its guidance applies to company and grey fleet vehicles and says privately owned vehicles used for work need to be safe, serviced, insured and covered by a valid MOT where required.
That means organisations need appropriate processes for identifying grey-fleet drivers and checking relevant documentation.
It also raises a broader question: is the employee’s own vehicle actually suitable for the journey they are being asked to undertake?
Duty of care follows the work journey, not the ownership model of the vehicle.
Treat the Journey as a Risk Factor
The third part of the HSE framework is sometimes the least visible in fleet systems: the journey itself.
A competent driver in a safe vehicle can still face unnecessary risk if the organisation creates unrealistic schedules.
HSE guidance recommends considering journey duration, location, timing, weather, rest breaks and whether the journey is necessary in the first place. It also advises employers to avoid exceptionally long working hours and ensure sufficient time is allowed for safe deliveries and collections.
This is particularly relevant where productivity targets and road safety can unintentionally conflict.
If an employee can only meet their schedule by speeding, skipping breaks or driving while tired, a driver-training course alone will not solve the underlying problem.
The organisation needs to examine the work design.
Take Fatigue Seriously
Fatigue affects reaction time, vigilance, concentration, information processing and decision-making, according to the HSE.
It therefore needs to be treated as an operational risk rather than simply a driver’s personal responsibility.
Fleet managers should consider mileage, working hours, journey schedules and opportunities for appropriate rest.
Technology can provide additional support. The HSE notes that drowsiness-detection technology can be effective where fatigue is a risk, while stressing that it should not replace fatigue-management measures such as appropriate shift scheduling.
That distinction is important across fleet safety technology generally.
Technology can identify risk.
It should not become an excuse for creating the risk in the first place.
Use Cameras as a Safety Tool, Not Simply an Incident Recorder
Vehicle cameras are often associated with providing evidence after collisions or disputed incidents.
Increasingly, however, camera systems can form part of proactive driver-risk management.
Exeros Technologies provides vehicle CCTV, AI camera and driver-safety systems designed for commercial fleets, including technologies capable of detecting and alerting drivers to hazards.
For fleet managers, camera technology can potentially support several objectives: incident evidence, driver protection, visibility around larger vehicles, investigation and targeted coaching.
But introducing cameras also requires appropriate governance.
Drivers should understand why technology is being used, what information is collected, who can access it and how that information may be used.
Safety technology works best when employees understand that its purpose is to reduce risk rather than simply to catch people doing something wrong.
Investigate Near Misses as Well as Collisions
A collision provides obvious evidence that something went wrong.
A near miss can provide an opportunity to fix the same problem before somebody is injured.
HSE guidance recommends systems for reporting work-related road incidents and near misses, followed by investigation to identify underlying causes and whether controls need to change.
Telematics and camera systems can add useful evidence to that investigation.
But fleet managers should look beyond the immediate driver behaviour.
Why was the vehicle there? Was the schedule realistic? Was fatigue involved? Was the vehicle suitable? Had similar events happened previously?
The aim should be learning rather than simply allocating blame.
Build a Road Safety Culture
Technology, policies and checks can provide the structure for duty of care.
Culture determines how consistently that structure works.
Brake, the Fleet Summit’s charity partner, works with employers and fleet professionals to manage work-related road risk and encourages organisations to establish road-safety cultures supported by policies, procedures, driver training and education.
That means employees need to feel able to report concerns.
A driver should be able to say that they are too tired to continue safely, that a schedule is unrealistic or that a vehicle has a defect without believing that doing so will automatically be treated as poor performance.
Equally, organisations need clear expectations about unsafe behaviours.
Duty of care should be something employees experience in everyday fleet operations rather than something they encounter only during induction.
Make Responsibility Visible
Fleet risk can cross several departments.
Fleet teams may manage vehicles. HR may hold employee information. Health and safety teams may own risk policies. Operations may determine workloads and schedules. Procurement may choose vehicles and technology.
If responsibility sits everywhere, there is a danger that it effectively sits nowhere.
The HSE recommends clearly allocating health and safety responsibilities so that people understand their roles and accountability.
Fleet managers should therefore establish who is responsible for checking, escalating and acting on different areas of road risk.
Technology can make those responsibilities easier to administer, but ownership still needs to be clear.
Questions to Ask Fleet Duty-of-Care Providers
When assessing technology and services, fleet managers should consider:
- Which drivers, vehicles and journeys can the system monitor?
- Can it include grey-fleet and occasional business drivers?
- How are driving-licence and eligibility checks managed?
- Can vehicle compliance, servicing and defects be monitored centrally?
- Which driver behaviours can telematics identify?
- How is driver risk scored and prioritised?
- Can camera or video evidence be integrated into incident investigation?
- How does the system distinguish isolated events from repeated risky behaviour?
- Can high-risk drivers automatically trigger intervention workflows?
- How are training and coaching outcomes recorded?
- Can managers identify trends across teams, locations or vehicle types?
- How does the platform support incident and near-miss investigation?
- What controls govern access to driver and camera data?
- Can information be exported for audit and compliance purposes?
- How does the technology help managers turn risk information into action?
Frequently Asked Questions
What is fleet duty of care?
Fleet duty of care refers to an organisation’s responsibilities for managing health and safety risks affecting employees and others when vehicles are driven for work. HSE guidance treats work-related driving as a health and safety activity and recommends assessing the driver or rider, vehicle and journey.
Does duty of care apply to grey-fleet drivers?
Yes. HSE guidance explicitly states that work-related road-safety responsibilities apply to both company and grey-fleet vehicles, including employees’ own vehicles used for business purposes.
Can telematics support fleet duty of care?
Yes. Telematics can help identify driver behaviour and journey risks and support performance monitoring and incident investigation. The HSE recommends implementing it as part of a documented risk-management process rather than treating technology as a standalone solution.
What should fleet managers monitor?
Relevant areas can include driver eligibility and risk, vehicle roadworthiness, incidents and near misses, mileage, journey patterns, speeding or other driving behaviours, fatigue exposure and whether identified risks result in appropriate interventions.
Are employers responsible for journey planning?
Employers should consider work-related journey risks including duration, routes, schedules, weather and opportunities for breaks. HSE guidance also recommends considering whether journeys are necessary and allowing employees enough time to complete work safely.
Product Guide
Exeros Technologies Ltd
Vehicle technology specialist providing commercial fleets with vehicle CCTV, camera and driver-safety systems. Its solutions can support incident evidence, driver visibility and proactive identification of risks around commercial vehicles.
Website: https://www.exeros.co.uk/
FleetCheck
Fleet-management software provider supporting vehicle and driver administration, compliance and maintenance. Its platform includes tools for areas such as driver management, licence checking, vehicle inspections, servicing and fleet records.
Website: https://www.fleetcheck.co.uk/
ORBCOMM
Industrial IoT and fleet telematics provider offering connected vehicle and asset-management technology. Its fleet solutions can provide visibility into vehicle location, utilisation, journeys and driver activity to support operational and safety management.
Website: https://www.orbcomm.com/
SambaSafety
Driver risk-management specialist providing technology that combines driver-record, telematics and other risk information. Its solutions are designed to help organisations identify higher-risk drivers and use data to target training, coaching and other interventions.
Website: https://sambasafety.com/
Supporting Safer Roads with Brake
The Fleet Summit is proud to support Brake, the road safety charity, as its charity partner.
Brake works with employers and fleet professionals to help organisations manage work-related road risk, promote safer driving behaviours and build stronger road-safety cultures. Its work also extends beyond fleets through campaigns to prevent road death and injury and support for people affected by road crashes.
For fleet professionals, Brake provides resources and programmes focused specifically on managing occupational road risk.
Find out more: https://www.brake.org.uk/
From Compliance to Continuous Risk Management
Duty of care should not be reduced to proving that a licence was checked or a vehicle had a valid MOT on a particular date.
Road risk changes continuously.
Drivers change. Vehicles develop faults. Working patterns alter. Journeys become longer. Behaviour changes. New risks emerge.
The strongest fleet duty-of-care strategy therefore connects: driver → vehicle → journey → risk → intervention → review
The first three tell the organisation where risk exists. Technology can help reveal how that risk is changing. But intervention and review are what turn the information into safer outcomes.
The Fleet Summit brings together senior fleet decision-makers and relevant solution providers through pre-arranged one-to-one meetings, providing an opportunity to explore driver-risk management, telematics, vehicle safety, compliance and wider fleet technologies.
With Brake as the Fleet Summit’s charity partner, work-related road safety also forms part of a wider commitment to reducing road death and injury and making journeys safer for everyone.
Related Reading
This is the first article in our October Duty of Care series.
The follow-up will move from establishing a duty-of-care framework to using the information it generates: how fleet managers can identify higher-risk drivers, turn telematics and incident data into meaningful interventions, and use coaching, training and continuous monitoring to reduce work-related road risk.
Sources
- HSE – Driving and Riding Safely for Work: Employers – https://www.hse.gov.uk/roadsafety/employer/
- HSE – Plan and Manage Journeys – https://www.hse.gov.uk/roadsafety/employer/plan-manage-journeys.htm
- HSE – Make Sure Drivers and Riders Are Safe – https://www.hse.gov.uk/roadsafety/employer/make-sure-drivers-riders-are-safe.htm
- HSE – Look After Your Workers’ Health – https://www.hse.gov.uk/roadsafety/employer/look-after-workers-health.htm
- HSE – Make Sure Vehicles Used for Work Are Safe – https://www.hse.gov.uk/roadsafety/employer/maintain-vehicles.htm
- Brake – Fleet Professionals and Employers – https://www.brake.org.uk/get-involved/for-professionals/fleet-safety
- Brake – Road Safety in the Workplace – https://www.brake.org.uk/get-involved/take-action/in-your-workplace
- Exeros Technologies – https://www.exeros.co.uk/
- FleetCheck – https://www.fleetcheck.co.uk/
- ORBCOMM – https://www.orbcomm.com/
- SambaSafety – https://sambasafety.com/
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