Grey fleet vehicle management

Despite a national four-month lockdown in 2020, road traffic accidents were still excessive in the UK. There were an estimated 1472 fatal collisions, 22,014 seriously injured casualties, and 115,333 casualties of all severities. Of these accidents, Brake – a road safety charity – estimates that at least 31% of fatal and 26% of all road traffic accidents involve someone driving for work, with driving for work established as the most dangerous activity most workers will undertake. Therefore, managing Work Related Road Risk (WRRR) is a prominent matter for all employers and employees.


The HSE has been prompted to issue new guidance around ‘driving and riding for work’ due to the changing nature and exponential rise in other forms of work-based transport. This will incorporate the vast expansion of gig economy workers who use vehicles they themselves own for business purposes, known as grey fleet vehicles and drivers. The guidance will replace that of the ‘driving for work’ guidance published in 2002 and relay the legal requirements imposed by the Health and Safety at Work Act and other associated legal requirements.

The law

The Health and Safety at Work Act applies to work activities on the road as it does on a fixed site and requires employers and employees to manage the health and safety risks associated with their works. The duty of the employer and employee must ensure work vehicles and drivers/themselves are appropriately licensed, maintained, and competent in undertaking work tasks. Companies are exposed to prosecution or third-party claims if an employee driving on company business is involved in an incident and their vehicle is not in a roadworthy condition or not adequately insured with business insurance use cover.

Management and policy

Health & Safety management requires employers to establish a fleet management system for grey fleet vehicles and workers to ensure they meet their obligations. Typical management requirements would evidence and be evidenced annually or with a change in circumstances. These would entail safe vehicle checks:

  • Valid MOT testing certificate
  • Certification of motor insurance, valid for business use
  • Road tax

All documentation is available online through the DVSA vehicle look-up tool.

Other appropriate measures may include:
  • Planning and managing employees' journeys
  • Competency, capabilities, training and instructions
  • Distractions being removed while on a journey (do not disturb functions are available on smartphones)
  • Worker's health, fatigue, stress, mental health issue and posture
  • Driver's licence and any other applicable documentation


The Health & Safety obligations employers and employees uphold are commonly confused and misconceived when managing grey fleet vehicles. Employers usually believe that giving a driver cash instead of a company car dismisses any formal Health & Safety liability and responsibility towards an employee, which is untrue.

Gig economy workers are in abundance and can be mainly characterised by short-term working relationships. It can be non-standard, casual, unpredictable, irregular, and temporary, and take into account almost all types of work.

  • Limb b - workers who are dependent contractors, characterised as self-employed but provide a service for someone else’s business would still be required by the Health and Safety at Work Act to ensure obligations are met. The contract provider would need to make sure the vehicle and contractor conformed to these associated legal obligations.
  • Self-employed - similarly to ‘limb b’ workers the Health and Safety at Work Act would require the self-employed worker to conform to legal obligations that ensure the Health & Safety of themselves, and anyone affected by their work.
  • Temporary work and employees – the employment business has a contractual obligation to assign employees temporary work and should regard the worker in the same respect of the HASAWA and ensure their health and safety whilst in employment or carrying out works.

How Citation can help

If you’ve got any questions about vehicle and driver safety in your business, as a Citation client you can call our Health & Safety advice line 24/7, 365 days a year on 0345 844 4848 or email 

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