OK, I'm back at my desk now having done my best to forget all about tachos for the last 10 days until you lot spoilt it! Driver's rest rules do have a sort of logic but are nevertheless overcomplicated and in my opinion the ferry break rules in particular fly in the face of road safety, which is supposed to be what tachos were all about in the first place.
Re ferry (or train) breaks, you are allowed to interrupt a normal 11 hour break no more than twice and for a total of 1 hour which must then be added to the break ie an 11 hour break becomes 12 hours. This can only be done for the purpose of getting on or off a ferry (or train) and said conveyance must allow access to bunk or couchette.
The problem with recording non-tacho activity is a common one for "occasional" drivers who must be able to produce records for the previous 28 days when they drive an in-scope vehicle (generally over 3.5 tonnes). We give our drivers an "attestation" (see link below) if they've not driven for a while eg after a holiday, which is a set format document and has to be completed in type (ie not handwritten) and signed by driver & manager with a copy retained by both. This is accepted by authorities for professional HGV drivers but it's a bit more complicated if you only drive every now and then and this is where a detailed log book is normally used. You could also use the back of a paper tacho disc as you would if the tacho was broken, but you have to keep a record for every day between driving stints so a log book makes more sense than a pile of loose charts. However, the law merely requires that a record should be kept and doesn't specify the precise format. Those of us blessed with digital tachos can make manual entries on those.
Ideally, you need to show how your time is spent each day eg 00.01 - 08.00 daily rest, 08.01-12.00 other work, 12.01-13.00 break and so on through to 24.00. Tacho rules still apply to this non-driving time so you need to show adequate daily rest and don't forget to record weekly rest as well. You can't finish work on the car at midnight and set off in the truck at 6am. However we all know how the motorsport industry works and the problem for race truckies is that they might drive for a day or two and work all weekend before driving home and spending a few days in the workshop then do it all over again, which is clearly in breach of both Working Time and tacho rules. You could be tempted to erroneously record non-tacho time, but the Man from the Ministry isn't daft and will use wage slips, email records, mobile phone logs etc to prove that someone was working when they claim to have been on rest. Whether they have the will or resources to do this when there is easier meat to be found elsewhere is another matter. I think the priority for most drivers will be to avoid trouble at a roadside check so having clear records with you at the time will reduce the risk of a follow-up visit to your office which is when the worm can will well and truly empty out.
Slightly off the original topic, but perhaps more of a roadside risk than tacho infringements (because it's so easy to detect), is the lack of a Driver CPC card which I'm sure a lot of casual and part time drivers might not have due to the disproportionate (IMO) investment in time & money needed to achieve it when they may only drive on odd occasions. Without this card the driving licence is only valid for purely personal use, so any form of commercial driving over 3.5T cannot be undertaken. I think this will become a real issue as the enforcement authorities tighten up on what is still relatively new legislation. Penalties are already commonplace.
If you haven't already lost the will to live (I'm getting close) this is an exerpt from the VOSA (now DVSA) guide which can be enjoyed in its entirety at
https://www.gov.uk/government/upload...and-europe.pdf This is a 2011 document and some minor changes have since been made, but generally is still holds good. There are however a couple of points I would make about the guidance below, firstly the advice to keep records only for the current week is at odds with the general requirement to keep records for 28 days, so I would always do the latter. Secondly, simply showing start and finish times on non-driving days may not satisfy a suspicious official at a roadside check, I would always record full details:
Recording other work
Drivers must record all other work and periods of availability – including work for other employers – on all driving and non-driving days within a week where they have undertaken driving that comes within the scope of the EU rules on drivers’ hours since their last weekly rest.
For example, a driver who works in a warehouse on Monday, Tuesday and Wednesday and wishes to drive a vehicle within the scope of the EU rules on Thursday of the same week must complete records for Monday, Tuesday and Wednesday.
The record must be either:
u written manually on a chart;
u written manually on a printout from a digital tachograph;
u made by using the manual input facility of a digital tachograph; or
u for days where a driver has been subject to the domestic drivers’ hours rules and a record is legally required (see page 27), recorded in a domestic log book.
For the non-driving days, the record may simply show the driver’s name, the date, and the start and finish of the shift. These records must be carried on the vehicle by the driver to be produced to enforcement officers for the relevant period (see individual sections on how to make manual entries).
Information to operators
A driver who is at the disposal of more than one transport undertaking must provide each undertaking with sufficient information to allow them to make sure the rules are being met.
Rest and other days off
The period of time unaccounted for between successive charts produced by a driver should normally be regarded as (unless there is evidence to the contrary) a rest period when drivers are able to dispose freely of their time. In the UK, drivers are not expected to account for this period, unless enforcement authorities have reason to believe that they were working. Nevertheless, on international journeys it is recommended that letters of attestation from the employer are provided for drivers travelling through other countries to cover any sick leave, annual leave and time spent driving a vehicle which is out of scope of EU/AETR rules during the preceding 28 days. An EU approved attestation form can be downloaded from:
http://ec.europa.eu/transport/road/p...al_form_en.htm