Watermill Coaches Ltd – Enforcement Action and Tyre Management Shortcomings

Last updated: July 20, 2026

Traffic Area: Scottish Traffic Area

Traffic Commissioner: R Turfitt

Decision Date: 4 June 2026 (Published 10 July 2026)

Regulatory Outcome: Formal Warning issued; Operator’s Licence curtailed by four vehicles.

Executive Summary

Watermill Coaches Ltd, a long-established PSV operator holding a Standard National Public Service Vehicle Operator’s Licence authorising 65 vehicles, was called to a Public Inquiry following a DVSA maintenance investigation. The investigation revealed widespread compliance failures, directly triggered by a severe, safety-critical tyre defect detected during a roadside encounter.

The case underscores the fundamental role of robust tyre management and effective driver walkaround checks within a Safe System approach to road safety.

Background & Initial Incident

  • The Trigger Encounter: On 15 December 2025, vehicle WM68 LLL was encountered at Inverurie Academy and attracted an S-marked Immediate Prohibition Notice (PG9).

  • The Defect: The nearside outer sidewall tyre wall was severely scuffed with the internal cord/cords exposed.

  • Failure of Controls: The defect was long-standing and should have been identified prior to the vehicle being driven that day, and likely for several days prior. However, there was no record of a driver walkaround check being carried out on the morning of the encounter.

DVSA Maintenance Investigation Findings

Following the prohibition, DVSA Vehicle Examiner Hal Mackie conducted a maintenance investigation on 22 January 2026, grading the operator’s compliance management as unsatisfactory. The investigation highlighted systemic failures in tyre management, driver defect reporting, and record-keeping:

1. Ineffective Driver Walkaround Checks

  • The S-marked tyre prohibition was directly attributable to an ineffective or missed driver walkaround check.

  • Multiple other instances were identified where vehicles were put into service without any driver walkaround check recorded.

2. Tyre Maintenance & Record-Keeping Deficiencies

  • Unrecorded Measurements: Tread depths and tyre pressures were routinely checked during Preventative Maintenance Inspections (PMIs) but were not recorded on inspection sheets.

  • Lack of Tyre Age Monitoring: Tyre age was not recorded across the entire vehicle fleet.

  • Misunderstanding of Guidance: Management incorrectly assumed that displaying generic tyre pressure guidelines on the workshop wall removed the requirement to record actual physical tyre pressure readings during PMIs.

3. Broader Maintenance & Management Failures

  • Stretched PMIs: 64% of safety inspections exceeded the specified 6-weekly interval, driven by an ineffective forward planner and misinterpretation of inspection intervals as “flexible guidance”.

  • Brake Assessment Deficiencies: 32% of safety inspections lacked proper brake assessments, and historical annual test failures included safety-critical brake defects.

  • Transport Management Oversights: Continuous Professional Development (CPD) had not been updated for 9 years, leading to a failure to keep pace with evolving statutory compliance standards.

Corrective Actions Implemented by the Operator

In response to the DVSA findings and ahead of the Public Inquiry, the operator initiated several remedial measures:

  • Updated PMI Documentation: Job cards were revised to explicitly mandate the recording of actual tyre pressures and tread depths at every inspection.

  • 3mm Tyre Replacement Policy: Implemented a strict internal policy where any tyre with a tread depth below 3mm is automatically replaced.

  • Tyre Age Fleet Tracker: Established a dedicated central spreadsheet managed by the workshop manager to record and monitor tyre age across the fleet.

  • Enhanced Walkaround Oversight & Gate Checks: Introduced digital driver walkaround checking via the VMS (Vehicle Management System) software, supplemented by physical gate checks at depots, driver retraining, and formal disciplinary action against non-compliant drivers.

  • Management Restructure: Re-aligned workshop leadership, appointed an experienced workshop manager, and transitioned Allan Clark out of the Transport Manager role while bringing in Ryan Clark alongside Raymond Clark.

Traffic Commissioner’s Determination

The Traffic Commissioner recorded adverse findings under Sections 17(3)(a), 17(3)(aa), 17(3)(b), 17(1)(c), and 17(3)(e) of the Public Passenger Vehicles Act 1981.

Although acknowledging the operator’s significant corrective efforts and 47-year history, the Traffic Commissioner stressed that preventative vehicle maintenance and tyre safety are non-negotiable. To signal that such failures cannot recur and to ensure future compliance, the Traffic Commissioner ordered:

  1. Formal Warning: Issued to the remaining Transport Manager regarding future conduct.

  2. Licence Curtailment: A reduction of authorisation by four vehicles through 14 August 2026.

Key Tyre Safety Takeaways for Operators

  • S-Marked Prohibitions Signal Systemic Failure: An S-marked prohibition indicates that a defect is due to neglect or poor maintenance routines. Exposed cords do not occur overnight; their presence highlights an immediate failure of driver daily checks.

  • If It Isn’t Recorded, It Didn’t Happen: Checking tyre condition and pressure is insufficient on its own; actual physical tread depths (in mm) and pressure readings must be recorded on PMI documentation to provide leading indicators of vehicle roadworthiness.

  • Tyre Age Management is Vital: Operating a fleet without clear records of tyre age poses significant compliance risks, particularly on heavy passenger-carrying vehicles where tyre integrity is critical.

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