Working time guide

Understanding the 17-week WTD average.

What the 48-hour average means for HGV drivers, what counts as working time, and why POA and breaks matter.

The short answerFor HGV drivers in scope of the road transport working-time rules, weekly working time must average no more than 48 hours over the reference period. The normal reference period is 17 weeks, although it can be extended to 26 weeks if a valid collective or workforce agreement allows it.

What is the 17-week WTD average?

WTD is often used by drivers as shorthand for working-time rules. For many HGV drivers under assimilated or AETR drivers’ hours rules, the relevant rules come from the Road Transport (Working Time) Regulations.

The important point is that the 48-hour limit is an average. One heavy week does not automatically mean a breach, but that week has to be balanced across the reference period.

How do you calculate the average?

Add the working-time hours across the reference period, then divide by the number of weeks in that period.

Total working time over 17 weeks816 hours
Reference period17 weeks
Average working time48 hours

If the total for 17 weeks is above 816 hours, the average is above 48 hours. If it is below 816 hours, the average is below 48 hours.

What counts as working time?

Working time is wider than driving time. It can include time when the driver is at the vehicle or workstation, available to the employer, and doing road transport work.

  • Driving.
  • Loading and unloading.
  • Vehicle checks, cleaning and maintenance connected with the work.
  • Work linked to safety of the vehicle, load or passengers.
  • Administrative tasks directly linked to the transport operation.
  • Waiting time where the likely duration is not known in advance.

What does not usually count?

Breaks and genuine periods of availability are normally excluded from working time. A period of availability is not just any waiting time. In plain English, it usually means waiting where you know the likely duration in advance and can reasonably dispose of your time.

Examples can include waiting while other workers load or unload the vehicle, or time on a ferry, when the period is known in advance and the driver is not doing other work.

Can you work more than 48 hours in one week?

Yes, provided the average remains within the limit. Under the road transport working-time rules, a single week can reach 60 hours of working time, but the average across the reference period must still stay at or below 48 hours.

That is why a driver can have a busy week and still be compliant, but repeated high weeks quickly use up the room in the average.

How do WTD breaks fit in?

The working-time rules also include break requirements. A mobile worker should not work more than six consecutive hours without a break. If working time is more than six hours but not more than nine, breaks should total at least 30 minutes. If working time is more than nine hours, breaks should total at least 45 minutes. Breaks should normally be at least 15 minutes long.

Drivers’ hours break rules may also apply, so drivers need to consider both sets of rules rather than treating WTD as the only check.

Who keeps the records?

Employers are responsible for keeping working-time records for employed mobile workers. The official guidance says records need to be kept for two years. Self-employed drivers in scope also need to keep their own working-time records and make them available if required.

A personal diary app can help you understand and check your own week, but it should not be treated as a replacement for tachograph, employer or legally required records.

Common questions

Does POA count towards the 48-hour average?

Genuine periods of availability normally do not count as working time. The key is whether the waiting period is known in advance and whether the driver is free from work during that time.

Does driving time count as working time?

Yes. Driving is working time. But working time can also include other road transport work such as loading, vehicle checks and job-related administration.

Can I opt out of the 48-hour WTD average?

For mobile workers under the road transport working-time rules, there is no individual opt-out from the average 48-hour weekly limit.

Is the reference period always 17 weeks?

The normal reference period is 17 weeks. It can be extended to 26 weeks where a collective or workforce agreement permits it.

Does CabLog replace my tachograph or employer records?

No. CabLog can help you keep a personal working record and understand your totals, but official tachograph and employer records remain the source of truth.

Official source

This guide was checked against DVSA’s Drivers’ hours and tachographs: goods vehicles — Annex 2. Working time rules. Rules can change, and different work patterns or exemptions may affect which rules apply.

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