Advice / Support

Here you will find answers to the most frequently asked questions regarding operations. Please scroll down for more information. 

We have a passenger who keeps removing their seatbelt while the vehicle is in motion. Can we use a buckle guard to prevent them undoing their seatbelt?

The Road Vehicles (Construction and Use) Regulations state anything (such as commercially available ‘buckle guards’) that modifies the seatbelt or prevents easy access to the buckle should not be used and could be subject to enforcement action. Our advice to operators would be to avoid the use of any tools, guards, or restraints which do not comply with these regulations, and use alternative measures such as distraction, additional support in the vehicle, and (if needed) disabled people’s seatbelts.

Can we advertise on our minibuses?

Yes, you can advertise your own services on your minibuses when they are operated using section 19 permits if these services are not operated for profit. Remember that section 19 permits cannot be used ‘with a view to profit nor incidentally to an activity which is itself carried on with a view to profit’. 

Commercial Advertising or Sponsorship  Section 19 permit vehicles:  As a vehicle operated using a section 19 permit cannot be used ‘with a view to profit nor incidentally to an activity which is itself carried on with a view to profit’; then care has to be taken when considering commercial advertising or sponsorship on your vehicles.  

These types of deals are common these days and lawyers for the Department for Transport have clarified that it is the relationship between the permit bus operation and the sponsor that must be taken into account when deciding whether the requirements of ‘with a view to profit nor incidentally to an activity which is itself carried on with a view to profit’ are met.  

The purpose of section 19 as a whole is to enable certain types of non-commercial service to be operated without the need for an operator’s licence. For example, a section 19 service supported by a supermarket, could not provide a service to the store because the use of the bus would be incidental to a profit-seeking activity.  However, other types of sponsorship unconnected with the operation of the vehicle may not violate the section 19 restriction.  

Examples would be a vehicle supplier or manufacturer donating vehicles in return for the operator carrying their sponsorship details on the vehicle, or a vehicle carrying general advertising (e.g. of commercial products) unconnected with its operation. In both cases, the operation of the permit vehicle is independent of the sponsors or advertisers, who only gain a fringe benefit from the display of their name or advertising message.  Section 22 permit vehicles:  The rules which enable section 22 permits contain no restrictions on the use of commercial sponsorship or advertising. 

Can we use school bus signs?

Yes, buses being used to carry children under the age of 16 to and from school at the beginning and end of the day must display a special prescribed sign both at the front and the rear of the vehicle. Minibuses operated using section 19 permits which provide home-to-school transport should display school bus signs.  

The signs must have a black border enclosing a silhouette of two children on a yellow reflective background. There should be a sign displayed at the front of the vehicle which must be at least 250mm × 250mm with the black border not more than 20mm wide and one displayed at the rear of the vehicle at least 400mm × 400mm with the black border not more than 30mm wide. 

Can we use a bus lane?

Bus lanes on general purpose roads and “Buses only” roads are reserved for ‘buses’ and also, where indicated on the signs, pedal cycles and taxis.  A ‘bus’ in the context of these regulations includes all passenger vehicles with more than 8 passenger seats as well as any local buses not so constructed or adapted when operating a registered local service. 

The lanes are clearly marked with special signs which indicate times of operation and it is an offence for other vehicles to use them at these times except for taxis and cyclists if the sign so indicates. County councils, unitary authorities’ councils, metropolitan county councils and in Scotland, regional councils may make local traffic regulations orders to restrict lane use to “local” buses and to control picking up and setting down points used by buses providing local and/or other services and excursions and tours services.  If a bus lane is marked as ‘Local’ then only buses operating on a local registered bus service may use the lane, if this is the case a minibus or bus operated using a section 19 permit cannot use it.  

Minibuses and buses operated using section 19 permits are allowed to use bus lanes as they are within the definition of a ‘bus’.  An accessible minibus which has had seats removed for the carriage of passengers who are using their wheelchair as a seat will still be, by definition, a bus as the legislation states that they have to be constructed or adapted to carry more than 8 passengers. 

In NI there are different regulations around the use of bus lanes, dependent on the type of bus lane and time of use. Find out more here: https://www.infrastructure-ni.gov.uk/articles/use-bus-lanes