I'm emailing you this just as a reminder, as in all three Districts where I help with MiDAS, I have come across illegal minibus operation!
In order to be operating legally, every minibus which you use, whether or not you own it, must display a fully valid Section 19 Permit. To be valid, the Permit:
a) must be "in date"
b) must be COMPLETELY legible - i.e. you must be able to read every bit of it. The Scout Association, unfortunately, have got some dodgy pens and the ink often completely fades after less than a year.
c) be applicable to the passengers you are carrying.
Could I urge everyone to make it part of their regular checks to examine their Permits? Could I also urge to to stress to your drivers that they should never, ever get behind the wheel of a minibus without being absolutely sure that everything is tickety-boo? As I mention as part of MiDAS theory, you are driving a Public Service Vehicle, and therefore higher standards apply. I'm concerned that drivers are obviously regularly getting behind the wheel without checking the vehicle's permit. Although I can't find an easy internet link to any cases, MiDAS assures me that minibuses are being impounded, passengers left at a DVSA checkpoint or motorway service station, and the drivers being issued with fines and points for driving otherwise than in accordance with their licence, for incorrect Section 19 Permits (or even none at all!)
I have come across a number of minibuses in all three Districts that I work with, where the Section 19 Permits are faded, in some cases to the point that the ink has completely vanished. I've actually had to cancel practical driving sessions on several occasions because the driver cannot produce a valid Section 19 Permit, and that's a waste of both my time and the driver's time, especially as the driver and I are both putting ourselves out in order to provide a service for their Group/Unit.
If the writing on your Permit fades, it is NOT legal to overwrite it, it must be returned to the Scout Association and a new Permit be requested.
I should note that I've had information from MiDAS that the fact that the Permits fade from purple to blue is not relevant, they are still valid. It's the writing on them that matters.
As regards item (c) above, generally if the Permit is for Class A only, this is usually not enough. If your application form gives you options, you need to ask for Classes A & B. If you are using a "free text" form, you need to ask for "Members of the body holding the permit, persons whom the body exists to benefit and persons assisting them," in which case you might get Classes A & F instead. When you get your Permit, you then need to make double-check that it is valid for those classes of passenger. Why? Because if you want to take a parent or non-Scout instructor for any reason, you can't without Class B/F, because that person is not a member of the Scout Group/District, and needs to be included in Class B/F as a "person assisting."
To be absolutely correct, only one Permit should be showing, and that should be the one relevant to the trip (i.e. a Group one or a District one). Leaving a cluster of Permits on your windscreen could cause trouble at a DVSA checkpoint. Issuing a Permit could, therefore, be part of the system for issuing the keys - the driver picks up the keys and the relevant Permit. To say that the driver might forget is to admit that your drivers are not completing proper roadworthiness checks before driving, if you look at it logically.
There is a spotlight on minibuses at the moment, due to some changes in regulations which are currently out for consultation ( https://www.gov.uk/government/consultations/section-19-and-22-permits-how-to-apply-eu-regulation-10712009 ). It is likely that the regulations will get tighter, not looser.
As always, I'm very happy to field any questions, as it is quite easy to get it wrong and hugely important to get it right.
This email has been sent to leaders who are the Group/District contacts for minibuses and the DCs of those Districts.
Yours in Scouting
District Administrator, Cotswold Edge Scout District