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The inability of the driver to alter or delete the data is listed as an advantage. But to the driver that most certainly wouldn't be an advantage. To me this seems like a POV issue; when something is an advantage to one group and a disadvantage to another, aren't we not supposed to accept one group's point of view as the valid one for the purposes of an article? flarn2006 [utc] time: 01:58, 23 March 2018 (UTC)[reply]
It's an advantage in the use of the system as it is less susceptible to forgery. And it may be a disadvantage to drivers who want to forge their records in order to drive more, but an advantage to drivers who don't want to be overworked and risk having an accident from being too tired to drive. That's one of the main reasons for the use of tachographs: it protects drivers from being made to drive past the point of tiredness, as the burden is shared between the driver and the company (and defence cases for drivers will recognise drivers being pressured into driving for too long).
I agree with the forgery point, but there are other, legal reasons why the restrictive methods of recording data on digital tachographs are disadvantageous.
Firstly, recording corrections and/or deviations from regulations. The regulations allow a driver to depart from the regulations under certain circumstances - for example, to drive beyond the legal number of hours in order to get to safe parking, in the case of unforeseeable circumstances. Also, drivers are human, and as such, are not infallible. It is possible to make mistakes (e.g. "I forgot to put it on break and accidentally recorded my daily rest as other work"), and these are unlikely to be prosecuted unless obviously fraudulent or happening frequently. Under the analogue tachograph regime, the method for recording these deviations was to write on the back of the corresponding tachograph chart. Therefore, these annotations were, by definition, recorded and stored along with the tachograph records to which they corresponded.
With digital tachographs, the required method for recording these deviations is to do a printout and then write on the back of that. The disadvantage of this is that these records are stored separately to the (digital) data downloaded from the cards. Digital data is the "normal" way of keeping records, and it is easy for the data to get separated, unless the operator is meticulous about keeping records. If the operator is subsequently audited, the driver may find it difficult to defend against what could be a legitimate departure from the rules - "Can you explain why you drove for too many hours on X day, 18 months ago?" If the paper chart gets misplaced, the driver is out of luck because the incriminating evidence is available, but the exonerating evidence is not.
I agree that the digital tachograph system should not allow drivers to alter recorded data; however, I think it should allow drivers to record corrections/annotations on the card, so that they get downloaded and stored together with the "normal" data.
Secondly, not everyone driving under tachograph rules is a full-time driver. Personally, I drive approximately once a week. The rest of the time, I'm working in an office job. In order to be legal, I have to carry around tachograph records showing all my working time. I have two options for doing this - either manually fill out analogue charts or digital tachograph "till roll" paper (which then needs to be stored by the operator, see above comments related to that), or make manual entries onto my card.
The ONLY legal way in which you can make manual entries onto a card is to use an approved tachograph head unit that has been calibrated and installed into a vehicle. The interface for making manual entries is very clunky, if you're having to make a lot of them. At the start of a shift, I can easily spend half an hour just making manual entries for the previous couple of weeks' worth of office work.
The old regime of manually filling out charts is still rather inconvenient, but it is simpler, less stressful, and it is possible to correct mistakes (throw away the chart and do a new one). If you make a mistake in your manual entries on a digital tachograph, you cannot correct it and hence you have to take a lot of care to ensure they are correct.
I think it should be possible to make manual entries onto the card using a device other than a tachograph head. There is a plethora of card reading hardware and software on the market; it would not be difficult to add the ability to record activity onto the card (possibly being marked as having been made by non-tachograph hardware), and computer software could do this with a much easier interface, but this is not currently possible because the cards have been designed to prevent it. I cannot (currently) think of any reason why adding the ability to make manual entries onto the card would assist a driver in forging records.
