The Overlooked Danger of Shadowing in the DVS PSS Market

The DVS Progressive Safe System market has grown rapidly as London's HGV operators work to achieve and maintain compliance. With growth has come a problem that fleet operators need to be aware of: shadowing.

What Is Shadowing?

Shadowing refers to the practice of fitting camera and sensor equipment that appears to meet DVS PSS requirements but doesn't actually satisfy the technical standards required for accreditation. Operators who have been advised they're compliant may find, when scrutinised by TfL, that their system doesn't meet the standard.

This can happen for several reasons: equipment that was compliant under previous standards but not the updated ones; systems that meet some but not all requirements; or, in some cases, deliberate misrepresentation by suppliers.

The Risk for Fleet Operators

The consequences of operating a non-compliant system in good faith are the same as operating a non-compliant system knowingly: penalty charges and the liability exposure that comes from operating a vehicle that doesn't meet the safety standard it's supposed to meet.

Fleet operators have a responsibility to verify that the systems fitted to their vehicles actually meet the current DVS PSS requirements — not just the requirements at the time of installation.

How to Protect Yourself

Work with suppliers who can provide unambiguous documentation of compliance for specific vehicle configurations. Use TfL's DVS checker to verify compliance status independently. And when requirements change, review existing configurations proactively rather than assuming that existing equipment remains compliant.