扒哥吃瓜

WESTERN TRAFFIC AREA

T M A HAULAGE LTD: OH1142579

TRANSPORT MANAGER: Andrew Tucker

DRIVERS: Andrew Tucker & Bradley Baulf

AT A PUBLIC INQUIRY AND DRIVER CONDUCT HEARINGS IN BRISTOL

11 JUNE 2026

BACKGROUND

TMA Haulage Limited is the holder of a standard international goods vehicle operator鈥檚 licence authorising the use of five vehicles and two trailers from a site at Old Emborough Quarry, Wells. Four vehicles are shown as in possession. The sole director is Andrew Shaun Tucker. The licence was granted in February 2016. The transport manager from grant is also Andrew Shaun Tucker. 听

DVSA began an investigation following intelligence suggesting that drivers for the company were using a second card to avoid the need for breaks. The period considered by the investigation was 2 June 2025 to 3 August 2025. The company produced driver card and vehicle unit data for that period. The driver card data identified no significant infringements. However, analysis of the vehicle unit data indicated potential misuse of a driver card belonging to Bradley Baulf.

The Traffic Examiner Visit Report identified a number of weaknesses that reflected upon the fitness of the operator and the competence, in the general sense of that word, of the transport manager leading to a direction from a Deputy Traffic Commissioner that the operator, transport manager and two drivers be called to public inquiry and conduct hearings respectively.

THE PUBLIC INQUIRY

Director, Transport Manager and driver Andrew Tucker, administrator Michelle Washington and consultant Barry Hood attended for the operator represented by Millicent Dooher, barrister, Smith Bowyer Clark. Traffic Examiner Chris Eggins attended for DVSA. There was no appearance from driver Bradley Baulf.

The operator had provided further evidence to Mr Eggins who had produced a pre-public inquiry report for which I was grateful, particularly as the operator had submitted their evidence late. The report appeared to identify further possible falsification of records through the use of another person鈥檚 driver card and multiple occasions of manual entries not being made.

The proceedings were recorded and a transcript can be made available on request. I record here only the key points necessary to make a decision.

I noted that there had been no written submissions which was unusual for this representative. Ms Dooher told me that submissions were a matter for the solicitor who had prepared the case and the decision had been taken to make those submissions orally. Ms Dooher apologised for the late submission of a contiguous set of bank statements.

Ms Dooher told me that the pre-PI report was not contested. She told me that Mr Tucker would now accept that he was using someone else鈥檚 card for the three instances in the original report and two further instances in the pre-PI report.

The evidence of Traffic Examiner Chris Eggins

Traffic Examiner Eggins adopted his public inquiry statement. He told me that DVSA had intelligence provided that indicated drivers at TMA Haulage were using a second person鈥檚 driver card, triggering the investigation. Mr Eggins told me that there were virtually no drivers hours infringements in the driver card data. Patterns of driver card changes indicated the potential use of a third-party card belonging to Bradley Baulf. Mr Baulf had been offered five weekday dates for interview but said he could not take time off during the week. He had then been offered a Saturday which he declined in advance. A date was then set for a Sunday and a colleague travelled from Plymouth to Bridgwater for the interview under caution. Mr Baulf contacted him at around 2 o鈥檆lock to ask where specifically the interview would be held. At 2:45, Mr Baulf emailed to say that his son had been taken ill and he could no longer attend. TE Eggins then emailed Mr Baulf to say that he could make written submissions or meet mid-week but nothing further was heard.

For the pre-PI report, a large bundle of documents was produced but not raw data. That had been chased by my office and then provided. There was reference in the vehicle data to driving by a Bradley Tucker and a Harry Hillard but there were no driving licence checks for those drivers nor driver card data.

There remained an issue of missing records in relation to Mr Tucker and a Jessica Reynolds. In relation to Ms Reynolds, the card is withdrawn neither at home nor at the operating centre with no means of getting to and from the vehicle. There were two further examples of Mr Baulf鈥檚 card having been used.

The evidence of Andrew Tucker

Mr Andrew Tucker introduced himself as director, transport manager and driver. Mr Tucker confirmed that he had been interviewed in relation to the three allegations of driving while using another person鈥檚 card and he had denied them. The position now was that he accepted that the allegations were true. It had been him driving the vehicle with Mr Baulf鈥檚 card inserted.

On 11 June 2025, 40 minutes of driving had been carried out with Mr Baulf鈥檚 card in the head. On 24 June, it was 2 hours and 50 minutes of driving. On 22 July 2025, 3 hours and 10 minutes of driving were recorded.

Mr Baulf is an ex-employee. When selling his vehicle, he had found the card down the side of the seat. He had tried to contact Bradley but been unable. Mr Baulf left employment in March 2025. The two further instances in the pre-PI report during April 2026 had not been subject to interview. On both occasions, Mr Tucker had been driving using Mr Baulf鈥檚 card. The card had now been cut-up and put in the bin.

Ms Dooher asked for some contextual evidence to be heard in private 鈥� see Appendix 1.

James Brown is an employed driver. On 2 July, it had been discovered that he had withdrawn his card and used Mr Baulf鈥檚 card. Mr Brown suffered from Crohn鈥檚. He had a medical incident where he had to be back home very quickly. He asked to use Mr Baulf鈥檚 card and Mr Tucker gave it to him. Mr Tucker didn鈥檛 know how much driving time he had left but could see the seriousness of the incident. Both had been delivering to the same site in Castle Cary.

In terms of missing manual entries for positioning journeys, Mr Tucker had not until recently known how to enter them. He had always kept a diary of his transport manager duties. A couple of drivers knew how to do manual entries.

Bradley Tucker is unrelated and the owner of West Wilts commercials, the maintenance provider. I was satisfied that driving by Mr Tucker could be associated with maintenance events.

Harry Hellard is Jessica Reynolds鈥� partner. Jessica is an employed driver. I was satisfied that there was no wrongdoing in relation to Mr Hellard鈥檚 driving; without access to his driver card data, it is not possible to know whether he properly recorded the positioning journey. Ms Reynolds鈥� trip home at that point was not recorded on a manual entry as required. Mr Tucker told me that sometimes a female driver could not be parked-up in a layby overnight and they needed proper facilities. All drivers had now had a toolbox talk on manual entries and education from Mr Hood.

Mr Hood had been first engaged with the business around 2017. Mr Tucker ceased membership of Mr Hood鈥檚 organisation in 2022. Mr Hood had been re-engaged in April this year to bring Mr Tucker and the company back to standard; it had been triggered by the public inquiry call-up.

Mr Hood had offered to stand in as transport manager to keep the business moving and the drivers employed. Mr Tucker would dearly like to stay on the licence but Mr Hood was a fall-back.

The work was aggregate deliveries, moving soils and road construction, generally local, sometimes further afield if necessary. Four vehicles were in use at the moment, Monday to Friday with the odd weekend. All four vehicles were constantly in use.

His father Donald had resigned as director through ill health.

There were six or seven customers who called him with work. Drivers could work for any customer. Revocation of the licence would end the business. Suspension would cease the business and drivers would be out of work. Customers would not give even a short period of a break and sub-contracting was not possible. Curtailing the licence would put drivers out of work.

Mr Tucker was aware of the starting point in the vocational driver conduct statutory document. The impact of him losing his vocational entitlement would mean that the vehicle would have to be sold if a driver could not be found. The business relied on him and wasn鈥檛 big enough to support him.

Ms Dooher pointed Mr Tucker at the offending dating from June 2025 but repeated in April 2026 and asked him how I could be reassured that it would never happen again. Mr Tucker told me that the third-party card had been disposed of and it had been a huge wakeup call. He had not been in the right mindset for that period of time. Only preparing for the public inquiry had brought it home.

Mr Tucker was confident that he could work with Mr Hood as transport manager.

I put it to Mr Tucker that his actions in July 2025 were not consistent with, for example, a driver who needed to get home. He had driven over 200 kms on local work. The explanation did not seem credible to me. Mr Tucker told me that he would have to check tracking data to know where he was. Mr Eggins pointed to his evidence that ANPR data had put the vehicle in Basingstoke on the day concerned.

I suggested to Mr Tucker that it was unlikely to be 212 kms from Basingstoke to the operating centre. Mr Tucker told me that he would not know how far it was which I found surprising for a professional driver. He then guessed it would be about 70 miles.

The evidence of Barry Hood

Mr Hood confirmed the engagement his business had with the operator. He had spent two or three days a week with Mr Tucker once reengaged this year, helping him prepare for the public inquiry. He had seen the recent offending on the raw data before sending it to the solicitor to send on to DVSA. He had discussed with Mr Tucker how serious it was. He had provided training material relating to manual entries.

Mr Hood confirmed that he was willing to be nominated as transport manager on the licence. He was named on one other licence and had sufficient time available. Ms Washington was due to undertake transport management training, with Mr Hood remaining involved to provide support.

Submissions

Ms Dooher submitted that Mr Tucker had attended today and been candid and, in doing so, had opened himself up to accept that these matters had happened. He had not realised the seriousness of his actions as he hadn鈥檛 been in the right headspace. It had now hit home.

It was not a big business, just four vehicles but all four are in use every day. The driving with another鈥檚 card, it was accepted that it was serious. As transport manager, action seemed inevitable. He would like to keep his repute but it was understood that may not be possible.

There were no wider concerns. There were no issues with maintenance and the improvements recommended by TE Eggins had been implemented. Ms Dooher referred me to the case of Alistair Walters which found it possible to distinguish loss of good repute as transport manager from that of the director. In this instance it would be disproportionate to tar Mr Tucker as director with the same brush as that of Mr Tucker as transport manager.

Revocation would be the end of the business. Suspension would be a back-door way to revocation. A curtailment would reflect the actions of Mr Tucker whilst reflecting also the positive elements. Any curtailment beyond the margin would have a serious impact on the running of this business. Nothing more demanding than a temporary limited curtailment was necessary.

I was referred to paragraph 66 of STC SD 6 where personal circumstances can be relevant. Further submissions repeated points previously made.

I reserved my decision.

FINDINGS OF FACT

Andrew Tucker has now accepted that he falsified records by using the card of a previous employee on three occasions in June and July 2025. He also now accepts that he repeated that wrongdoing in April 2026.

Mr Tucker attended an interview under caution on 17 October 2025 with Traffic Examiner Chris Eggins. The following is a series of extracts of that interview which can be found in my bundle at page 89 onwards. I have adopted the Examiner鈥檚 annotation such that CE is Mr Eggins asking a question and R is the response.

CE	[in relation to 11 June 2025] Can you see that your driver card is withdrawn at 1731?
R	I can鈥�.
That was the emergency where I had to get home. Brad was sat waiting for me.	听
CE	Was he driving the L777TMA or were you driving the vehicle
R	I wasn鈥檛 driving the vehicle
听	听
CE	Were you driving L777 from 0430 to 1736 on the 25th of June?
R	Yes I was
CE	The driver card in the name Bradley Baulf is inserted. Can you see that?
R	I can
CE	The driver card in the name of Mr Baulf is withdrawn at about 2108. Was Bradley Baulf driving L777 from 1736 to 2108 when the card was (sic) or was it you?
R	It wasn鈥檛 me
CE	How did Bradley get to New Frome Quarry?
R	In his personal car
CE	Were you driving L777 using Bradley Baulf鈥檚 card?
R	I was not
听	听
CE	The 22nd of July, your driver card is in N777TMA. Were you driving N777TMA on 22nd July 2025?
R	I was
CE	鈥�can you see that your driver card is withdrawn at about 1331 hours?
R	Yes
CE	The driver card for Bradley Baulf is inserted, can you see that?
R	I can
CE	Bradley Baulf鈥檚 driver card is withdrawn at about 1700 the same day. Was it you driving N777TMA with Bradley Baulf鈥檚 driver card in slot 1?
R	It is telling me it wasn鈥檛
CE	Can you give me a yes or no, were you driving N777 with Brad鈥檚 driver card in Slot 1!
R	No
听	听
CE	On 2 July 2025, James Brown is driving R777TMA. On page 14 of CRE/01 it shows that he withdrew his driver card from the VU at about 1719,鈥�,a driver card in the name of Bradley Baulf is inserted until it was withdrawn at about 1759. Can you see that?
R	I can
CE	Was Bradley Baulf driving between 1719 and 1759 that day or was James Brown using Bradley鈥檚 card?
R	This is telling me that Brad is driving the vehicle
CE	Do you know what the circumstances?
R	Yes, James knew he was going to run out of time. I called Brad and he was available to bring the vehicle back to the Emborough operating centre

It is now clear that Mr Tucker fabricated the existence of Bradley Baulf as an active driver and lied to Traffic Examiner Eggins throughout the interview.

Having been interviewed under caution by a DVSA Traffic Examiner in October 2025 about the use of another person鈥檚 driving card, Mr Tucker repeats the offending twice in April 2026. Eighty-five kms are travelled using Mr Baulf鈥檚 card on 7 April 2026, and 56 km on 27 April 2026. March was outwith the scope of the pre-PI update 鈥� and an investigation has to stop somewhere 鈥� but I can鈥檛 help but notice a comment in Mr Eggin鈥檚 statement (pg 505):

• 鈥淎 manual entry of REST has been made in the data held of the driver card in the name of Bradley Baulf to account for the period between its last withdrawal, that being 1904 on 30/03/2026 and its insertion as 1819 hrs on 07/04/2026鈥�

It is irresistible to conclude anything other than that Mr Tucker had used Mr Baulf鈥檚 card on 30 March as well.

It has been Mr Tucker鈥檚 evidence throughout that the lack of him completing manual entries was that he did not know how to do it. Now that the true position in relation to Mr Baulf, or rather the lack of Mr Baulf, is known, it becomes readily apparent that Mr Tucker has lied about his incompetence in that regard throughout. However, in contrast with his position in relation to the use of Mr Baulf鈥檚 card, Mr Tucker also maintained his lack of knowledge throughout the public inquiry. Thus, I find that he lied to me whilst giving evidence as operator, transport manager and driver. I also find that the failure to keep complete records using the manual entry function was deliberate and not through any lack of knowledge.

I was told of personal circumstances in private evidence. In relation to the use of the third-party card to be available for family at home, I find that there is nothing in that. On at least one occasion, that being 22 July 2025, Mr Baulf鈥檚 card was inserted in Frome, around 20 km from the operating centre. Mr Tucker then travelled from there to Basingstoke and back covering 212 kms. Mr Tucker sought to tell me that his state of mind was such that he just wanted to drive. I resist that. It is readily apparent from the control report at page 140 of the brief that Mr Tucker had reached 4 hours 27 minutes driving and was due a 45-minute break when his card was removed and he continued the remainder of the shift using Mr Baulf鈥檚 card without taking the necessary break. That was a cynical and fraudulent act for commercial gain.

I note that I was offered no supporting evidence in relation to the evidence heard in private. Whilst I do not doubt the facts, I do doubt that they contributed to the serious offending which I find to have been deliberate and calculated. That is supported by the fact that it has continued through to April this year despite the spotlight of the DVSA investigation.

There are positive features. Elements of the TEVR identified good or at least satisfactory practice. Drivers are properly employed. Most compliance systems are in place. The MOT pass rate at 90% is in line with the national average. There is the reengagement with Mr Hood and the taking of professional legal advice and support for the public inquiry.

In relation to the legislation cited in the call-up, I can see no evidence of a breach of licence conditions and Section 26(1)(b) is not made out. Prohibitions have been issued but not since 2023. Section 26(1)(c) is made out but I attach little to no weight.

The operator has deliberately and determinedly operated outside the rules governing tachographs and driving times and rest periods. It has done so over a prolonged period. Section 26(1)(f) is made out and I attach significant weight.

CONSIDERATION AND DETERMINATION

I must have regard to the fact that Mr Tucker is called as driver, transport manager and sole director. Each decision must reflect the impact of the decisions taken as a whole.

As a driver, the starting point for a single offence of using a device, including another person鈥檚 card, to interfere with the tachograph record is to revoke the entitlement and disqualify for 12 months, longer for 2 or more offences. Case examples 21 to 23 indicate that the spread is between one and four years. 听

Annex C of the Statutory Document sets out positive and negative features in relation to drivers鈥� hours and tachograph offences and identify the following:

Positive Features

• Limited commercial advantage

Negative features

• Deliberate falsification
• Ghost driver (Bradley Baulf)
• Deliberate failure to record all other work
• Offending over a sustained period of time
• Offending committed with the express intention of misleading DVSA

I add here that the driver was the transport manager

Ms Dooher referred me to paragraph 66. It says the following:

• When exercising judgement whether the conduct must lead to revocation and disqualification or suspension, personal circumstances may be relevant. If the experience of referral and the risk of revocation have sufficiently brought home to the licence holder that his livelihood is in jeopardy, such that the traffic commissioner is persuaded that further offences are unlikely, the traffic commissioner is open to conclude that the sanction of revocation is not required. The vocational licence holder鈥檚 conduct must be considered in context and in the round and references from an employer, for example, are relevant. Explanations as to the detail of a person鈥檚 life (both private and commercial) after the incident and/or the conviction should also be taken into account. Any other approach would be too arid and would not allow an applicant鈥檚 personal circumstances to be considered

I have said above that I do not find what I was told in private session to be convincing as a cause of, or mitigation for, the offending. I was told that the driver card had been found and that it had not been possible to contact its owner. So why not destroy it at that point? That was March 2025. Even if I were persuaded in relation to the offending in June and July 2025, why not destroy the card at that point? But no, Mr Tucker keeps it and is found to be using it in April 2026 by which time I am told the personal pressures have eased. When asked how I could be sure that offending would not recur, Mr Tucker鈥檚 main argument was that the card had now been destroyed. But what of the next time he finds a card down the back of a sofa? I do not trust Mr Tucker not to offend again at all. I find that he is unhappy that he has been found out but that does not mean that he has changed his ways.

Were it not for the wider impacts of my decisions in relation to the transport manager and operator, a period of disqualification far higher than the starting point would be appropriate. I adopt the starting point only because of the combined effect.

I turn now to Mr Tucker鈥檚 good repute as transport manager. Annex IV of EU Regulation 1071/2009 as adopted into UK law, and at Appendix Road A 1.1 of the EU:UK Trade and Cooperation Agreement, identifies the most serious infringements that require that a transport manager or operator must lose their good repute if a penalty is issued. Number 2 of the 7 is the following:

• Not having a tachograph and/or speed limiter, or having in the vehicle and/or using a fraudulent device able to modify the records of the recording equipment and/or the speed limiter or falsifying record sheets or data downloaded from the tachograph and/or the driver card.

There is no conviction here and my action as a driver is regulatory not punitive, although it may feel that it is. But there are admissions of guilt such that I find the reference instructive. Taking that with the lying of Mr Tucker to the Traffic Examiner and, by his own admission, as a minimum providing to his driver a driver card to use to get home, I have no hesitation in finding that Mr Tucker has lost his good repute as transport manager. The DVSA intervention was a clear opportunity for Mr Tucker to turn the corner and operate compliantly. He did not do so but chose to continue to use Mr Baulf鈥檚 card. Having not taken that opportunity, which included an interview under caution, I can think of no means of Mr Tucker restoring that good repute and his disqualification must be at the highest level.听

Finally, I turn to the good repute of the operator and the action that must be taken. I look first at the Senior Traffic Commissioner鈥檚 Statutory Document No 10 on proportionality. Helpful starting points can be found in Annex 3. The actions here are clearly deliberate. There has been a commercial advantage and, in driving over the prescribed hours without the necessary breaks, there will have been road safety implications, albeit not the worst that I have seen. The use by the operator and transport manager of a third party鈥檚 card is a strongly negative feature. When I factor in lying to the Traffic Examiner, I find that this is a case in the Severe category. Action should materially affect the transport operation.

There are positive features identified above. Ms Dooher points me at the case of T/2015/55 Alistair Walter. In that case, the DTC was criticised for not having provided sufficient reasons for allowing Mr Walter to keep his good repute as operator having lost it as transport manager. I am not sure that the decision encourages Traffic Commissioners to make such a separation, but it does point me towards answering the two leading questions in the cases of Bryan Haulage (No.2) (2002/210) and Priority Freight (2009/225).

So, is this an operator I can trust to be compliant in the future? As currently constituted, I answer that in the negative and, in doing so, I rely on the reasons set out above in relation to the transport manager and driver who is sole director. I simply cannot trust Mr Tucker, and Mr Tucker is, currently, one and the same as the business, being sole director and sole shareholder. It is appropriate to pierce the veil of incorporation.

So, next I must answer the question, is this an operator who deserves to be put out of business? As currently structured, the answer is yes, very definitely, given the cynical and fraudulent offending and lying to DVSA. However, it is possible that the business structure could be changed such that I might answer that question differently. Should Andrew Shaun Tucker step down as a statutory director, and should he relinquish his shareholding such that he holds no more than 50% of the shares, then I could allow this business to continue provided I can be assured that any replacement director and shareholder have true control of the operation. That may take time, so I allow a period of three months for restructuring. Meanwhile, I make a decision based on the business as currently structured.

Should a restructure take place, any growth would be inappropriate until compliance has been demonstrably reestablished. Noting that my decision in relation to driver Tucker will have a material impact on the business, I make a curtailment order under Section 26(1)(f) to remove the margin.

Finally, the man at the centre of this although not actually part of it at all. Bradley Baulf has not attended interview with DVSA nor the driver conduct hearing. I know nothing of his state of knowledge of the whereabouts of his driver card or the mischief to which it was put. Whilst that is the case, I find he is no longer fit to be the holder of a heavy goods vehicle vocational entitlement. He is free to apply at any time and will have to appear before a Traffic Commissioner.

DECISIONS

Pursuant to a finding of loss of good repute, Andrew Tucker is disqualified from acting as a transport manager indefinitely.

Pursuant to a finding of failure to manage drivers hours and tachographs, the licence is curtailed to four vehicles immediately and indefinitely.

Pursuant to an adverse finding under Sections 27(1)(a) and (b), that there is no transport manager and no effective control, the licence is revoked. I provide a period of grace until 6 October 2026 to allow that to be rectified.

Pursuant to an adverse finding of loss of good repute under Section 27(1)(a), the licence is revoked with effect from 6 October 2026. This order for revocation will be set aside if, by that date, Andrew Shaun Tucker has been removed as a statutory director and replaced by another who can satisfy me as to their control of the operation, and his shareholding is reduced to no more than 50%, with any additional shareholder able to satisfy me that they have real significant control over the operation.

Pursuant to a loss of fitness to hold vocational entitlement under Sections 115 and 117 of the Road Traffic Act 1988, the vocational entitlement of Andrew Shaun Tucker is revoked with effect from 23:45 hours 24 July 2026 and he is disqualified from holding same for 12 months.

Pursuant to a loss of fitness to hold vocational entitlement under Sections 115 and 117 of the Road Traffic Act 1988, the vocational entitlement of Bradley Baulf is revoked with effect from 23:45 hours 24 July 2026 and he is disqualified from holding same indefinitely.

Kevin Rooney

Traffic Commissioner

3 July 2026

APPENDIX 1 鈥� EVIDENCE HEARD IN PRIVATE 鈥� NOT FOR PUBLICATION OR RELEASE WITHOUT PERMISSION OF A TRAFFIC COMMISSIONER

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