You can often spot vehicles from some of the UK’s largest fleets by their colour. Red for Royal Mail, green for Eddie Stobart, yellow for DHL, black for Addison Lee, to name a few.

But the biggest fleet of all is far harder to spot – because it’s grey.

When any non-company vehicles are driven on company business, often in return for a cash allowance or fuel expense, these then become considered part of the ‘grey fleet’.

According to the Energy Saving Trust, there are more than four million ‘grey fleet’ vehicles in the UK – three times more than the number of company-owned cars in the whole country.

While they’re owned by individuals, when these vehicles are on company business, they are the responsibility of the owner’s employer.  

Which can be tricky for fleet managers. Because grey fleet vehicles don’t belong to the company, managing them often involves additional financial, legal and environmental difficulties compared to managing a conventional fleet. A personal car may not be covered by the company insurance policy for example, and managers need to know the vehicles in their grey fleet meet legal road requirements.

The grey fleet is growing too. More organisations now allow their employees to drive non-company cars for work journeys, so it’s crucial for any grey fleet operator to understand the kinds of challenges these throw up.

One thing to be aware of is duty of care for grey fleets. Department for Transport and Health and Executive guidelines stipulate that an organisation has the same duty of care responsibilities towards all its employees making work-related journeys regardless of vehicle ownership.

Then there’s the Health and Safety at Work Act 1974.  This requires employers to ensure, as far as is reasonable, the health and safety of all employees while at work. Employers and employees also have a responsibility to ensure that others aren’t put at risk during any work-related driving activities, and corporate manslaughter laws mean that having to prove your organisation has fulfilled its legal obligations following an incident can be a considerable burden.

Grey fleets require accurate record keeping too. An organisation must hold details for all those who drive for work. This helps ensure drivers have valid licences and are fit to drive, and that any vehicle being used for business journeys is properly maintained, insured and has a valid MOT (if applicable).

Some firms outsource specialist grey fleet management support to ensure they have a thorough risk management policy, giving them peace of mind that DoC has been fulfilled.

One of the main challenges with any initiatives to make drivers and road journeys safer is that driving is a very emotive issue. Most drivers believe that they are ‘better than average’ but statistically, that can’t possibly be true. With grey fleet drivers there is the additional emotional attachment that people have to their cars, so fleet managers need to be mindful of this when introducing any initiatives to improve safety.

Organisations should remember that anything they do for an employee using an owned or leased vehicle must also be offered to employees in the grey fleet. For example, if eyesight screening is mandatory for an organisation car driver, it must also be mandatory for the user of a private vehicle, and if you pay for one to have the test, you must also pay for the other.

Overall, a grey fleet should be subject to the same risk assessments, auditing and maintenance procedures as any regular fleet, although there will be some emotional factors to consider. This becomes more challenging with grey fleets because managers are less able to precisely monitor and control important facts about their drivers and vehicles.

For example, how do you ensure your driver’s grey fleet vehicle is constantly maintained to the required safety standards? The answer is to establish thorough driver training programmes, sophisticated driver and vehicle auditing, and water-tight record systems to ensure your organisation is fully compliant.

Ultimately, it is important to ensure that a proven risk management process is used to manage all work-related road risks, including the grey fleet. Duty of care, regardless of the vehicle’s ownership, should always be a top priority for fleet managers.

Andy Allen is head of BP Fuel Cards.