A correspondent says that:

Non-emergency patient transport (NEPT) providers in Victoria have recently started hiring drivers still on probation.

Is there a requirement for them to display ‘P’ plates whilst driving NEPT vehicles?

The obligation to display P plates is set out in the Road Safety (Drivers) Regulations 2009 (Vic) r 55. The obligation to display a P plate does not apply (r 55(3)) to:

(a) a police officer who, in the course of duty, is driving a motor vehicle; or

(b) a member of the Country Fire Authority who is driving a motor vehicle in the course of fire fighting operations; or

(c) driving an ambulance service or a Victoria State Emergency Service vehicle in the course of duty.

The language of subparagraph (c) is odd as it doesn’t start with ‘a person’ or ‘a member’ but nothing turns on that.

The question then is what is an ‘ambulance service’ and therefore an ambulance service vehicle?  An ambulance is defined by the Oxford Dictionary (Online) as ‘A vehicle equipped for taking sick or injured people to and from hospital, especially in emergencies’.  It is clearly arguable that a NEPT is an ‘ambulance service’.

On the other hand, in Victoria ambulance services are regulated by the Ambulance Services Act 1986 (Vic). That Act defines ‘ambulance service’ as ‘an ambulance service created under section 23 or listed in Schedule 1’ (s 3); that is one of the 17 Ambulance Services that make up Ambulance Victoria.

NEPT providers are regulated by the Non-Emergency Patient Transport Act 2003 (Vic).  Under that Act ‘”ambulance service” has the same meaning as in the Ambulance Services Act 1986’ (s 3).  Whilst it could be argued, I would infer that for the purpose of the Road Safety (Drivers) Regulations 2009 (Vic) r 55 an ‘ambulance service vehicle’ would mean a vehicle operated by Ambulance Victoria, not an NEPT vehicle.


If my analysis is correct, then there is a requirement for a driver who holds a probationary licence to display ‘P’ plates whilst driving NEPT vehicles.