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10 Essential Tips for Managing External Transport Managers:
A Comprehensive Guide for Operators
Zed Aziz
6th Aug 2024
In crafting this guide, we've drawn from numerous experiences and case studies highlighting the challenges faced by operators and their External Transport Managers (ETMs). These challenges often arise from misunderstandings and poor communication. This guide aims to address these issues by providing a clear vision and actionable strategies to foster a more effective partnership between operators and ETMs.
The ten key points outlined in this guide provide a structured approach to managing this relationship effectively. By implementing these strategies, you can transform the perception of your ETM from a regulatory enforcer to a valuable ally. Embracing this collaborative mindset will help you achieve a harmonious working relationship, ensuring that your business not only meets legal obligations but thrives in a compliant and safe operational environment.
What is an ETM? An External Transport Manager (ETM) is a contracted professional who brings expertise in transport management to small and mid-sized operators, typically working on a part-time basis. Their main responsibilities include ensuring vehicle roadworthiness and driver compliance with traffic laws and drivers’ hours regulations.
Qualifications: ETMs must hold a Transport Manager Certificate of Professional Competence (CPC), a mandatory qualification for holding an Operator’s Licence. This certificate encompasses knowledge relevant to both national and international transport operations.
Good Repute: Ensure that the ETM has a solid reputation for honesty and integrity. Conduct thorough background checks and seek testimonials or references to confirm their standing in the industry.
Professional Competence: Verify that the ETM possesses the necessary professional competence. They should have a comprehensive understanding of transport operations and the skills required to manage them effectively.
Traffic Commissioner Approval: An ETM must not be barred from acting as a transport manager by the traffic commissioner. Ensure that they are in good standing with the regulatory authorities.
Operator Limits: An ETM should not manage transport operations for more than four operators or be responsible for more than 50 vehicles (or a lesser number as determined by the traffic commissioner).
Quality Over Quantity: Prioritize the quality of management over the number of clients. An ETM with too many commitments may struggle to maintain high standards, affecting their effectiveness.
Adequate Time Allocation: A transport manager should carefully consider any attempts to reduce the hours worked from those declared in the application. They must ensure they have sufficient time to fulfil their duties effectively and comply with all regulations.
Legislative Framework Considerations: While there are no statutory limitations on the number of standard licences for which a suitably qualified “internal” transport manager can be nominated, it is crucial to understand the Senior Traffic Commissioner’s determining factors when assessing the suitability of a proposed transport manager within the legislative framework.
Framework and Methodology for Clear Expectations: Establish a comprehensive framework that clearly defines the ETM’s responsibilities and expectations from the outset. This should include a detailed discussion of their role, documented in a written agreement or service contract. Ensure mutual understanding by outlining specific duties, performance metrics, and accountability measures. Regularly review and update this framework to adapt to any operational changes or regulatory updates.
Regular Updates and Open Communication: Implement a structured communication plan to keep the ETM informed about operational changes, emerging challenges, and compliance issues. Schedule regular meetings, such as monthly or quarterly reviews, to discuss ongoing matters and provide updates. Utilize various communication channels, including emails, phone calls, and video conferences, to ensure continuous and effective dialogue.
Collaborative Problem-Solving: Adopt a collaborative approach to address compliance gaps and safety concerns. Encourage the ETM to work closely with your team, participating in regular compliance audits, safety checks, and operational reviews. Foster a culture of teamwork and shared responsibility to maintain high standards of operational safety and legal compliance.
Evidence and Documentation: Maintain thorough documentation of all communications and collaborative efforts. Use emails, meeting minutes, and memorandums to record discussions, decisions, and action plans. This documentation serves as evidence of compliance and proactive management, ensuring transparency and accountability in all interactions with the ETM.
Driver Compliance: Ensure that drivers adhere to regulations concerning hours of service, tachograph usage, and mandated rest periods. ETMs play a crucial role in monitoring and enforcing these rules. Implement set routines and cyclic checklists to regularly verify that all compliance checks are completed over a defined period. This systematic approach ensures continuous monitoring and prompt identification of any issues.
Vehicle Compliance: Regularly review vehicle records, maintenance schedules, and safety features to ensure all vehicles meet legal and safety standards. Establish a cyclic checklist system to periodically check each aspect of vehicle compliance. This routine helps in maintaining consistent oversight and addressing any discrepancies promptly.
Audits and Inspections: Conduct periodic audits and inspections to verify compliance with all relevant regulations and standards. Implement a structured schedule for these audits, ensuring they cover all necessary areas over time. This proactive approach helps in identifying and rectifying issues early, maintaining high standards of compliance and operational safety.
By incorporating set routines, checks, and cyclic checklists into your compliance monitoring processes, you can ensure that all necessary checks are systematically completed, enhancing overall compliance and performance.
Develop and Implement Multiple Policy Areas: Operators should establish and enforce a range of policies covering critical aspects of transport management. The ETM plays a vital role in ensuring adherence to these policies and providing oversight. Below are essential policy areas to consider:
Vehicle Off-Road (VOR) Policy: Outline procedures for taking vehicles off-road due to maintenance, repairs, or safety concerns. Define clear criteria for when a vehicle should be classified as off-road and ensure timely communication with the ETM to manage fleet availability effectively.
Wheel & Tyre Policy: Establish standards for the maintenance, inspection, and replacement of wheels and tyres. Include guidelines for regular checks, tread depth requirements, and procedures for addressing damage. The ETM should monitor adherence to this policy to prevent safety issues and maintain vehicle roadworthiness.
Drug Usage Policy: Implement a zero-tolerance policy for drug use within the organization. Define protocols for drug testing, consequences for violations, and support programs for affected employees. The ETM should ensure that drivers and staff comply with this policy and that testing is conducted regularly and fairly.
Mobile Phone Usage Policy: Create clear rules regarding mobile phone usage while driving. Prohibit the use of handheld devices and specify acceptable uses of hands-free technology. The ETM should monitor compliance and address any violations promptly to promote safe driving practices.
Dashcam & CCTV Camera Policy: Develop guidelines for the installation, use, and management of dashcams and CCTV cameras. Ensure policies cover data privacy, recording protocols, and footage review procedures. The ETM should oversee the correct use of these technologies to enhance safety and security.
Additional Relevant Policies:
Environmental Policy: Set standards for reducing the environmental impact of transport operations, including fuel efficiency measures, emission reduction targets, and waste management practices. The ETM should monitor and report on compliance with these environmental initiatives.
Health & Safety Policy: Establish comprehensive health and safety protocols, including risk assessments, emergency procedures, and training requirements. The ETM should ensure that all safety measures are implemented and that staff are adequately trained.
Training and Development Policy: Define the requirements for ongoing training and professional development of drivers and staff. Include mandatory refresher courses and certifications. The ETM should track training schedules and ensure compliance.
Policy Compliance Monitoring: The ETM should conduct regular reviews and audits to ensure adherence to all established policies. Implement a structured framework for policy compliance checks, including routine inspections and performance assessments. Document findings and take corrective actions as needed to maintain high standards.
By developing comprehensive policies across multiple areas and ensuring diligent monitoring and enforcement through the ETM, operators can create a robust framework for managing transport operations effectively and safely.
Stay Informed: Keep abreast of industry changes, legal requirements, and best practices. Staying updated ensures that both you and your ETM are aware of the latest developments in transport management. Being part of a professional organisation like the RHA or CILT can support with continuous development.
Transport Manager Refresher Courses: Encourage ETMs to attend refresher courses regularly. These courses help in updating their knowledge and adapting to new regulations or industry standards. They are legally obliged to attend a refresher training periodically.
Contractual Agreements: The operator should agree contractually how often the External Transport Manager intends to attend on-site. It is essential that the ETM visits the operating centre regularly and makes unannounced visits to ensure checks are done to demonstrate control and management.
Immediate Action: If an ETM identifies any non-compliance or safety issues, act promptly to address and rectify these problems. Swift action can prevent minor issues from escalating into major compliance breaches.
Traffic Commissioner Reporting: ETMs are obligated to report any instances of non-compliance to the Office of the Traffic Commissioner. Ensure that there are clear protocols in place for such reporting to maintain transparency and accountability.
The Senior Traffic Commissioner has outlined a non-exhaustive list of activities that are expected of a transport manager:
Compliance Systems
Manage, audit, and review compliance systems to ensure they are effective.
Review any shortcomings such as prohibitions and/or annual test failures.
Ensure relevant changes are notified in accordance with operator licence requirements.
Stay updated on relevant changes in standards and legislation.
Drivers – Administration
Ensure drivers hold the appropriate licence for the vehicle they are driving.
Conduct regular checks on drivers’ licences.
Verify that vocational drivers hold a valid driver CPC qualification.
Maintain drivers' hours records for at least 12 months and working time records for at least 24 months.
Drivers – Management
Ensure compliance with driving hours rules (EU or Domestic).
Ensure drivers properly record duty, driving time, and rest breaks.
Download and store data from digital tachographs and drivers’ smart cards.
Retain and produce records of drivers' hours and working time as required.
Train drivers to be competent in operating relevant vehicles and equipment.
Participate in training and disciplinary processes as needed.
Drivers – Operations
Ensure drivers complete and return defect reporting accurately.
Ensure drivers and mobile workers take adequate breaks and rest periods.
Vehicle – Administration
Retain vehicle maintenance records for at least 15 months.
Ensure vehicles are specified as required and operator licence discs are current.
Verify vehicle payload notifications, height indicators, and tachograph calibrations.
Ensure up-to-date certificates of insurance for company vehicles.
Maintain a suitable maintenance planner, including dates for inspections and tests.
Vehicle – Management
Keep vehicles and trailers in a fit and roadworthy condition.
Record and repair reported defects promptly.
Remove unroadworthy vehicles and trailers from service (VOR).
Make vehicles and trailers available for safety inspections and testing.
Conduct safety inspections and statutory testing within maintenance intervals.
Liaise with maintenance contractors, manufacturers, hire companies, and dealers to ensure proper servicing of vehicles and trailers.
Conclusion: Partnering with Your External Transport Manager
It's crucial to recognise that an External Transport Manager (ETM) is not a traditional part of your organisation but should be viewed as an executive transport health and safety director working in partnership with you. The primary role of an ETM is to protect your business from non-compliance with operator obligations, thereby safeguarding your operations and reputation.
Rather than viewing the ETM as an outsider imposing additional hurdles and costs, understand that their efforts are focused on your benefit. They are there to ensure that your business adheres to all regulatory requirements, minimising risks and potential liabilities. Embrace the ETM as a valuable ally who is on your side, dedicated to maintaining the highest standards of transport safety and compliance.
By fostering a collaborative relationship and working alongside your ETM, you not only enhance the efficiency and safety of your operations but also ensure the long-term success and sustainability of your business. Remember, it’s your business at risk, and a strong partnership with your ETM is essential for its protection and growth.
By understanding the comprehensive role of an ETM, selecting the right professional, managing their workload, and fostering effective communication and collaboration, you can ensure your transport operations run smoothly and comply with all relevant regulations. Regular monitoring, continuous learning, and readiness to act on compliance issues are key to maintaining high standards in transport management.