Too many operators assume that once a TM is appointed, compliance is handled. But who is managing the manager? All too often, the answer is nobody.
By Zed Aziz, Transport Compliance Consultant
As a transport compliance consultant with over two decades in this industry, I've sat in more Public Inquiries and investigations than I care to count. A recurring, frustrating theme emerges: it's rarely outright negligence from the operator director that leads to serious trouble. More often, the breakdown lies with those entrusted with day-to-day compliance — specifically the Transport Manager (TM), or the nominated responsible person on a restricted licence.
Many operators only realise the true value of robust TM support when facing enforcement action.
Too many operators assume that once a TM is in place, compliance is handled. But who is ensuring the TM is fulfilling their duties effectively? Who is managing the manager? All too often, the answer is nobody — and that's a gamble you can't afford to take. Based on my experience, here are four key areas where some TMs, especially External Transport Managers (ETMs), fall short.
The TM1 form isn't just a piece of paper; it's a declaration of commitment. It specifies the hours a TM will dedicate to your operation. Yet how often is this honoured? I've heard every excuse — other business interests, extended holidays, a three-month cruise, one too many golf days. Life happens, but a TM's legal responsibility doesn't pause. A lack of dedicated time on-site, interacting with your operation, is a foundational crack that can destabilise everything.
Passing the Transport Manager CPC is a significant achievement, but it's the starting line, not the finish. Legislation evolves, best practice changes, and much of the nitty-gritty lives in grey areas. I encounter TMs content with their initial qualification, doing the bare minimum and hoping for the best. That "it'll be alright on the night" attitude is dangerous — in transport, the wheels can come off very quickly if knowledge isn't current and actively applied.
No one expects a TM to scrutinise every driver, vehicle and record every day — that's impractical. But there must be a robust, risk-based system: a documented methodology, agreed and signed off by both TM and operator, ensuring all critical compliance areas are checked regularly. This isn't box-ticking; it's collaborative understanding, mutual support and a shared goal of unshakeable compliance. Sadly, this structured approach is often conspicuously absent.
This is arguably the most critical, yet most neglected, aspect. Driving can be isolated and demanding. Your drivers are at the coalface of your compliance, so regular, structured, documented conversations with them are paramount — covering wellbeing, infringements, tachograph discipline and the quality of their walkaround checks. When TMs don't invest this time, small issues fester into significant problems.
The Traffic Commissioners place immense trust in the nominated Transport Manager.
At Fleet Transport Consultants we see these challenges daily, which is why we developed a service to provide that crucial oversight and support. It's not about undermining your TM — it's about empowering them and giving you, the operator, peace of mind. Think of it as a central pillar supporting your entire compliance structure. It's also an invaluable coaching tool for new or less experienced TMs, helping good TMs become great.
If you're feeling overwhelmed, unsure whether your TM is truly on top of their game, or your TM would benefit from expert support and a robust framework, let's talk. Get in touch with Fleet Transport Consultants for a confidential discussion, or learn more about our External Transport Manager services.
Book a free, no-obligation consultation and we'll talk through exactly what your fleet needs — no pressure, no jargon.
