Can One Transport Manager Look After More Than One Operator?

It is a common question from operators who want to share a Transport Manager, and from CPC holders who are asked to take on another licence. The answer depends on whether the Transport Manager is internal or external, and on one test that applies to both: can they genuinely manage each operation continuously and effectively?

The short answer

• External Transport Managers can act for no more than four operators, with sole responsibility for no more than 50 vehicles in total. The Traffic Commissioner can set a lower limit.
• Internal Transport Managers have no statutory limit on the number of standard licences they can be named on. But the Traffic Commissioner must be satisfied, case by case, that they have the time and the genuine link to manage each one properly.

Whatever the numbers say, the guidance is blunt: a Transport Manager who is one in name only is a serious problem for the operator and for the Transport Manager’s own repute.

Internal and external: what is the difference?

An internal Transport Manager has a genuine link to the operator. They might be the licence holder, a partner, a director, or a full or part-time employee. An external Transport Manager is hired in under a contract that specifies the tasks they will perform. Our guide to what an External Transport Manager actually does sets those tasks out.

A person can be an internal Transport Manager for one operator and an external one for another. But the guidance says the starting point in that case is to apply the external limits of four operators and 50 vehicles across all of their licences.

The four-operator, 50-vehicle limit

The limit has three details that people often miss:

• It counts operators, not licences. An operator with two licences counts once. A Transport Manager cannot act for a fifth operator, however small it is.
• It counts authorised vehicles, the number the licence allows, not the vehicles running on a given day. The 50 is a combined total across all the operators.
• It is a maximum, not an entitlement. The Traffic Commissioner can decide that, for a particular person, the number should be lower.

Additional time may also be needed for trailers, so a fleet with many trailers may need more input than its vehicle count suggests.

The real test: capacity

Staying within the limit does not mean someone has enough time. The Traffic Commissioner looks at the Transport Manager’s whole working life. The factors include:

• Hours. The guidance gives starting points that rise with fleet size: 2 to 4 hours a week for 2 vehicles or fewer, 4 to 8 for 3 to 5 vehicles, 8 to 12 for 6 to 10, 12 to 20 for 11 to 14, 20 to 30 for 15 to 29, and 30 hours to full time for 30 to 50. Above 50 vehicles it is full time with additional assistance. Our article on Transport Manager time commitments explains how to judge it.
• The number and location of operating centres, on every licence they cover, and how far the Transport Manager lives from them. A Transport Manager who lives abroad, or at the opposite end of the country, will struggle to show effective management.
• Other work. Another job, self-employment, or other duties in the business such as driving, directing or contracts management all count against their availability.
• Working time. The average working week is limited to 48 hours over the reference period, with no week above 60.
• Access and authority. They need ready access to the records, the authority to take decisions such as taking a vehicle off the road, and the support of the operator.

The guidance also flags a Transport Manager who is already named on at least three other licences, or already solely responsible for 50 vehicles, as a starting point for closer scrutiny. And when someone proposes to be on more than one licence, or to work fewer hours than the starting point, they should expect to be asked for evidence of continuing professional development, such as a recent two-day Transport Manager CPC refresher course.

What the contract must say

For an external Transport Manager, the contract with the operator must name the individual and specify the tasks they will perform. The legislation lists the sort of tasks to be covered: vehicle maintenance management, checking transport contracts and documents, basic accounting, assigning loads and services to drivers and vehicles, and checking safety procedures. In addition:

• they must act solely in the interests of the operator and independently of the operator’s transport customers;
• they must be of good repute, professionally competent, and resident in the UK; and
• the hours stated must be real. Signing the TM1 commits the Transport Manager to the declared hours, and if they cannot do the job in them, they should increase their input or step down. Both the operator and the Transport Manager must tell the Traffic Commissioner if the hours are reduced, or if the Transport Manager resigns.

The guidance also says a Transport Manager cannot be employed through, or be part of, a package supplied by a transport consultancy, and that the Upper Tribunal has warned against tying a Transport Manager to a consultancy service. The appointment needs to be a genuine arrangement between the operator and the individual.

Questions to ask before you appoint one

1. How many other operators and vehicles are you responsible for, internal and external?
2. How many hours a week are you declaring for my licence, and what else takes up your week?
3. Where do you live, and how often will you visit each operating centre?
4. Is the contract directly between you and my business, and does it list your tasks?
5. Can you show recent CPD or a refresher course?
6. What systems will you use, and who helps you with the day-to-day work?
7. Have you met me and seen the operation?

A refusal to answer, or an unusually low price from someone covering many operators, is a warning sign.

If you are a CPC holder

For a Transport Manager, taking on one more operator is tempting income, but each name on a licence is a personal commitment. A Transport Manager who lets their capacity slip risks a finding on their own repute, and in serious cases disqualification. Before you take another, add up your declared hours across every licence, include all your other work, and check the total against the starting points above.

How HGV Consult can help

If you need a Transport Manager, we can help you find a CPC-qualified External Transport Manager whose location, experience and availability fit your fleet and operating centres. If yours has already left, read our guide to what to do when your Transport Manager leaves.

If you are a CPC holder, you can join our CPC network. Or request a call back and tell us about your operation.

This article is general information, not legal advice. The rules are set out in the Goods Vehicles (Licensing of Operators) Act 1995 and the Senior Traffic Commissioner’s Statutory Document No. 3, so check the current version, and the Traffic Commissioners’ guidance on Transport Managers ↗, before you rely on it.