Why Your Transport Manager Must Be ‘Continuous and Effective’ — Not a Name on Paper In the waste and recycling sector, transport operations are fast-paced, often reactive, and carry a higher-than-average level of compliance risk. Skip wagons running multiple collections per day, hook loaders moving waste between sites, roll-on roll-off containers, tippers, grab wagons, cage vans and articulated bulkers — all create complex maintenance demands, variable driver behaviours, and constant time pressures. For this reason, the Traffic Commissioner expects every Operator Licence holder to have a Transport Manager (TM) who provides continuous and effective management, not someone whose name appears on the licence simply to satisfy a legal requirement. In recent years, the waste sector has been a repeated feature in Public Inquiries where the TM was either absent, overwhelmed, part-time without oversight, or completely disengaged from the fleet. This blog explains exactly what “continuous and effective” means — and why the waste industry must take it seriously. 1. The Legal Definition of ‘Continuous and Effective Management’ Under the O Licence regime, a Transport Manager must: Have real authority over fleet decisions Be involved day-to-day Be able to demonstrate control Ensure legal compliance is maintained at all times Take action when drivers or management fail to comply This means the TM must be: Available Informed Engaged Resourced Empowered And — most importantly — seen to be actively managing compliance The Traffic Commissioner will not accept: “They only come in once a week.” “They only look at the tachograph data.” “I didn’t know the maintenance was overdue.” “The drivers don’t report defects to me.” If a TM cannot prove active involvement, the operator and the TM both risk regulatory action. 2. Why Waste Operators Are Under Extra Scrutiny Waste transport is inherently high-risk. The Traffic Commissioner regularly highlights the following industry challenges: Frequent stops and starts Skip wagons and tippers experience higher brake wear and suspension stress. Heavier load weights RoRo containers, bulkers and hook-loaders often run near gross limits — sometimes unknowingly exceeding them. Contaminated and uneven loads C&D waste, scrap metal, soils and RDF all affect load stability. More complex defect patterns Cracked springs, worn sheeting systems, split air lines, bent bin lifts, tailgate issues and hydraulic leaks are common. Drivers under pressure Multiple collections per day encourage shortcuts in walkaround checks and load security. Because these risks directly link to road safety, waste operators are expected to have above-average transport supervision, not less. 3. What Continuous and Effective Management Looks Like in Practice Here is what an effective TM should be doing routinely at a waste fleet: 3.1. Maintenance Oversight Ensuring PMIs are booked and completed on time Reviewing inspection sheets for recurring defects Checking brakes, suspension, hydraulic systems and lifting gear maintenance Verifying MOT pre-checks Challenging any missed or delayed PMI 3.2. Driver Management Reviewing daily defect reports Managing drivers who repeatedly submit “nil defects” Conducting tool-box talks and refresher training Addressing high tachograph infringement rates Ensuring walkaround checks are actually being completed 3.3. Tachograph & Drivers’ Hours Weekly or fortnightly review of infringements Action plans for repeat offenders Analysing working time patterns Ensuring agency and foreign drivers understand the rules 3.4. Record Keeping Up-to-date maintenance planner Evidence of defect rectification Calibration records Vehicle files and audit trails Driver training files 3.5. Load Security & Weight Compliance This is especially important in waste operations: Securing skips, containers and sheeting operations Ensuring drivers understand how C&D waste settles Monitoring overloading risks through weighbridge data Correct use of chains, nets and sheeting systems 3.6. Auditing & Reporting A TM must complete internal audits on: PMIs Tacho data Defect reports Maintenance provider performance And must report issues directly to the Operator / Director with corrective action plans. 4. Warning Signs the TM Is “Name on Paper Only” Traffic Commissioners see the same patterns repeatedly in PI cases. You may have a paper TM if: Drivers don't know who the TM is The TM hasn’t been to site for weeks No tool-box talks or driver meetings take place Tacho infringements go unchallenged Nil-defect reporting is the norm The TM doesn’t understand waste-specific vehicle risks PMI intervals drift without action There is no maintenance planner Records are missing, incomplete, or unorganised These issues almost guarantee a Public Inquiry. 5. Consequences for Having a Non-Effective TM Operators often believe the TM carries the risk — but Traffic Commissioners regularly prosecute both when compliance fails. Operators risk: Licence curtailment Licence suspension Licence revocation Fines Increased DVSA targeting Loss of contracts Transport Managers risk: Loss of repute Disqualification Requirement to re-sit CPC A ban on acting as a TM anywhere in the UK Public Inquiry outcomes are published publicly and reputational damage can be significant, especially within local authority and large contractor frameworks. 6. How Many Hours Should a TM Spend Managing a Waste Fleet? Hours are not fixed in law — they depend on: Fleet size Vehicle type Operation complexity Number of depots Agency driver usage However, waste fleets generally require more time than standard haulage due to higher defect rates, load risks, and driver turnover. A typical guideline: Fleet Size Recommended TM Hours/Week (Waste Fleet) 1–2 Vehicles 2–4 hours 3–5 Vehicles 4–6 hours 6–10 Vehicles 6–10 hours 11–20 Vehicles 10–20 hours 20+ Vehicles Full-time TM If your TM hours look unrealistically low, the TC may view this as non-compliant. 7. What Waste Operators Should Put in Place Immediately 7.1. Written TM Agreement Clearly define: Duties Hours Reporting structure Authority 7.2. Weekly Compliance Meetings Short meetings to cover: Defects PMIs Infringements Overloading Incidents 7.3. Proper Walkaround Check Training Waste vehicles have unique hazards: Bin lifts Chains Hook-arms Sheeting systems Rear steer lift axles Generic walkaround videos are not enough. 7.4. Internal Auditing Process Evidence is everything. 7.5. A TM with authority The TM must be able to say: “That vehicle is parked until repaired.” “That driver needs training.” “We’re increasing PMI frequency.” If the TM is ignored, the TC will view the operator as non-compliant. 8. How Transport Managers Can Prove They Are ‘Continuous and Effective’ During DVSA audits or Public Inquiry, TMs must evidence: Records of actions they have taken Emails, reports, or meeting minutes Internal audits Driver training notes Defect challenge logs Corrective actions for the same drivers repeating issues Traffic Commissioners are very clear: If it isn’t written down, it didn’t happen. Final Thoughts The waste sector needs strong transport management more than most industries. Heavy loads, high turnover, busy routes, tight urban access, and difficult waste environments all demand consistent and proactive supervision. A Transport Manager cannot simply be a name on an O Licence. They must be: Present Active Knowledgeable Empowered Documented Accountable Without genuine TM oversight, operators expose themselves to enforcement risks that can close a business overnight. Need Support? I help waste operators with: TM audits O Licence compliance systems Driver training Transport compliance reviews External TM services Public Inquiry preparation Strong transport management isn’t optional — it’s the backbone of a safe and legal fleet.

Managing end-of-life tyres (ELTs) is one of the more tightly controlled activities in the waste sector. The risks are well-known: fire, stockpile collapse, arson, environmental harm, and commercial operators entering the market without suitable controls. As a result, the Environment Agency (EA) places a heavy emphasis on robust management systems, site design, fire prevention controls and technical competence long before a permit can be issued. With 24 years in the waste industry and extensive experience preparing permit applications, this guide sets out exactly what operators need to know before applying — and what the EA expects to see before they will even consider granting permission. This article is purposely written in a practical, straight-talking way for operators, recyclers, hauliers, and new entrants to the tyre sector. 1. Understanding the Regulatory Scope for End-of-Life Tyres End-of-life tyres are regulated as non-hazardous waste, but the regime surrounding them is far more restrictive than most non-hazardous streams due to two primary risks: Fire Stockpile instability and abandonment The EA regulates tyres through: Environmental Permitting Regulations (EPR) 2016 Fire Prevention Plans (FPP) Guidance Specific waste codes related to tyres 16 01 03 – End-of-life tyres Control of major accident hazards (COMAH) thresholds, where applicable Duty of care and storage limits Most tyre operations will require a bespoke environmental permit rather than a Standard Rules Permit because ELTs typically breach SRP limits or require treatment not covered under standard rules. If you intend to: Store tyres Shred tyres Treat tyres mechanically Bale tyres Export tyres Produce shred, chips, or crumb rubber …then a permit will be required. Operators who underestimate the regulatory load associated with tyres are very unlikely to progress through permitting smoothly. 2. Common Activities Involving End-of-Life Tyres Most tyre businesses fall into one or more of the following categories: 2.1. Storage Only Tyres are stored before onward transport to recovery or recycling. Permits limit: Maximum tonnage stored Stack height Stack footprint Separation distances Fire compartments Even a “storage only” operation requires a full Fire Prevention Plan. 2.2. Mechanical Shredding Includes shredding whole tyres into: 150mm shred 50mm shred PAS 107 specification products Mechanical treatment increases fire risks and therefore requires detailed engineering controls, ATEX consideration and strict maintenance systems. 2.3. Baling or Processing Required for export or commercial resale. Baling has caused some of the most serious tyre site fires in the UK due to inadequate separation and overstocking. 2.4. Mobile Plant Tyre Shredding Requires a mobile plant permit registered by an operator with a fixed base, including waste acceptance and tracking systems. If your site does any combination of storage and treatment, the EA expects a high level of management sophistication. 3. What the EA Looks for Before They Approve Tyre Sites End-of-life tyre permits attract heavy scrutiny. Inspectors will typically assess: 3.1. Technical Competence (TCM Requirements) Operators must demonstrate: A suitable TCM with relevant WAMITAB units Continuous cover (not a TCM “on paper”) A CPD plan The EA views tyre sites as higher risk, so they expect technical leadership to be robust and demonstrable. 3.2. Fit and Proper Person Test The EA will consider: Past compliance history Financial competence Criminal convictions Previous site abandonment Insolvency events Tyre operations have historically been associated with rogue operators, so the EA’s tolerance for risk is extremely low. 3.3. Fire Prevention Plan (FPP) No tyre permit will be granted without an FPP fully accepted by the EA. Your FPP must demonstrate: Maximum storage tonnage Stack dimensions 6m separation distances Site layout Ignition source control Quarantine areas Firewater containment Access for emergency services Stock rotation strategy Maximum dwell time Tyre-related fires are notoriously difficult to extinguish, and many have burned for days or weeks, causing millions in damages. This is why the EA scrutinises the FPP more aggressively than any other part of the application. 3.4. Waste Acceptance Procedures Before tyres arrive on site, operators must have: Inspection procedures Load rejection criteria Controls against contamination Acceptance documentation Tracking and storage location systems Tyres often arrive mixed with: Rims Rubber strip Metal wire Plastics General waste Contamination causes fires, sparks, and equipment hazards. 3.5. Firewater and Pollution Risk Your application must include: Pollution inventory Secondary containment Surface water protection Drainage plan Accident management procedures The EA will reject applications that cannot demonstrate secure control of firewater run-off. 4. Site Design: The Foundation of a Successful Permit Application Tyre sites must be designed with: 4.1. Clear traffic flow Separate pedestrian and vehicle routes, turning areas for HGVs, and clear signage. 4.2. Adequate surface infrastructure Concrete surfaces free from cracks and potholes are essential for fire control and drainage integrity. 4.3. Sufficient space for stack separation Operators regularly underestimate how much space 500 tonnes of tyres requires. 4.4. Security High fencing, anti-arson measures, and CCTV. Tyre sites are frequent targets of arson. 4.5. Power supply Mechanical shredders have high load demands. A common reason applications fail is that the operator tries to make the site fit the permit, instead of designing a permit that fits the site. 5. Management System Requirements Your management system (MS) should demonstrate: Training and competency Daily inspections Tyre rotation and stock tracking Housekeeping checks Maintenance records At least one named senior manager responsible for environmental performance TCM involvement and oversight The EA expects management systems to be site-specific, not generic templates. 6. Demonstrating Financial Competence Operators must prove they can: Manage site operations Fund fire prevention measures Maintain shredding machinery Cover clean-up costs if stockpiles must be removed Abandoned tyre sites are one of the largest financial liabilities in the waste sector. Expect the EA to scrutinise your financial modelling and contingency costs. 7. Maximum Storage Capacity and Throughput You must define: Maximum storage on site Maximum operational stock Annual throughput Retention and dwell time The EA will assess whether your stated throughput is realistic when compared to: Shredder capacity Staffing Operating hours Export markets Site size If you cannot demonstrate that tyres will not accumulate, your application will be refused. 8. Common Reasons Tyre Permit Applications Are Rejected After supporting operators through many tyre permit applications, these are the most frequent reasons for regulator refusal: ❌ FPP not acceptable ❌ Stockpiles too large ❌ Inadequate site drainage ❌ Lack of genuine TCM involvement ❌ Unrealistic throughput claims ❌ History of poor compliance ❌ Inadequate financial evidence ❌ No demonstrable storage rotation strategy ❌ Sub-standard infrastructure (gravel yards, broken concrete) Tyre permits are awarded only to operators who can clearly demonstrate control and stability. 9. Preparing a Successful Application: What Operators Should Do Step 1 – Commission a Feasibility Assessment Identify: Whether the site is suitable What infrastructure is missing Compliance gaps Step 2 – Prepare detailed site drawings Including stack layout, drainage, fire access, quarantine area. Step 3 – Develop a robust Fire Prevention Plan Expect several rounds of EA feedback. Step 4 – Create a site-specific EMS Housekeeping, acceptance, training, maintenance, and contingency controls. Step 5 – Outline your TCM structure Demonstrate continuous and effective management. Step 6 – Engage with the local Fire & Rescue Service Their comments can strengthen your FPP. Step 7 – Submit a high-quality permit application Include everything the EA expects up front. Step 8 – Maintain compliance from day one Permit conditions are legally binding the moment the permit is issued. 10. What a Good Tyre Site Looks Like (From a Compliance Perspective) A compliant facility has: Hardstanding Clearly marked stacks 6m separation Good drainage No vegetation Daily inspection logs A high level of housekeeping Competent staff Controlled access CCTV and security measures Shredder maintenance logs A safe loading/unloading system Good sites look organised. Bad tyre sites look cluttered, chaotic, and unstable — and the EA can spot the difference instantly. 11. Final Thoughts: Should You Enter the Tyre Sector? Tyre recycling is a growing industry with strong demand for: Shred Crumb Reuse Export Civil engineering applications However, it is also a sector with: High regulatory scrutiny Serious fire risks High equipment costs Strict compliance expectations If you cannot demonstrate operational discipline, this is not the area to cut your teeth in. But for operators who invest properly, demonstrate competence, and maintain control, tyre recycling can be a profitable and future-proof waste stream. Need Support With a Tyre Permit? I support operators with: Feasibility assessments Environmental permit applications Fire Prevention Plans Site layout design EMS development TCM oversight Pre-application EA engagement If you want your tyre permit to progress smoothly, professional preparation is essential.

What Documents Should Be On-Site During an Environment Agency Visit?

earn how to set up a Waste Transfer Station in Nottingham, Derby & Chesterfield. Hart Waste Consultancy provides full permit applications, EMS, FPPs & EA compliance support.

Learn how to manage fire water on waste and tyre recycling sites. Hart Waste Consultancy designs compliant Fire Prevention Plans and containment systems across the Midlands.

Avoid losing your waste exemption. Discover the top 5 mistakes that lead to Environment Agency revocations and how to stay compliant with expert help from Hart Waste Consultancy.

Need help with tyre exemptions or permits? Hart Waste Consultancy provides expert support for T8 Waste Exemption and SR2021 No.13 Tyre Storage & Treatment

One major development is the government’s plan to introduce mandatory digital waste tracking starting from April 2026. This new system is a core part of the UK’s Resources and Waste Strategy and aims to revolutionise how waste is tracked, regulated, and managed across all sectors. What Is Mandatory Digital Waste Tracking? Digital waste tracking will create a centralised, real-time electronic system for recording the movement and treatment of waste throughout the UK. It will replace outdated, fragmented, and mostly paper-based systems with a streamlined digital platform accessible to waste producers, carriers, brokers, regulators, and disposal sites. This means businesses and regulators will have access to reliable, up-to-date information on: Where waste is produced Who is handling it How it is being treated or recycled Where it ultimately ends up Why Is This Important? The digital tracking system will deliver multiple benefits for waste compliance, environmental protection, and the circular economy: Stronger Duty of Care Compliance: Businesses will be better equipped to meet their legal responsibilities for waste management by having clearer, digital records of waste transfers and processing. Effective Waste Regulation: Environmental regulators will gain improved tools to monitor compliance, prioritise inspections, and swiftly act against waste crime such as illegal dumping, misclassification, and unauthorised exports. Combatting Waste Crime: Digital tracking will reduce opportunities for criminals to operate unregulated, protecting legitimate waste businesses and the environment. Supporting a Circular Economy: By fully tracking waste streams, we can maximise resource recovery, reduce landfill, and increase recycling rates, moving towards more sustainable waste management. Smarter, More Efficient Systems: The new digital service will be scalable, secure, and user-friendly, making it easier for all businesses involved in the waste chain to comply with regulations without unnecessary burdens. Working Together Across the UK While waste management is a devolved matter, the UK government, Scottish Government, Welsh Government, and Northern Ireland’s Department of Agriculture, Environment and Rural Affairs are working in partnership to deliver a UK-wide, harmonised digital waste tracking system. This collaboration ensures consistent standards and data sharing across all four nations. What Does This Mean for Your Business? From April 2026, if you produce, transport, treat, or dispose of waste, you will likely be required to use the new digital waste tracking platform. This means: Entering key waste data electronically instead of relying on paper-based waste transfer notes. Keeping up-to-date digital records that are easier to audit and share with regulators. Understanding and adapting to changes in waste duty of care requirements as the legislation evolves alongside the system. Stay Ahead of Waste Regulation Changes Mandatory digital waste tracking marks a significant step forward in the UK’s environmental strategy to improve waste management, fight waste crime, and promote sustainability. Keeping your business compliant will protect you from penalties and contribute to a greener, more circular economy. Visit our website or contact Waste Consultancy today to learn more about preparing for digital waste tracking and other essential waste management compliance services.

One of the most fundamental legal obligations you must meet is the Waste Duty of Care. This duty exists to ensure waste is managed safely, responsibly, and legally from the moment it leaves your control until final disposal or recovery. What Is Waste Duty of Care? The Waste Duty of Care is a legal framework under the Environmental Protection Act 1990. It requires every business producing, storing, transporting, or disposing of waste to take reasonable steps to ensure waste is handled without causing harm to the environment or public health. Key Responsibilities under Duty of Care: Secure Storage: Waste must be stored in a way that prevents escape or pollution. For example, construction waste should be kept in locked skips or containers that prevent wind-blown debris. Use Authorised Waste Carriers: You must only transfer waste to carriers who hold a valid waste carrier licence issued by the Environment Agency or equivalent authority. Provide and Keep Waste Transfer Notes (WTNs): Each time you transfer waste, a detailed WTN must be completed, outlining waste type, quantity, carrier details, and destination. Keep Records: Waste transfer documentation and other compliance records must be kept for a minimum of two years. Proper Waste Classification: Using correct waste codes ensures that hazardous and non-hazardous wastes are identified and managed appropriately. Why Is Duty of Care So Important? Non-compliance with Duty of Care obligations can result in severe penalties including fines, prosecution, or even closure of your site. Improper waste management risks environmental pollution, public health hazards, and damages your business reputation. How Waste Consultancy Supports You We help businesses like yours by providing practical guidance on Duty of Care compliance. From training staff on proper waste handling, verifying waste carrier licences, to reviewing your waste transfer documentation, our experts ensure you meet your legal obligations with confidence.