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148 
hat the law says await part-tine twi;-nowers
Page 45
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As far as the law is concerned, the key phrase when thinking about transport management is "continuous and effective responsibility" for the fleet. What is not open to negotiation is that, even as an ownerdriver; you either need to hold a CPC yourself or have access to the services of someone who does.
The CPC holder can be part-time. But Tim Culpin, partner in charge of the transport team at law firm Aaron & Partners, says a haulier could find themselves on thin ice if he does not have a full-time transport manager to handle his affairs—this was mandatory until the law was changed in 1991.
"With two or three vehicles then maybe you can," says Culpin. "But the law says 'continuous and effective responsibility' and with a part-time transport manager I think that's difficult. TCs are becoming increasingly concerned and suspicious—they want real evidence and expect far more by way of an audit trail.
"My advice to people is always get your own [transport manager], or do the course and do it yourself," he adds. You are making life difficult for yourself if you don't. You can delegate the tasks, but you can't delegate the responsibility."