muckles:
I believe you’re wrong about DVSA not enforcing WTD, unless you mean they don’t really worry about it?
I have seen reports of DVSA prosecuting WTD offences, but they seemed to be included in a long list of offences for companies or drivers they were trying to get off the road.
I suppose it depends what you mean by the WTD being enforced, I believe it’s true that WTD infringements will be used as supporting evidence and possibly even acted on where a driver or company are facing much more serious offences in court, but to the best of my knowledge no-one has been fined or prosecuted or penalised in any way by the DVSA for only WTD infringements.
I suppose if we’re saying that the one in a million chance (don’t take that figure too literally because I’ve just made it up 
) that a driver will face serious charges in court in which his/her none compliance of the WTD is brought up is enforcing the WTD then it’s being enforced, however I would say that for the vast majority of drivers it’s not being enforced in any meaningful way by anyone other than their companies.
muckles:
I’ve just attended a New Operator Seminar and they said they were responsible for it, but don’t enforce it on the road, however they will expect to see a recording system in place if they do a site visit and offered a spreadsheet to record them if we wanted.
I don’t blame the DVSA for expecting companies to show that they’re complying with the WTD, lets face it if a company is prepared to ignore one piece of law it’s probable that they would choose to ignore any law that they feel doesn’t suit them.
I’ve argued this case myself in the past when people have suggested that companies shouldn’t or needn’t bother with the WTD because the DVSA don’t bother with it, at the end of the day it’s the law and it’s not for companies to pick and choose which laws they choose to comply with.