View the feedback we have received on the Heavy Vehicle National Law statutory instruments consultation paper.

• Do you have any feedback specific to the draft Ministerial Guidelines for Heavy Vehicle Accreditation?

  Standard market forces apply to the transport industry, eg supply and demand, cost comparison for similar services etc. As a business that meets its safety obligations and has a robust and agile SMS, we don’t rush drivers, and we constantly monitor fatigue risk. Our vehicles are well maintained, and our incident investigation process feeds into our process development to expedite improvements to our training. As a customer, the goal is to get a product from A to B at the lowest cost possible, as quickly as possible. Many customers, I would say most, are unaware of CoR requirements, and their place in the chain. A transport provider that is not accredited and does not have an SMS, will have a lower operating cost than one being run correctly. Without proper education about the risks involved in transport, and their exposure to negative consequences, all a customer is likely to see is a better deal. We also educate our drivers and customers on what constitutes a prohibited request, eg working through breaks or speeding to meet deadlines. Unaccredited transport providers can simply not tell their drivers what can and can’t be done, potentially resulting in them getting the job done sooner than us, with the customer none the wiser as to their complicity in an illegal act. All they will see is a cheaper and faster option. Does it not seem likely that this will result in more unaccredited transporters on the road, doing more work, as they can offer a lower price? Over time, safe operating procedures pay for themselves, in reduced incidents, public perception, and the like. However, this plan seems likely to increase the public risk, especially combined with the intention to increase overall mass limits. I would think that if this system is intended to close gaps in the current HVNL and improve safety, then why not make it compulsory? I understand that this would be quite a bit of work, but an opt-in system seems likely to reduce the impact of the intended changes. Otherwise, is there any plan to directly interface with customers of the transport industry, to better educate them on CoR liabilities? Overall I agree with the changes being made, heavy vehicle regulations have absolutely saved lives over the decades. But I do think that going one step further, by making an auditable safety management system a compulsory feature of any transport provider would significantly improve results.