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View the feedback we have received on the HVNL review consultation regulation impact statement paper.

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The WCRA WHS Group after their review would like to submit the following comments regarding the HVNL proposed policy position.

8.2.2 Making standard hours less complex (Option 8.1)
 Proposed 1-hour transfer: This would allow a driver to work for up to 13 hours in a 24-hour period, ONCE, in a 7-day period. The maximum work time of 72-hour in a 7-day period would still apply
 Supported by WCRA. A very simple change that will assist a Heavy Vehicle Driver (once per 7 day cycle) if caught in traffic, to finish the allocated shift.

 Proposed split rest break: This would allow drivers to split a 7-hour continuous rest break ONCE in a 7-day period. A 7-hour continuous rest break could be replaced with a work/rest pattern of 2 hours rest, 1 hour driving and then another 6 hours rest. The 72-hour work time cap would still apply
 Not supported by WCRA. It in fact makes the standard hours option more complex, therefore very likely to be misunderstood & will cause compliance issues

Option 8.1(b): Reclassifying time using a “rest reference” Proposed
 Not supported by WCRA, it will create more complexity in record keeping. The advantage of the current system is that for a heavy vehicle driver there are only two definitions of time – work and rest.
 Any reclassification of time definitions, may have unintended negative consequences

Thank you for your hard work and opportunity to comment.

Please contact me if you have any questions or require further detail.

Regards

Glenn Caffyn
0438 087 318