As safety has become an ongoing concern and regulation changes fast approaching for the transport industry, it’s time to look at the risks facing your business to help develop a plan of action. For many people, figuring out where to start is the biggest challenge. So we spoke with Transport Solutions Specialist (and former truck driver) Shannon Kyle, to find out what you need to know.
Q: We know there are changes to Chain of Responsibility legislation on the horizon. Will these affect how businesses manage risk?
A: Definitely. This is going to be the year of safety. It’s important to review your policies and procedures, and get your business ready for upcoming regulation changes.
The Chain of Responsibility (CoR) essentially means any party in the logistical chain with influence over the transport task is now actively responsible for safety on the road. So, it’s all about how businesses can demonstrate they’re managing any risks standing in the way of that goal. The number one thing is: you’ve got to identify those risks. And then you’ve got to put systems, processes and business practices in place to mitigate them.
Q: What’s actually changing?
A: Nothing really changes at the coalface. Standard driving hours, BFM, mass limits, load restraint regulations – these are all the same. Alongside increased penalties, the key changes are around primary duty. So, the fact that every party in the supply chain has a duty to ensure safe practices, prior to a breach occurring.
Q: What does that mean for a business?
A: In practical terms, the primary duty means you’re obliged to eliminate (or minimise) potential harm and risk, by doing all that you can to ensure safety. The big change is that you’ll need to show what steps you’ve taken to address risks before they eventuate – not after a breach. You need to show you’ve done a risk assessment.
I always say, it’s like taking a maths test at school and writing down the answers without showing the work. You’ll only get half marks. You need to show why you came up with that idea and what the process was to get there. In transport, that means clearly identifying that you understand what risks are present in the business.
Q: How should businesses demonstrate they’ve addressed risks?
A: A great starting point is the NHVR chain of responsibility gap assessment tool. Whether you’re a consigner, receiver, loader, packer, driver or fleet manager, you can use it to identify potential gaps in your business where risks aren’t being addressed.
The best way to demonstrate compliance is to have a safety management system in place, which includes processes to identify, evaluate and control risk. Some things you’ll want to include are:
- Your current risk register
- Risk assessment processes
- Risk monitoring and review procedures
- Incident reporting
- How you’re addressing identified risks
- Safety accountabilities in the team
- Documented internal safety investigations
- Your hazard ID form
Q: What are some of the risks fleet managers should be looking at?
A: The Australian Logistics Council and Australian Trucking Association are currently putting together a master code of practice for the transport industry, which is designed to provide guidance on how businesses can stay compliant. Once that’s available, it will be no good standing up in court and saying, “I didn’t know that was a risk for the industry”. If it’s on the registered master code, you should be managing it. That’s the document that prosecutors and legislators will be looking at.
Overall, there are some common risks that affect most fleets. Speed and fatigue are two of the big ones. Yet this is where a telematics system is very useful. It captures vehicle performance and driver behaviour automatically so you can clearly see what the biggest risks for your business are. It may not be speed at all, but rather harsh braking or staff allocating too many jobs for a driver to complete safely in one day.
Q: So is having a telematics system in place enough?
A: It’s not enough on its own. One of the biggest gaps we see is a telematics solution being put in place, but no reference to it in the policies and procedures. So, businesses aren’t documenting how they’re using this tool to manage and mitigate the risks.
If you’re capturing all the information on business practices and risks, that’s great. But if you’re not actually managing any of the breaches you’re seeing in the system, you’re not doing enough. It simplifies things, and it makes your task more efficient, but ultimately it requires commitment from management to act on the information if you want to achieve the best outcomes.
Q: Are businesses already looking at these kinds of risks as part of usual business process. What’s the difference between that and what’s expected now?
A: You wouldn’t still be operating a successful business if you weren’t doing most of this in some form already. This change just makes it important that you’re clearly documenting every process and action, and that you can easily demonstrate to a regulator that you’ve thought about the risks to prevent breaches – not just responding when an incident has already occurred.
Q: Fatigue is one of the biggest risks in transport but it can often be hard to manage. How can a business be more proactive about addressing fatigue?
A: Traditionally in the transport industry, we get the paper work diary pages and we’ll bang them through a log-checking process which might take a week. Then you can say, “mate, you had a breach a week ago, let’s sit down and talk about it” – but the driver probably can’t even remember where it was or what happened.
As a driver, I was bloody hopeless at trying to add up my work diary when I was driving. I would have welcomed a device that told me how many hours I’d driven, when my next long rest break was due, when my next consecutive rest was coming up, etc. To have all that information available on the device is a huge help to the driver – and also shows that you’re mitigating one of the biggest risks.
Implementing an electronic work diary allows you to tell the driver in advance, “Hey, there’s 30 minutes before you need to take a rest break”. Now there’s 15 minutes. And now you’re in violation of your fatigue rules and the back-office has been alerted. That means there’s no risk of a driver breaching fatigue rules without operations being alerted and it being recorded and documented.
Q: This sounds like a lot of work for a small business. Do they really need to implement these new technologies and processes?
A: Obviously, with a small team, it’s more difficult to get new processes and tools in place. But it’s worth it. Aside from the safety benefits to your staff, changes to the regulations are also dramatically increasing penalties – up to millions of dollars.
The benefits of a fleet management system also go beyond compliance. Telematics will actually reduce admin time significantly across the board, whether it’s completing and checking logbooks, preparing invoicing, collating paperwork for an audit or executing payroll. You can integrate telematics into all these areas of your business to get a heap of time back in your day.
It’s also important to note that business size doesn’t matter when it comes to the benefits of the system. Telematics will put you on the same playing field as all the big players, so you’re managing compliance at the same level.