Subcontractors have always been an integral part of the transport & logistics industry. Over 79 per cent of all freight carriers use subcontractors in their fleets, according to an MFAC/VTA report. With increasing emphasis placed on the Chain of Responsibility (CoR) due to upcoming legislation changes, it’s important to understand where subcontractors fit.
Subcontractors Are On You
Subcontractors (and their obligations) are a transport operator’s responsibility. In a practical sense, this means that if you hire a subcontractor to complete a job in any capacity, you’re liable for what they do and their compliance requirements. You can’t afford to overlook their actions. It’s crucial to ensure they’re compliant with all applicable fatigue, speed, mass and vehicle regulations.
Consider this scenario:
You’re ACME Corp, a freight carrier based in Melbourne. A customer needs you to deliver two containers of perishable goods to their distribution centre in Brisbane. ACME Corp only has the capacity to carry freight between Melbourne and Sydney, so a subcontractor is hired to continue the journey to Brisbane.
What are your responsibilities if an accident happens during the subcontractor’s leg of the job?
If an accident occurs at any point of this scenario, authorities will look at where the faults occurred in the transport chain. Fatigue will be investigated, processes and policies on speed monitoring will be requested, and enforcement officers will check right through to how the job was booked. The obligations can vary depending on the operation, but you can be sure that all elements of the supply chain will be looked at.
What Can You Do To Minimise Risk?
Ensure that everyone in the transport chain or anyone who exerts any influence is responsible for his or her duty to the CoR. This can be anyone, from the warehouse arranging the load, the staff delivering the freight and even the on-forwarding task. Each step of the journey must be checked for safety and compliance.
Incidents happen, yet they can be avoided by implementing and following simple policies. For example, developing procedures for staff to check fatigue hours, maintenance records are up-to-date and vehicle road-worthiness each time a subcontractor is brought on board for part or all of a freight task. This includes providing a proper induction to your company’s policies and practices – subcontractors should be trained in the same way as your full-time employees.
Implementing these company-wide safety policies, practiced every day, helps you to prove that you’ve done all that is reasonably practicable to ensure compliance. This means covering speed, fatigue, mass, dimension, loading and vehicle standard requirements, and must include the actions of your subcontractors. Regular audits of risk management policies and procedures should also be conducted to satisfy requirements and make sure they’re up to date.
Streamlining Safety With Smart Technologies
This can all seem overwhelming, but the right technology makes managing subcontractors and safety simple. With telematics, you can make sure any drivers working for you are following fleet safety policies and address unsafe behaviour immediately. Combined with analytics tools, you can access real-time feedback on the actions of subcontractors to monitor things like:
- Fatigue at any point of the journey, calculated in real-time against fatigue laws to ensure the driver remains compliant through each leg of the job.
- Real-time mass information for each axle-group, configurable to any vehicle combination.
- Results of a configurable pre-trip checklist to ensure the vehicle and trailer being driven are up to standard.
An in-vehicle display for drivers also means they can manage their own fatigue, speed, documentation and more while they’re on the road. The data generated by these systems is a huge benefit when proving CoR compliance, as it demonstrates that you’ve taken proactive steps to manage and reduce risk in your business.
The aim of the CoR is to make sure everyone in the supply chain shares responsibility for safety. Under the legislation, if you have control or influence over any transport task, you must guarantee that the Heavy Vehicle National Law is complied with – you can’t leave it in the hands of your subcontractors. Effective training, clear guidelines and the right tools will make it easy for everyone in the chain to stay safe and compliant.