The heavy vehicle industry is currently subject to an inordinate amount of regulatory review and reform, all focused on the common goal of achieving improved safety, productivity and efficiency outcomes.
One of the topics attracting attention is ‘assurance’ and how individual businesses can demonstrate their understanding and active management of safety and compliance to stakeholders, be that other transport companies, freight forwarders and customers. The Australian Trucking Association (ATA) has come out in favour of a voluntary accreditation system, approved by the National Heavy Vehicle Regulator (NHVR), as a way to appease the demands of supplier audits and deem compliance with the legal safety duties.
It’s been acknowledged by the NHVR and more recently by the ATA that the proliferation of customer compliance audits is costly and time consuming to the industry.
Before committing to any assurance scheme, it’s useful to look outside the heavy vehicle industry and see what we can learn from the experience of other industries and jurisdictions. With the Heavy Vehicle National Law (HVNL) safety duties mirroring those in work health and safety law, there are valuable lessons to be learnt from the workplace health and safety journey.
WHAT IS ASSURANCE?
The term assurance is used by the NHVR in its safety management system model to describe the process of internal checks and monitoring of safety management system performance.
The NTC assurance models paper takes this further and describes three levels of assurance – internal, stakeholder and third party. Once beyond the internal level, compliance with the assurance criteria may award the business accreditation to a recognised audit framework or standard.
In the case of a supplier audit, the objective is to meet the customer’s criteria and gain or retain the work. Regardless of the level, assurance/accreditation schemes are reliant on documentation in the first instance, backed up with a snapshot of evidence of implementation. Put simply, does the business do in practice what it says it does on paper?
The three accreditation schemes within the heavy vehicle industry now are the National Heavy Vehicle Accreditation Scheme (NHVAS), the Western Australian Heavy Vehicle Scheme and Trucksafe.
While these are likely to be considered as third party schemes as audits are carried out by a qualified Exemplar Global third party auditor, the criteria and subject matter competencies have been developed within the industry and may not be fully understood or as widely recognised outside of the heavy vehicle industry.
Third party accreditation programs readers may be familiar with are those under the International Standards Organisation (ISO) banner:
• ISO9001:2015 – Quality Management Systems
• ISO45001:2018 – Occupational Health & Safety Management Systems
• ISO14001:2015 – Environmental Management Systems.
As a point of difference to the Industry accreditation schemes, these audit frameworks are globally recognised and approved by the ISO. The framework for such a standard is scrutinised by a panel of international experts and must be approved at government level. Industry programs are not subject to this rigour.
WHAT DO WE KNOW?
Assurance or accreditation schemes (we’ll call it accreditation) have existed in work health and safety since the 1990s and there has been much research done to examine their effectiveness. The heavy vehicle industry is not the lone ranger.
There are many years of experience to draw upon to help understand the efficacy of accreditation schemes, the costs and benefits and their relationship to improved safety outcomes.
Accreditation schemes are built around management systems. The auditor will conduct a desktop audit – review documentation, looking to verify that what is done on paper is done in practice, issues raised are actioned and closed out and there is a proactive approach with management oversight.
As an auditor and a consultant who has helped many businesses prepare for third party certification audits, there are ways to show the auditor what you want and hide what may be detrimental to the cause.
It is widely stated that the heavy vehicle industry is made up predominantly of small business (as much as 98 per cent) and as far back as 2003, research questioned the applicability of safety management systems to small employers and noted they are most easily applied in larger organisations with more safety knowledge, resources and training available.
So although accreditation schemes are said to be suitable for all size businesses, small business is disadvantaged and many have the added expense of using a consultant for the preparation and the audit process. Let’s not forget, all third party assurance programs are commercial ventures.
CAN NHVR RUN IT?
Can the NHVR run the scheme, as suggested by the ATA?
There are comparisons made between the heavy vehicle industry and rail. The Office of the National Road Safety Regulator (ONSR) directly employs auditors (rail safety officers) to carry out rail safety audits against the requirements of Schedule 1 of the Rail Safety National Law National Regulations 2012.
The profile of the heavy vehicle industry compared to rail is vastly different. To quote the Productivity Commission report, the heavy vehicle industry has more than 39,000 operators and 890,000 registered vehicles while rail has 184 accredited operators and about 2,200 locomotives. The scale of a centralised, regulator controlled accreditation scheme for heavy vehicles is mind boggling.
SOME TAKE OUTS
In the health and safety space, we have been through this. Management systems were once considered the panacea, but 20+ years later, safety is working its way through the concept of ‘safety clutter’. Policies, procedures and forms that are designed for a safety management system which does not always equate to a safer workplace or work practices. We have learned that ‘work as imagined’ by the people who write the safety management system is not how ‘work is done’.
When you have that disconnect between the paper and the practices, what value is the safety management system adding?
WORK IN PROGRESS
The industry is already under pressure from rising costs, so to make any voluntary assurance scheme attractive, the cost to participate could be offset through some tangible benefits in addition of course to the expected outcomes – improvements in safety, efficiency and productivity.
The NTC Industry Advisory Group on Assurance has a very important role to play in getting this right and ensuring an even playing field for this very large and diverse industry.
Denise Zumpe is a qualified and experienced consultant with practical industry knowledge in work health and safety and heavy vehicle safety and compliance, establishing SafeSense Workplace Safety in 2010. She is one of three representatives of the Australian Institute of Health and Safety (AIHS) participating in the HVNL review.