What is CoR and what does it mean for a brewer?
Like any other manufacturing business, a typical brewery will receive deliveries, and dispatch goods on heavy vehicles. So did you know that you have a role in ensuring the safe transport of goods on heavy vehicles?
If you are wondering why, have a look at this dashcam video of an empty keg impacting with a car on the M4 motorway in Sydney only two weeks ago.
The Heavy Vehicle National Law (HVNL) places obligations on every party in the heavy vehicle transport supply chain to ensure the safety of their transport activities. This is often known as the “Chain of Responsibility” or CoR.
The NHVL enforces the requirements for managing the risks associated with mass management, load restraint, dimensions, speed and vehicle standards for all heavy vehicles. Fatigue management is enforced for vehicles over 12 tonnes in weight; anything under this weight falls under your business safety management system. Changes to the legislation that will come into force in October 2018 will require organisations to be able to demonstrate they have discharged their duty in identifying, assessing and managing the risks associated with the heavy vehicle transport related to their business, even where they are not an operator of heavy vehicles.
Heavy vehicle operators, for the most part, have become well versed in the requirements of the legislation. But at Victual, we have regularly found that it is the others in the chain that are potentially exposed. The reality for most organisations is that transport operations are outsourced. Many organisations that outsource their logistics function assume that compliance with the HVNL is not their responsibility.
CoR obligations can be breached in many ways. A consignee will have a more significant role to play if they are packing the goods and loading the vehicle. Requirements for mass management and load restraint need to be considered.
An example that could apply to a consignor or a consignee may be the planning of a delivery with unrealistic timeframes that may require or influence a driver to breach fatigue management requirements, or speed limits.
Driver fitness for duty will also be an area requiring consignors and consignees to act where they identify potential issues, or risk being caught as not being proactive to prevent harm.
Striving for compliance
As a party in the supply chain, the best way to achieve compliance is to embed CoR into your safety management systems. This will include training, procedures and review processes that:
- identify, assess, evaluate, and control transport risk
- manage compliance with speed, fatigue, mass, dimension, loading and vehicle standards requirements through identified best practice
- involve regular reporting, including to executive officers
- document or record actions taken to manage safety
To this extent a transport related incident should be treated just like a safety incident or near miss. To demonstrate your diligence in this regard, follow the same logic applied to your obligations as officer’s under WHS legislation. As yourself these six questions:
- Do I know my obligations under HVNL?
- Do I understand the risks?
- Have I provided adequate resources?
- Do I respond to incidents and hazards in a timely manner?
- Do I enforce these requirements when breaches occur?
- Can I provide evidence?