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Sutherland Shire Council’s approach to CoR changes

By intouch * posted 21-05-2018 15:08

  

Words by: Mark Mills, Manager Fleet and Workshops, Sutherland Shire Council

IPWEA FLEET Council member

Heavy Vehicle National Law (HVNL) and the respective regulations were enacted into NSW legislation in February 2014, placing greater levels of accountability for those throughout the supply chain associated with the use of heavy vehicles, to control Chain of Responsibility (CoR) risks and ensure transport safety.


David_Newell_Courtney__Fleet_Coordinator__Mark_Wood__Engineering_Operations_Group_Manager__Mark_Mills__Manager_Fleet_and_Workshops.jpgAs a large operator of heavy vehicles, Sutherland Shire Council was aware of this change but we were not overly concerned, given that we already had good systems and practices in place from both a WHS maintenance and operational perspective. HVNL and CoR was something else we placed on our list of priorities, believing that full level of compliance would only be a small body of work – how wrong we were! Although we had good systems and practices in place, we discovered we had 12 months of solid work ahead of us.

The degree of work involved in implementing recommendations directly relates to the level of risk and controls. We operate our own waste fleet, which puts us at greater risk. The level of effort for most organisations will vary based on risk exposure, but I would expect most to experience a similar fate in regards to CoR audit outcomes.

In late 2016, we engaged a consultant, an expert in the field of HVNL CoR, to complete a one-day desktop audit in relation to SSC’s (organisational level) holistic application and compliance with CoR. The audit results were pretty alarming, given our perception of what we thought CoR looked like from the distance.

It’s not normally appropriate to share this level of information publically but our organisation has come a long way over the past 12 months and sees benefit in sharing our CoR experience and journey with others. We’ve now successfully implemented nearly all of the audit report recommendations and those flagged required changes in HVNL for later this year.

The below table reflects our initial audit results based on an assessment against relevant National Logistics Safety Code standards and criteria (10 standards, 58 criteria) for CoR application and compliance.

Picture1.pngGiven that CoR was clearly an organisational-wide issue, one of the most challenging parts of being faced with such a result was developing a strategy to deal with these recommendations, while gaining organisational acceptance and support in contributing to a program of works against an agreed timeline.

Fortunately, I involved our audit and risk and WHS teams very early in the initiation phase of the audit, knowing this was likely going to have deep reaching impacts across the organisation (executive, procurement, project delivery, operational areas, waste, leisure centres, suppliers and contractors, etc).

The next step was to complete a risk assessment on the identified gaps to determine the appropriate control measures for our organisation. Once completed, significant efforts went into grouping actions and assigning responsibilities prior to placing them into a project schedule, which made a complex subject matter digestible for communicating and reporting purposes.

The executive team had already been briefed on HVNL CoR through the enterprise risk process (flagged by fleet), so they possessed a basic understanding of the law and CoR concepts.

An audit report was prepared and presented along with the project brief and schedule requesting endorsement for the implementation of the 12-month improvement program, along with funding support.

Our executive acknowledged the level of risk and how HVNL and CoR impacted our organisation, and the importance of taking a proactive approach to ensure we assume our responsibility for transport safety.
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