29 June 2022
Every person conducting transport activities in the heavy vehicle supply chain has a responsibility to prevent or minimise dangers that could cause injuries or loss by ensuring their transport activities are safe.
Having a safety management system (SMS) in place in your business can be one of the most effective ways of meeting your safety obligations under the Heavy Vehicle National Law (HVNL). Adopting and actively using an SMS has proven to help reduce safety-related incidents in other heavy transport industries, such as maritime, rail and aviation.
This article highlights the benefits of implementing an SMS and demonstrates how an SMS can assist businesses to meet their safety obligations under the HVNL.
An SMS is a systematic approach to managing safety – including the necessary organisational structures, accountabilities, policies and procedures – which is integrated throughout a business wherever possible.
An SMS helps businesses continuously improve the safety of their operations through the following four components:
Essentially, implementing the above components provide businesses with a structured set of guidelines that detail an organisation's processes for maintaining safety in accordance with established regulations, specifications or legislation.
As with any compliance framework, the components seek to implement communication processes, risk controls and governance practices for maintaining compliance. We deep-dive into each of these components and how they can be implemented below.
Safety policy and documentation
Your entire business should be committed to establishing and maintaining policies and procedures that ensure work is performed safely.
Business owners or executives have direct duties under the amended HVNL and are accountable for their business using safe practices throughout their commercial operations. Of course, executives can delegate tasks to implement those safe practices, but ultimately executives cannot delegate their duties under the HVNL.
As a first step for limiting liability and ensuring safety across a business’s commercial activities, you should put a documented safety policy in place. This will point the business in the right direction.
A safety policy should:
As a second step, you should implement safety objectives. The purpose of these objectives is to complement the safety policy, and help workers envision how safety can be achieved in practical terms. Some examples of safety objectives include:
As a third step, you should clearly establish the safety responsibilities of each employee. Responsibilities should be clearly defined, appropriately allocated to the right person in the business and there should be a direct reporting line to upper management or executives to report safety issues.
Establishing a direct reporting line is a critical part of ensuring compliance. It allows executives to demonstrate that not only are safety measures in place, but that they are taking proactive steps to ensure any safety issues during day-to-day operations of the business are appropriately reported.
Lastly, all staff members should make an effort to gain operational experience and boost their knowledge of safety in their organisation. Everyone within a business has some responsibility to ensure safety, and having appropriately trained staff is a major step in the right direction.
Underpinning all of the above is a need to document each step. It is often the most burdensome, but it needs to be done. While you may be confident your business is compliant, you need to ensure the documentation can demonstrate to someone outside the business that you are compliant. Documents may include, for example, procedures, checklists and forms, which can all be used to support the steps you take to ensure safety.
Safety risk management
There are four sub-components to safety risk management:
Together, each sub-component ensures there is a proactive approach to managing safety and creates a process of identifying, assessing, treating and monitoring risks the business encounters.
Your risk management processes may improve where the entire organisation collectively works towards the day-to-day identification and management of risk. This requires all employees of all levels to be mindful of the safety risks, and identify hazards that your organisation is exposed to and likely to encounter. Employees engaged in the day-to-day operations of the business are best placed to identify different hazards, such as:
Once hazards are identified, you should then undertake a risk assessment. A risk assessment is useful in identifying the consequences if a hazard materialises, the extent to which hazards may interact or compound, and the manner and timeframe in which these hazards should ideally be resolved.
Once the risk has been identified and assessed, the next step is to ensure that the risk has been addressed and mitigated. This requires implementing a control to mitigate the risk, and then monitoring and reviewing how that control is addressing the risk. Do not wait until something goes wrong – it’s important to review the effectiveness of your risk controls periodically.
As part of a business’s safety risk management framework, there should also be a robust incident reporting mechanism.
Despite a business’s efforts, incidents and near-misses will inevitably occur. When those incidents occur, you must have a system in place to allow employees to report those incidents to the appropriate person, to gather that information, document it and allow the event to be investigated and analysed to improve future safety outcomes. The incident reporting framework should specify the following:
In addition to undertaking risk assessments, you should also prioritise safety assurance in your business.
Safety assurance is achieved by making a commitment to the following four aspects in your organisation:
Safety promotion and training
An effective SMS can be achieved by promoting and communicating safety at all levels of your organisation. In practical terms this means:
It can often seem like an insurmountable task to develop and implement a well-functioning SMS. However, it can be done one step at a time. If you have any questions or need assistance with developing an SMS, please contact us below or get in touch with our team here.
Author: Nathan Cecil
The information in this article is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, we do not guarantee that the information in this article is accurate at the date it is received or that it will continue to be accurate in the future.