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THE IMPORTANCE OF BLAZING NEW TRAILS
Over the past few weeks I have noted with interest the newsletter articles of a particular industry association about the extension of the NSW and QLD 160km radius log book exemption for rural carriers into SA, TAS and ACT.
It was alleged that the NHVR has ‘made a mockery of the principle of fatigue management’ by harmonising the rules across the jurisdictions without also extending the exemption to all other drivers.
Not only does this demonstrate a poor understanding of the rationale for seeking the change, it belittles the important role that sectoral interest groups play in opening the door to benefits that, when proven safe and effective in a real operational environment, can be extended to others across the transport industry.
Why do we need two sets of rules for work diaries?
This issue is not so much about the 160km radius – it is about continuous driving time.
The fatigue ‘body of knowledge’ (as experts like to call it) says that fatigue risk is at its lowest during the first two hours of continuous driving time. As you might expect, the risk increases as the continuous driving period becomes longer.
While a log book can help manage increased fatigue risk, it imposes a much higher administrative burden on short trips because it is filled out at every change of activity.
So, to reduce unnecessary red-tape for low risk drivers, governments have previously allowed a log book exemption for all drivers operating wholly within a 100km radius of their home base.
This works well in metropolitan areas. Assuming that a driver starts and finishes at their home base, most trips can be completed in under two hours of continuous driving at an average speed of 50km an hour.
The problem for rural operators is that 100km equates to around 76min driving time at an average speed of 80km an hour. Increasing the radius to 160km simply gives low-risk rural carriers the same driving opportunity as their metropolitan counterparts before an increased administrative burden is imposed.
Having two sets of rules is the only way to achieve the same outcome in what are very different operating circumstances.
What about other drivers in regional areas?
In considering the ALRTA’s proposal, decision-makers demanded a high degree of assurance that any change would not increase fatigue risk in any other part of the industry.
This was achievable for rural carriers by limiting the exemption to primary produce because it is already defined in regulation and the vast bulk of it is necessarily transported in rural areas.
Proving a similar case is more difficult for other freight types that regularly travel in both urban and rural environments. How do you distinguish between a load of tissue paper in western Sydney and a load of tissue paper in far western NSW?
One very good way to do that would be to apply the exemption to all vehicles moving within non-urban zones regardless of the freight type. Unfortunately however, the reality is that we have been pushing for a zonal approach to fatigue laws for decades now without success. So for now, the options are limited and we just can’t wait for the zonal issue to be resolved.
The NHVR and State and Territory Governments should be applauded for taking what action they can to harmonise this law nationally.
Is there a role for interest groups in improving regulation?
It’s no secret that sectoral industry bodies exist to pursue the specific interests of their members. Such interests tend to get lost within umbrella associations with decision making structures that favour the interests of the majority.
Fortunately, governments recognise the enormous diversity that exists within the transport industry and know that it is important to progress safety and productivity reforms at all levels. Listening only to the large players would be to ignore most of the industry.
Regulators will sometimes work with an expert high-need sector to progress particular reforms that are known to be of broader interest. This is an appealing risk-reduction approach for governments because proposed reforms can be contained, analysed and refined before a decision is made about broader introduction. Small steps are infinitely better than none at all.
For example, the ALRTA is currently working with the NHVR to pilot a new AFM template system that will allow a fortnightly work cycle. While we are working to improve flexibility and reduce red-tape for our members, we are at the same time using our resources to help establish the principles, processes, frameworks, data and documentation that, if successful, can be rolled out across the heavy vehicle industry.
This works at an individual business level also. How often have you seen depots progressively open up access for higher productivity vehicles? Once the concept is proven for one class, there is vastly more potential for other classes to benefit.
So, despite the criticisms that will occasionally come our way when we meet with success, the ALRTA will continue to seek worthwhile sectoral reform at every opportunity. We can only hope that some of the more enlightened transport associations recognise that we are in fact opening doors, not closing them.
NTC UNDER THE SPOTLIGHT
This week I met with Mary Anne O’Loughlin who is a member of an Expert Panel conducting an independent review of the NTC. The National Transport Commission Act 2003 requires that the Transport and Infrastructure Ministerial Council review the NTC every six years.
In particular, the Expert Panel is examining the NTC’s:
- Operational effectiveness;
- Future role and relationships; and
- Future work priorities and governance arrangements.
Please contact me if you would like to discuss your views on the future role of the NTC. The ALRTA intends to lodge a written submission by the closing date of 28 April 2015.
Last week I met with representatives of the NTC to discuss the four reform options proposed in the January 2015 regulatory impact statement on the NTC/NHVR Heavy Vehicle Roadworthiness Program.
Each of the four options includes potential changes to inspection processes and procedures, education and training, greater capability to target the highest risks, scheduled inspections, accreditation schemes, and possible changes to chain of responsibility laws.
The ALRTA has been working with the ATA Safety Committee to progress a response to the options by 23 March 2015. A national position will be adopted by the ALRTA Executive this week.
LBCA CONFERENCE WRAP UP
This year’s LBCA conference was a resounding success with more than 200 people making their way to the Snowy Mountain country around Jindabyne to voice their opinions, catch up with old friends and make new ones.
Right from the opening address by the NSW Minister for Roads and Freight it was clear that the LBCA is seen as the premier road transport association in NSW. There was the usual lively debate in the various panel sessions on access, animal welfare and bulk grain issues and I was very happy to hear that ALRTA’s work on NHVR issues, ramps, effluent and harvest management schemes is very much in line with what grass-roots members are looking for.
Jock Carter was re-elected LBCA President at the AGM and I must congratulate the new team in the LBCA office who have done an outstanding job in organising and managing the event.
ALRTA EXECUTIVE AND COUNCIL MEETINGS
The ALRTA Executive met via teleconference this week. Members are advised that the next ALRTA face-to-face National Council meeting will be in Melbourne on Friday, 17 April 2015. If you are interested in observing proceedings please contact the ALRTA Secretariat.