Have you been asked for a Chain of Responsibility (CoR) Policy? It is a common request when seeking to confirm that a transport business is compliant with Chain of Responsibility obligations, but what is a CoR Policy and why do you need one? Transport Operators need a Chain of Responsibility Policy because it demonstrates to supply chain partners, customers and regulators that you’re proactive and take the safety of your road transport activities seriously.
Just like a Work Health and Safety Policy, a CoR Policy will consist of an overarching statement of intent to comply with CoR laws and commitment to minimising risks arising from your transport operations, as far as reasonably practicable. The objective being to prevent harm to people and infrastructure.
Next comes what actions you will take to achieve this. The Heavy Vehicle National Law requires transport operators to identify and control risks with transport operations, including not influencing a driver to speed, carry an overweight or over-dimensional load, travel in an unroadworthy/unsafe vehicle or drive while fatigued. So these would typically be mentioned in your policy. Other actions may be to encourage reporting of CoR breaches and engage with supply chain partners to work collectively to manage transport risks and improve safety for all.
Everything you say in your Policy should be part of your everyday business operations. For each of your actions, you will need processes and records. For example, if you state in your Policy that drivers will be licenced, competent and fit for work – how will you demonstrate this? This could include:
- Sourcing driver history reports issued by the Regulator to monitor licence and demerit point status.
- Having a drug and alcohol policy and testing program
- A daily fitness for work declaration for drivers
- Training for drivers and operations in recognising and responding to fitness for work issues
To monitor compliance with your Chain of Responsibility Policy, you will be gathering and reviewing data which will help guide your decisions. If, through monitoring fatigue, you become aware of fatigue management breaches in relation to a particular route, client or driver, you can use this information to make changes.
If you don’t have a Chain of Responsibility Policy, think about all the actions you have in place to manage transport risks and compliance and document these and there’s your Policy. Alternatively, you can start with a Policy template and this can structure your compliance program. Either way, next time you are asked if you have a Chain of Responsibility Compliance Policy, you will be able to confidently answer, Yes, I do.