In its latest regulatory advice for those with a legal duty in the Chain of Responsibility (CoR), the NHVR addresses the risks associated with workers who are insufficiently trained to do their job.
Taking steps to manage these risks is not only critical to ensuring the safety of your heavy vehicle transport activities, it’s also a requirement under the Heavy Vehicle National Law (HVNL), reminds the regulator.
What are the safety risks?
Undertrained workers pose a serious safety risk to themselves, their colleagues and the general public. They can also present a danger to infrastructure and the environment.
Heavy vehicle crashes and other safety incidents due to inadequate training can also result in significant reputational damage to your business.
Having a heavy vehicle driver’s licence is not always proof of a driver’s ability. Even if highly skilled and experienced, the driver may need additional training to ensure they can drive safely and efficiently within a particular industry sector or new work environment.
Why is it important to manage safety risks?
Ensuring new and existing workers are appropriately skilled at their jobs is a critical way to ensure the safety of your heavy vehicle transport activities. It’s also a requirement under the HVNL (section 26C).
Workers in the heavy vehicle industry need to perform their work safely and understand the risks and hazards associated with their job and workplace. Effective management of training within the heavy vehicle industry will ultimately result in a safer community and a safer and more productive workforce.
Taking proactive steps to manage safety risks and meet your legal obligations also helps protect your business from possible regulatory action.
Who has a duty to manage safety risks?
Drivers and other workers have a role to play in participating in training. However, the onus is on CoR parties and their executives to ensure workers are adequately trained with the necessary skills to undertake tasks safely.
At a minimum, CoR parties should undertake a risk assessment to consider the risks associated with insufficient or inadequately trained workers and how to mitigate those risks. Executives should endorse or approve a final risk assessment.
Executives of business that are a party in the CoR have a distinct duty to exercise due diligence to ensure the business complies with its primary duty. Executives must also ensure sufficient financial, human and other resources are available to the business to implement training effectively. They should also actively invest in monitoring tasks to assess the ongoing effectiveness of training and promote continuous improvement of safe business practices.
How can I manage these risks?
Providing appropriate training is not simply a matter of allocating and spending a training budget. Training must be relevant to the industry and aimed at improving the skills and safety of the workforce. To understand the required skill set of a business’s workforce, conduct a training needs analysis.
After completing the training needs analysis, a training plan should be developed, implemented and communicated with workers, taking into consideration:
• The particular skills needed to undertake the role safely and efficiently.
• If a qualification is required to perform the role.
• A level of assurance that workers have been adequately trained the new skills required if a worker is promoted or moved to a new role within the business.
Training should include
• Induction training: Specific to each workplace, induction training should instruct workers in everything they need to know about the location, activities, procedures and safety risks relevant to the role. It should also outline the business’s expectations for a safe workplace. Workers new to the business, worksite or role; workers returning after a long absence; or visitors to a worksite require induction training. The on-boarding of staff may take several months of on-the-job training to complete.
• Task-specific training: This should cover the specific skills and knowledge needed for a worker to perform tasks competently and safely at all workplace locations, including:
- acquiring necessary documentation (for example, a specific vehicle class licence or first aid certificate)
- ensuring that specialised roles, such as forklift drivers or crane operators, are appropriately trained with correct certification
- providing loading and load restraint training (for example, for general freight, mixed loads, livestock or dangerous goods).
• Other training: Through the risk assessment process, a business may identify other training workers should complete to do their job safely (for example, site-specific work health and safety training at distribution centres).
There are typically three types of training delivery methods:
• Internal training – training developed and delivered in-house by staff with relevant experience/skills/qualifications.
• Accredited training – nationally accredited training delivered by approved educational institutions (RTOs, TAFE, Uni).
• SME consultants – external consultants who offer non-accredited training services based on a particular expertise (for example, load restraint, crane operation, ancillary attachments to vehicles).
Businesses are responsible for ensuring any external training delivered is fit for purpose and contextualised to their work environment. In other words, avoid generic ‘tick the box’ training that offers little impact or benefit. Make sure your training provider is clear on your specific training needs.
Regularly conduct a review of your business’s training needs to check it’s up to date, fit for purpose and responsive to emerging risks or changing situations. Reviews may also be helpful to identify gaps in training or alternatives for delivery as part of your wider Safety Management System (SMS). Conduct reviews on a regular, scheduled basis and on an as-needed basis.
Refresher training may be required because of a workplace incident. This kind of training is essential to help workers:
• Retain previously delivered information.
• Reinforce the skills necessary to do their job.
• Identify gaps or correct any misunderstandings in their knowledge.
The depth and regularity of refresher training will vary according to the level of risk. For example, refresher training on fire extinguishers on a fuel tanker may be required more regularly than manual handling refresher training.
You may not need to repeat the original training in full. It may be enough to offer a summarised version in the form of an information sheet or email, reminding workers of their obligations and the business’s expectations.
Maintaining training records
Keep records to track information related to training. Records should, at a minimum, capture any information required to be documented by law, but can also provide useful information to further assist training.
Training records should be endorsed by both an appropriate member of the management team and the worker that completed the training. Records should be kept, stored and maintained in accordance with legal record-keeping requirements. This will assist in promoting transparency, accountability and awareness across the business.
Providing adequate supervision
A worker may need to be supervised during their training depending on the level of risk involved, the ability of existing controls to reduce the risk, and the individual’s experience level. A lower level of supervision may be reasonable for a skilled worker performing a relatively low-risk task, while a higher level of supervision may be required for an inexperienced worker or while performing a high-risk task.
Supervisors should be suitably experienced and competent and understand their responsibilities. They are expected to provide proper supervision, guidance and direction to workers and respond appropriately to instances of non-compliance with a business’s procedures.