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View the feedback we have received on the Reforms to Heavy Vehicle National Law Consultation Regulation Impact Statement paper.
All vehicle masses and classes should be monitored equally.
Having different standards for different vehicle masses
- does not account properly for a driver that may drive different classes of vehicles in a single period.
- incorrectly presumes that there are more accidents involving larger vehicles than lighter ones.
- does nothing to address the problem that a unmonitored tired member of the 'public' can just as easily collide with a compliant heavy vehicle
Having different standards for different vehicle masses
- does not account properly for a driver that may drive different classes of vehicles in a single period.
- incorrectly presumes that there are more accidents involving larger vehicles than lighter ones.
- does nothing to address the problem that a unmonitored tired member of the 'public' can just as easily collide with a compliant heavy vehicle
Option 2c is the only genuine scenario for monitoring.
Fatigue management should be applied to all heavy vehicle operations regardless of range. There is nothing in the studies which justifies the 100km exemption. A tired driver can just as easily cause an accident at the local intersection as at the intersection in a town 101 km away.
The application of fatigue management should be homogenous across distance, employers and vehicle classes.
Fatigue management should be applied to all heavy vehicle operations regardless of range. There is nothing in the studies which justifies the 100km exemption. A tired driver can just as easily cause an accident at the local intersection as at the intersection in a town 101 km away.
The application of fatigue management should be homogenous across distance, employers and vehicle classes.
The proposal for a 'lite' diary will introduce negative administrative and technical confusion to the system. If the diary system is adequately refined it should be the same across all vehicle classes.
The diary system needs to allow for the fair monitoring of a driver
- who drives more than one class of vehicle during work hours
- who works for more than one employer.
The diary system needs to allow for the fair monitoring of a driver
- who drives more than one class of vehicle during work hours
- who works for more than one employer.
The proposal for a 'lite' diary would impede the successful adoption of EWD's. The EWD's currently available already have limitations and shortcomings. Having multiple classes of diary and logging would make meaningful tracking of an individual driver very difficult unless their employment arrangements and work tasks were very homogenous.
The 14 day limit is sufficient. There is nothing in the studies which meaningfully imply somebody who didn't get enough rest 27 days ago is a danger to society. It doesn't matter if the offence is detected by a roadside officer, a camera or electronically. Scrutiny beyond 14 days is an unnecessary daily compliance burden of little to no value to public safety.
Compared to the unpoliced weight and dimension issues of car/caravan combinations, the changes proposed for heavy vehicles are minimal relative to the driver/vehicle.
The manufacturers operating specifications of many heavy vehicles operating in Australia are well higher than the regulations permit. The increases proposed create efficiencies without pushing the safe operating limits of imported vehicles.