View the feedback we have received on the NTC Issues Paper - Assurance models paper.

• Question 1 - Have we covered the issues relating to assurance accurately and comprehensively? If not, what do we need to know?

  At the moment the consultations are happening only between the legislative body and industry businesses leaving behind the most key stake holder who bears the rough end of the deal every time - the operators , the owner drivers . All these added safety standards are good only if the additional time to secure load each time (has to be done for safety of the operator and road users undoubtably) are compensated as well . At the moment all owner drivers are forced to be a company so that when it comes to any responsibility regarding any breaches of law are conveniently passed on the the owner operators who in reality are employees who are knowingly or unknowingly forced to become companies so that they can work .

• Question 2 - Is there evidence of third parties, such as site managers, customers or loaders, performing audits on heavy vehicle operators that duplicate certification audits? Can third parties be assured (by an accreditor or certifier, within the HVNL, or some other means) that their audits are unnecessary?

  All heavy vehicle operators must be well aware of the risk their respective vechicle poses for the road users and to public / private property . The system has to be changed in such a way that the practise of making single vehicle operators as companies and exploiting them by passing on the added costs of public liability , work cover & marine transit which should be the responsibility of the transport company taking on the booking not the driver who is working to make ends meet . There should be set minimum remuneration mandated by legislation and reviewed every year in consultation with a companies and also subcontractors through consultation and consensus. Fair wages will reduce mental stress and anxiety of survival and all these safety measures will be easy to implement . Without fair remuneration, any added pressure will result in more mental stress to the subcontractor who will forced to spend his/ her time to implement the added controls at no gain and losing valuable time on road, thus pushing working hours to meet the minimum survival income to stay afloat . This will put a fatigued driver on the road who is risk to him/herself but also to others.

• Question 3 - Does the HVNL need an assurance scheme? Could the flexibility operators want be achieved simply through performance standards, or are some operators and operations sophisticated or specialised enough to need alternative compliance options? Does technology or vehicles or any other operational area need assurance under the HVNL?

  Technology can be used to audit the working hours to ensure compliance is achieved . There should be system where transport operator allow constant real time flow of data to an auditing authority who will be able to monitor the data pertaining to operating hours and other compliance document on random fleet members. The audit on load safety should be enforced by an independent authority concurrently with loaders, operators by performing random site visits and truck inspections on road.

• Question 4 - Which of the models do you prefer? What should they assure and why? Do you have an alternative model? Who should perform the key roles in an HVNL assurance scheme?

  Safety should be a priority for everyone . It should occur naturally than something that is being forced upon . The first step is to make sure all the stake holders are given enough time comply with regulation and clear instructions on achieving what is expected upon them . It should be a collective responsibility and an independent authority established by HVNL should be given powers to be the enforcer and auditor . It should perform audits on on the stake holders in the transport supply chain from the transport operators , loaders and to the heavy vehicle operators and also take strict actions in the case of breaches . The legislation should empower such a body with necessary tools to prescribe punitive action.

• Question 5 - Fully developing a new assurance scheme could take a long time, even if writing it into law is relatively simple. What can we use from what we have, and how can we transition to the desired end-state?

  Please have more consultations with the vehicle operators when the laws that are made have direct impact on their every day lives . Top down flow of legislative consultation means that only the interests of the top end of the supply chain is protected - the businesses . Even though business are necessary to sustain economic activity and employment creation, there has to be some consideration for the bottom end of the supply chain .