The National Heavy Vehicle Regulator (NHVR) has released its new Master Code of Practice, providing practical guidance for businesses on how to meet their Chain of Responsibility (CoR) obligations under the Heavy Vehicle National Law (HVNL).
One of the key messages from the Master Code is that CoR is no longer simply about complying with rules relating to fatigue, maintenance, loading and speed. Instead, the focus is on managing safety risks associated with transport activities through a structured safety management approach.
To help businesses get started, the Master Code outlines 45 transport activities that may create or influence safety risks. The first 10 are described as Foundation Activities and are intended to apply to every party in the Chain of Responsibility, regardless of their size, role or position in the supply chain.
The NHVR says these activities should be viewed as a starting point for understanding how safety is managed within an organisation. Businesses may perform additional transport activities that are not listed in the Master Code, but the foundation activities provide a framework for developing a mature safety management system.
1. Developing Organisational Safety Capability
The first foundation activity focuses on creating a strong safety culture throughout the organisation.
This includes demonstrating leadership commitment to safety, encouraging employees to report hazards and incidents, training workers to identify risks, investigating issues promptly, and creating open communication channels between frontline workers, managers and executives. The Master Code also highlights the importance of managing psychosocial hazards, promoting mental wellbeing and engaging with business partners on safety matters.
2. Ensuring Executives Understand the Business
Executives have a specific due diligence obligation under the HVNL.
The Master Code recommends ensuring executives understand their responsibilities, receive training in risk management, and maintain detailed knowledge of how the business operates, including its relationships with contractors, suppliers and customers. Executives are also encouraged to participate in training activities to better understand operational realities.
3. Establishing Policies and Procedures
Policies and procedures provide the framework for consistent decision-making and safe operations.
The Master Code recommends every business develop a Chain of Responsibility policy and supporting procedures that clearly explain how transport activities should be performed and how safety risks will be managed.
4. Recruiting and Employing the Right People
The Code recognises that safety begins before a person starts work.
Businesses are encouraged to recruit for safety attitudes and behaviours, not just technical skills. Referee checks should explore an applicant’s commitment to safety and verify their previous work performance through supervisors or colleagues who have directly worked with them.
5. Training Employees
Training is one of the largest foundation activities in the Master Code.
It covers induction programs, recurrent training, competency assessments, supervision of inexperienced workers, ongoing professional development, maintaining training records and ensuring qualifications remain current. The Code also emphasises training workers on fatigue risks, safety responsibilities and how their actions can affect heavy vehicle safety outcomes.
6. Managing Fitness for Work
The Master Code places significant emphasis on ensuring employees are fit to perform their duties safely.
Recommended controls include fitness-for-work programs, mental health support, drug and alcohol testing for safety-critical roles, medical clearances following incidents and empowering workers to speak up when they are unfit for work. For drivers, this includes the authority to stop driving if they become unfit to continue safely.
7. Working with Other Businesses
The Master Code recognises that heavy vehicle safety is rarely controlled by a single organisation.
Businesses are encouraged to assess the safety performance of contractors and suppliers, work collaboratively to identify risks, agree on responsibilities, and select business partners based on safety performance rather than price alone. Collaboration and communication are recurring themes throughout the Code.
8. Monitoring and Assurance
Having controls in place is only part of the process.
The Master Code recommends businesses establish assurance activities to confirm that controls are working as intended. This may include audits, reviews, performance measures and monitoring systems that provide confidence that safety risks are being effectively managed.
9. Sharing Information
The ability to exchange information quickly and accurately is considered essential to safe transport operations.
The Code recommends identifying what information is required by each party, creating systems for sharing it, providing time-critical information promptly and ensuring key information can be accessed for monitoring and review. Real-time information sharing across multiple parties is strongly encouraged.
10. Making Better Agreements
The final foundation activity focuses on contracts and commercial arrangements.
The Master Code recommends that agreements support safe operations by providing realistic timeframes, appropriate payment levels, clear responsibilities, information-sharing obligations and rights to verify safety performance. Contracts should also be reviewed regularly to ensure they remain suitable as operating conditions change.
A Different Way of Thinking About CoR
The Master Code encourages businesses to move away from viewing Chain of Responsibility as a compliance exercise and instead treat it as a risk management framework.
The NHVR’s guidance explains that businesses should first identify their transport activities, then consider the hazards and risks associated with those activities before implementing appropriate controls. Importantly, the regulator notes that the first 10 foundation activities are relevant to every CoR party and should form the basis of a broader safety management approach.
For many organisations, the foundation activities provide a useful checklist to assess whether existing systems, processes and behaviours are helping to eliminate or minimise risks so far as is reasonably practicable.
Businesses wanting to better understand their obligations, access the Master Code, or explore the supporting risk assessment tools should visit the NHVR website. The regulator has developed practical guidance, templates and resources to help organisations identify hazards, assess risks and implement effective controls across their transport activities.
