INTRODUCTION

Risk management is required to be more than a checklist of hazards that organisations need to avoid. It is as much about how the organisation’s responsibility becomes part of its strategic and operational planning and decision making and how it uses a risk management approach to minimise risk for its employees, itself and others.

To improve risk you can attempt to eliminate the hazard altogether or you can reduce its probability or severity.

By far the better outcome is risk elimination but unfortunately it is not always possible or practical to do so. So the next best thing is to reduce risk to a level where an event is unlikely to occur or the outcome of an incident will be less severe than it might otherwise have been.

A systematic risk reduction approach is multi-layered:

• The primary level is the risk assessment, analysis and evaluation;
• The second level is the control measures for risk mitigation – those systems and procedures that maintain and ensure that control is functional;
• The third level is the maintenance/compliance management control system;
• The fourth level is the emergency and contingency plans should there be a failure.

All this takes place within the framework of the organisation and more importantly its culture and its attitude with regard to its degree of risk acceptance.

LEGAL REQUIREMENTS AND RESPONIBILTY

Does the organisation understand its legal obligations?

ORGANISATION AND CULTURE

Does senior management accept that driving is one of the riskiest parts of their employees’ jobs and that this risk needs to be minimised?

Does the organisation’s culture support and emphasise the importance of a safe working environment?

This may not be as simple as it sounds. For example does the company adopt a hard line with employees who miss work due to illness? If so does this encourage employees to come to work while still ill and perhaps still under medication, feeling feverish, dizzy or suffering fatigue and therefore posing a safety risk?

Does the organisation have an integrated organisational structure that allows co-operation across departments with different responsibilities for work related risk and ensure there are links between an active management system and driving activities?

SYSTEMS

Do you have adequate systems to allow you to manage work-related risk and safety effectively? For example are you confident that your vehicles are regularly inspected and serviced in accordance with manufacturers’ recommendations?

OPERATIONS

Are all the operations for fleet activities clearly defined and understood? Are your transport needs clearly identified and vehicles tailored to meet those needs?

MONITORING

Is performance monitored and is sufficient information collected to allow informed decisions to be made about the effectiveness of existing policy and procedures and to identify any need for changes?

Does the system contain the facility to regularly check licenses and permits of those using company vehicles or driving on company business?

ANALYSIS

Is there regular analysis of data, leading to conclusions being drawn, requirements identified and corrective action initiated accordingly?

INTERVENTION

Are these conclusions and corrective actions implemented into operational activities via modified policy and procedures?

RISK ASSESSMENT

Risk assessments for any work-related driving activity should follow the same principles as risk assessments for any other work activity and they should be appropriate to the circumstances of your organisation.

Assessments should be carried out by competent people with a practical knowledge of activities being assessed. Look for risk/hazards that may result in harm when driving on public roads. Remember to ask your employees what they think, as you need not only the views of those who drive extensively, but also the views of those who only use the roads occasionally.

All findings should be recorded and conclusions drawn as to whether risks have been identified and addressed.

The object of your review is to identify hazards in your overall transport process. It is important to get input from all those involved in the task. Ask employees what they think as they will have first hand experience of what happens in practice.

Decide who might be harmed and consider whether there are any groups who may be particularly at risk, such as young or newly qualified drivers and those driving long distances.

Remember that if you authorise anyone to perform a transport task on your behalf (whether in a company or privately owned vehicle) you should assume that if there are any problems or negative outcomes it is your organisation that will most likely be held responsible.

Should the worst happen and a driver was involved in a serious or fatal incident, a Police investigation will be carried out.

The nature of any enquiry will depend on which authority is investigating. The police will focus on breaches of road traffic law, while WorkSafe will look at breaches of the OH&S and associated legislation.

Which specific areas are investigated will depend on the exact nature of the collision. Typically, the police will look at areas such as vehicle maintenance, fatigue management, speed and mobile phone usage, while WorkSafe will look at all aspects of your work-related road risk management program.

Both will look at how you managed the employee and whether any management failings contributed to the employee being involved in the collision. This will cover all operating practices and procedures, not just those related to driving.

The company will need to have robust and comprehensive policies and procedures in place, and a strong audit trail. The audit trail should be able to demonstrate not only that you have given your employees the relevant training and documentation, but also that they have understood it.

Evaluate the risk and decide whether or not you have a system in place that manages that risk adequately. This goes beyond mere identification of any risk, it also needs to include how the organisation will ensure full compliance with system requirements.

What you have to decide for each significant hazard is whether or not the organisation’s assessment has adequately addressed the risk and reasonable precautions to reduce and/or manage the risk have been taken.

All your risk assessment findings need to be recorded to demonstrate that a proper check was made, that you consulted those who might be affected and that you have dealt with all the obvious hazards.

The easiest way to remove risk is not to place the organisation in harms way in the first place. Therefore you should always ask whether there is a need to take on the risk or can the hazard be eliminated. For example, could you hold a telephone or videoconference instead of requiring people to travel to a meeting? If you cannot avoid the risk, you need to investigate how you can control it:

• Consider whether your vehicle allocation policy actively encourages employees to drive rather than using alternative means of transport, such as trams or trains;
• Ensure that company policy reinforces acceptable behaviour in observing the law such as driving within the legal speed limit;
• Avoid situations where employees feel under pressure. For example, avoid unrealistic delivery schedules and timings which encourage drivers to drive too fast for the conditions, or to exceed speed limits;
• Ensure that drivers and passengers are adequately protected in the event of an incident by ensuring vehicles are fit for purpose and that they make use of all available safety systems. (Eg Electronic Stability Control (ESC), Antilock Braking Systems (ABS), traction control, side curtain airbags, etc.);
• Organise maintenance work to reduce the risk of vehicle failure, by ensuring that maintenance schedules are in place and that vehicles are regularly checked by a competent person.

Activities such as monitoring data collection and analysis, system failure investigation, corrective action, change management and refresher training all need to be factored into the overall process.

To do this you need to have a system for gathering, recording and analysing information about such things as the task to be undertaken, applicable legal and statutory requirements, the driver, the vehicle, the journey and changing circumstances, such as the introduction of new routes, new equipment or a change in vehicle specification.

Review your assessment and revise it if necessary. You will need to monitor and review your assessment periodically to ensure that the risks remain suitably controlled.

These considerations are not exhaustive and you may be able to think of others but working through these will assist you in evaluating whether or not you are managing work risk effectively.

SYSTEMS REQUIREMENTS FOR OPERATIONS RISK REDUCTION

A system is required to accurately define a method by which the organisation:

• Has documented the risk/hazard review and its outcomes and ensures that all the obvious hazards have been dealt with and that your risk assessment is suitable and sufficient;
• Has recruitment procedures which specify the standard of skill, expertise and fitness levels required for a particular job;
• Can determine whether a prospective employee, current employee or any additional approved driver has the:
  • satisfactory skills;
  • licenses (do they require anything more than a standard licence);
  • driving record, confirmed by reference checks;
• Authorises people to drive company vehicles or drive on company business;
• Can confirm that licenses and permits remain current;
• Makes drivers aware of company policy and what is expected of them;
• Provides induction training for drivers;
• Identifies training needs as well as the need for remedial training, additional skills training or knowledge updates i.e. the use of upgraded vehicles;
• Compiles records reflecting the driver’s performance;
• Provides vehicles that are ‘fit for purpose’;
• Identifies both people and groups at risk within the organisation and those at risk outside the organisation (eg. employee’s families etc);
• Identifies and records, for each journey, the required transport task needs including any legal, licensing, signage, height and route or driver health check requirements;
• Establishes and maintains relevant Key Performance Indicators (KPI’s);
• Assures itself that its risk assessment remains current and relevant by reviewing KPI selection to ensure relevance to changing circumstances, new equipment and changing legislation;
• Ensures that company policy clearly outlines unacceptable behaviour;
• Monitors and analyses information on safety incidents and systems and procedures are modified as required;

• Actively manages the process and ensures that standards are met and assures itself that performance remains adequate.

Further, in the event of an incident there needs to be a system and procedures in place to be able to provide:

• An emergency response to the incident;
• A support response where an employee or approved driver is injured;
• Procedures to ensure the continuity of the business;
• Monitoring and analysis of safety incidents; and

• A review of systems and procedures, modifying them where appropriate.

When determining policy and procedures it might be helpful to categorise drivers as:

• Professional drivers who are employees whose regular daily assignments include driving on company business regardless of whether it is a company owned, rented, leased or Novated vehicle.

• Occasional drivers who are employees who have a company vehicle as part of their employment entitlement or drive a company vehicle or personal vehicle for business on an occasional basis or any other authorised drivers such as an employee’s spouse or family.

PREVENTABLE INCIDENTS

All incidents or near misses should be investigated, analysed and conclusions drawn and corrective action taken. Incidents should be defined as either Preventable or Non-Preventable. An incident will be considered preventable:

• If it involves a company vehicle and results in property damage and/or personal injury, in which the driver in question has failed to exercise every reasonable precaution;
• Where lack of proper care and maintenance of the vehicle is the cause;
• Where damage to the interior of the vehicle is caused by improperly locked doors, cigarette burns, or by any element resulting from a lack of care by the operator;
• Where, excepting for extenuating circumstances, the driver fails to:
  • Observe traffic laws;
  • Observe company operating rules or special instructions;
  • Adjust speed to conditions of light, weather, road or traffic;
  • Adjust to clearance at top, sides, front, or rear of vehicle;
  • Follow defensive driving practices;
  • Yield or give way when necessary to avoid an incident;
  • Observe conditions behind the vehicle while reversing;
  • Control speed so as to be able to stop within an assured clear distance ahead;
  • Report and correct obvious vehicle deficiencies, for example, faulty brake signal lights.

NON-PREVENTABLE INCIDENTS

Those incidents occurring under the following conditions will usually be considered as being “non-preventable” where the company driver exercised every reasonable precaution to prevent the incident or when the vehicle is:

• Hit in the rear;
• Hit while properly parked.

SYSTEM REVIEWS

The system must also include the provision to periodically monitor and review your assessment and revise it if necessary to ensure that the previously identified risks, as well as any new risks, are being suitably controlled.

The system should also monitor whether or not the Key Performance Indicators (KPI’s) being used is still relevant and a true reflection of what should be monitored.

SAFETY REVIEW COMMITTEE

There should be a safety review committee to review all company vehicle incidents.  Its purpose is to determine if an incident was preventable and whether or not appropriate action was taken. While this can vary from organisation to organisation the overriding criteria is that the response is adequate from a safety standpoint.  It must be clearly demonstrated that an analysis was made and, in all cases, corrective action specified and taken.

No one should be exempt and it is unacceptable to excuse, mitigate or accept any exceptions based on commercial criteria such as the person being the best sales employee or a senior manager.

The system applies to all employees whose regular or principal duties involve driving a company owned vehicle or who lease, rent, or use their own vehicles on company business regardless of how infrequent that use might be.