Fleet Managers and executives have been urged to rethink their approach to Chain of Responsibility (CoR), with the National Heavy Vehicle Regulator (NHVR) warning that compliance with speed, fatigue, mass and loading rules alone is no longer enough to demonstrate safety.
Speaking at the AfMA Summit, Graeme Cooper, Policy Advisor (Safety Duties and Codes) at the NHVR, said the upcoming Master Code, which takes effect on 1 August 2026, reinforces a broader interpretation of CoR that focuses on how organisations manage risk across their entire operation.
“CoR is about the planning and preparation that the business does in advance of the activity commencing,” Cooper told delegates.
The message from the regulator is clear: safety starts long before a driver turns the key.
CoR Is About Public Risk
Cooper reminded delegates that the primary duty under the Heavy Vehicle National Law requires every party in the Chain of Responsibility to ensure, so far as reasonably practicable, the safety of transport activities involving heavy vehicles.
That duty extends beyond traditional compliance areas and requires businesses to eliminate or minimise public risk.
According to Cooper, safety under the law includes protecting drivers and passengers, other road users, infrastructure, the environment and the broader community.
“The law is deliberately broad in scope and creates an obligation for you to focus upon safety in respect of all the many and varied ways that your business can influence how it interacts with heavy vehicles,” he said.
This broader interpretation challenges the long-held belief that CoR is primarily about avoiding speeding infringements, fatigue breaches or overloading offences.
A New Approach to Safety
Cooper argued that many organisations still view CoR through an operational lens, focusing on what happens when a vehicle is on the road.
The NHVR wants businesses to instead focus on the systems and decisions that occur before transport activities begin.
“If I’m not getting tickets or I’m not getting defects, then I must be operating safely,” Cooper said, describing a common industry mindset.
“That’s a very, very narrow view of what safety amounts to.”
He outlined four key areas that organisations should consider:
- Driver selection, training and competency
- Vehicle selection and specification
- Technology and data management
- Organisational safety systems and culture
For Fleet Managers, vehicle procurement decisions are a critical part of meeting CoR obligations.
“How do you know that you’ve got the right vehicle that’s fit for purpose, has the right equipment, the right safety features, is properly maintained and then is managed in the context of your broader fleet?” Cooper asked.
“That’s a fundamental component of ensuring safety within the heavy vehicle industry.”
The Data Responsibility
One of the strongest messages from the presentation centred on telematics and emerging fleet technologies.
While many fleets are investing heavily in connected vehicle technologies, Cooper warned that collecting data creates additional responsibilities.
“The expectation on you from the perspective of your primary duty is that you are engaging with that data and information, you are accessing it, you are interrogating it, and you are responding to it,” he said.
“It doesn’t just generate reports that nobody sees.”
The NHVR’s position is that organisations must actively use information generated by telematics, fatigue monitoring systems and other safety technologies to identify and manage risk.
Installing technology alone is not enough.
“The decision to install the hardware into the vehicle is excellent,” Cooper said when discussing fatigue detection systems.
“But if it’s two o’clock in the morning, your business has to be equipped to receive that alert and respond to it.”
The New Master Code
The 2026 Master Code was registered by the NHVR in January and becomes operational from 1 August 2026.
Developed as a practical guide to support businesses in meeting their primary duty obligations, the code contains guidance across 45 transport activities, more than 70 hazards and over 500 recommended controls.
Importantly, Cooper stressed that the code is not a mandatory checklist.
Instead, it serves as a practical resource that courts may use as evidence of what a reasonable party in the Chain of Responsibility should have known about hazards, risks and available controls.
“A party can’t say I didn’t know about that risk, I couldn’t know about that control, if it’s published in the code of practice,” Cooper explained.
The regulator expects businesses to review the guidance and adapt controls to suit their specific operations.
“There isn’t a single business in Australia to which the whole code would apply,” he said.
Leveraging Existing WHS Systems
Perhaps the most practical advice for Fleet Managers was Cooper’s recommendation to use existing Work Health and Safety (WHS) systems rather than creating separate CoR processes.
“There is absolutely no upside in reinventing the wheel,” he said.
“All of you who are operating businesses that have mature and well-established WHS management processes should absolutely leverage those processes to do your safety work in respect of being a party in the Chain of Responsibility.”
According to Cooper, the principles are largely identical: identify risks, assess risks, eliminate or minimise them so far as reasonably practicable, and continually improve.
For organisations already operating mature safety management systems, the new Master Code provides an opportunity to integrate heavy vehicle safety risks into existing governance frameworks rather than creating standalone compliance programs.
A Wake-Up Call for Executives
The NHVR’s message is particularly relevant for senior leaders.
The Heavy Vehicle National Law includes executive due diligence obligations, meaning directors and executives can be held personally accountable for ensuring their organisations effectively manage heavy vehicle safety risks.
As the Master Code comes into effect on 1 August 2026, Cooper’s presentation highlighted a significant shift in regulatory thinking.
The focus is no longer simply on compliance outcomes. It is on whether organisations have effective systems, processes and leadership in place to identify and manage risk before incidents occur.
For Fleet Managers and executives, the new Master Code may be less about learning new rules and more about recognising that Chain of Responsibility is fundamentally a safety management obligation, not a compliance exercise.
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