CCAA has offered insights on the draft Heavy Vehicle National Law instruments, emphasising the need for practical and effective accreditation to guarantee the safe and efficient transport of construction materials.
Key Concerns
- Accreditation misuse: Accreditation must not become an enforcement tool.
- Subcontractor obligations: Proposed rules exceed Chain of Responsibility principles and are impractical in multi-operator supply chains.
- Auditing burden: Prescriptive 6–7 month audits create costs; a risk-based, scalable model is preferred.
- Fitness to drive: Obligations must align with Austroads AFTD standards and focus on observable indicators.
- Fatigue risk: Draft settings fail to reflect early-start industry realities.
Additional Considerations
- Productivity reforms remain modest; broader changes are needed.
- Competitive distortions may arise between accredited and non-accredited operators.
- Enforcement imbalance risks undermining confidence.
- PBS streamlining is positive but needs faster pathways.
- CLOCS-A alignment is critical to reduce duplication.
- Steep penalty increases may discourage driver participation.
Read complete submission here.