NATIONAL GUIDE

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Vehicles as a Workplace: Work Health and Safety Guide
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Published September 2022

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Contents

1. Introduction ......................................................................................................................... 1
1.1 Who has a duty? .......................................................................................................... 1
1.2 What vehicles does my organisation have WHS responsibility for? ........................... 2
2. Purpose and scope ............................................................................................................. 4
2.1 Purpose of this guide ................................................................................................... 4
2.2 Relationship between road traffic safety and work health and safety ........................ 5
2.3 WHS law ...................................................................................................................... 6
2.4 Road traffic law ............................................................................................................ 7
2.5 Vehicle as a workplace ................................................................................................ 7
3. Principles............................................................................................................................. 9
3.1 Compliance with road traffic law................................................................................ 10
3.2 Managing road traffic risks ........................................................................................ 10
3.3 Hierarchy of control applied to road traffic ................................................................ 12
3.4 Establishing a robust system supported by a culture of safety................................. 13
4. Process ............................................................................................................................. 16
4.1 Step 1: List the extent and type of exposure ............................................................. 17
4.2 Step 2: Identify opportunities to eliminate or substitute safer travel ......................... 18
4.3 Step 3: Determine remaining exposure to road traffic hazards ................................ 19
4.4 Step 4: Identify the particular hazards associated with each vehicle group ............. 19
4.5 Step 5: Develop controls ........................................................................................... 19
4.6 Step 6: Document and implement policies and procedures ..................................... 20
4.7 Step 7: Conduct periodic reviews .............................................................................. 20
4.8 Guidance for small business ..................................................................................... 21
5. Road traffic safety hazards ............................................................................................... 23
5.1 Inadequate journey planning ..................................................................................... 24
5.2 Roads providing inadequate protection..................................................................... 25
5.3 Vehicles providing inadequate protection ................................................................. 26
5.4 Speed in excess of safe exposure thresholds .......................................................... 28
5.5 Unauthorised drivers.................................................................................................. 30
5.6 Unsafe drivers ............................................................................................................ 31
5.7 Non-use or misuse of personal protective equipment .............................................. 36
5.8 Inadequate post-crash responses ............................................................................. 38
Glossary ................................................................................................................................... 40
Resources ................................................................................................................................ 42
Attachments...................................................................................................... 45
Tables
Table 1 WHS Duties and RTS Considerations....................................................................... 9
Table 2 The hierarchy of control applied to RTS .................................................................. 13
Table 3 Safe speeds for different road environments ........................................................... 29
Table 4 Checklist 1 - Assessing the nature and extent of exposure ..................................... 45
Table 5 Checklist 2 - Issues to consider for each vehicle group ........................................... 46
Table 6 Checklist 3 - Road traffic safety controls to consider ............................................... 48

Figures
Figure 1 The hierarchy of risk control.................................................................................... 12
Figure 2 Risk Management Process ..................................................................................... 16
Figure 3 Motorised land transport risk................................................................................... 18
Figure 4 Small business risk management process .............................................................. 21
1. Introduction
Vehicle use is the most significant contributor to work-related traumatic injury.

This guide is for firms, organisations and individuals who use vehicles for work purposes on the
road networks of Australia or New Zealand.

The guide describes a process for dealing with road traffic hazards in line with work health and
safety (WHS) legislation and road traffic safety (RTS) principles. It covers all vehicle use in road
traffic and complements other legislative requirements that apply to businesses whose primary
purpose is transport, such as bus, truck or taxi operators.

1.1 Who has a duty?

WHS laws in Australia are generally harmonised and similar principles apply in New Zealand.
While there is some variation between jurisdictions, generally, a person conducting a business or
undertaking (PCBU) must ensure the health and safety of workers and other persons while
workers are at work. In this context, it means PCBUs must do all that is reasonably practicable to
manage the risks associated with the use of vehicles, both on public roads and on private
property.

A PCBU can be an individual (e.g. sole business owner/operator) as well as a corporate

entity. Duty holders under WHS law have different roles in ensuring that they and their
organisation meet their obligations. Duty holders also include those supplying and servicing
vehicles as well as those designing,manufacturing and importing vehicles and other
equipment.

• A PCBU must manage road traffic safety risks if their workers are engaged in travel on the
road, regardless of who owns or operates the vehicle used. This primary duty requires them to
eliminate risks to health and safety or, if that is not reasonably practicable, to minimise risks
so far as is reasonably practicable.
• Officers, such as company directors, must exercise due diligence to ensure that the
organisation is complying with WHS laws to ensure that the business or undertaking is using
appropriate resources and processes to eliminate or minimise road traffic safety risks.
• Workers must ensure that they take reasonable care for their own and others’ health and
safety, and also co-operate with any reasonable policies, procedures and instructions.

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These duties apply:

• to vehicles on the road, no matter how far from the premises they travel
• whether the vehicle is owned by the firm or organisation, or a worker, or a third party
• to the requirements under road traffic or transport regulations.

Safety on the road depends not just on individual behaviour but more importantly on the higher
order actions and controls put in place to ensure that risk is eliminated or minimised so far as is
reasonably practicable. Performing your health and safety duties requires you to take a
systematic risk management approach to safety. This involves:

• identifying the hazards (sources of risk) in your road traffic operations

• where necessary, assessing the risks (considering the likelihood that an incident will happen
and the consequences)
• controlling the risks (making sure the right procurement, training, maintenance, safety
guidelines and other measures are in place to reduce the risks)
• reviewing the controls (regularly checking to make sure your controls are still relevant,
effective and up to date).

Organisations are required to consult with their workers and others affected by the business or
undertaking when identifying hazards and risks and deciding on measures to control those risks.

1.2 What vehicles does my organisation have WHS

responsibility for?
The responsibility to provide and manage safe workplaces whenever workers use vehicles
can include :

• Vehicles owned, leased or hired by the organisation as work vehicles

• Vehicles owned, leased or hired by the organisation for private use but which are used in the
course of work (for example vehicles included in salary packaging arrangements)
• Vehicles operated by other organisations, which their workers use, either as drivers or
passengers
• Vehicles owned or leased by workers that are used in the course of their work, either regularly
or from time to time (referred to as “grey fleet” vehicles), and
• Public transport vehicles, including trains, buses, taxis and ride share vehicles.

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While many organisations have comprehensive policies and procedures to manage the
acquisition, operation and use of their own vehicles. Sometimes, less attention is given to
vehicles that may be used, especially grey fleet.

WHS legislation does not distinguish between vehicles which an organisation directly owns or
leases, including other vehicles. The degree of responsibility and what is reasonably practicable
will depend on the extent of control or influence the duty holder has to eliminate or minimise the
risk.

However, outsourcing vehicle operations to contractors or to employees themselves does not

remove the obligation to provide a safe workplace, which retains options for how a safe
workplace is achieved. The question of what WHS duties apply will always be determined on the
facts and circumstances of each case, rather than contractual terms.

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2. Purpose and scope
This guide promotes safe systems of work for road-based travel. It does not prescribe specific
safety actions or provide an exhaustive list of risk controls to achieve a safe system ofwork. It
provides a framework and supporting advice for organisations to consider and manage road
traffic safety risks within their work environment.

The guide does not attempt to provide a complete reference to all the potential hazards, risks
and controls that relate to vehicle use which are unique to each organisation. However, use of
this framework should allow organisations to develop the policies and procedures they need to
ensure they meet their obligations to provide a safe workplace.

2.1 Purpose of this guide

Vehicle use is the most significant contributor to work-related fatalities in Australia. Safe Work
Australia's Key WHS statistics Australia 2020 reports there were 79 fatalities from vehicle
collisions in 2019, accounting for 43 per cent of all fatalities. This document also reports that
there were 2,660 serious claims by from vehicle collisions in 2018–19.

In 2016, there were 98 work-related fatalities recorded by Safe Work Australia involving a vehicle
on a public road. However, this significantly under-states the true situation. Road traffic safety
agencies recorded 213 people killed in crashes involving heavy vehicles during 2016. Most of
these crashes would have been work-related. Work-related crashes involving light vehicles
would have added to this total. The trends are very similar in New Zealand.1

WHS law includes a general duty of care, and this applies in road traffic when a vehicle is used
for work-related purposes. Specific guidance is available to responsible persons addressing a
wide range of WHS issues. This Guide aims to address gaps about exposure to, management
of and road traffic injury.

1 The data is very similar for New Zealand. For example, WorkSafe NZ data indicates that for the four years (2009-12) there
were on average 60 fatalities per annum notified under the HSE Act 1992, excluding maritime or aviation sectors or
fatalities due to work related crashes on the road. During those four years, an average of 61 fatalities involving trucks,
buses and taxis were reported in road crash statistics. A study of over 10,000 coronial files published in 2003 by the Injury
Prevention Research Unit of the University of Otago identified that there were 1688 work related fatal traffic injuries
between 1985-98, to either a person engaged in work-related activity on a public road (not commuting), or a person who
died in the process of another person’s work activity on a public road. On average over this 14 year period, the study
indicates that there were approximately 120 work related injury fatalities on the road, compared with 75 other work related
injury fatalities.

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The impact of harm in the road traffic system on the community and workplaces is large, and the
impact on businesses in terms of productivity and business continuity is significant. Even the
temporary absence of a worker could have a substantial impact on the viability of smaller and
growing business. The socio-economic cost of road trauma is estimated at $27 billion per
annum in Australia, and $3.79 billion per annum in New Zealand.

Organisations in different industry sectors and operating different types of fleets will identify
different risks that need to be managed and will adopt different implementation processes
depending on the size and maturity of their WHS systems.

For large organisations with well-established and comprehensive WHS procedures and systems,
this document provides guidance in how to ensure that road traffic safety management forms an
integral part of these existing systems. For smaller organisations, with a need for simpler
processes that are fit for purpose, the guidance highlights risks and controls for consideration.

The broad principles for implementation are the same are governed by WHSlegislation. These
principles are described in detail in other guidance documents and codes ofpractice and some
of these resources are listed at the end of this Guide.

2.2 Relationship between road traffic safety and work health

and safety
This guide brings together established WHS management principles and relatively new RTS
management principles.

The modern “Safe System” approach to RTS, which is widely accepted and is government policy
throughout Australia and New Zealand, continues to recognise the obligation of road users to
comply with the design features of the road traffic system.

This evolution of thinking in road safety has moved from blaming the individual and accepting
that a certain level of road trauma is inevitable to a systems approach. This is underpinned by
the position that fatalities and serious injuries are not an acceptable in the road traffic system.

This has brought road traffic management much closer to the safety approaches that have been
adopted in the workplace for many decades. Well-managed organisations have moved beyond
considering who did the wrong thing to identifying what went wrong in their processes and how
this can be prevented from happening again.

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This guide describes a hierarchy of controls and a broad range of potential controls that require
a systematic response from management, rather than one that puts the responsibility for safety
solely on the driver.

The use of vehicles in road traffic represents one of the most critical workplace risks that
organisations must manage. Better workplace safety systems and practices can make a
significant contribution toreducing road trauma.

2.3 WHS law

WHS laws in the Commonwealth, Queensland, New South Wales, the Australian Capital
Territory (ACT), Tasmania, South Australia and the Northern Territory (model law jurisdictions)
are based on the Model Work Health and Safety Act, with minor variances between jurisdictions.
Victoria, Western Australia, and New Zealand each have similar health and safety laws.

Under legislation in model law jurisdictions, a PCBU has a primary duty of care and must, so far
as is reasonably practicable, ensure workers and others are not exposed to a risk to their health
and safety. This duty of care is owed when:

• directing or influencing work carried out by a worker

• engaging or causing to engage a worker to carry out work (including through sub-contracting)
• having management or control of a workplace.

A worker can be:

• an employee
• a contractor or subcontractor
• an employee of a contractor or subcontractor, or a labour hire company
• an outworker
• an apprentice or trainee
• a student gaining work experience
• a volunteer.

This guide has been prepared to assist compliance with the WHS laws in model law jurisdictions.
Requirements in jurisdictions that have not implemented the model WHS laws will vary, and
organisations should ensure that they comply with the provisions of the jurisdiction in which they
are operating. However, the principles of good safety management described in this Guide are
consistent with other requirements and should assist organisations to improve safety and comply
with the law wherever they are operating.

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2.4 Road traffic law
All jurisdictions in Australasia have enacted legislation to regulate how people and vehicles can
access and use the road network. Legislation also defines the role and powers of the various
regulatory agencies, such as licensing authorities and the police.

Operators of heavy vehicles in most Australian jurisdictions (Queensland, New South Wales, the
ACT, Victoria, Tasmania and South Australia) must comply with the Heavy Vehicle National Law
(HVNL), which puts additional obligations on the drivers, operators and others involved in the
road transport industry. These obligations closely align with the obligations defined by WHS law,
so that both bodies of law will include a primary duty for road traffic safety risks to be eliminated
or minimised so far as reasonably practicable. New Zealand and Western Australia have their
own legislation covering heavy vehicle operations.

The HVNL recognises the relationship with WHS law. If a provision of the HVNL and a provision
of the primary WHS law deal with the same thing, and it is possible to comply with both
provisions, a person must comply with both provisions. However, to the extent it is not possible
for the person to comply with both provisions, the person must comply with the provision of the
primary WHS Law.

Organisations need to consider a broad range of RTS issues relevant for all vehicles and
jurisdictions whether or not they are covered by HVNL or other legislation. Those organisations
involved in the road transport industry may wish to develop, implement and operate a single
safety management system that will allow them to meet fully their obligations under both WHS
law and HVNL.

The National Heavy Vehicle Regulator (NHVR) provides guidance to the road transport industry
to help organisations achieve compliance with HVNL and enforces compliance. This guide helps
organisations to establish a safety management system that will support compliance with both
bodies of law. It should be used in conjunction with guidance provided by the NHVR and the
regulators in jurisdictions not covered by HVNL.

2.5 Vehicle as a workplace

As a workplace, there will be numerous other requirements that apply equally in the vehicle as at
the workplace or other locations. Ergonomics, particularly seating, getting in and out of the
vehicle, comfort and position, provision of first aid, and environmental comfort should be
considered as well as issuesarising from working remotely from the organisation.

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Vehicles in the workplace are also considered to be an item of plant under WHS law and WHS
responsibilities will extend to situations where vehicles are not subject to road traffic law, such as
vehicles operated in a variety of industries, such as retail, manufacturing, agriculture, transport,
mine sites, or otherwise off-road.

These issues are beyond the scope of this guidance document and the reader should refer to
other more specific guidance from their WHS regulator.

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3. Principles
Primary duty holders must as reasonably practicable ensure the health and safety of workers
they engage or caused to be engaged by the person, including workers whose activities in
carrying out work are influenced or directed by the person while the workers are at work in the
business or undertaking.

The primary duty holder must also ensure so far as is reasonably practicable, that the health and
safety of other persons is not put at risk from work carried out as part of the conduct of the
business or undertaking.

‘Reasonably practicable’ represents what can reasonably be done in the circumstances. In

relation to the duty to ensure health and safety, it means that which is, or was at a particular time,
reasonably able to be done in relation to ensuring health and safety

To decide what is (or what was at a particular time) reasonably practicable in managing risk,
duty holders are required to weigh up all relevant matters. This includes five factors set out in
Table 1 along with considerations relevant to road traffic safety.

Table 1 WHS Duties and RTS Considerations

In relation to road traffic, duty holders should

Duty holders must consider
recognise
The likelihood of the hazard or risk The likelihood of exposure to the hazard is extremely
occurring high

The degree of harm arising from the hazard The degree of harm that can arise is extremely high

Knowledge (or what would be reasonable to

The hazards and risks commonly experienced in
know) about the hazard, and ways to
road traffic are well known
eliminate or minimise the risk

Availability and suitability of ways to There are numerous, proven controls to minimise
eliminate or minimise the risk risks

Whether the cost of controls is grossly

Analyses have shown that the benefits of these
disproportionate to the risk (only after taking
controls can far exceed the costs
account of the above four matters)

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3.1 Compliance with road traffic law
Compliance with road traffic law are not necessarily sufficient to ensure that WHS obligations are
met.

Road traffic law seeks to achieve a certain level of safety for road users,by requiring certain
vehicle standards or by prescribing driving behaviour, through road rules for example.

Whilst compliance with these will result in a certain level of safety, these requirements may not
ensure that vehicle operation is safe so far as is reasonably practicable, as is required in WHS
legislation.

For example, all registered motor vehicles are required to meet minimum safety standards.
These are set by government, which means that all vehicles meet these standards before they
can enter the road traffic system and be used on the road. Vehicle operators and drivers have an
obligation to ensure that they continue to comply throughout their service life and authorities
require checks of roadworthiness at various times.

However, the safety protection offered by different vehicles can vary considerably. The fatality
risk for the least safe vehicles, which just meet mandated standards, can be as much as double
the fatality risk of the safest vehicles. Programs such as the Australasian New Car Assessment
Program provide ratings information to vehicle purchasers to allow them to make an informed
choice.

To meet WHS requirements, an organisation should consider specifying vehicles with the best
safety rating that meet their business needs. Many organisations are now choosing to go
beyond compliance and specifying that only 5-star vehicles can be used.

This principle applies equally across all other aspects of traffic law. For example, some
organisations now specify maximum operating speeds for their vehicles that are lower than
regulated speed limits.

3.2 Managing road traffic risks

Road traffic risk management should be undertaken through a process to:

• identify hazards
• assess risks
• implement measures to control risks
• review control measures.

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Safe Work Australia publishes a range of useful guidance on managing risk including the How to
Manage Work Health and Safety Risks Code of Practice. Extensive guidance is also published
by Worksafe New Zealand, such as Identifying, Assessing and Managing Work Risks.

In many cases the nature of road traffic safety risks and relevant controls are well understood. In
these cases, a decision to impose a control does not depend on a formal risk assessment.

However, organisations are required to use the hierarchy of risk controls, giving the highest
level of protection through to the least reliable, providing the lowest level of protection. This is
summarised in Figure 1.

Level 1 controls aim to eliminate the hazard. This is the most effective solution but is not always
practicablein the case of the road traffic system, in which many of the hazards are outside the
direct control of the organisation. Considering that the use of vehicles for work purposes is
necessary (as opposed to being incidental to work).

If it is not reasonably practicable to eliminate the hazard and associated risks, Level 2 controls
introduce measures in the system to minimise risks which do not rely on individual behaviour.

Level 3 controls rely on human behaviour and supervision and are therefore the least reliable
and effective. But an effective risk management process looks at all levels to minimise risks so
far as is reasonably practicable.

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Figure 1 The hierarchy of risk control

Source: Safe Work Australia (2011), How to Manage Work Health and Safety Risks Code of Practice.

3.3 Hierarchy of control applied to road traffic

Road traffic is a hazard and is the cause of many deaths and serious injuries in the community. It
is the cause of many work-related deaths and serious injuries, either to an organisation’s own
workers, their customers, or other road users who encounter work vehicles in the road traffic
system.

Organisations should consider their exposure to road traffic system hazards and apply the
hierarchy of control to eliminate, substitute or isolate this hazard or to take action to minimise the
associated risk. Primary RTS mechanisms for this are set out in Table 2.

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Table 2 The hierarchy of control applied to RTS

Level of
Control Primary RTS Mechanisms
control
Level 1 Eliminate the hazard Eliminate exposure to road traffic, and consider
alternatives to travel

Level 2 Substitute the hazard Avoid the use of motorcycles, and consider safer modes
with something safer of transport such as buses, trains, and aeroplanes

Isolate the hazard Ensure non-road activities are adequately separated

from people from road traffic

Reduce the risks Specify vehicles, equipment and technology to reduce

through engineering the risk of crashes, and of harm arising from those
controls crashes that occur

Level 3 Reduce exposure to Introduce policies, provide training and supervision, and
the hazard by using develop procedures to control access to and use of
administrative actions vehicles and increase compliance with safety policies

Use personal Ensure safety equipment is used and consider additional

protective equipment equipment for specific risks

3.4 Establishing a robust system supported by a culture of

safety
Good practice in change management and sustainable improvement can be achieved through
effective leadership, consultation and co-ordination, and planning and performance
management.

Leadership

The leadership of organisations and establishing safety culture are critical to for an effective
safety management system.

Leadership needs a strong policy statement that is shared with everyone in the organisation,
supported by the behaviours of its leaders to show a visible commitment to safety culture. Road
traffic safety policies apply to everyone equally, from the executive using their packaged vehicle
to a meeting or the use of pool vehicles.

Organisational culture is very difficult to change and the behaviours of leaders often prevent
change. Developing an open culture to ensure that workers’ feedback is used to improve the
system is vital.

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Leadership is key to a safe system of work with everyone inside the organisation, and with whom
the organisation interacts. Leadership needs to ensure that all understand and accept the role
that they have in contributing to the establishment and operation of an effective safety
management system and making it clear why staff need to support the safety culture.

Buy-in at all levels of the organisation is critical and the use of documentation to record signed
commitment to the policy should be considered, particularly when the implementation represents
a new and plan for safety.

Consultation and co-ordination

Consulting with workers is an obligation under WHS laws and is a key component of an effective
road traffic safety management system. When conducting the risk management process you
should gather information from those who are in the best position to identify risks and the
feasibility of controls. The purpose of consultation is to ensure everybody has a shared
understanding of the risks, who will be affected and how the risks will be controlled. The
exchange of information helps each person to meet their duty and minimise gaps in WHS
management.

A variety of workers within and outside of an organisation will have a role in the management of
safety. Co-ordination across this is important. For heavy vehicles operations covered by Heavy
Vehicle Law, these are set out in the Chain of Responsibility obligations and reference should be
made to the guidance provided by NHVR.

WHS laws also require a duty to consult, cooperate and coordinate with other duty holders
(including other organisations in their supply chain) on WHS matters affected by their business or
undertaking. Consultation should be broad enough to encompass likely situations, including the
use of the grey fleet and other third-party vehicles. The duty to consult does not require
agreement. However, without agreement, negotiation will be necessary to ensure that no gaps
remain.

Each duty holder retains responsibility for meeting their health and safety duties. In many large
organisations, responsibilities for the management of safety policies and procedures are often
quite separate from those for fleet acquisition and management. These arecommonly split
between human resources, and finance or purchasing functions. In an effective road traffic
safety management system, should include co-ordination, and/or integration, of these activities
ensure that organisational objectives are aligned.

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Planning and performance management

Managing road traffic safety should include a set of performance factors that relate to the
different elements to be managed and allow for measurable evaluation of performance.

While measures such as number of crashes and their injury outcomes, lost time etc areimportant
to assess progress and the need for improvement. Intermediate outcome and output measures
are more useful to quickly identify trends and opportunities to adjust the program. These
measures should be identified and agreed during the implementation to ensure that they match
the specific risks and controls identified at that time.

Organisations should consider their obligations under WHS law relating to notifiable incidents
and the process for notifying relevant agencies, in addition to any obligation to report road
crashes to the police.

A notifiable road traffic incident is one resulting in:

• death
• immediate treatment in hospital as an in-patient, or
• immediate treatment for a serious injury (for example amputation, scalping, spinal injury, loss
of bodily function or a serious laceration, burn, head injury or eye injury).

This obligation applies to any workplace vehicle but not, for example, to a crash involving a
worker driving to work in their private car.

Incidents must be reported by the fastest possible means and the site of an incident should not
be disturbed until an inspector arrives at the site or directs otherwise. A record of each notifiable
incident must be kept for at least five years. Further information on notifiable incidents is
available from Safe Work Australia WorkSafe New Zealand and other WHS agency websites.

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4. Process
A recommended process for identifying road traffic hazards and developing effective controls to
eliminate or minimise the risks arising from these hazards is shown in Figure 2.

Figure 2 Risk Management Process

List the extent

and type of
exposure to road
traffic

For each type,

identify
opportunities to
eliminate travel or
use safer travel
modes

Determine
Consider the
remaining travel
hazards involved in
necessary for the
for each vehicle
conduct of the
group
business

5 7
Develop controls to
eliminate or reduce
these hazards or Periodic review
minimise the
consequent risks

Document,
implement and
measure

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The process is in three parts. The first part:

Identifies the vehicle types and their operations to understand the exposure to road traffic.
Determines actions to eliminate road travel or use safer transport modes.
Identifies remaining travel that is essential for the business and the vehicles involved in that
travel.

The second part:

Considers the hazards in road traffic that need to be addressed generally and for each vehicle
group.
Develops controls to reduce risk so far as reasonably practicable.
Establishes the documented policies, procedures and measurement processes to ensure that
these controls can be implemented.

The third part:

Defines a periodic review process to continually improve the effectiveness of the safety
management system.

While the controls developed may be common across different vehicle types, this process
ensures that all exposure to road traffic injury is identified and allows the organisation to consider
specific controls for specific situations.

4.1 Step 1: List the extent and type of exposure

The risk associated with road traffic varies according to the vehicle type used, where and how it
is operated, and how well it is managed. Organisations need to consider the circumstances that
result in an exposure to road traffic, and how significant these are.

Checklist 1 (see attachments) below provides guidance in assessing the nature and extent of this
exposure. Which prompts organisations to consider their operational fleet and other vehicle
groups in which their workers may be exposed to the road traffic hazard.

These have the potential to present a high risk to organisations. Even though occasional use
may not require the same controls to operate a large operational fleet, the lack of adequate
control of individual use could collectively result in a significant risk.

Exposure to the extent and type of risks should be carried out for each of the vehicle group
identified for the organisation. High use groups may represent the greatest exposure to the
hazard but other groups with higher individual risks should not be overlooked.

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4.2 Step 2: Identify opportunities to eliminate or substitute
safer travel
The risks associated with vehicle use should be examined, the more effective control is to
eliminate road travel or substitute it with something safer. These opportunities should be
considered first.

Options for eliminating the road traffic hazard include telecommuting, teleconferences, and
combining trips to eliminate duplicated travel.

Substituting the hazard for a safer alternative requires work travel to be organised through
safer means by selecting safer modes of transport as shown in Figure 3. Substitutionmight
also include the use of taxi services in situations where a worker is for whatever reasonunfit or
unauthorised to drive, such as after a long workday.

Figure 3 Motorised land transport risk

Motorcycle Car Bus Train

Higher risk Lower risk

A review by Austroads in 2010 estimated that casualties would increase if car drivers transferred
to walking, cycling or riding motorcycles, but would decrease if they used a car or in a bus.
While these findings were based on population-wide shifts, similar trends could be expected for
individual organisations and individual journeys. Risk reduction could also be expected from the
use of trains or aeroplanes.

Organisational programs to enhance health and well-being through increased walking and
cycling can have a role in determining transport modes. These need to be considered in
conjunction with responsibilities to reduce road traffic risks to ensure that both health and safety
outcomes can be achieved.

The wider use of virtual meetings is now used as a substitute for long-distance travel. If travel is
necessary, public transport options may be safer, cheaper and environmentally beneficial.

The safety of the whole journey from door-to-door should be considered but is unlikely to
remove the safety benefits of public transportuse providing adequate controls are in place. For
example, personal security at night..

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For freight operations, different transport mode choices should be an integral part of supply
chain strategies to reduce costs and improve reliability. Safety needs to be a factor in this
assessment.

4.3 Step 3: Determine remaining exposure to road traffic

hazards
Review Checklist 1 to identify which type of vehicle travel is essential to the business. This is
where further attention is required to eliminate risks or reduce them so far as reasonably
practicable.

This should identify the vehicle group most in need of attention through its:

• Risk (for example, use of motorcycles)

• Nature and extent of exposure (for example, how often they are used)
• Controls (for example, on grey fleet).

4.4 Step 4: Identify the particular hazards associated with

each vehicle group
You can use Checklist 2 which provides guidance on the characteristics of different vehicle
groups and the ways they might be managed and operated.

Consultation with the people involved in each vehicle group as drivers, passengers or managers
will be an essential part of this process to ensure that controls are developed from an
understanding of the actual situation and not on existing policies that may or may not be followed
in practice.

4.5 Step 5: Develop controls

You can use Section 5 of this Guide for guidance on the controls associated with different risks
in the road traffic system. These are also summarised in Checklist 3. There are however,
extensive resources available from a number of sources to help identify further controls or to
provide more detail on the controls listed. A list of resources is provided below.

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4.6 Step 6: Document and implement policies and procedures
Accurate and complete records can help sustain the viability of the safety management
system and provide valuable data to identify trends in performance. Including the evidence
necessary for the continual improvement of the system.

Collecting incident data encourages the reporting of incidents and the rigorous analysis of this
data is a key to gathering evidence of risks and the ability manage and track the performance of
the system.

Documentation should be implemented and integrated with existing safety management systems
and be appropriate for the size and complexity of the organisation.

Documentation may include sensitive and personal information, so appropriate controls

should be in place to ensure that the collection, storage and retrieval of this information
complies with relevant privacy principles and legislation.

Performance measures will also be improved through alignment with other organisational
aspects, such as individual performance management and development plans.

4.7 Step 7: Conduct periodic reviews

Reviewing and improving policies/procedures is essential to ensure the continuation and
relevance to reduce risks.

Support this by seeking:

• Workers provide feedback on how they use vehicles

• Incident investigation and hazards are reported
• Performance measures are reported
• Information on new technology and safety devices are reported

The review of control measures are conducted and there is a need to systematically review the
process to test assumptions about vehicle use. These reviews may perhaps be less frequent
but should be informed by data that measures exposure to road traffichazards for all vehicle
groups.

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4.8 Guidance for small business
The principles and risk management process outlined in this Guide are applicable to
organisations of any size and in any industry. However, for small businesses, where there is a
small and well-defined fleet of vehicles to consider, and where communication between all levels
of the organisation is informal, some of the steps outlined below can be combined and simplified.

Figure 4 Small business risk management process

1-3
Identify the
vehicle groups of
greatest concern

4-5
Consider the
hazards involved in
these vehicles
group and develop
controls

Periodic review

Document
decisions and
agree how to
monitor progress

Use Checklist 1 (for steps 1 to 3 above) to determine the vehicle groups. These may be owned
or leased by the business, or be other vehicles that workers use. Because of the amount of
use, the risk associated with the type of vehicle, and the controls in place. Businesses should
focus on the main vehicle groups.

You can use Checklist 2 and 3 (for steps 4 and 5 above) at the same time. This involves staff in
a process to help identify the hazards and come up with controls to eliminate or reduce risks. A
few key actions to address the greatest risks and to start a process of continuous improvement
are recommended. nature and extent of documents should be appropriate for each
organisation’s needs, Step 6 is a critical step. For small business, simple checklists and direct
communication to workers can be adequate to provide information of decisions to clarify roles.

Step 7 remains a requirement for all organisations, and a periodic review should be
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undertaken, this includes:

• changes in the size of the business

• changes in operations or the nature of the business
• opportunities to improve, such as the acquisition of new vehicles.

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5. Road traffic safety hazards
Modern road traffic safety management is heavily influenced by the systems approach to safety
and is adopted in other critical safety domains, such as the workplace.

In the traffic system, considers three factors:

• Human behaviour - The road traffic system needs to accommodate the behaviour, risk
perceptions and management of risk by workers that influence road use, and respond
to the vast bulk of serious road crashes as system failures.
• Human frailty - There are known physical limits to the amount of force a human body can
withstand before it is seriously injured. Exposure of workers to the transfer of energy involved
in a vehicle crash is comparable to the exposure of workers to heat or to electricity. Neither
road traffic nor the workplace can be considered safe unless the exposure is managed in
such a manner that allows the human body to withstand the exposure without suffering injury.
• Shared responsibility - System designers have the final responsibility for the design, operation
and use of the road transport system. They are therefore responsible for the level of safety in
the entire system.

Road users are responsible for following traffic rules, and showing due regard, judgment and
responsibility on the roads. If road users cannot, are incapable, or unwilling to take their share of
this responsibility, then “system designers” must make further efforts to ensure that people are
not harmed. The “system designer” is any organisation or professional that influences the safety
experienced by system users, including the use of vehicles in the course of work.

Not all individual hazards in the road traffic are required to be considered the appropriate controls
to eliminate or reduce risk. For example, improved vehicle safety technology which protects
occupants from impacts with roadside objects, will be of value in a wide range of situations.
Therefore, it’s not necessary to identify this particular hazard in order to conclude that vehicle
safety technology is necessary.

RTS management functions and processes have been codified by the International Standards
Organisation in ISO Standard 39001 – Road traffic safety management systems.2 ISO 39001.
Categorises safety performance factors used here to identify the critical hazards that each
organisation will need to consider to meet its WHS obligations.

2 Organisations can use ISO 39001 to align their RTS management systems alongside their quality and environmental
management systems which they may have developed in line with ISO 9001 Quality Management Systems or ISO 14001
Environmental Management Systems.

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These hazards and potential controls are discussed below.

5.1 Inadequate journey planning

Journey planning is an essential control that spans the full hierarchy of controls from potential
hazard elimination through to administrative procedures.

Risks

When a journey is required for business operation and cannot be reasonably avoided, it’s
important to recognise that some journeys are more hazardous than others. For example, the
route options that are available (high speed country roads or access restrictions for heavy
vehicles), the time of day and/or weather conditions, or the demands of the journey on the
driver.

The way work is designed and managed influences the safety of the journey. Such as long
distances and travel times, the number and length of stops in a journey, and driver fitness should
be taken into account. Early consideration of the journey planning should be taken into account,
and identify opportunities to substitute with safer modes of travel.

Potential controls

Planning the journey before driving can help control some of the risks identified in this
section. These include:

• schedule to avoid fatigue – planning rest stops, encouraging overnight stays after all day
meetings, for example
• avoid times when travel may be more risky, due to weather conditions or the driver’s
sleepiness, presence of wild animals, etc
• allow sufficient time to avoid pressure to speed
• avoid certain roads, intersections or turning movements and selecting safer, higher-
standard roads
• ensure that the driver can navigate with minimum distractions.
• ensure any equipment or goods will be adequately restrained or stored so that is will not bea
hazard for other road users or occupants of the vehicle.

Drivers should also have the ability and authority to alter plans should circumstances change.

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5.2 Roads providing inadequate protection
Different roads present different hazards and risks, which makes the choice of roads and
conditions of their use critical.

Risks

The safety afforded by different roads varies with depending on the characteristics of the road.
The overall rating of a road’s risk can be obtained from audit programs such as Australian Road
Assessment Program (AusRAP) or New Zealand Road Assessment Programme, KiwiRAP.
Which regularly assesses major highways, and an assessment of relative risk can be made by
considering the differences between alternative routes. In general, main roads and highways in
urban and rural areas provide significantly greater safety than more minor roads.
PCBUs should be aware that most metropolitan workers are unfamiliar with the hazards
associated with regional driving. Australia is a relatively urbanised country, and many
Australians do not leave the metropolitan area at all. If a worker is asked to undertake rural or
regional driving on an exceptional or occasional basis, some further detail about the hazards
and how to undertake the driving task safely should be provided.

Potential controls

Consult with drivers to provide information about particularly problematic roads or

locations.

Characteristics of safer roads include:

• separation of opposing traffic

• separation of local traffic from through traffic
• elimination of or protection from roadside obstacles
• wide, sealed shoulders or emergency stopping lanes
• safe provision for pedestrians and cyclists
• speed limits aligned to the safety of the infrastructure
• well-maintained road surface
• roundabouts instead of traffic lights
• clear line marking.

In determining whether it is practicable to avoid certain roads, it should be noted that use of
higher-standard roads might also result in reductions in vehicle operating costs. On the other
hand, a longer route may also increase time on the road and hence the risk of the driving whilst
fatigued. u
If alternative routes are neither available nor reasonably practicable then the organisation should
consider whether the risks warrant additional controls. This can be selected from the remaining
factors described below and tailored to the specific needs of the route.
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5.3 Vehicles providing inadequate protection
Vehicles themselves are not a major causal issue in road traffic injury and present major risk
management opportunities.

Risks

Vehicles that do not have the latest safety technologies will have a far greater chance of being
involved in a crash and offer far less protection than those that do.

Mechanical failure is a significant factor in relatively few vehicle crashes, but the safety
performance of vehicles can be degraded by inadequate maintenance. This can include poor
tyres and brakes leading to loss of control and damage or deterioration of safety equipment such
as seat belts and air bags leading to lack of protection in the event of a crash.

Potential controls (specification)

Recent and emerging vehicle technologies represent a significant opportunity for organisations to
improve the safety of their vehicle workplace. Technologies can reduce the likelihood of crashes
and reduce the harm from those crashes.

Side airbags that protect the head and torso have been estimated to reduce the risk of death or
injury by 51%; electronic stability control has been estimated to achieve 53% reductions in run-
off-road crashes, which accounted for 38% of road fatalities. These technologies are now
standard on the light vehicle fleet but will not be on all older vehicles. Policies that allow the
purchase of used vehicles should consider including these features as mandatory requirements.

Some emerging technologies are showing similar promise. In particular, autonomous emergency
braking (AEB) which can detect other vehicles and apply the brakes if the driver has failed to
react. In some cases this technology can also detect pedestrians and cyclists and apply the
brakes. . An analysis of crashes involving vehicles fitted just with low speed AEB demonstrated a
38% reduction in crashes, even in higher speed roads. These technologies are being continually
being improved and being fitted to an increasing number of vehicle models.

The assessment of these technologies is included in vehicle ratings provided by the

Australasian New Car Assessment Program (ANCAP). These ratings are continually reviewed
and are displayed with a date stamp to attempt to keep pace with developments and to ensure
that star ratings reward the most effective technologies. Some vehicles with an older date
stamped rating will not have been tested to the latest, most stringent, standards. Fleet policies
that require vehicles to have the most recent 5-star rating, or alternatively no more than three
years old, can ensure that safety performance is maintained.

However, the rapid development of new technologies is can also be achallenge for
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organisations to identify those with the greatest safety potential. Simply relying on a five-star
rating policy does not guarantee that these vehicles have these technologies and other
important safety features fitted, such as lane departure warning and speed limit warnings.
Organisations should consider specifying features over and above those included in current
ratings.

While these ratings do not cover heavy vehicles, the same technologies are being supplied into
the heavy vehicle fleet and should be considered.

The pace of development of vehicle technology should prompt organisations to consider their
fleet turnover policies to determine whether shorter periods are necessary.

If a fleet incorporates used vehicles, the Used Car Safety Ratings provides information on the
significant differences in crash performance between different car models and these can be used
to help select the safest used vehicles. These ratings also demonstrate that the newer the
vehicle the greater the protection it likely provides.

Specific road types may warrant further consideration of the vehicle specification required. For
example, a road with many sharp curves or freeway exit ramps, will increase the risk that a
poorly loaded or unsuitable vehicle to lose control or roll over.

While fleets under the control of the organisation can be managed in this way, other controls
should be considered for other workplace vehicles. These include:

• Mandatory minimum features and/or maximum age for grey fleet and other vehicles
• Requiring similar standards for contractors’ vehicles.

Potential controls (modification and maintenance)

Vehicle safety performance can be very sensitive to alterations in vehicle configuration. Some
vehicle modifications are only allowed with the approval of the vehicle registration authority.
Requirements for this vary in different jurisdictions. In some situations, particularly for large fleets
with significant modifications, organisations should seek the advice and/or approval of the vehicle
manufacturer.

The impact of vehicle modifications should be subject to a rigorous risk assessment. For
example, the installation of roll bars to mitigate risks associated with vehicle rollover may in fact
increase the risk of rollover occurring by increasing the centre of mass of the vehicle.

Similarly, the installation of bull bars may increase risks for pedestrians and cyclists and
preventthe correct operation of airbags within the vehicle.

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Modifications and additional equipment must be installed in a way that preserves the
performance of safety equipment such as air bags and thatdoes not interfere with the driver’s
ability to operate the vehicle safely. Modifications or accessories such as cargo barriers should
by specified to ensure than any loads can be carriedsecurely and safely.

Vehicle regulators around Australasia have varying requirements and processes for
roadworthiness inspections. Poor roadworthiness is associated with a relatively small proportion
of crashes, particularly for light vehicles. As a result, compliance with statutory requirements may
be sufficient in many cases, but the obligation to ensure roadworthiness at all times remains with
theorganisation.

Enabling and encouraging drivers to provide feedback is very important to ensure

roadworthiness is maintained. Organisations need to pay attention to tyres and brakes. Vehicles
that are found to be unroadworthy either from a regular inspection or based on driver feedback
should be removed from the fleet until it is fixed.

For heavy vehicles, reference should also be made to the NHVR or other authorities to
determine statutory requirements relating to vehicle modifications and roadworthiness.

5.4 Speed in excess of safe thresholds

Moderating speed is one of the most effective controls to reduce risk. Lower speeds reduce both
the likelihood of being in a crash and the impact on the human body in the event of a crash

Risks

The risks associated with exceeding the speed limit are well documented, and they begin at what
might be regarded as a relatively low level of speeding. For example, exceeding a 60 km/h speed
limit by just 5 km/h doubles the relative risk of involvement in a casualty crash and the risk
approximately doubles with each increment of 5 km/h. This is similar to the risk associated with
driving at the legal .05 drink driving limit in Australia and New Zealand.

A leading research institute in the Netherlands has set out safe impact speeds for different road
environments, set out in Table 3 below. “Safe” in this context is where there is only a 10% risk of
a fatal injury arising from such a crash.

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Table 3 Safe speeds for different road environments

Type of Road Safe Speed km/h

Roads with possible conflicts between cars and unprotected road users 30

Intersections with possible lateral conflicts between cars 50

Roads with possible head-on conflicts between cars 70

Roads where head-on and side conflicts with other road users are impossible > 100

Currently, speed limits on urban and rural roads are typically weighted towards the free
movement of motor vehicles but do not imply that it is always safe to travel at the limit. Lower
speed limits may be imposed at locations and times where the risk is greater, such as schools
or where there is a concentration of pedestrians.

Potential controls

Regardless of the known safety risks associated with excess and inappropriate speed,
considerable attention is required to ensure an understanding the underlying issues. Compliance
with speed limits should be a critical component of any safety management system. However,
organisations might consider policies to reduce speeds where warranted. In addition to safety
improvements, reductions in vehicle operating costs are also likely.

Drivers should also slow down to drive to the conditions whenever necessary, as the safe speed
may be below the posted speed limit. This might include poor road conditions, times of
inclement, ,weather, dusk and dawn when visibility may be limited and wild animals, or when
pedestrians and cyclists are in the area.

Control measures to manage speed by seeking and to alter the attitudes and consequent
behavioursof individual drivers will have limited success unless supported by other measures.
Controls that can be considered should include:

• Strong communication and leadership to demonstrate total commitment to the policy at all
levels and to ensure that everyone understands the correlation between safe driving speeds
and road conditions and the implications of non-compliance.
• Monitoring of vehicle speeds and speeding infringements with triggers for intervention with
offending drivers.
• In-vehicle technology to assist compliance through alarms or speed limiting.
• Organising schedules to prevent speeding being necessary or inadvertently encouraged.

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These controls can be applied either to statutory speed limits or any lower operational limits
imposed by the organisation.

Further detailed guidance on managing speed through driver awareness and technology is
available from a number of sources (for example, ETSC, 2011).

For operators of heavy vehicles and others involved in the Chain of Responsibility, the HVNL has
specific requirements and the NHVR can provide guidance.

5.5 Unauthorised drivers

For many vehicle operations, legislated authorisation requirements are likely to be sufficient, and
the focus should be on managing compliance and related information.

Risks

The driver licensing process provides some assurance that an individual has reached an age and
has undertaken the pre-requisite activities to be allowed access to drive a certain category of
vehicle. Unlicensed drivers are significantly over-represented in crash statistics.

However, fully licensed drivers still represent a risk as the perception and management of risk
are key behavioural factors that influence road use and safety. The broad access to vehicles
and the road traffic system enabled bythe licensing process may represent a greater risk to an
organisation than if authorisation were more restricted.

Potential controls

Organisations should have checks in place to ensure drivers have the appropriate licence forthe
category of vehicle that they are driving and that drivers comply with any conditions on the
licence. Certain drivers, such as young and novice drivers may have additional conditions
imposed. Organisations should also be aware of different restrictions that might apply in different
jurisdictions or with licences from other jurisdictions.

A documented process of driver authorisation provides the organisation with a record of these
checks. Combined with a process of logging each vehicle use, this provides a record of who is
driving at any particular time. The process also provides a point of engagement to ensure that
drivers are aware of organisational policies and procedures.

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This process allows organisations to impose additional conditions or restrictions on drivers’
access to vehicles, which may be necessary to mitigate particular risks in a more targeted way
than is possible for licensing authorities, which can only apply broad policies across the
community.

Less experienced drivers may be limited in their access to certain vehicle types or the times and
locations they are permitted to drive.

Establishing a process of driver authorisation also allows for a process to remove this
authorisation should the driver be found to be unfit to drive safely. In the case of medical
conditions that affect fitness to drive, reference to the relevant licensing authority should be
made.

In other cases, questions over authorisation to drive may arise as a result of traffic infringements
or more serious traffic offences. A single offence can be used as a trigger for intervention with
the individual to assist them to improve. Organisations can establish a process of escalating
controls in the event that subsequent offences are committed with the removal of authorisation to
drive being one available sanction, and control measure.

Duty holders need to identify information needs regarding authorisation to drive such as the
current driver licensing status. Some licensing agencies have mechanisms to assist in ensuring
that this information is made available in a manner which meets privacy and safety
considerations. Where this is not available, other mechanisms within the workplace should be
considered.

5.6 Unsafe drivers

Drivers’ perception and management of risk are the key behavioural factors that influence road
safety, their fitness before and during each journey is essential, and they need to be supported
by technology.

The holding of a valid licence is insufficient to ensure fitness to drive at any one time. Authorities
generally apply risk-based approaches to focus enforcement on the greatest risks, but
organisations should consider other measures to ensure that risk is reduced so far as reasonably
practicable.

Medical Fitness

Risks

The ability to identify risks and operate vehicles depends on a wide range of cognitive and
physical capabilities.

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In many cases these can be well managed by the individual to ensure that their ability is not
impaired. However, the risk associated with uncontrolled issues can be significant. While these
medical issues may be more prevalent with age, organisations should be aware that many of the
significant contributors to risk can occur at any age.

Processes for regulating medical fitness vary from jurisdiction to jurisdiction but the general
principles are similar and are based on extensive research that has linked different medical
conditions to crash risk. Apart from eye tests at initial licensing, assessment of medical fitness for
the car licence is generally only undertaken after a report of a problem or at a certain age. More
stringent requirements are imposed on commercial vehicle drivers and organisations should refer
to driver licensing agencies in their jurisdiction.

Potential controls

Guidance for medical fitness standards used by driver licensing agencies is publicly available
(Austroads, 2016), and provides examples of conditions, such as:

• blackouts
• substance misuse/ dependency
• diabetes
• psychiatric conditions
• musculoskeletal conditions
• vision problems
• sleep disorders
• neurological conditions such as epilepsy and dementia
• cardiovascular disease.

Programs to manage driver fitness may also provide other benefits in relation to worker health
and wellbeing, as many of the issues of concern in the driving situation are symptoms of broader
health effects.

Organisations with concerns regarding medical fitness of drivers are advised to seek professional
advice or to refer the driver to the relevant driver licensing authority for their review.

Fatigue
Risks

Fatigue can be defined as “...a state of mental and/or physical exhaustion which reduces a
person’s ability to perform work safely and effectively.”

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Fatigue can contribute to inattention to the driving task and poor judgement. However, lack of
adequate sleep will inevitably lead to loss of consciousness, initially momentarily (micro sleeps)
but then longer as the body demands its only remedy for fatigue: sleep.

There are no statutory limits to define what is legal for most drivers, but fatigue may be a factor
indetermining liability in the event of a crash. However, for heavy vehicle operators there are
extensive regulatory controls over driving hours, rest breaks etc.

Factors that can increase the risk of fatigue include lack of quality sleep, driving long hours
without a break, driving at times when the person is usually asleep or in the mid-afternoon.

Signs of fatigue
A driver must not drive a fatigue-regulated heavy vehicle on a road while impaired by fatigue. Drivers may be
impaired by fatigue even when complying with work and rest limits. It is important to spot the signs of fatigue
and take a break.

Your body

• A lack of alertness
• Inability to concentrate
• Making more mistakes than usual
• Drowsiness, falling asleep or micro-sleeps
• Difficulty keeping your eyes open
• Not feeling refreshed after a sleep
• Excessive head nodding or yawning
• Blurred vision
• Mood changes
• Changes to personal health or fitness

Your vehicle

• Near miss or incident

• Not keeping in a single lane
• Not maintaining a constant speed
• Overshooting a sign or line
• Poor gear changes

Please refer to the National Heavy Vehicle Regulator (NHVR) guidance - About fatigue
management | NHVR

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Potential controls

Organisations should use controls to reduce this risk, both by reducing the hazard of sleepiness
and take actions to mitigate the of fatigue:

• check that workers have adequate sleep before driving

• schedule meetings to avoid driving after a long day of work, particularly at night, or driving
early in the morning
• require and facilitating regular rest breaks
• share the driving where possible
• identify and treating sleep apnoea
• arrange alternative transport for workers who are fatigued.

Workers also need to understand the context of local driving conditions considering that fatigue is
a major factor in crashes. According to the Australian Automobile Association indicates that 20 to
30 per cent of all car crashes in Australia are attributed to fatigue.

PCBUs and workers both have responsibilities in the fatigue space, especially PCBUs often direct
when and where a worker must drive.

Further guidance is available from a number of sources and those responsible for heavy vehicles
should refer to NHVR.

Alcohol and drugs

Risks

The connection between alcohol consumption and driver impairment is well established, with
numerous studies showing how the risk increases exponentially with increasing concentration of
alcohol in the blood. Also well-established is drink driving legislation with 0.05 blood alcohol
concentration now the standard limit across Australasia. Lower limits, effectively zero, are
applied to drivers who are in higher risk categories, such as young drivers or previous offenders,
or who are in control of vehicles with potentially greater consequences of harm in the event of a
crash, for example heavy vehicles and buses.

Drug use is also associated with increased risk either from the consumption of illegal stimulants
or of prescription drugs, particularly in excessive quantities.

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Potential controls

Many organisations have workplace alcohol and drug policies and procedures in place.
However further controls are available to isolate the alcohol hazard from driving. These
include:

• Workplace alcohol testing before driving

• Removal of any authority to drive work vehicles
• Installation of alcohol interlocks to be used by all drivers
• Limitation of alcohol and/or provision of alternative transport at work-related functions.

While high intensity random breath testing provides a general deterrent to drink driving, there
remains a cohort of drivers, (including those who are alcohol dependent and need to managed in
terms of medical fitness), who may continue to drive after consuming alcohol. A number of
jurisdictions have now introduced legislative alcohol interlock programs. These require the
installation of a device that prevents the vehicle from being started unless the driver has provided
a breath sample with alcohol. Alcohol interlocks are widely available for organisations to control
this hazard through technology.

Distraction and inattention

Risks

The rise of mobile communication technologies and social media has led to an increase in the
use of mobile phones and similar technology in vehicles. Road rules generally prohibit the use of
hand-held devices, and any communication technology should be assessed to ensure that its
can be used within the law. However, research data indicate that there are also risks associated
with hands-free use. In particular, taking eyes off the road to look at a screen or press buttons is
a significant risk factor. Sending an SMS whilst driving a heavy vehicle has been measured to
increase risk by 23 times.

However, there are other sources of distraction that should be considered, such as loose objects
in the vehicle, other passengers, map reading or reading or filling in paperwork.

Potential controls

Anything that could take eyes away from the road for more than a glance should be prevented.

Organisations have a responsibility to design any work that is required to be carried out in the
vehicle. Must ensure that it can be done safely and does not distract a drivers’ ability to
undertake the primary task of driving safely.

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Specific controls include:

• organisations and their staff understand the mobile phone rules f and ensure compliance
for all staff
• strict policies to eliminate unsafe mobile phone use
• if handsfree use is essential, then using vehicle bluetooth connections that remove the need
to touch the phone – these vehicle connections are usually designed to restrict access whilst
the vehicle is in motion
• whether factory-fitted or aftermarket, any required communications technology should be
installed and operated to minimise the potential for distraction whilst driving
• ensure that scheduling allows for non-driving activities to be undertaken before or after driving
• ensure that journeys are planned and routes determined before starting

Immaturity and inexperience

Risks

In the driving context, the immaturity of drivers can be a hazard. Combined with inexperience, it
represents one of the most significant risk factors on the road. Australasian licensing authorities
require young drivers to accumulate experience and impose restrictions on them to manage their
elevated risk.

Potential controls

Organisations should consider this hazard when requiring young workers to drive. Young drivers
will demonstrate varying maturity and many will have the attitudes to manage the driving task
quite safely. However, until the age of about 26, there is a likelihood that they will be less able to
assess risks and decide appropriate responses. Laws restricting young drivers vary considerably
covering areas such as vehicle selection, speed, use of mobile phones, curfews etc and
organisations should ensure that they understand these and ensure compliance. Mentoring by
older drivers, minimising travel at night or with other young passengers, and paying particular
attention to potential distractions should be considered.

5.7 Non-use or misuse of personal protective equipment

While the use of equipment such as seat belts and motorcycle helmets are mandatory, other
personal protective equipment also has the potential to significantly reduce risk when all other
controls have failed.

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Risks

The use of seat belts has been mandatory in Australasia for decades, there still is a proportion of
drivers and passengers who do not use them. Each year, approximately 20% of vehicle
occupants killed in crashes were not wearing a seat belt and it is known that unrestraineddrivers
and passengers are eight times more likely to be killed in a road crash.

Potential controls

Organisational policy should maintain that everyone must use a seat belt, all the tims when
driving. Workers should be instructed that, if a seat belt in the vehicle is not operative, or has
been removed, then they should immediately seek alternative transport. Organisations may
consider monitoring systems for seat belt use, and escalating consequences for failing to
adhere to their policy

The use of seat belts in buses is also mandatory, where they are fitted. In low-speed urban
settings, bus crashes seldom reach a level of energy requiring seat belts but, at higher speeds,
when the risk of rollover increases, specifying that only buses with seatbelts can be used may be
practicable.

In some situations, workplace vehicles will need to transport children. The rules governing this
are complex and organisations should ensure that they are aware of the current regulations for
the location they are operating, from the point of view of both road traffic safety and child
protection.

Poor installation of restraints is a common fault and organisations should ensure that all
installation instructions are followed and that the restraint is installed by a competent person. All
road safety agencies and motoring organisations provide extensive guidance on the correct
selection, installation and use of child restraints.

While helmet use by motorcyclists and cyclists is a legal requirement, attention should be paid to
ensuring the selection of the safest helmets, their prompt replacement if damaged and their
correct use. The Consumer Rating and Assessment of Safety Helmets (CRASH) program
provides advice on the safety performance of different helmets available in the Australasian
market.

Additional protective equipment over and above that required by traffic laws should be
considered where practicable. Helmets for quad bike riders and others in relatively unprotected
vehicles or high-risk activities should be considered. Additional protective equipment for
motorcycle riders, such as gloves, boots, protective clothing and armour have proven benefits.

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High visibility clothing should be considered for vulnerable road users such cyclists, motorcyclists
and workers who have to exit their vehicle, particularly at night.

Additional protective equipment over and above that required by traffic laws should be
considered where practicable. Helmets for quad bike riders and others in relatively unprotected
vehicles or high-risk activities should be considered. Additional protective equipment for
motorcycle riders, such as gloves, boots, protective clothing and armour have proven benefits.

Please note: Tasmania amended the Work Health and Safety Regulations 2012 to improve
quad bike safety.

The new regulation 216A includes a duty on a person conducting a business or undertaking
(PCBU) with management or control of a quad bike to:
• ensure an approved helmet is available for use with the quad bike
• ensure the person using the quad bike has appropriate training
• ensure the quad bike is not used to carry a passenger unless designed for that purpose.

Regulation 216A also requires a user of a quad bike to:

• have had appropriate training
• wear an approved helmet
• not carry a passenger unless the quad bike is designed for that purpose.

5.8 Inadequate post-crash responses

Systems to alert emergency services and the organisation to a crash, and the response by the
organisation can be critical to reducing the incidence and severity of an injury.

Risks

Vehicles should be equipped to support the provision of first aid and should also be considered
in the organisations’ emergency management plans. These provisions should apply across all
vehicles used as workplaces, whether the vehicles are under the control of the organisation or
not, such as grey fleet vehicles or vehicles being driven by third parties. However, the nature of
these provisions is likely to vary.

Risks will arise from both the use of the vehicle and its isolation from the organisation.

Potential controls

Fast response to crashes is one of the most effective measures for reducing fatality risks.
Whether notification is by individuals or through automated alerts triggered by vehicle safety
Vehicles as a Workplace – Work Health and Safety Guide
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systems both depend on adequate communication network performance. The risk management
process should consider whether communications to notify emergency services would be
adequate in all the locations where the vehicle may be.

In the event of a crash, following the management of the immediate response, a review should
be undertaken to assess hazards to determine whether current controls are adequate.

There is evidence that the involvement of drivers in discussion groups to review incidents and
their own behaviour can provide improvements in their safe driving performance that outweigh
any benefits that might accrue from driver training programs, at far less cost.

In the longer term, systematic collection and analysis of all incidents will provide a vital source of
information to drive continuous improvement in the safety management system.

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Glossary
Buses: Light or heavy vehicles carrying passengers for hire or reward

Controls: Actions to eliminate health and safety risks so far as is reasonably practicable, and if
that is not possible, minimising the risks so far as is reasonably practicable

Grey fleet: Vehicles used for work that are not directly provided by the organisation that employs
the driver

Hazard: A situation or thing that has the potential to harm a person.

Heavy vehicles: Vehicles requiring specific heavy vehicle driver licences

Hire cars: Cars hired for short-term or long-term use and driven by a worker

Light commercial vehicles: Vans, pick-up or other utility vehicles able to be driven on a
passenger car licence

Motorcycles: two- or three- wheeled motor vehicles, including scooters and mopeds, requiring a
motorcycle licence to ride

Packaged cars: Cars supplied to an individual by the organisation for use as a private vehicle
but which may also be used as a pool cars during work hours

Plant: Specialised vehicles, such as fork lifts, that may be registered for use on public roads

Pool Cars: Cars operated by the organisation that are used by a number of people on a regular
or ad hoc basis

Public road: Roads or other areas where road traffic law applies

Risk: The possibility that harm (death, injury or illness) might occur when exposed to a hazard

Road traffic safety: management of hazards and consequent risks associated with the use of
public roads so as to ensure death or serious injury does not occur

Taxis: Taxis, ride sharing services or other services in which workers may ride as passengers

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Third party vehicles: Vehicles operated by customers, suppliers, clients or other third parties in
which workers may drive or ride as passengers

Work health and safety: management of hazards and consequent risks associated with a
workplace

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Resources
Websites with resources relating to vehicles in the workplace

National Road Safety Partnership Program (NRSPP): [Link]

Preventing Road Accidents and Injuries for the Safety of Employees (PRAISE):
[Link]/projects/praise

Driving for Better Business: [Link]

United States Department of Labor: [Link]/Publications/motor_vehicle_guide.html

Work health and safety processes

“Code of Practice – How to Manage Work Health and Safety Risks”, Safe Work Australia,
Canberra, December 2011

“Code of Practice – Managing the Work Environment and Facilities”, Safe Work Australia,
Canberra, December 2011

“Code of Practice – Work Health and Safety Consultation, Co-operation and Co-ordination”, Safe
Work Australia, Canberra, December 2011

“Guide for Managing the Risk of Fatigue at Work” Safe Work Australia, Canberra, November
2013

“Guide to The Model Work Health and Safety Act “, Safe Work Australia, Canberra, March 2016

“Work Health and Safety - Seven Steps for Small Business”, Safework SA, Government of South
Australia, [Link], October 2013

“Identifying, Assessing and Managing Work Risks”, Worksafe New Zealand, Wellington, July
2017.

Road traffic safety management

ISO, 2012, “Road traffic safety (RTS) management systems – Requirements with guidance for
use”, International Standards Organisation, ISO 39001:2012(E), Geneva, October 2012

Vehicles as a Workplace – Work Health and Safety Guide

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“The business case for managing road risk at work”, PRAISE report, European Transport Safety
Council, Brussels, May, 2014

“Workplace road safety risk management: An investigation into Australian practices”,

Warmerdam et al, Accident Analysis and Prevention, 98 (2017)

“Improving Fleet Safety – Current Approaches and Best Practice Guidelines”, Austroads
Publication AP-R321/08,

“Guide to safe work related driving”, Transport Accident Commission, WorkSafe Victoria,

“A guide to applying road safety within a workplace – A Bilateral Approach to Organisational

Road Safety in Australia and New Zealand”, National Transport Commission (NTC),Australia,
Accident Compensation Corporation (ACC), New Zealand.

“Driving at Work – managing work-related road safety”, Health and Safety Executive, UK,
INDG382, 04/14, [Link]/pubns/[Link]

“Road Safety Manual for the Queensland Government Fleet” Qfleet, Department of Housing and
Public Works, Third Edition

“Thought Leadership: Road Safety Management Systems”, National Road Safety Partnership
Program, Melbourne, October 2015

“Thought Leadership: ‘Just culture’ – The key to an effective safety culture”, National Road
Safety Partnership Program, Melbourne, November 2015

Specific road traffic safety issues

“Assessing Fitness to Drive for commercial and private vehicle drivers” Austroads / National
Transport Commission joint publication

“Driving for Work: Managing Speed”, PRAISE Thematic Report No. 8, European Transport
Safety Council, Brussels, November 2011

“Framework for alcohol and drug management in the workplace”, Workplace Health and Safety
Queensland, Department of Justice and Attorney-General, PN10875 Ver. 2, Brisbane,
July 2012

“Managing young drivers at work”, PRAISE report, European Transport Safety Council, Brussels,
May 2015

Australasian New Car Assessment Program (ANCAP): [Link]

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Australian Road Assessment Program (AusRAP): [Link]

New Zealand Road Assessment Programme, KiwiRAP, [Link]

“Grey Fleet Safety Management Guide”, National Road Safety Partnership Program, Melbourne,
October 2017.

Used Car Safety Ratings (UCSR) [Link]

Consumer Rating Assessment of Safety Helmets (CRASH) [Link]

Child Restraint Evaluation Program (CREP) [Link]

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Appendix A Attachments
Table 4 Checklist 1 - Assessing the nature and extent of exposure

Vehicle Use

Vehicle Small to Medium Enterprises Large Firms

Low use Medium use High use Low use Medium use High use

Bicycles Occasional Regular use Regular Occasional Regular use Regular

use use as part use use as part
of our of our
business business

Motorcycles 1 or 2 Operate a Operate a Operate a Operate a Operate a

vehicles small fleet – small fleet small fleet large fleet – large fleet –
occasional it supports – it is our – it it supports it is our
use our business business supports our business business
our
business

Pool Cars 1 or 2 Operate a Operate a Operate a Operate a Operate a

vehicles small fleet – small fleet small fleet large fleet – large fleet –
occasional it supports – it is our – it it supports it is our
use our business business supports our business business
our
business

Packaged Used only Occasional Used Used only Occasionally Used

cars by the use as a regularly as by the used as a regularly as
vehicle pool vehicle a vehicle pool vehicle a
custodian supplement custodian supplement
to the pool to the pool
fleet fleet

Grey fleet Occasional Regular use Regular Occasional Regular use Regular
use use as part use use as part
of our of our
business business

Third party Occasional Regular use Regular Occasional Regular use Regular
vehicles use use as part use use as part
of our of our
business business

Hire cars Occasional Regular use Regular Occasional Regular use Regular
use use as part use use as part
of our of our
business business

Taxis Occasional Regular use Regular Occasional Regular use Regular

use use as part use use as part
of our of our
business business

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 Vehicle Use

Vehicle Small to Medium Enterprises Large Firms

Low use Medium use High use Low use Medium use High use

Light 1 or 2 Operate a Operate a Operate a Operate a Operate a

commercial vehicles small fleet – small fleet small fleet large fleet – large fleet –
vehicles occasional it supports – it is our – it it supports it is our
use our business business supports our business business
our
business

Heavy N/A Operate 1 or Operate a Operate a Operate a Operate

vehicles 2 trucks small fleet small fleet small fleet extensive
fleet

Buses Public Operate 1 or Operate a Public Operate a Operate

transport 2 buses small fleet transport small fleet extensive
use use fleet

Plant Occasional Regular use Regular Occasional Regular use Regular

use on the on the road use on the use on the on the road use on the
road road as road road as
part of our part of our
business business

Table 5 Checklist 2 - Issues to consider for each vehicle group

Vehicle Issues to consider

Bicycles Are bicycles maintained adequately?
Are helmets worn correctly?
Is additional PPE provided (high visibility jackets etc.)?
Are riskiest times (e.g. wet or dark conditions) minimised?
Do any locations or modes of operation increase risk?
How are any loads carried?

Motorcycles Are latest safety features provided, particularly advanced braking?

Are riders experienced with the models used?
Is additional PPE provided (gloves, boots, jackets, pants, armour)?
Are riskiest times (e.g. wet or dark conditions) minimised?
Do any locations or modes of operation increase risk?
How are loads carried?

Pool Cars What are the vehicle standards for purchasing/leasing?

Are cars available for use by all or only specific roles?
Is there a policy on garaging and private use?
Who is responsible for management of the vehicle

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 Vehicle Issues to consider
Packaged cars Same as for pool vehicles
What access and use controls are in place?

Grey fleet Is usage incidental or a de facto outsourced fleet

Are there any controls over vehicle specification/age?
Are there controls in place to ensure vehicles are roadworthy,
particularly in respect of tyres and brakes?
Is there an authorisation process and are there controls over use?
Are pool cars offered as a preferred option?
Are drivers aware of their obligations to comply with organisational
policies?
Is there adequate insurance coverage?

Third party vehicles Whose vehicles might be used: customers’, suppliers’, others?
Are there any controls over vehicle specification/age?

Self-drive hire cars Planned, regular use or irregularly in response to particular needs?
Are there minimum vehicle standards?
Are there risks from drivers operating in unfamiliar vehicles, locations,
when fatigued etc.?
Are there standard hire contracts?

Taxis, hire cars, Uber Planned, regular use or irregularly in response to particular needs?
etc.
Are there standing arrangements/contracts allowing additional controls?
Can workers provide feedback regarding their experience as
passengers?

Light commercial What are the vehicle standards for purchasing/leasing?

vehicles
How are loads and equipment carried?
Are vehicles available for use by all or only by specific roles?
Are drivers familiar with the characteristics of the vehicle,
laden/unladen?

Heavy vehicles Are processes fully compliant with HVNL or other road transport
legislation, particularly in relation to Primary Duty and Chain of
Responsibility?
Are there other potential risks not covered by this legislation?

Buses – as operators For hire or reward: Refer to advice from transport safety regulators
See Light commercial and heavy commercial issues, as relevant

Buses – as Planned, regular use or irregularly in response to particular needs?

passengers
Are hazards for the total door-to-door trip considered?
Where relevant, are there contractual requirements to require seat belts?
Are workers advised of their obligation to wear any available seat belts?

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 Vehicle Issues to consider
Plant What are the circumstance in which vehicles such as lawn mowers, fork
lift trucks, tractors etc. are used on the road (or footpath, verges etc.)?
Have all required permits been obtained and any conditions complied
with?
What vehicle safety features, e.g. roll-over protection systems, and PPE
are required?
If vehicles cannot mix with general traffic, what traffic management
arrangements are required?
Are drivers aware of their traffic law obligations?

Table 6 Checklist 3 - Road traffic safety controls to consider

Road safety hazards Controls to consider

Inadequate journey Is the trip necessary?

planning
Can trips be combined?
Are there alternative modes to use?
How can trip preparation and scheduling reduce risk?

Roads providing Are there any roads of concern?

inadequate protection
Are there practicable alternatives?
What controls are required to reduce risks?

Vehicles providing Do all vehicles comply with standards?

inadequate protection
Do maintenance and inspection programs ensure continuing
compliance?
Are vehicles and options specified to be as safe as reasonably
practicable?
Do all vehicle modifications preserve the vehicle’s safety performance?
Are measures in place to ensure that unsafe vehicles are not used?
Do other organisational WHS programs consider the vehicle as a
workplace?

Speed Is speed compliance monitored?

What measures are needed to improve compliance?
Are lower speeds necessary in some situations?

Unauthorised drivers Are all drivers licensed for all the vehicles that they drive?
Are additional limitations required to authorise drivers for all or particular
situations?
Are measures in place to ensure that unfit or at risk drivers are
supported and, if necessary, prevented from driving?

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 Road safety hazards Controls to consider

Unsafe drivers – Are drivers medically fit?

fatigue distraction,
What measures are in place to prevent drivers being fatigued when they
alcohol etc.
start driving?
What practices ensure drivers do not suffer fatigue while driving?
Are people with alcohol or drug impairment prevented from driving?
Is there an adequate policy on mobile phone use?
Have other distraction risks been identified and managed?
Do younger drivers require particular controls?

Non-use or misuse of Are seat belts and other restraints fitted correctly?
personal safety
Are seat belts and other restraints always worn correctly?
equipment
Is any other equipment required?

Post-crash response Do organisational first aid and emergency management plans consider
vehicle use?
Are processes in place to respond when an incident or breakdown
occurs and to advise drivers and passengers what to do?
Is systematic incident data used to identify hazards and help develop
controls?

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Austroads
Australian Government
Comcare
Queensland
Government
--
NSW -
GOVERNMENT
Government of South Australia
Saf eWor k SA