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A u g u s t 2 0 1 7

Heavy Vehicle National LawMajor legislative changes commencing 1 October 2018A guide for judicial officers and legal practitioners

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Foreword

1 ‘Work-related Traumatic Injury Fatalities, Australia 2015’ Safe Work Australia (October 2016).2 Heavy Vehicle National Law and Other Legislation Amendments Bill 2016 (Qld),

Explanatory Note, page 2.

The fatality rate in the road transport industry is over eight times higher than all other industries1. In the 12-month period ending June 2017, 212 people died in crashes involving heavy vehicles or buses (just over four per week) and approximately 1,600 people were hospitalised from crashes involving heavy vehicles (more than 30 per week).

The Australian Work Health and Safety Strategy 2012–2022 has declared road transport a priority industry and the HVNL is a key component of the safety agenda.

From its inception in 2012, the Heavy Vehicle National Law (HVNL) has aimed to regulate drivers and the off-road parties who influence the supply chain and logistics—the so-called “Chain of Responsibility” or CoR provisions.

Amendments commencing in October 2018 reformulate the CoR obligations on a party as an overarching and positive duty of care, consistent with the duty of care approach adopted in other safety laws, such as the Model Work Health and Safety Act (Model WHS Act)2.

This guide is intended to introduce judicial officers and legal practitioners to the components of the HVNL, its jurisdictional operation, key concepts, and available penalty orders.

An indicative reprint of the amended legislation is available on the Queensland Government Legislation website (www.legislation.qld.gov.au).

Sal Petroccitto CEO Chief Executive Office

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ContentsForeword 2

Structure of the HVNL 4

Introduction of a primary duty in October 2018 6Transport activities 8

Safety 8

Reasonably practicable 9

Codes of practice 11

Executive officer liability 12

Prescriptive offences 13Vehicle Standards (Chapter 3) 13

Access (Chapter 4) 13

Mass, Dimension & Loading (Chapter 4) 13

Fatigue Management (Chapter 6) 13

Investigative and enforcement powers 14

Particulars of an offence 14

Evidentiary considerations 15

Interpretation 15

Sentencing 15Principles 16

Fines and demerit points 16

Jurisdictional limits 16

Additional Sentencing Orders 17

Commercial benefit penalty order – s 597 18

Cancelling or suspending registration – s 598 18

Supervisory intervention orders – s 599 19

Prohibition orders – s 607 19

Compensation orders – s 611 19

Injunction for noncompliance with notice – s 576E 19

Enforceable undertakings – an alternative to prosecutions 20

Publications of court outcomes 20

Glossary 22

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Structure of the HVNL

3 The states and territories are able to enact law with extraterritorial effect. However, there must be a ‘sufficient connection’ between the enacting state or territory and the extraterritorial persons, acts, omissions, events, matters, things, etc. in relation to which the state or territory law operates. This requirement flows from the state constitutions and the self-government Acts of the territories, which relevantly mandate that state or territory laws must be for the ‘peace, order and good government’ of the state or territory concerned. See generally Pearce v Florenca (1976) 135 CLR 507, 517-8; Union Steamship Co of Australia Pty Ltd v King (1988) 166 CLR 1, 14; and Port MacDonnell Professional Fishermen’s Association Inc v South Australia (1989) CLR 340, 372.

The HVNL is an applied law scheme. Put simply, an applied law scheme works as follows:

a. One jurisdiction (the ‘host’ jurisdiction) enacts a model law in its jurisdiction (usually as a Schedule to an Act of Parliament and, in recent times, usually called a ‘National Law’).

b. Then other jurisdictions (‘participating jurisdictions’) enact an Act (an ‘application Act’) that applies the National Law in that jurisdiction—and, more particularly, in the ‘gap’ in the ‘reach’ or ‘coverage’ achieved by the exercise of legislative power of the host jurisdiction.

In the case of the HVNL, the ‘gap’ that is being ‘filled’ by the laws of the participating jurisdictions is a result of the fact that the host jurisdiction’s power to legislate extraterritorially (i.e. with respect to persons, acts, omissions, events, matters, things etc. outside the host jurisdiction) is limited.3

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For the HVNL, Queensland is the host jurisdiction, with each of the other participating jurisdictions (i.e. all states and territories except Western Australia and the Northern Territory) adopting the Queensland legislation through application Acts.

The HVNL commenced as a national law in February 2014 and operated on a deemed liability basis. That is, when an on-road offence was detected, other “parties in the chain of responsibility” were deemed to be liable.4 Parties in the CoR include employers, prime contractors, operators, consignors, consignees, schedulers, loaders and others.

It was then incumbent on those parties in the CoR to prove they had taken all reasonable steps to prevent the breach from occurring.

Under that regime, an individual faced a maximum fine of $21,590 in the case of a severe risk breach of a mass requirement,5 $16,190 in the case of a critical risk work/rest breach6 and $10,790 for failing to ensure business practices would not cause a driver to exceed a speed limit7 (and five times the maximums for a corporation8). As first enacted, the HVNL generally only contemplated offences against fatigue, speed, mass, dimension and loading of a heavy vehicle.

4 See for example, Heavy Vehicle National Law s 183(2).5 Ibid s 96(1).6 Ibid s 251(1).7 Ibid s 204(1).8 Ibid s 596(3).

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Introduction of a primary duty in October 2018The new legislative regime abolishes deemed liability for parties in the CoR and replaces it with a duty to ensure, so far as is reasonably practicable, the safety of the party’s transport activities relating to the vehicle.

26C Primary duty

(1) Each party in the chain of responsibility for a heavy vehicle must ensure, so far as is reasonably practicable, the safety of the party’s transport activities relating to the vehicle.

(2) Without limiting subsection (1), each party must, so far as is reasonably practicable-(a) eliminate public risks and, to the extent it is not reasonably practicable to

eliminate public risks, minimise the public risks; and(b) ensure the party’s conduct does not directly or indirectly cause or

encourage-i. the driver of the heavy vehicle to contravene this Law; orii. the driver of the heavy vehicle to exceed a speed limit applying to the

driver; oriii. another person, including another party in the chain of responsibility, to

contravene this Law.(3) For subsection (2)(b), the party’s conduct includes, for example-

(a) the party asking, directing or requiring another person to do, or not do, something; and

(b) the party entering into a contract-i. with another person for the other person to do, or not do, something; orii. that purports to annul, exclude, restrict or otherwise change the effect of

this Law.

Like the Model WHS laws, there will be three categories of breaches, which are outlined in the table opposite:

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Category 1 – Breach of duty creating risk of death or serious injury or illness (reckless) s 26F HVNL

Category 2 – Breach of duty creating risk of death or serious injury or illness s 26G HVNL

Category 3 – Other breach of dutys 26H HVNL

The person:• has a duty under s 26C;• without reasonable

excuse, engages in conduct related to the duty that exposes an individual to a risk of death or serious injury or illness; and

• is reckless as to the risk

The person:• has a duty under s 26C;• contravenes the duty;• the contravention exposes an

individual, or class of individuals, to a risk of death or serious injury or illness.

The person:• has a duty under

s 26C; and• contravenes the

duty.

Maximum penalty:Individual: $300,000 fine or 5 years imprisonment, or both.Corporation: $3,000,000 fine.

Maximum penalty:Individual: $150,000 fineCorporation: $1,500,000 fine

Maximum penalty:Individual: $50,000 fine.Corporation:$500,000 fine.

While the new legislation is modelled on the WHS scheme, there are important differences. However, in the absence of any other jurisprudence, principles from the WHS laws are likely to be applied.

The primary duty creates a broad general duty which, although inclusive of mass, dimension, loading, speed, fatigue and maintenance, is not limited to these breaches. The elements of the primary duty do not require the satisfaction (or proof) of some other obligation. The primary duty creates an obligation where none previously existed under the HVNL.

In practical terms, on the facts of a particular case, there may be overlap in the application of the primary duty and other obligations.

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Transport activitiesA key difference between the duty provisions in the HVNL and those in the Model WHS laws is that the duty applies not to workers and workplaces but to a party’s transport activities relating to a heavy vehicle.

transport activities means activities, including business practices and making decisions, associated with the use of a heavy vehicle on a road, including, for example-

(a) contracting, directing or employing a person-i. to drive the vehicle; orii. to carry out another activity associated with the use of the vehicle (such

as maintaining or repairing the vehicle); or(b) consigning goods for transport using the vehicle; or(c) scheduling the transport of goods or passengers using the vehicle; or(d) packing goods for transport using the vehicle; or(e) managing the loading of goods onto or unloading of goods from the

vehicle; or(f) loading goods onto or unloading goods from the vehicle; or(g) receiving goods unloaded from the vehicle.

The breadth of this definition is tempered by principles in ss 26A and B that confine a party’s duty by inter alia their capacity to influence and control the conduct of others.

SafetySafety is defined by reference to three terms: “public risk”, “safety risk” and “public safety”. The first of these is the broadest term. It incorporates the safety of drivers and passengers of vehicles, persons or property in or likely to be in the vicinity of road infrastructure, and risks to road infrastructure and the environment.

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Reasonably practicableThe definition of what is “reasonably practicable” is the same as in the Model WHS laws, so practitioners who are familiar with this area will recognise this concept. The High Court has spoken about the concept on two previous occasions (see Slivak v Lurgi (Australia) Pty Ltd9 and Baiada Poultry Pty Ltd v R10).

reasonably practicable, in relation to a duty, means that which is, or was at a particular time, reasonably able to be done in relation to the duty, weighing up all relevant matters including-

(a) the likelihood of a safety risk, or damage to road infrastructure, happening; and

(b) the harm that could result from the risk or damage; and(c) what the person knows, or ought reasonably to know, about the risk or

damage; and(d) what the person knows, or ought reasonably to know about the ways of-

i. removing or minimising the risk; orii. preventing or minimising the damage; and

(e) the availability and suitability of those ways; and(f) the cost associated with the available ways, including whether the cost is

grossly disproportionate to the likelihood of the risk or damage.

In its earlier form, the HVNL included specific guidance about matters courts could take into account when assessing whether a party had or had not taken reasonable steps.11 To a certain extent those questions might assist in the assessment of what is reasonably practicable. However the shift to duties-based offences and the change in the onus of proof both require a different approach.

Codes of practice provide a further source of guidance about what might be reasonably practicable.

9 (2001) 205 CLR 304.10 (2012) 246 CLR 92.11 s 620-624.

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Codes of practiceRegistered Industry Codes of Practice establish standards and procedures for parties in the CoR to identify, analyse, evaluate and mitigate general risks associated with meeting obligations under the HVNL.

Codes of practice registered by the National Heavy Vehicle Regulator (NHVR) are published on its website and freely available. Compliance with a code of practice does not afford a party a defence to an offence. However the code may assist the court to determine what was generally known about industry hazards and methods used to minimise them.

632A Using code of practice in proceeding

(1) This section applies in a proceeding for an offence against this Law.(2) A registered industry code of practice is admissible as evidence of whether

or not a duty or obligation under this Law has been complied with.(3) The court may –

(a) have regards to the code as evidence of what is known about a hazard or risk, risk assessment, or risk control, to which the code relates; and(b) rely on the code in determining what is reasonably practicable in the circumstances to which the code relates.

(4) Nothing in this section prevents a person from introducing evidence of complying with this Law in a way that differs from the code but that provides a standard of safety or protection equivalent to or higher than the standard required in the code.

(5) However, the person may introduce the evidence mentioned in subsection (4) only if the person has given written notice of the person’s intention to do so to the complainant at least 28 days before the day fixed for a hearing of the offence.

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Executive officer liability

12 “Safety duty” is defined as a duty under ss 26C, 26E and 16 other offences in the HVNL.13 [1995] NSWIRComm 14.14 [2009] 2 All ER 645.15 [2012] WASC 15.16 (2003) 125 IR 361.17 [2015] ACTIR 1 (3 August 2015).

An executive of a legal entity that has a safety duty12 must also exercise due diligence to ensure the legal entity complies with the duty. The maximum penalty for an executive is the same as for an individual for the previously mentioned breaches.

An executive is defined broadly in s 26D(3):

executive, of a legal entity means-(a) for a corporation – an executive officer of the corporation; or (b) for an unincorporated partnership – a partner in the partnership; or (c) for an unincorporated body – a management member of the body.

The definition of “due diligence” follows the Model WHS definition, which has been the subject of substantial judicial consideration (see Dawson v Waugh13, R v Chargot Ltd14, Keating v Fry15, O’Sullivan v New South Wales Department of Education and Training16, Al-Hasani v Kenoss Contractors Pty Ltd (In Liq)17.)

Executives, partners and management members who knowingly authorise or permit conduct that constitutes an offence also commit the offence. These accessorial provisions are found in ss 636 – 638 and apply in respect of the hundred or so offences in Schedule 4 of the HVNL.

Prescriptive offencesIn addition to the overarching safety duty described in s 26, the HVNL maintains a large number of regulatory offences that apply to drivers and other parties.

Vehicle standards (Chapter 3)Heavy vehicles must comply with requirements in the Heavy Vehicle (Vehicle Standards) National Regulation and Australian Design Rules. Non-compliance is an offence.

Access (Chapter 4)Heavy vehicles that do not fit within prescribed dimension and mass limits are not allowed access to the road network without authorisation—whether this be an individual permit or in compliance with a gazetted notice. Travel without authorisation, or in breach of a condition of access, is an offence.

Mass, dimension and loading (Chapter 4)Where a vehicle exceeds mass and dimension limits or loading requirements prescribed in the Heavy Vehicle (Mass, Dimension and Loading) National Regulation, drivers and persons who permitted the use of the vehicle commit offences.

Fatigue management (Chapter 6)Drivers of heavy vehicles over 12 tonnes and some buses must comply with prescribed work and rest hours in the Heavy Vehicle (Fatigue Management) National Regulation. Drivers, schedulers and employers also have a range of obligations about recording work and rest hours in a Work Diary, retaining those records and monitoring driving hours.

The NHVR publishes a hardcopy Written Work Diary that summarises the work and rest hours rules and has space for drivers to record all prescribed details. NHVR-approved Electronic Work Diaries may be also used as an alternative.

Accreditation (Chapter 8)Operators who meet certain requirements about their management of fatigue, vehicle maintenance and mass management may be accredited in the National Heavy Vehicle Accreditation Scheme and are entitled to certain concessions. There are offences for failing to comply with requirements of participation in the scheme.

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Investigative and enforcement powers

18 Chapters 9 and 10.19 Immunity also applies to information obtained pursuant to ss 569(1)(c)-(f), 570(1)(a) and (b) or 577.20 Kird v Industrial Relations Commission (NSW); Kirk Group Holdings Pty Ltd v WorkCover Authority of

NSW (Inspector Childs) (2010) 239 CLR 531.

Authorised employees of the NHVR or its delegates and police officers may exercise powers18 to enter places and vehicles, obtain evidence, question persons and request documents. They have particular powers relating to stopping, inspecting and directing heavy vehicles at the roadside. The use of force against persons is restricted to police officers.

To support the investigation of the new safety duty offences, the amended HVNL introduces a compulsory information and evidence power in s 570A. This can only be exercised if an authorised officer reasonably believes a person is capable of giving information about a possible contravention of a safety duty or an executive officer’s due diligence obligations, or will assist the authorised officer to monitor and enforce compliance with those duties. There is an immunity clause for individuals who are compelled to give information under this section19. The immunity does not extend to companies.

Particulars of an offenceThe particulars of an offence must include the nature of the breach and the measures that should have been but were not taken.20

Relevantly for a breach of safety duty, it will be necessary to particularise that there were one or more measures that the defendant did not take which, if taken, would have eliminated or reduced the risk, and that those measures were reasonably practicable at the time stipulated in the particulars and the circumstances revealed by the evidence.

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Evidentiary considerations

21 Defined in s 5.

Division 2 of Part 13.3 has numerous specific evidentiary aides to proof for proceedings under the HVNL. These provisions are designed to complement the various evidence Acts of the participating jurisdictions, not replace them. Some of the aides to proof are:

• averments of certain information – s 710

• evidentiary certificate provisions – ss 711 – 716

• admissibility of transport and journey documentation21, and proof of information those documents contain – s 719.

• admissibility of evidence obtained in a different jurisdictions – s 726C.

InterpretationIn interpreting the HVNL, it is important to note that each jurisdiction has ‘disapplied’ the relevant Acts Interpretation Act. In lieu, the HVNL has its own interpretation provisions in Schedule 1.

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Sentencing

22 (2016) 93 NSWLR 338.

PrinciplesThe HVNL does not displace the relevant statutory sentencing provisions available in each jurisdiction.

In Bulga Underground Operations Pty Ltd v Nash22, in relation to WHS sentencing, the NSW Criminal Court of Appeal held that employers must take the obligations imposed very seriously. The community is entitled to expect that both small and large employers will comply with safety requirements. General deterrence is a significant factor when safety obligations are breached.

Fines and demerit pointsMaximum fines for offences are indexed and adjusted every year. These amounts are published on the NHVR’s website for all offences in the HVNL and its regulations. Other information shown includes the infringement penalty (10%) for infringeable offences and demerit points for a small number of fatigue and defective vehicle offences.

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Jurisdictional limitsDivision 1, Part 13.3 of the amended HVNL allows indictable offences23 to be brought either on indictment or in a summary way.

If proceedings are brought in a court of summary jurisdiction, a defendant can elect to have the charge/s prosecuted on indictment.

Further, if the court determines that the defendant, if convicted, may not be adequately punished in a court of summary jurisdiction, the matter may be referred to a higher court.

Each jurisdiction has its own statutory limits that apply to courts of summary jurisdiction.

Part 13.3 Legal ProceedingsDivision 1 Proceedings707 Proceeding for indictable offences

(1) The prosecution may bring a proceeding for an indictable offence-(a) on indictment; or(b) in a summary way.

(2) However, a court of summary jurisdiction must not hear and decide an indictable offence in a summary way if-(a) at the start of the hearing, the defendant asks for the charge to be

prosecuted on indictment; or(b) the court is satisfied-

i. after hearing submissions from the prosecution and defence at any stage of the hearing, that the defendant, if convicted, may not be adequately punished for the particular offence on a summary conviction; or

ii. on an application may by the defence, that the charge should not be heard and decided in a summary way because of exceptional circumstances.

(3) If the court decides that the offence be prosecuted on indictment-(a) the court must conduct the proceeding as a committal proceeding; and(b) any evidence given in the proceeding, before the court decided that

the offence be prosecuted on indictment, is taken to be evidence in the committal proceeding; and

(c) the court must disregard any plea that the defendant made at the start of the proceeding.

23 Indictable offence is defined as “an offence mentioned in s 26F (i.e. a Category 1 breach of primary duty). See s 5.

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707A Proceeding for the other offences

(1) The prosecution must bring a proceeding for an offence against this Law, other than an indictable offence, in a summary way.

(2) The proceedings must start-(a) within 2 years after the offence is committed; or(b) within 1 year after the commission of the offence comes to the complianant’s knowledge, but within 3 years after the offence is committed.

(3) A statement in a complaint for an offence against this Law that the matter of the complaint came to the complainant’s knowledge on a stated date is evidence of when the matter came to the complianant’s knowledge.

Additional sentencing ordersIn addition to the penalties prescribed for each offence, the HVNL has a number of other orders that a court can make. These include the following:

Commercial benefit penalty order – s 597If a court determines that a defendant derived a commercial benefit from the offending, the court may make a commercial benefit penalty order. This requires the defendant to pay, as a fine, an amount not exceeding three times the amount estimated by the court to be the gross commercial benefit.

Cancelling or suspending registration – s 598If the court convicts a person for a severe risk breach of a mass, dimension or loading requirement, or any other offence, the court may make an order cancelling, or suspending for a stated period, the registration of a heavy vehicle of which the person is a registered operator.

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Supervisory intervention orders – s 599Upon conviction, if the court considers the person to be, or likely to become, a systematic or persistent offender of this Law, the court may make an order requiring the person, at their own expense and for a stated period of not more than one year, to do any number of conditions that the court considers will improve the person’s compliance with the HVNL. Conditions can include appointing or removing staff, training and supervising staff, installing equipment for monitoring or managing compliance with the HVNL and have a person appointed to monitor the person’s compliance with the law.

Prohibition orders – s 607Upon conviction, if the court considers the person to be, or likely to become, a systematic or persistent offender of this Law and a supervisory intervention order would not be appropriate, the court may make an order prohibiting the person, for a stated period of not more than one year, from having a stated role or responsibility associated with road transport.

Compensation orders – s 611If damage is caused to road infrastructure as a result of an offence against the HVNL, the court may make an order to pay compensation to the road manager.

Injunction for noncompliance with notice – s 576EAn authorised officer may apply to the Supreme Court for an injunction either compelling a person to comply with a notice or restraining a person from contravening a notice. An injunction may be sought whether or not proceedings have commenced for non-compliance with the notice, or if a period for compliance for the notice has expired.

A court may also issue an injunction requiring a person to cease contravening the law.

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Enforceable undertakings – an alternative to prosecutionsEnforceable undertakings will be introduced as an alternative to prosecution. This is consistent with the Model WHS laws. They are not available for Category 1 offences.

An enforceable undertaking is a high-level statutory agreement that will only be used as an alternative to prosecution where the alleged offender can demonstrate to the NHVR their ability to undertake organisational reform and implement effective safety measures for transport activities.

While the court has no direct involvement in the negotiation and implementation of an enforceable undertaking, a court may be asked to adjourn proceedings while these negotiations take place. A court may also be required to adjudicate an offence of failing to comply with an undertaking.24

The defendant may, with the agreement of the NHVR or specifically authorised officers, enter into an enforceable undertaking at any time before a prosecution ends.

The NHVR’s decision to accept an enforceable undertaking, along with reasons for the acceptance, will be published on the NHVR website (www.nhvr.gov.au).

If the undertaking is breached, a discrete offence is committed, as well as having the effect that a court can make an order that the defendant comply with the undertaking or else discharge the undertaking (with associated costs of the proceedings).25

Publication of court outcomes The NHVR may publish information about court orders made upon a person’s conviction of an offence against the HVNL. Identifying details of the person or company may not be published.

The purpose of publication is to raise awareness of the provisions in the HVNL, to encourage operators to improve their safety and compliance, and to show examples of conduct that attracts the most serious penalties, as well as instances where genuine efforts at compliance have resulted in reduced penalties.

24 s 590B(2).25 s 590D.

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Glossary

ADR Australian Design RulesAFM Advanced Fatigue ManagementBFM Basic Fatigue ManagementCML Concessional Mass Limits (Schedule 2 MDL Regulation)CWD Container Weight DeclarationDMA Dimension Measurement AdjustmentEWD Electronic Work DiaryFRHV Fatigue Regulated Heavy VehicleGML General Mass Limits (Schedule 1 MDL Regulation)GVM Gross Vehicle MassHML Higher Mass Limits (Schedule 5 MDL Regulation)HV Heavy Vehicle – a vehicle over 4.5t GVMLRG Load Restraint GuideMDL Mass Dimension and LoadingMMA Mass Measurement AdjustmentNHVAS National Heavy Vehicle Accreditation SchemeNHVIM National Heavy Vehicle Inspection ManualPBS Performance Based StandardsRAV Restricted Access VehicleRTO Registered Training OrganisationSPV Special Purpose VehicleVSB Vehicle Standards Bulletin

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Contact usFor further information about the Heavy Vehicle National Law, please visit our website or contact us via:

Principal Prosecutor Regulatory and Legal Services National Heavy Vehicle Regulator PO Box 3448 Rundle Mall SA 5000

P 08 8214 9717 E prosecutions@nhvr.gov.au

www.nhvr.gov.au