Draft regulation Impact Statement for Underrun Protection a draft statement inviting discussion and comments from parties affected by the proposed heavy commercial vehicle safety initiative January 2007 Report Documentation Page
Option 3: Industry Code of Practice
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- Option 4: Australian Standard
- Option 5: State and Local Government Fleet Purchasing Arrangements
Option 3: Industry Code of PracticeCodes of practice are neither mandatory nor carry the force of the law. A code of practice for Underrun Protection (UP) could set out guidelines on what constitutes industry practice. The code would establish a common standard and expectations between different players. The Truck Safe program managed by the Australian Trucking Association is an example of an industry initiated safety accreditation scheme. Industry standards are established for four areas: health, vehicle maintenance, management and training. Operators must meet the standards set in these four areas for accreditation, be audited by an external auditor, and reviewed and accepted or rejected by an accreditation council. To date over six hundred transport companies have achieved safe accreditation. The program has been recognised as an excellent initiative and has helped operators improve their long-term viability. However, MMI Insurance in their submission to the House of Representatives Standing Committee on Communication, Transport and Arts inquiry into managing fatigue stated that: “Truck Safe operators are not better risks than any other group of operators; some are in fact the highest risk operators in the industry with the worst accident records to date.” MMI Insurance felt that the key problem is that the Truck Safe audit process does not audit many aspects of road transport law such as driving hours, driver schedules and vehicle compliance. If vehicle compliance could be included in Truck Safe, then it may also be able to include the provision of UP. Industry codes of practice are only effective if they are recognized and accepted by all concerned and if there are some rewards for complying and sanctions for non-compliance. Accordingly, industry and government needs to pay close attention to establishing suitable incentives for compliance so as not to diminish the effectiveness of a code of practice. Currently there are an estimated 47,000 businesses operating in the hire and reward part of the road freight industry, 98.5 per cent of which are in road freight operations and the remainder which are in the road freight forwarding sector. According to NTC estimates, there are 210,000 trucking establishments in existence of which 21 per cent belonged to the hire and reward sector and 79 per cent to the ancillary sector. It appears that Truck Safe coverage of the hire and reward segment of the road freight industry is below 10 per cent, and as such it may not be able to guarantee a high field application rate. In an effort to reduce collisions between heavy commercial vehicles and motorists resulting from the heavy vehicle not being seen by a motorist, particularly in poor weather conditions or hours of darkness, the Australian Trucking Association (ATA) introduced a code of practice for improving the visibility of heavy commercial vehicles. The Australian Heavy Vehicle Visibility Code of Practice is voluntary, sets guidelines for operators wishing to take advantage of the added safety of high visibility markings, and provides recommendations for the use of retro reflective graphics. It is based on UN/ECE Regulation 104 - Uniform Provisions Concerning the approval of Retro Reflective Markings for Heavy Vehicles and their Trailers. As a voluntary code of practice it cannot guarantee a high field application rate and enforce negative sanctions for non-compliance. As such this option is unable to meet the net benefit test and hence it will not be analysed for impacts on affected parties. The extent of coverage of the visibility code of practice across heavy commercial vehicle establishments is unknown at this stage and it would be useful if the ATA could advise the Department on the extent of coverage. Option 4: Australian StandardStandards Australia International Ltd (SAI) is a publicly listed company that develops and publishes documents setting out technical specifications or other criteria necessary to ensure that a device will perform as expected. As SAI is a non-government organization, the standards it promulgates are voluntary unless they are specifically incorporated into regulatory frameworks by governments. These standards are usually well-founded and comprehensive and so incorporation is not uncommon. Australian Design Rule 62/01 - Mechanical Connections between Vehicles incorporates a number of Australian Standards which include; AS 2213, AS 2175, AS 4235, AS 4177 and several others. SAI is a member of the International Organization for Standardization (ISO), and contributes to the development of and promotes compliance with international standards developed by the ISO. There are currently about 122,000 Australian Standards in operation. While there is scope for making use of an Australian Standard for provision of Underrun Protection (UP) for heavy commercial vehicles, no standard on UP is currently available. Developing Australian Standards with requirements specific for Australia would impose additional costs, especially for European sourced heavy commercial vehicles, as these are already compliant with UNECE R 93. The availability of UNECE R 93 for front UP makes this option redundant and so it will not be reviewed for impact analysis in Section 4. Option 5: State and Local Government Fleet Purchasing ArrangementsState and local governments purchase a considerable number of commercial vehicles to provide services to their rate payers. As such they are in a position to influence the configuration of heavy commercial vehicles entering their fleets. By insisting on the installation of Underrun Protection (UP) in their heavy commercial vehicles, governments would be introducing these in to the general fleet through resale, and setting a benchmark for others to follow. Currently, state and local governments purchase around 10 per cent of commercial vehicles and dedicated sub-contractors purchase another 10 per cent. Most of these are rigid vehicles. If government purchasing managers could influence the installation of UP, the uptake of front, rear and side UP could be more rapid that that which could be achieved through vehicle design rules, although what the final proportion in the fleet would be is not clear. Directory: barreirastecnicas -> pontofocal -> textos -> regulamentos pontofocal -> Ind- 2001 0382 nl- en regulamentos -> Kenya standard ks 06-77: 1978 ics 13. 340 Download 5.27 Mb. Share with your friends:
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