What should we expect from a National Heavy Vehicle Auditor?
Is your auditor providing the required assurance?
The first question is:
Are you getting a general audit or an audit under an existing scheme?
A financial auditor will have accounting qualifications and audit qualifications, but is this the same for your CoR, Trucksafe and NHVAS Audits?
NHVR – for NHVAS the current system does not require the auditor have credentials under the Australian Skills Quality Authority / Transport Industry Skills Council which develops the programs in consultation with both industry and the regulator themselves.
So why are we not seeing the Regulator specifying this as a key factor in credentialing a Heavy Vehicle Auditor?
CoR, Fatigue, Load/ Unload and Dangerous Goods credentials are an important part of an Auditors ability to review and recommend appropriate actions for a firm to act on to operate safely and within the laws.
This also ensures that the auditor is required to demonstrate through an accredited course that they understand the National Heavy Vehicle Laws across NHVAS areas of Mass, Maintenance and BFM and AFM as well as Codes of Practice that are now being touted as a Reasonable Steps defence by some Association bodies.
So its clear. …….NHVR Audits are only to verify that the Transport Company with the NHVAS accreditation, is complying with the relevant NHVAS requirement. This is not an audit for compliance under the National Heavy Vehicle Law.
Codes of Practice Audits are a starting point for a company to demonstrate they are undertaking “Reasonable Steps” with Chain of Responsibility and is mapped against the National Heavy Vehicle Law which considers CoR areas such as Speed, Fatigue, Mass, Dimension, Load/Unload and Maintenance.
Mandating that the auditor demonstrates competency through an accredited course for COR, Fatigue, Load / Unload and Dangerous Goods is a good starting point to ensure consistency in results by Auditors.
If we look at the National Landscape and the groups requiring Auditors such as the National Heavy Vehicle Regulator, Australian Logistics Council and the Australia Trucking Association to determine compliance for codes of Practice, NHVAS and TruckSafe, it makes sense to map a proper set of national standards for Auditors and allow them to work across all areas and not be restricted to just one scheme.
Currently under all three systems it is not clear that the person undertaking the audit has two demonstrated skills:
- Independently assessed competency in the area of audit
- Independently assessed competency on how to audit a system
So the question has to be asked, how can you be sure the advice from the auditor, without a proper credential, is:
- Based on a proper understanding of the law
- Correct improvement based on a correct understanding of the National Heavy Vehicle Laws
- Going to provide a reasonable steps defence under the National Heavy Vehicle Law
So ……..What do you specify you want the auditor to audit and what credentials do you make sure they have to enable a result that is ?
We have seen training material that is clearly over 10 years old being used to support training on National Heavy Vehicle Laws which is clearly wrong.
Similarly we have seen audits with 100% pass rate, which were clearly not a representation of the non conformance of the Transport Company.
Clearly the audit framework are in need of review if it is to provide assurance to clients, to the regulator and enforcement agencies as well as the community that these groups are operating safely.
So what can you do before you allow an auditor on your site?
If you just want just document that says you are perfect then….hire whoever you like. It’s no comfort in a court of law when you have killed someone.
If you just want compliance, hire an auditor without demonstrated competency through accredited training who can only comment on the checklist they are given to check off against. Remember …..Just because the industry participants have an audit framework does not mean the framework is being audited properly and it certainly does not exempt a person in the chain of responsibility from prosecution.
If you want to improve your systems and work towards eliminating hazards consistent with WHS and NHV Laws, then you need to ask you auditor to:
- Show you their audit qualification
- Show you the evidence of formal qualifications in the area of audit
- Explain how the auditor’s accreditation will support the audit
- Show the audit framework they have used
- Provide references from past customers of how the audit outcomes have improved the business
This is certainly a better way of staying out of jail, out of the regulators prosecution sights and off the front page of the newspapers.