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CTS AUDITING SERVICES Warren J Gibbs Reply to NTC Accreditation ...
CTS AUDITING SERVICES Warren J Gibbs Reply to NTC Accreditation Review Draft Policy Proposal 3rd December 2007 First impression: Staggered by the content and timing of the release of this “confusing and difficult to decipher” document into the public arena. Given the fact that the Fatigue module is less than 12 months away, how does NTC expect to promote confidence in a new and much heralded important module when accreditation & NHVAS is seen to be in the middle of a major review and the future of the programs as we know them is not certain.. Your document language and content is confusing operators and other readers and may effectively put the brakes on accreditation and NHVAS take up and credibility after a lot of work by a lot of people to get these important tools and products off the ground in the last few years. I applaud the NTC desire to have one NATIONAL single accreditation framework but it cannot be controlled by private enterprise, it must be presided over by government authority and regulation. I draw my comments, constructive criticisms and alternative proposal suggestions from 25 + years personal experience in most aspects of heavy vehicle manufacture, sales and road transport operations including working in NZ and North America in the road transport Industry. I also have local experience in four areas of accreditation for heavy vehicles: 1. Developing systems, implementing and supporting those systems; 2. Ensuring the developed systems, implementation and support process used, pass the scrutiny of approved NHVAS & HVA Certified Auditors and State Monitoring and Accreditation Agencies; 3. Conducted triggered reviews on pilot programs for jurisdictions; 4. Conducted/observed NHVAS and HVA audits on other implementers systems. The road transport industry in Australia seems unable work together to create and sustain effective self regulation, with many differences of opinion in the decision making board rooms within the industry and regulators not firm enough, or consistent, in their requirements (ground rules). The carrot & stick approach alone is not the answer, road transport in this country is a fickle, suspicious, non embracing industry that may need to be TOLD WHAT TO DO because they never agree amongst themselves, just as jurisdictions do not agree and that’s why it may be said that the only thing National about NHVAS is the name??. Every state takes the so called national program and are allowed to put their own political spin on it before sign off by a Minister who probably doesn’t know very much about the legislation and who’s only concern is “will it cost me /us votes”?. The result of this is that transport operators have to jump through different hoops as they travel through each state because there is little or no uniformity, co-operation or communication between the states jurisdictions. Accreditation could work effectively if the framework and focus embraces and includes the following: 1. Firm & mandatory Federal & State Govt regulatory requirements; 2. Accreditation to offer commercial benefits to all accredited operators - that are not available to non accredited operators; 3. Accreditation to be user friendly and valued; 4. Accreditation must be seen to have credible systems implementers auditors monitoring agencies; 5. Accreditation standards need beefing up – more descriptive – to prevent multi interpretation; 6. A mechanism in place for accommodating accreditation Business Rules/Standards changes in a timely fashion. MUST HAVES: It is my opinion that effective road transport accreditation systems must have 1. Independent Govt control & overall supervision of the programs in conjunction with jurisdictions and industry representatives; 2. Independent and accountable, Certified systems implementers (it is a business profession) who have their systems and procedures approved by stakeholders/jurisdictions and are subject to a strict code of conduct; 3. Independent Certified auditors who are professional, ethical, accountable, have industry knowledge; 4. Effective, experienced and well resourced jurisdiction/NHVAS monitoring agencies so that accreditation does impact on the transport workplace, the public and road safety in a positive manner in each participating state; 5. Competition in the market place with a choice of programs and suppliers so that operators have a choice and can tailor the accreditation to suit their needs and their budget OR make accreditation for Fatigue – Maintenance – Mass mandatory as part of the registrations requirements for commercial vehicles > 4.5t GVM – nationally; IF ACCREDITED VEHICLES ARE AS SAFE AS YOU SAY THEY ARE WHY WOULD YOU NOT MAKE ACCREDITATION MANDATORY FOR ALL COMMERCIAL VEHICLES? 6. Stakeholders in conjunction with jurisdictions and industry representation should be able to recommend and make changes to existing accreditation rules and regulations within a reasonable time frame; Trucksafe: Good concept – poor marketing – too much paperwork (industry comments / not mine). Throughout the NTC document there is a lot of positive spin written about the benefits and effectiveness of the Trucksafe Program and modules. If the Trucksafe Programs were so bloody good they would be swamped with operators wanting to get on board and NHVAS or anyone else would not get a look in. Trucksafe seem desperate to regain the ability to offer their members the exemption from annual pit inspections (in the applicable states). Since losing that exemption Trucksafe appears to have lost members to NHVAS or they simply dropped out of accreditation Trucksafe is seen to be a total management package (whether you need it all or not) and many operators tend to believe they do not need a total package and see NHVAS as a good alternative where they can select the module they need and utilize other acceptable industry packages/practices to comply with the regulatory requirements of the day very effectively. Many operators have effective, alternative health, training, management procedures in place The NTC appears to want to divest itself of the NHVAS responsibility and appears to have been convinced by Trucksafe management/board that a single accreditation framework is the way to go (with Trucksafe steering and controlling the ship). Industry representation is ok – industry control is not? Trucksafe is gleaning all of its positive statistics from NTI their insurance partner who are probably the only local insurer to have these statistics at this time. There are other insurance companies that have now built the requirements for NHVAS and Trucksafe accreditation into their risk assessment procedures also. Focus for road safety and continual improvement should be concentrating on the differences between “accredited & non accredited” vehicle results and not on which scheme you are accredited to, if the schemes are approved by the regulators. Suggested reasons for lack of uptake of accreditation to date: NHVAS: 1. Extremely poor marketing by stakeholder and jurisdictions. Next time you get the opportunity ask a transport inspector about NHVAS and the benefits for all players. I can just about guarantee you will be disappointed with the answer. When the NHVAS modules were released in 2001 the doors were thrown open at jurisdictions in anticipation of the rush for applicants but no one was really told about it and there was no effective marketing campaign. Operators were not told and did not understand about commercial benefits of accreditation, thought it was just another big stick to belt truckies with; 2. When NTC and jurisdictions talk about becoming accredited to NHVAS they infer that it’s as easy “as falling off a log”. Simply a matter of getting the “Do it yourself Kit “from the Jurisdiction – putting it in pace – creating a policy and procedures manual – a few templates and away you go – ready for an audit etc etc. To do accreditation properly and effectively most operators need professional assistance. Most of the operators we have dealt with in the last 3 years all went and picked up a copy of the NHVAS kit or brochure and after reading through it they decided it was too hard and the info pack was duly filed into a drawer for ever or until an implementer came on the scene. 3. A few transport operators with poor compliance history and questionable maintenance practices have gained and retained accreditation – simply to avoid the annual inspections - through luck, lack of audits or “soft audits”, lack of roadside checks etc and have reduced the value of having NHVAS Accreditation to zero in the eyes of other operators. 4. Exorbitant charges for implementation and very poor systems implemented by inexperienced and “part time consultants” have cheapened the value of NHVAS Accreditation. Some NSW owner drivers have paid up to $4500 + audits + NHVAS Fees for single unit Mass accreditation by interstate implementers while others have failed their 6 monthly audit because they didn’t have compliant systems in place and were not properly trained in the requirements of accreditation re quarterly reviews etc where the implementer did a hit and run job after day 1. 5. Most operators need the assistance of a professional, ethical, industry savvy systems implementer to effectively design, implement, and monitor the operators’ accreditation. This saves the operator a lot of time, frustration and cost by putting the right systems in place first time and getting the accreditation process completed quickly and efficiently. Implementation should include all aspects of the operators’ needs from initial plan thru to accreditation approval and also on going review support. There needs to be at least a basic certification process for systems implementers as this is a full blown profession and we are dealing with workplace, road safety and heavy vehicles. If the implementer gets it right and knows and does what is required for compliance then the whole accreditation process is effective, streamlined, compliant and auditable - from the start. Implementers should be required to present their systems and procedures (sample kit and explanation) to stake holders (or at least jurisdictions where they implement) so that it can be determined that their systems and procedures are in fact compliant. Implementers would then be certified or otherwise and accountable via a Code Of Conduct. This would reduce the likelihood of deliberate non compliant systems being implemented, (accountability) family members/partners rotating the implementing and auditing process to keep non compliant operators accredited and would raise the bar for accreditation generally. IT IS A SERIOUS BUSINESS – NOT A PART TIME JOB?? 6. Some jurisdictions have not effectively monitored their accredited operators in the past and this also allows non compliant operators to retain accreditation and share the same benefits as compliant operators. This results in non accredited genuine operators treating NHVAS as a joke and not understanding that there are real commercial benefits. With active roadside checks and triggered reviews and audits NSW Roads & Traffic Authority has lifted the industry profile of NHVAS significantly over the last 12 months. Vicroads admit that they have not effectively monitored the NHVAS programs in the past and are aware that some operators are way past their audit due date and yet are still accredited. In NSW the operators’ accreditation may be automatically suspended if the compliance audits are not received on time. This is how effective monitoring and enforcement should occur. Some jurisdictions offer additional mass benefits without the requirement for NHVAS Mass thereby nullifying the benefit of accreditation in that state (for some units) but causing all sorts of chaos when the operator crosses the state border with the same payload without accreditation. 7. It is inferred by Trucksafe that their auditing systems and process is more effective because they control the who when and where of auditors of their programs. I believe a professional ethical auditor should (as in other industries) be able to deal directly with the operator and this does not lessen the effectiveness of nor undermine the integrity of the audit process. Considering the anguish and arguments displayed by Trucksafe auditors at the recent Trucksafe Auditors Conference 13th Nov 2007, regarding the low audit fees paid by Trucksafe, it seems that Trucksafe are either not charging industry rates for a professional service or they are retaining too large a share of the fee for Trucksafe revenue. 8. Fees for NHVAS: Professional implementers are able to calculate reasonable accurately the cost per unit per year for NHVAS accreditation (over each 2 year period – inclusive of audits etc) and can outline any savings and additional revenue available to the operator from being accredited. Most jurisdictions charge a minimum admin fee per unit yet even with this minor expense there is no uniformity. SA does not charge anything – so do they put a value on NHVAS Accreditation, like wise for Vicroads if you are accredited to 2 programs at once you only pay one lot of fees and on renewals fees are not payable. NHVAS PROGRAMS PROVIDE SIGNIFICANT COMMERCIAL BENEFITS TO OPERATORS IN MOST STATES AND IF SOMETHING DOES NOT HAVE A FEE THEN IT IS NOT VALUED??. The NHVAS fees displayed in the draft paper for NSW are incorrect?, the current operator fee is $79 for 2 years – payable once only on initial joining and unit accreditation fees are $26 per module – per 2 years. I f something as simple as this is incorrect I have to wonder about the crash statistics. 9. Costs of Implementation: As is the case with auditing it is not practicable to put a fixed price on Accreditation (Trucksafe try and fail) each operator is different, has different needs and costs more or less to implement systems for. Most operators who understand the requirements and commercial benefits of NHVAS Accreditation have no problem with paying systems implementation and support costs based on a breakdown of cost per unit per year. There is also an affordable accreditation kit available for owner drivers and small fleets. Unfortunately most operators are not aware that advice is available on costs of accreditation and all they hear is how their mate was ripped off, so they do not become accredited. Trucksafe: Only Trucksafe management can honestly answer why members drop out or have not taken up membership: is it partly because: 1. Trucksafe cannot offer the (Maintenance) exemption from Annual Inspection (where it applies)?; 2. The total package is too cumbersome, time consuming and difficult to administer quickly, especially for small to medium operators. They can’t afford the admin time; 3. The Trucksafe package is not sold, implemented and supported effectively in the field?; 4. Is Trucksafe perceived as private enterprise – another trucking association that is struggling to survive – one went bust not long ago in NSW. Summary NTC seems to be terrified of Enforcement Based Strategies. You are allowed to raise your voice when it is warranted – provided you know what you are talking about and it is something the industry NEEDS?. When it’s a safety related outcome that can be achieved, the players need to be told (guided forcefully) what is the requirement and how and when it is to be achieved. This should be accepted by the players as an integral part of their compliant participation in that industry. Firm guidance can be linked to incentives at the same time. Why doesn’t the NTC focus on the real issues. They have been requested (on several occasions) to review the mass management standards to make it easier for accredited operators and all others involved, to understand the basic requirements. It is little wonder that there are so many different interpretations of the rules/regulations/standards between jurisdictions and operators. Instead of just looking at crash data, without a demonstrated causative relationship, why don’t the NTC “get pro active” and look at some credible data such as (compliance history) defect notices and weight breeches issued to accredited and non accredited vehicles by jurisdictions. These statistics are directly related to the effectiveness of accreditation also. As a matter of urgency the NTC should develop a Code Of Conduct for Systems Implementers. Ensure the Code Of Conduct for auditors is effectively monitored to prevent auditing of own systems and any other deliberate breeches of the code. Compiled and written by Warren Gibbs CTS Auditing Services 3rd Dec 2007
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