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CTS AUDITING SERVICES Warren J Gibbs Reply to NTC Accreditation


CTS AUDITING SERVICES Warren J Gibbs Reply to NTC Accreditation ...

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									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
                                                                    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
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
          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
       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;

     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
     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:

  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.

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
   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.

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

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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