●Transport

Chain of Responsibility Assurance

Chain of Responsibility obligations sit with every party in the transport chain, not just the driver. CMG builds the assurance framework that shows a business took reasonable steps: documented controls, verification of what schedulers and drivers actually did, and escalation when it did not happen.

●What's Included

Scope of work

  • CoR party mapping (you may be more than one party)
  • Executive due diligence evidence pack
  • Fatigue, speed, mass, dimension, load restraint and maintenance verification
  • Scheduler versus actual hours reconciliation
  • Breach, exception and near miss register with escalation
  • Contract and subcontract flow-down that does not pretend to shift the duty
  • Training, induction and acknowledgement records
  • Monthly leadership exception report

Who this is for

  • Operators and prime contractors
  • Schedulers and employers of drivers
  • Consignors, consignees, packers, loaders, unloaders and loading managers
  • Executives with a personal due diligence duty under HVNL s26D

What changed on 1 August 2026

  • The amended Heavy Vehicle National Law commenced on 1 August 2026 in NSW, Victoria, Queensland, South Australia, Tasmania and the ACT. WA and the NT sit outside the HVNL.
  • NHVAS closed to new applicants on 1 August 2026 and is being progressively replaced by the Heavy Vehicle Accreditation (HVA) scheme. Existing NHVAS accreditations remain valid until expiry, with a transition period of up to three years. An operator can only be accredited in one scheme at a time.
  • HVA introduces a tiered framework: General Safety Accreditation (GSA) is the core requirement, and Alternative Compliance Accreditation (ACA) provides flexible pathways for Mass and Fatigue. GSA is a prerequisite for ACA.
  • Accreditation is no longer audited module by module. Operators are audited against a whole-of-business Safety Management System under the ministerially approved SMS Standard 2026, across five categories: Leadership and Commitment, Risk Management, People, Assurance, Monitoring and Improvement, and Safety Systems.
  • The audit test is now PSOE: the system must be Present, Suitable, Operating and Effective. A folder of policies is not enough; auditors look for the system working in daily operations, and SMS audit findings are admissible in court.
  • Maintenance accreditation remains: GSA plus additional maintenance requirements gives access, and accredited operators stay exempt from annual vehicle inspections in applicable states.
  • Core mass management requirements continue within the new schedules, and operators seeking Higher Mass Limits access must still meet them. PBS access requirements are unchanged.
  • ACA Fatigue replaces BFM and AFM, with templated Tables of Hours published by the NHVR to reduce the work of preparing bespoke work and rest hours.
  • A new duty not to drive while unfit to drive now covers every heavy vehicle over 4.5 tonnes, not just fatigue regulated vehicles over 12 tonnes. Unfit includes illness, injury, mental health, medication, alcohol and drugs, and drivers can lawfully refuse to drive when unfit.
  • General Mass Limits rose to the old Concessional Mass Limits levels, and general access length increased from 19 to 20 metres.
  • More than 70 penalties changed, with higher CoR safety penalties and no grace period: accredited operators were expected to be compliant from day one.
  • The primary duty under the HVNL still sits with every party who influences the transport task. It cannot be contracted out.

What this means for your business

  • If you hold NHVAS accreditation, know your expiry date. The NHVR contacts operators directly, and extensions are considered case by case where more time is needed to transition.
  • If you are seeking new accreditation, you enter under HVA: build the SMS first, then prepare for an independent entry audit.
  • If you are a principal, consignor or scheduler, the expanded unfit to drive duty and higher penalties reach your contracts, rosters and site rules, whether or not you own trucks.
  • CMG builds the SMS and the CoR evidence framework; the official HVA audit is conducted by an independent NHVR-approved auditor, not by CMG.

Important: Accreditation and documented systems support due diligence. They do not transfer or remove duties under the Heavy Vehicle National Law. Official HVA audits must be completed by an NHVR-approved auditor independent of the system author. CMG builds and implements the system; it does not conduct official HVA scheme audits.

Ready to take control of the operation?

Request our capability pack, which includes the operating model, service scope, compliance approach and sample reporting outputs, or book an operational assessment.

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