In its third submission to the National Transport Commission's HVNL review project, the CVIAA, representing over 1,300 member companies and 80,000 workers in the heavy vehicle industry, outlined 13 key recommendations for comprehensive reform. The submission marks the latest development in a five-year review process that many industry insiders say has progressed too slowly to meet the sector's evolving needs.
Among the most significant proposals is the establishment of a dedicated Heavy Vehicle Safety Office to oversee fleet safety performance and develop industry guidelines. The CVIAA argues this would fill a crucial gap between the National Road Safety Strategy and best practices for in-service vehicles. The proposed office would be tasked with determining fleet safety performance, developing technical guides, and liaising with the operator community to enhance safety outcomes.
The association has also highlighted the urgent need for a national Approved Vehicle Examiner (AVE) scheme, noting that current disparities between jurisdictions are "intolerable." Queensland's scheme differs fundamentally from other participating jurisdictions, creating inconsistencies in vehicle modification approvals across the country. The CVIAA's submission emphasises that this disparity has been a point of discussion with the National Heavy Vehicle Regulator (NHVR) for nearly a decade, with no substantial progress made.
"The reform proposals for the HVNL are limited in scope, and mainly focussed on regulatory flexibility and efficiency," the submission states. "The review process has failed to deal with many existing problems, challenges and opportunities that the industry experiences."
A particularly pressing concern highlighted in the submission is the absence of a national Written-Off Vehicle Register for heavy vehicles. Currently, New South Wales and South Australia stand alone as the only jurisdictions maintaining such a register, leaving a significant gap in vehicle safety oversight across the rest of the country. The CVIAA argues this oversight leaves purchasers vulnerable, as damaged heavy vehicles can be repaired and sold without disclosure or independent approval processes.
The submission also addresses critical workforce competency issues, proposing:
- Introduction of minimum competency requirements for heavy vehicle repairers
- Development of new accreditation standards for authorised officers
- Creation of a NHVAS productivity module to support Australia's emissions reduction targets
- Establishment of appeal processes for enforcement decisions
- National technical standards for specific vehicle types including tow trucks, crane trucks, and school buses
The CVIAA emphasised that with the average age of heavy motor trucks at 17 years, the industry faces significant challenges in dealing with accelerating technological change. This extended vehicle lifespan means workshops and suppliers must maintain expertise across an increasingly broad range of technologies, highlighting the need for improved access to training and technical information.
In a notable focus on environmental concerns, the submission addresses Australia's commitment to a 43% reduction in greenhouse gas emissions by 2030. The CVIAA notes that the current reform project is "silent about productivity and fuel efficiency" despite the transport sector's significant role in emissions. To address this, the association proposes a new productivity module within the National Heavy Vehicle Accreditation Scheme (NHVAS), which could help identify and recognise best practices in fuel efficiency and productivity.
The submission also calls for reform in emergency situations, particularly regarding driving hour limitations for recovery operators. The CVIAA highlights specific challenges faced by operators in remote areas, such as the Nullarbor Plain, where complex recovery operations often conflict with current driving hour restrictions.
The National Transport Commission's HVNL review process will continue, with the CVIAA expressing hope for more dialogue on its recommendations in the next phase of the project. The association's comprehensive submission underscores the complexity of modernising heavy vehicle regulation in an era of rapid technological change and increasing environmental pressures.
Download the submission here: 2024 CVIAA submission on HVNL.pdf