The concept of a nationally consistent based risk-based inspection system replacing a fragmented state-based system is appropriate for an industry with operators providing services to a national economy and registering vehicles in several different jurisdictions. This is an issue that has been discussed since 2015, and most recently in 2022.
ALC remains supportive of the proposition that the level of vehicle inspection should be tied to operator performance (including operator history) normalised for the size of the operator’s fleet.
It agrees with the risk assessment methodology proposed on pages 14 and 15 of the Paper and generally agrees the accompanying risk factor category and category variable weighting summary set out in Table 3 of the Discussion Paper, although care needs to be taken that gathering evidence to determine operator risk is not too time consuming and costly relative to any improvement in safety outcomes.
For instance, proving to the regulator that the implementation of an SMS ‘truly represents a culture of safety and proactive risk management’ could involve significant time and cost on an operator if providing evidence to show a compliant culture is given a moderate to high weighting in developing a risk score. The associated costs and benefits should be thoroughly examined, particularly concerning the weight given to a compliant culture in developing a risk score. Furthermore, recognising the concerns of transport operators regarding data sharing, the ALC emphasises the importance of addressing potential risks associated with unintended use of information. Confidentiality, competitive advantage, and proprietary considerations may contribute to operators' reluctance to provide specific data.