Chain of Responsibility
Hey, I’ve got a few questions around storing goods in my warehouse. What the dickens am I supposed to use as far as bits of timber dunnage, pallets, boxes, cages, plastic bins? Can someone give me a guide to the know-how on retaining product according to Australian Standard AS 4068 – 1993 pallet standard and in-keeping with Pallet Racking Australian Standard AS 4084 – 2012.
And once I have sorted out which cage or box or pallet to use, who can help me about strapping or restraints? Is there such a thing as re-usable strapping systems? And is steel strap allowed to be used when goods are dispatched? How do I know that my strapping won’t come loose during transportation? I have seen some straps use metal clips, some use plastic clips or buckles, and some seem to simply have a melted joint.
I have also had information given to me that heavy duty plastic that is heat-shrinked around a pallet is deemed an acceptable restraint method: is this correct?
Besides all this I have guys telling me about chain of responsibility in my warehouse and when I dispatch gear I am also responsible…is this true? Seems crazy – doesn’t it?
Are you saying that if we consign or pack or load or receive goods as part of our business, we could be held legally liable for breaches of the Heavy Vehicle National Law?
The answer is yes.
According to the National Heavy Vehicle Regulator (HVNR) website, the following parties are all examples of parties in supply chain:
• prime contractors of drivers
• the operator of a vehicle
• schedulers of goods or passengers for transport in or on a vehicle, and the scheduler of its driver
• consignors/consignees/receivers of the goods for transport
• packers/loaders/unloaders of goods
• loading managers (the person who supervises loading/unloading, or manages the premises where this occurs).
• corporations, partnerships, unincorporated associations or other bodies corporate
• employers and company directors
NHVR is subscribed to by 6 of the 8 states/territories in Australia; these are ACT, NSW, QLD, SA, TAS, VIC.
Western Australia (HVO) and Northern Territory (NHV) have their own statutory bodies, that govern these standards in those regions.
In documentation on the WA Main Roads website, the following outline is made clear:
‘There is no real change for drivers but now there are more people responsible along the ‘chain’. If you are involved in any of the following ‘road transport activities’, you are a party in the ‘chain of responsibility’ and may be deemed liable in the event of a breach of the road laws:’
• Consigning – a person or company commissioning the carrying of goods
• Packing – placing goods in packages, containers or pallets
• Loading – placing or restraining the load of the vehicle
• Driving – the physical act of driving a vehicle
• Operating/Managing – operating a business which controls the use of a vehicle
• Receiving – paying for the goods/taking possession of the load’
‘So, in simple terms it means that anyone who has control in the transport chain can be held legally accountable if by action, inaction or demand, they cause or contribute to road safety breaches. All persons within the Chain of
Responsibility need to demonstrate (within their own roles):
• They had taken all reasonable steps to prevent a breach;
• There were no reasonable steps they could have taken to prevent the breach; and
• There was no way they could reasonably be expected to know about the breach.’
Read more at www.mainroads.wa.gov.au/UsingRoads/HeavyVehicles/Compliance/Pages/CoR.aspx or email email@example.com to be sent additional information.
As a result of more persons deemed as being part of Chain of Responsibility, much more attention is being given to the type of pallet or stillage or cage or bin that is being used to pack product.
Instead of using a pine or hardwood pallet, where there can be concerns around timber pallets potentially having boards come loose, and thus causing the strapping or restraint system to lose its tension, there are now instances where engineer-rated steel pallets are required to cover all stakeholders in the Chain or Responsibility. This is especially the case where equipment needs to be sent off-site to be maintained or repaired. The Omni-tuff engineer-rated steel pallets offer a more cost-effective option to sites so that instead of the need to engage an consultant to design and engineer a cradle or dolly for each individual piece of equipment, this range of rated pallets can be used to handle multiple shapes and sizes with correct lugs and heavy duty construction. There are 1T, 2T, 3T and 6T, dimensions range from half pallet size, through standard 1165×1165, to double width size, and even going as large as 2330mm x 1500mm.
Others’ actions can often cause breaches; complying with transport law is a shared responsibility and all parties in the road transport supply chain are responsible for breach prevention. This is called CHAIN of RESPONSIBILITY (CoR).
Read more about the Chain of Responsibility (NHVR website) or request additional information to be sent to you by emailing firstname.lastname@example.org
If you consign, pack, load or receive goods as part of your business, you could be held legally liable for breaches of the Heavy Vehicle National Law.
Another source of regulatory information is the Load Restraint Guide, which is collated and published by NTC. Within this guide, is a section on Performance Standards.
This section outlines the standards around goods not becoming dislodged from the vehicle. Loads must be adequately restrained to prevent unacceptable movement. There are certain specific focus areas, such as horizontal movement, vertical movement, and so on.
For more specific information refer the Load Restraint Guide document.
In the Load Restraint Guide, there is also guidance as to suggested methods of testing a load restraint system. There is details as to tie-down systems, and also direct restraint systems.
So, there are options around rated ratchet strap systems – with various ratings and various lengths.
In a warehouse situation, (and not on the back of trucks) there can be the option to utilise the quick-release 50mm wide CamLock strapping systems, and these are a colour-coded system, rated at 500kg per strap and in 3m, 5m, or 7m lengths. However, the CamLock is not usually deemed correct load restraint method for transportation of product.
For more information on Chain of Responsibility (CoR), contact the team at Omni-tuff Group to arrange a technical consultant to make contact with you and your team.
1300 662 987