Chain of Responsibility Checklist
A Chain of Responsibility Checklist is a document used by parties in the heavy vehicle supply chain to verify they are meeting their legal safety duties under the Heavy Vehicle National Law and WHS Act.
A practical tool to help businesses in the heavy vehicle supply chain identify and manage safety risks under Australian law.
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About this Document
A Chain of Responsibility Checklist is an essential document for any Australian business that is part of the heavy vehicle transport supply chain. This includes not just truck drivers and transport companies, but also consignors, consignees, packers, loaders, schedulers and even those who manage the premises where heavy vehicles load or unload. The Chain of Responsibility laws, often referred to as COR, exist to ensure that everyone who shares responsibility for the transport task shares responsibility for safety. The checklist is the tool you use to make sure you are doing your part to comply with the Heavy Vehicle National Law (HVNL) and related state and territory laws. Under Australian law, a person is a party in the chain of responsibility if they have a role in the transport task. This means they have control or influence over the transport task. If you ask a driver to deliver goods by a specific time that is impossible to meet without speeding, you are breaching the law. If you pack a pallet so poorly it falls over and injures the driver, you are responsible. If you load a vehicle that is too heavy for the axles, you are liable. The checklist helps you identify these risks before they become problems. The primary piece of legislation governing this area is the Heavy Vehicle National Law (HVNL). While the law applies in specific states, other states have adopted mirror legislation that achieves the same outcome. The National Heavy Vehicle Regulator (NHVR) is the body that administers these laws. The checklist helps you comply with Section 26 of the HVNL, which states that a person must not cause or direct the driver of a heavy vehicle to breach the law. It also covers Section 27, which prohibits recklessness regarding breaches. The checklist serves as a record. In Australia, business owners and officers can be held personally liable for breaches of the law. This means you can be fined, lose your license, or in extreme cases, go to prison. Having a completed checklist shows that you have taken reasonable steps to prevent breaches. It demonstrates that you have systems in place and that you have used them. You need this document whenever you engage with the heavy vehicle transport industry. If you are a manufacturer sending goods to a distributor, you need it. If you are a farmer receiving fertilizer, you need it. If you are a construction company moving excavators between sites, you need it. If you own a warehouse where trucks load or unload, you need it. Completing the checklist involves a step by step review of your transport activities. You start by looking at scheduling. Are your deadlines realistic? Do they force drivers to speed or skip rest breaks to meet them? You then look at loading and packing. Are your staff trained to secure loads correctly? Do they check the weight distribution? You look at the premises. Is your yard safe for trucks to manoeuvre in? Are there overhead obstructions? You look at maintenance. If you own the truck, is it serviced? If you lease it, do you have records of its service history? The checklist prompts you to ask these questions. It asks for dates, names and specific actions. It is not enough to just say you are safe. You must prove it. The legal requirements are strict. The concept of Reasonable Steps is central to the defence. If you are accused of a breach, you must prove that you took all reasonable steps to prevent it. The checklist is the evidence of those steps. Without it, you have no defence. You must also be aware of your obligations under the Work Health and Safety Act 2011 (WHS Act). The WHS Act imposes a primary duty of care on a person conducting a business or undertaking (PCBU) to ensure, so far as is reasonably practicable, the health and safety of workers. This includes drivers who come to your workplace. COR and WHS laws work together. They both aim to stop people from being hurt. Common mistakes to avoid include leaving the checklist blank, filling it out months after the event or lying on the form to get the job done faster. Another common mistake is assuming that the transport company is responsible for everything. This is wrong. The law looks at who has control. If you control the loading, you are responsible. If you control the schedule, you are responsible. Australian Standards also play a role. Standards like AS/NZS 4377 provide guidance on load restraint. Your checklist should reference these standards to ensure your methods are up to date. The Fair Work Act 2009 is also relevant regarding driver fatigue. Drivers must be paid for all hours worked, which includes loading and unloading time. If you pressure a driver to work excessive hours to meet your deadline, you may be breaching industrial laws as well as safety laws. The Australian Tax Office (ATO) requires you to keep records for business purposes. While COR checklists are safety records, they also relate to the operation of your business. The checklist should be stored with your other important business documents. You should keep them for at least seven years. ASIC rules apply to company directors. Directors have a duty to exercise due care and diligence. Ignoring COR safety obligations could be seen as a breach of this duty. To use this document effectively, you should make it part of your daily routine. Do not treat it as paperwork that you do once a year. Every time a truck comes in or goes out, the relevant part of the checklist should be reviewed. You should assign a responsible person to oversee this. This might be the warehouse manager or the logistics coordinator. You should train your staff on how to use it. They need to understand why it matters. They need to know the questions to ask. The checklist should be clear and easy to read. Avoid jargon. Use plain English. If a hazard is identified, you must take action immediately. Do not load the truck until the weight issue is fixed. Do not send the driver out until the load is secured. The checklist is a trigger for action. If you tick a box that says no, you must have a follow up process. In summary, a Chain of Responsibility Checklist is a vital protection for your business and your staff. It helps you navigate the complex legal of heavy vehicle transport in Australia. It protects you from heavy fines and legal action. It ensures that everyone goes home safely at the end of the day. It promotes a culture of safety rather than a culture of speed. By implementing this checklist, you are demonstrating that you are a responsible member of the supply chain. You are showing that you understand your obligations under the HVNL and the WHS Act. You are taking proactive steps to manage risk. For Australian tradespeople and small business owners, this is not optional. It is a core part of running a compliant and professional business.
Key Facts
- Every party in the heavy vehicle supply chain has a duty to ensure safety of transport tasks.— Heavy Vehicle National Law (HVNL)
- A person must not cause or direct the driver of a heavy vehicle to breach a road law.— Section 26 HVNL
- Officers of a company can be held personally liable for breaches of the Chain of Responsibility.— Work Health and Safety Act 2011 (Cth)
- The maximum penalty for a corporation breaching a category 1 offence under the HVNL is over $5 million.— National Heavy Vehicle Regulator (NHVR)
- Load restraint systems must meet the performance standards of the National Transport Commission.— National Transport Commission (NTC)
Sources
Required Sections
Task Identification
Captures the basic details of the transport job including parties involved, vehicle details and job reference numbers.
Task Identification
Date: Business Name: ABN: Vehicle Registration: Consignor Name: Consignee Name:
You must record accurate details for every heavy vehicle task. This information is the foundation of your safety duties under the Heavy Vehicle National Law (HVNL). Under Section 26 of the HVNL, every party in the supply chain is responsible for ensuring their actions do not cause breaches of road transport laws. If you cannot prove who was responsible for a specific load or journey, you cannot manage the risk, and you leave your business open to prosecution.
Start by recording the date and the specific vehicle registration. In the event of an incident or audit, authorities use the registration number to track the vehicle's history and movements. Ensure the rego number matches the prime mover and any trailers. A mistake here breaks the chain of evidence and makes it difficult to identify which vehicle carried the load.
Your Business Name and Australian Business Number (ABN) identify you as the legal entity in the chain. The National Heavy Vehicle Regulator (NHVR) and police use the ABN to link operations across different sites or depots. You must use the correct legal entity name. If you operate as a sole trader, use your personal name rather than just a trading name, unless your ABN is registered specifically to that trading name. This clarity prevents confusion during Chain of Responsibility (CoR) investigations.
Identifying the Consignor and Consignee is critical. The Consignor is the party who sends the goods. The Consignee is the party who receives them. Both parties have explicit duties under the HVNL. The Consignor must ensure the load is safe and legal before it leaves their site. The Consignee must ensure unloading does not create safety risks. If a load is found to be non-compliant during a roadside inspection, the inspector will look at this section to see who accepted the load for transport and who was scheduled to receive it.
Do not leave these fields blank or vague. Use full legal names or the exact company names listed on the booking forms or dockets. If the load changes hands multiple times, record each transfer. This creates a clear audit trail showing that every party knew their obligations.
This section does more than list names. It proves you have identified every party in the Chain of Responsibility for that specific task. Without this documentation, you cannot demonstrate that you have taken reasonable steps to prevent mass, dimension, loading, or fatigue breaches. Keep this information legible and accessible. You must be able to produce it immediately if an officer requests it.
Scheduling and Routing
Checks if the delivery schedule and route planning encourage safe driving practices without speeding or fatigue.
Timeframes and Work Hours
- Have you allowed sufficient time for the driver to complete the trip legally without speeding or rushing?
- Does the schedule account for loading and unloading times, traffic delays, and rest breaks?
- Have you checked the driver’s work diary to ensure they are not exceeding fatigue limits under the Heavy Vehicle National Law (HVNL) and Heavy Vehicle Driver Fatigue (HVDF) legislation?
The schedule must be realistic. If you set deadlines that force a driver to speed or skip breaks, you breach your duty under Section 48 of the HVNL. Always factor in the maximum 12 hours of work time for a standard solo driver and the mandatory 30-minute breaks after every 5.5 hours of driving.
Fatigue Risk Management
- Is the driver fit for duty before starting the shift?
- Have you planned rest stops at approved facilities for long-haul trips?
- Does the roster allow for at least 7 continuous hours of stationary rest time?
Fatigue management is a safety critical obligation. You must ensure your drivers are not suffering from acute or cumulative fatigue. Review the roster to ensure it complies with Basic Fatigue Management (BFM) hours if applicable. Record all rest breaks in the National Driver Work Diary. Managing fatigue effectively reduces the risk of accidents and ensures compliance with the National Heavy Vehicle Regulator (NHVR) requirements.
Route Suitability for Heavy Vehicles
- Have you checked the route against the NHVR National Map or local council maps for height, width, and mass limits?
- Does the route contain low bridges, narrow streets, or load-limited bridges?
- Is the road surface suitable for the heavy vehicle weight and weather conditions?
Using a GPS meant for cars can lead to disaster. You must verify that the planned route can legally and physically accommodate the vehicle. Check for specific restrictions on local roads. Ensure the route avoids sharp corners that are difficult for long vehicles or school zones during restricted hours. Planning the correct route prevents infrastructure damage and fines.
Communication of Delivery Details
- Has the driver received clear written instructions regarding the delivery address and site requirements?
- Have you communicated the specific arrival time window and who to contact on site?
- Does the driver know the site rules regarding entry points, reversing, and parking?
Clear communication is vital to manage safety on arrival. Provide drivers with a site map if the location is complex. Inform the driver of any site-specific inductions they must complete. Ensure the receiver knows the scheduled delivery time to avoid waiting periods that contribute to driver fatigue. Effective communication ensures the handover is safe and efficient.
Loading and Unloading
Verifies that the physical act of loading is safe, weight limits are respected and loads are secured properly.
Loading and Unloading Verification
Before any vehicle leaves the depot, the Loading Supervisor must confirm that the load is safe, secure, and compliant. Use this checklist to verify the critical aspects of the loading process.
1. Weight Limits Compliance You must confirm that the total gross mass of the vehicle does not exceed the Gross Vehicle Mass (GVM) or Gross Combination Mass (GCM) listed on the manufacturer’s plate. Check that individual axle group weights are within the limits specified in the Heavy Vehicle (Mass, Dimension and Loading) National Regulation (MDLNR). Require the driver to present a current weighbridge ticket if the load is close to capacity. Remember that mass limits exist on registered axle limits and the Road Transport legislation specific to each state or territory.
2. Load Restraint Methods Inspect the tie-down equipment before use. Ensure chains, webbing, and ropes are free from cuts, fraying, or significant wear. Check that all load restraint equipment meets the strength requirements outlined in Load Restraint Guide 2018 (published by the National Transport Commission). You must verify that the load is restrained to prevent it moving forward, backward, sideways, or vertically. The restraint method must withstand the calculated forces based on the load's weight. If using tarps, check that they are secured and do not create a hazard by flapping or obscuring the driver's vision.
3. Weight Distribution Assess the placement of the load to ensure the weight is distributed evenly along the length of the chassis. Incorrect placement can overload a specific axle or make the vehicle unstable. Place heavier items low and centrally to maintain the vehicle's centre of gravity. A top-heavy load is prone to tipping during cornering or sudden swerves. Ensure the load is stacked in a way that prevents shifting during transit. Interlocking stacks or using dunnage and chocks are effective methods to maintain stability.
4. Safe Access for the Vehicle Check the immediate area around the vehicle to ensure it is clear of pedestrians, other equipment, and overhead obstructions like power lines. Verify that the ground is firm and level to support the vehicle and loading equipment during the process. If the vehicle is parked for loading, ensure the parking brake is applied and the wheels are chocked where necessary. Confirm that suitable lighting is available for night work. Inspect loading docks and ramps to ensure they are secure and capable of bearing the weight of the load handling equipment. Ensure the driver has a clear line of sight and a safe path to enter and exit the cab during the loading procedure.
Packaging and Labelling
Ensures goods are packed safely to prevent movement and are correctly labelled if dangerous.
Packaging and Labelling
Inspect the load before it leaves the yard. Damaged packaging is the most common cause of load shift and product loss on Australian roads. Under the Heavy Vehicle National Law (HVNL) and the Chain of Responsibility (CoR) legislation, everyone in the supply chain must ensure their actions do not compromise the safety of a transport task. If you pack a load poorly and it falls off, you are liable.
Start by checking the pallets. Do not use timber pallets with broken boards, protruding nails, or rot. These failures can cause the forklift tines to puncture the load or cause the pallet to collapse during transit. For export goods, verify compliance with ISPM 15 standards regarding timber treatment to avoid biosecurity fines.
Check the integrity of the secondary packaging. Boxes must be taped securely, and shrink wrap must be tight and free of large tears. If strapping is used, inspect the tension and the condition of the buckles. Strapping that has come loose under tension is a major hazard.
Verify the stacking order on the pallet. Heavy items must always sit at the bottom. Lighter items must be placed on top. This common sense practice is often ignored in busy warehouses, leading to crush damage and toppling loads. Ensure the stack is built as a stable block. Avoid creating pyramids or interlocking patterns that create overhang. Any box hanging over the edge of the pallet is at high risk of being ripped off by other vehicles or during loading.
If you are carrying dangerous goods (DG), the requirements become strict. You must refer to the Australian Dangerous Goods Code (ADG7). Check that every package bears the correct class label and diamond. Ensure the proper shipping name and UN number are clearly visible. If the load is packed into a freight container, you must attach the appropriate placards on the outside of the vehicle or container.
Use a load restraint guide when securing the load. The Load Restraint Guide 2018 provides the technical standards for lashings and webbing. A tarp thrown over a loose load is not a restraint. The packaging and restraint system must work together to withstand forward, rearward, and sideways forces. Do not sign the dockets or dispatch notes until you have physically inspected the pallet, the labels, and the security of the load.
Premises and Management
Assesses the safety of the physical site where the heavy vehicle operates, including yard space and overhead hazards.
Premises and Management Checklist
Manoeuvring Space
Measure your driveways and yards to ensure heavy vehicles can enter, exit, and turn without reversing excessively. Excessive reversing is a major hazard under the Heavy Vehicle National Law (HVNL). Design traffic flow so drivers can drive forward at all times. If drivers must reverse, ensure they have a clear line of sight or use a trained spotter. Check that pedestrian walkways are separated from vehicle paths. Use bollards or painted lines to define safe zones. Under Work Health and Safety (WHS) regulations, you must manage the risks of collisions between pedestrians and moving vehicles.
Ground Conditions
Inspect the ground where drivers park and load. The surface must be stable enough to support the fully loaded vehicle weight without sinking or shifting. Look for potholes, loose gravel, or soft ground after rain. Uneven surfaces create a tip hazard for trucks and a trip hazard for drivers. Under the Model Code of Practice: Managing the Risks of Plant in the Workplace, you must maintain safe ground conditions. If the ground is poor, restrict access or use concrete pads. Ensure drainage is working to prevent pooling water or mud build-up.
Overhead Clearance
Identify all overhead obstructions before vehicles enter the site. Measure the height of powerlines, roof awnings, and tree branches. Display clear height restriction signs at all entrances. If powerlines are present, contact the local electricity distributor to determine the safe clearance distances. Drivers must be aware of the height of their vehicle and load. If a load is oversized, you must have a written plan to ensure it fits safely without hitting overhead assets. Striking overhead powerlines is a serious breach of safety laws and poses a fatal risk.
Availability of Supervision
Ensure a responsible person is on site to supervise loading and unloading. This supervisor must understand the loading requirements under the Heavy Vehicle National Law. They need to know the legal load limits and how to secure the load correctly. The supervisor should stop work if they see unsafe practices, such as overloading or incorrect use of restraint equipment. Provide a clear induction for all drivers so they know who the site supervisor is and what the site rules are. If no supervisor is present, you must have strict written procedures for drivers to follow.
Sign-off and Hazards
Records the formal acknowledgement of the check by responsible parties and logs any specific hazards found.
Section 5: Sign-off and Hazard Management
This final section is mandatory. It acts as your legal proof that everyone in the supply chain has done their job properly before the heavy vehicle leaves the site. Under the Heavy Vehicle National Law (HVNL), every person in the Chain of Responsibility must ensure their safety duties are met. Simply signing this document is not enough if the load is unsafe, but a signature confirms you have physically checked the work and verified it meets the National Transport Commission (NTC) standards and the Load Restraint Guide 2018.
Hazard Identification and Control
Before anyone signs, you must assess the specific risks associated with this load. Look for anything that could cause injury during loading, unloading, or transit. If you identify a hazard, you must record the specific action taken to eliminate or minimise it. Use the text area below to describe the situation and your fix.
Examples of common hazards:
- Load shift risk: The load is unstable. Action: Used choke chains and dunnage to prevent movement as per the Load Restraint Guide.
- Falling objects: Items stacked loose on the trailer. Action: Applied cargo nets and shrink wrap to secure top layers.
- Restricted access: The delivery site has a steep driveway or low clearance. Action: Driver noted on the manifest and planned a reverse park to avoid swinging the trailer.
- Physical strain: Manual handling risks with heavy boxes. Action: organised a two-person lift and used a trolley.
Describe any identified hazards and actions taken:
[ Hazard Description and Actions Taken ]
Chain of Responsibility Sign-off
Each party must sign to confirm the load is safe, secure, and within legal mass and dimension limits. By signing, you acknowledge that you have complied with your Primary Duty under Section 26 of the HVNL.
1. Driver I confirm the load is secure, the mass does not exceed the vehicle's Gross Vehicle Mass (GVM) or Gross Combination Mass (GCM), and all documentation is correct.
- Name: __________________________
- Signature: ______________________
- Date: ____ / ____ / 20____
2. Loader / Packers I confirm the load was placed safely, restrained according to the Load Restraint Guide, and that no loose items remain on the vehicle.
- Name: __________________________
- Signature: ______________________
- Date: ____ / ____ / 20____
3. Manager / Supervisor I confirm that the loading procedure was supervised, the workers were trained and competent, and the vehicle is compliant for travel.
- Name: __________________________
- Signature: ______________________
- Date: ____ / ____ / 20____
Frequently Asked Questions
What is a Chain of Responsibility Checklist?
When do I need a Chain of Responsibility Checklist?
Is a Chain of Responsibility Checklist legally required in Australia?
Who is responsible for filling out the Chain of Responsibility Checklist?
What happens if I fail to use a Chain of Responsibility Checklist?
Does the Chain of Responsibility Checklist apply to vans and utes?
How long should I keep the completed Chain of Responsibility Checklist?
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This document involves significant legal or financial considerations. Professional review is strongly recommended.