The transport of dangerous goods is, by necessity, a detailed and compliance focused activity that is categorised as High Consequence Low Frequency. So while incidents are thankfully few, they have the potential to be catastrophic. It is with this reality at top of mind that fuel transport operators are asked to remind all drivers, schedulers and compliance officers to ensure that they are aware of, and staying away from, the prohibited routes.
A recent case in NSW and the latest Fuel Industry Safety Forum has redoubled the focus on prohibited routes.
A tanker was observed by the public on Bradfield Highway and reported to the EPA.
The EPA found the tanker was carrying petrol, a placarded load, but that the placard was not displayed as required resulting in the incorrect notice of “combustible liquid” being shown.
NSW EPA Executive Director Regulatory Operations, Steve Beaman, said the company had not given their driver sufficient training or supervision.
“Companies transporting bulk dangerous goods need to do everything they can to prevent high-risk behaviour from drivers. It is not enough to hand a driver a manual and a delivery address and let them loose with a petrol tanker,” Mr Beaman said.
“With incorrect signage on the vehicle, emergency services and the public have no idea of the danger of fire or explosion from the flammable liquid in the event of an incident.”
“Transport companies need to ensure dangerous goods are transported safely and lawfully. Their drivers should also be trained to use the correct routes for the goods they are carrying.”
Dangerous Goods transport companies can prevent their drivers from using prohibited routes by:
- Using GPS monitoring which can include ‘geofencing’ prohibited routes;
- Reviewing toll records for the vehicles;
- Looking for drivers who achieve substantially faster delivery times (indicating the use of faster, more direct motorway tunnels which are not allowed vs surface roads);
- Providing specific training on prohibited routes and what action to take if a driver has mistakenly found themselves on a prohibited route;
- Regular ‘toolbox talks’ to remind drivers of the rules and an opportunity to ask questions;
- Having internal processes that require drivers to report if they have used a prohibited route; and
- Undertaking random internal audits of driver behaviour and activities.
Learnings for all businesses
“At the recent Fuel Industry Safety Forum it was made clear that compliance with prohibited routes, particularly tunnels, is a great concern for safety and environmental regulators across the country. Incidents and cases like these are rare, but they are more common when drivers are new to a route. When a new customer is added, or a driver is doing a different run, it is not uncommon for them to default to driving between the new locations the way they usually would in a car, this can result in an accidental use of a prohibited route. Transport operators should recognise this situation and actively emphasise prohibited roads/tunnels when communicating new routes” explains ACAPMAs Elisha Radwanowski.
“There is also a need to review the GPS data that all businesses have, to identify patterns and have active conversations with staff about prohibited road use before there is an incident” concluded Elisha.
DG Prohibited Routes Guidance
National Dangerous Goods Code
Legislation and Regulation
Here to Help
Safety Highlights are things to consider, implement and watch out for in your business. They are provided as general information for you to consider and do not constitute advice. You should seek further advice on your situation by contacting your legal advisor. ACAPMA members can access resources and receive advice, guidance and support from the ACAPMA employment professionals via email@example.com , it is free for members. ACAPMA Membership delivers this and more benefits, see; https://acapma.com.au/membership/ for more information.
Elisha Radwanowski BCom(HRM&IR)