Cost vs benefit in move to electronic work diaries


NTC wants electronic work diaries, which have the potential to cut red tape but increase business costs

Cost vs benefit in move to electronic work diaries
Cost vs benefit in move to electronic work diaries
By Brad Gardner | July 24, 2009

Bureaucrats are calling for the introduction of voluntary electronic work diaries, which have the potential to slash red tape but also increase business costs.

The National Transport Commission’s (NTC) position paper, Electronic systems for heavy vehicle driver fatigue and speed compliance sets out options for operators to move away from paper-based diaries, while also outlining the potential problems in doing so.

The NTC’s General Manager of Safety and Environment, Tim Eaton, says a shift to electronic record keeping means drivers will no longer need to spend time filling out paper diaries.

"By reducing the burden of form-filling, drivers and support staff can get on with the job of running a safe and professional business," he says.

But under the NTC’s preferred option, businesses who choose the electronic path will need to submit an application to the Fatigue Authorities Panel, which currently assesses advanced fatigue management (AFM) applications.

Operators will need to pay an "independent technical expert" to assess their applications to the panel. This approach echoes the AFM process, as businesses must be audited by a fatigue management expert, which can cost thousands of dollars.

"There may be additional costs for industry in moving to electronic work diaries, especially where businesses are currently using only the written work diary," the report says.

And depending on the direction governments decide to take, companies may need to install in-vehicle printers or computers.

The report recommends two types of electronic systems, with the first using an in-vehicle printer to produce a paper copy should a road enforcement officer ask for one.

"The second example is a system that uses a hand-held device to display the information in the electronic work diary," the report says.

Under this method, the driver will be forced to save the electronic information on to a data stick or disc to give to the officer or send an email to the officer with the requested information.

The report says the move to electronic reporting may also require sanctions for fatigue management breaches to be amended.

"This is because telematics devices can reliably identify work or rest hours breaches of under one second and very minor speed breaches, potentially resulting in the accumulation of severe penalties over a very short period of time," the report says.

But while data will be automatically recorded, the NTC wants the driver to have the ability to change information if necessary.

"It is important that the driver be allowed an opportunity to check and, if necessary, correct any data automatically captured by the electronic work diary to ensure that they can comply with the model legislation," the report says.

During a consultation process held by the NTC on electronic work diaries, there was opposition to the policy of counting work hours, which are rounded up to the next 15 minute block. For example, work time as little as one minute must be counted as 15 minutes.

The report proposes counting work hours in increments of seconds, and for the same approach to be used when counting rest time, which is rounded down.

Despite the significant investment some companies may need to make to use electronic work diaries, the NTC says the technology can make roadside compliance checks quicker for drivers.

The report says electronic systems will automatically record work and rest time, meaning enforcement officers will not need to manually add up.

THE DEATH OF THE PAPER DIARY
The report also envisions a future without paper-based reporting where electronic diaries are mandated.

The NTC claims this will benefit companies and drivers because continuous monitoring will do away with roadside interrogation, while operators will be able to use the method to comply with chain of responsibility requirements.

However, the report says "rigorous auditing regimes" will replace roadside enforcement, while vehicles may still be inspected on the roadside to ensure compliance with other road laws.

"NTC sees merit in further consideration of this possible future option as part of the telematics strategy," the report says.

’REGULATORY FAILURE’
If governments agree to go ahead with electronic reporting, the NTC says minor legislative changes will need to be made to fatigue management laws.

Although a section in the model laws mentioned paper or electronic work diaries could be used to manage fatigue, those drafting the legislation forgot to include standards on how the approval process should work.

"The problem is a regulatory failure (rather than a market failure)," the report says.

The issue has led to duplication because some operators use their own electronic monitoring system but must still comply with paper work diaries.

During the consultation process, one stakeholder criticised the oversight by saying it undermined the regulatory framework because a non-functioning system was legislated.

Governments may also consider developing legal requirements for companies to maintain heavy vehicle speeding records, with the NTC saying the situation is currently at the discretion of operators.

"There are currently no regulatory requirements for speed record keeping or for the use of electronic systems," the report says.

The NTC is seeking submissions from the industry in response to the position paper by September 4. The submissions will be considered by the government body when it develops its draft policy proposal.

After this, the NTC will submit its final policy proposal to the Australian Transport Council (ATC) for approval.

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