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Opinion: what supplier audits are all about

Customer scrutiny is unavoidable these days, so best be prepared

 

There is a lot of activity in the transport industry around Chain of Responsibility (COR) supplier audits where prime contractors carry out audits of their transport supplier chain of responsibility compliance.

This stems from the principle of shared responsibilities in the Heavy Vehicle National Law (HVNL), Section 26A which states the safety of transport activities relating to a heavy vehicle is a shared responsibility of each party in the chain of responsibility. 

This initially caused parties in the chain to think they were responsible for the behaviour of other parties, but this has since been clarified by the National Heavy Vehicle Regulator (NHVR) in Issue 56 of On the Road, where NHVR executive director Geoff Casey of the states: “The law makes it clear that it’s the transport operators responsibility to manage their own operations and activities so as to ensure safety under the primary and safety duty provisions.”


Read more about what NHVR’s Geoff Casey says on COR expectations, here


Each party in the heavy vehicle supply chain is liable and responsible to the extent of their level of influence and control over the particular transport task.

Whilst under the Law, invasive investigation into how a transport operator runs its business are not necessary, some prime contractors, for other reasons want to ensure they are doing business with like-minded suppliers, who run a compliant business, with good governance and are good corporate citizens.

For a global company which spends millions on maintaining a wholesome, care and community focused brand, they do not want this tarnished by an ugly on-road event, such as a multiple fatality or accident caused by drug affected heavy vehicle driver. Their brand may be smack-bang on display if the truck is branded. 

We have found that supplier audits are prominent within global FMCG manufacturers and retail. In order to do business with these businesses, Supplier Audits are a necessary evil.

What to expect

A Supplier Audit will usually involve a representative from the Prime Contractor you are providing transport services for coming out to your site and working through an Audit Tool Checklist with you.

How detailed these checklists are will vary, as will the level of detail that is expected by the Auditor.

Some may be a ‘tick and flick’ where you will be required to confirm that you have certain policies and procedures in place and that you take action to ensure the core obligations of the HVNL are complied with – eg that loads are safely loaded and restrained, fatigue management is adhered to and checked, drivers are licenced and vehicles are safe.

You may or may not have to produce records and other documents to verify your responses. A more thorough audit will require you to show the auditor current and relevant policies and procedures and evidence of their implementation.

An example would be completed CoR Breach Reports, drug and alcohol testing records and training records.

What if you don’t have it?

This will depend on how strict the Auditor’s requirements are. Some audits will have a scoring system and pass rate, which may be 80% for example.

If you get to the pass mark, you may be given recommendation to implement the parts of the audit criteria you did not pass.

You may be given some time to meet the audit criteria and the Auditor will either ask you to provide evidence via email, or they may make another time to see you.

Lastly, and the worst result for everyone, you will be that you are no longer be able to supply transport services to the Auditing business. This is a reality and we have seen small businesses lose income as a result of not initially meeting the required standard of a Supplier Audit.

What can you do to be prepared?

Ask for a copy of the Audit Tool before the audit so you can prepare. Conduct a gap analysis to see what you do and don’t have in place.

We find that most supplier COR audits ask for:

  • COR policy, roles & responsibilitie
  • consultation mechanisms, internally and with supply chain partners
  • COR breach reporting form and system
  • risk assessment of your transport tasks
  • policies/procedures/systems for:

Drivers

  • checking drivers licences using driver history reports
  • fatigue management – fatigue-related vehicles adhere to regulated work/rest hours, daily records are kept and checked, breaches are addressed. non fatigue-related heavy vehicles, driver fatigue is understood and considered in scheduling.
  • fitness for work for drivers including self-assessment, training/awareness and response if a driver is not fit for work
  • drug and alcohol testing program

Mass, dimension & loading

  • understanding of your fleet and the mass and dimension of equipment and combinations
  • checking of gross and axle weights of loads and how breaches are detected and dealt with
  • identifying if a vehicle is over-dimension and compliance with hvnl requirements
  • load restraint – training, checking and how breaches are detected and dealt with, including outside carriers, compliance with the Load Restraint Guide

Vehicle standards

  • pre-start checks, defect reporting, repairs and maintenance, supplier standards and records.
  • governance
  • management oversight of COoR performance. Is the system working as planned? Are new risks identified and controlled?

Supplier audits have been in place long before the HVNL reforms of 2018 and despite the NHVR’s advice that they are not a legal requirement, they do seem to be accepted industry practice, particularly among the large supply chain corporates.

At the risk of losing a major client and affecting their livelihood, at this point smaller operators have little choice but to meet these requirements, even though it is outside of their legal obligations.

Denise Zumpe is a qualified and experienced consultant with practical industry knowledge in work health and safety and heavy vehicle safety and compliance, establishing SafeSense Workplace Safety in 2010

 

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