NBTA Releases Report On HVSI Project Outcomes: DG Performance Metrics And Education
August 14, 2023
The NBTA has published the final report summarising the outputs of Project 665. This project delivered under the National Heavy Vehicle Regulator’s (NHVR) Heavy Vehicle Safety Initiative (HVSI) funding program supported by the Australian Government.
The aim of Project 665 was to improve the safety of vehicles transporting dangerous goods (DG) and comprised three major components:
The development of an online education and awareness course to improve dangerous goods regulatory awareness, Transport Emergency Response Plans (TERP) and emergency response obligations (dangerous goods education course).
In-field training with the support of emergency services agencies (TERP in-field training); and
development and promotion of performance criteria on the dangerous goods industry response times, causality and data to assist with understanding how the industry is performing (performance criteria).
NBTA made a submission in May to the EPA NSW in response to their proposal to change their regulations. Many changes were subtle or some what small but the devil is always in the detail. You can read our submission here and we will find out more at Bulk Tanker Day when the EPA NSW join us in discussions.
The proposal before CAP in November 2016 seeks to bring this scheme in as a licence condition. We are not supportive of this approach or process. Our views are that the benefits of this approach have yet to be demonstrated and that proper process should be followed in order to do so.
There have been considerable discussions in recent times around the concerns expressed by NSW EPA as to safety issues with some tankers. EPA NSW has developed a draft inspection procedure and an inspection protocol, to be conducted by people designated as “suitably competent persons” (SCP’s). The NBTA has participated in this process but has not reached a final position as to supporting the initiative.
Whilst NBTA is supportive of the need to maintain the safety of all tankers at all times it has sought an assurance that this process be nationally consistent and in line with the current ADG Code and AS2809 standard.
At a meeting held on 14 September 2016 at Eastern Creek between EPA NSW and a range of potential SCP’s and NBTA tanker operator members, NSW EPA were asked for an assurance that should they diverge from the Code or Standard that they would follow established regulatory process. The NBTA believes that EPA NSW gave that undertaking at that meeting. We also believe that Senior Management at the NSW EPA has also given this undertaking to the NSW Government’s Better Regulation Office.
To not follow this path is in our view an abuse of process and not within CAP powers.
At present the inspection procedures and the SCP scheme lack definition and also are inconsistent with the Code and Standard. For those reasons we wish to register our opposition to CAP adopting a licence condition approach to this issue at this time.
Time For A Scorecard And Sharing Of Lessons On Tanker Safety
February 13, 2017
Investigation into DG tanker accidents
The NBTA seeks the support of CAP in sponsoring an investigation by MonashUniversity Accident Research Centre (MUARC) into the causal factors indangerous good accidents and the lessons that arise from these accidents.
In 2009 the NBTA signed a MOU with Australasian Fire and Emergency Service Authorities Council (AFAC) to work together to achieve improved safety outcomes. One initiative was to hold an annual Bulk Tanker Day (see https://www.nbta.com.au/bulktankerday/) to highlight the opportunities for improvements in safety as well as productivity.
In 2012 the then Victorian Deputy Coroner was invited to presented a paper tothe Bulk Tanker Day (see https://www.nbta.com.au/events/bulktankerday2012/ ) on deaths resulting from dangerous goods tanker accidents. She concluded that typically 10 deaths occurred annually as a result of these accidents and she drew a number of lessons from the Coronial investigations.
Since that time the NBTA has been calling for more data to inform industry, regulators and policy makers on the performance of the sector. The “scorecard” has proven challenging to compile. The NBTA has undertaken its own investigation for the year to September 2016 and concluded that some 35 accidents around Australia resulted in the loss of 15 lives, most of which were the public.
THE NBTA has sought a proposal from MUARC to conduct research into recent DG tanker accidents and the causal factors as well as lessons and policy recommendations that emerge. The NBTA seeks CAP’s support for this important work so that issues that are beyond the mechanical condition of vehicles can receive more attention, and that an annual scorecard can be compiled and used to drive future improvements in the operation of dangerous goods tankers.
Why Tanker Design And Operating Rules Need To Change
February 13, 2017
Tanker design and inspection issues: Design Approvals, DG trailer registration, EIP’s and Drive Away Protection
The NBTA wishes to raise with CAP four issues to do with DG tanker design approvals, registration and the interpretation of rules to do with EIP’s and drive away protection.
DG tanker design approvals
WorkSafe Victoria has changed their practices and now requires a considerable level of detail before signing off on design approvals for new tankers. This information request is, in the NBTA’s view, onerous and we wish to clarify the reason for this increase in detail as well as the decision to approve designs by UN number and not by class. These changes are adding significant cost to manufacturers. The reasons behind these changes have not been explained and we seek clarification as to the necessity to add this administrative burden to tanker approvals.
The NBTA view is that Competent Authorities should place the onus on the tanker manufacturer to sign off as to the compliance against the code and standard. Separate design reviews should not be necessary.
DG trailer and barrel registration
WorkSafe Victoria require the plating of tank trailers and barrels and have followed a process that results in a significant delay between registering the vehicle for road use and issuing of the DG plate for the trailer or barrel. The process followed in NSW can be carried out the same day and there is no delay between road registration and barrel registration. Queensland have dispensed with plating issue altogether.
The NBTA seeks a nationally consistent approach to this practice.
EIP’s and drive away protection
The NBTA is opposed to any ruling that interprets “substantially vertical” as “vertical” for EIP’s. This issue deserves a more considered discussion as the cost consequences are very high and the likely safety benefits are, in our view, almost negligible.
EIP and drive-away protection are both currently subject to a VCAT challenge in Victoria. We believe that CAP should wait until the VCAT has deliberated on this before further considering this issue. They should also consult with the Hazmat division of AFAC to obtain their views. NBTA has already held informal discussions with this group and does not believe there is strong support for a “vertical” position.
Why We Need A National Tanker Regulator
February 13, 2017
NBTA calls for establishment of a National Dangerous Goods Regulator
The National Bulk Tanker Association supports the establishment of a National Dangerous Good Regulator. The history of regulation of this sector leaves individual States and Territories responsible for OH&S rules and the supervision of compliance for a range of laws including the Australian Dangerous Goods Code and compliance with the AS2809 Tanker Code.
The inevitable result is that each State develops its own approach to compliance. Almost all companies involved in the transport and storage of dangerous goods operate nationally.
We currently have a situation where NSW has mandated electronic braking standards for dangerous goods tankers, however none of the other Sate based regulators have chosen this outcome, despite industry support for them to do so.
We also have initiatives from various States around inspection practices and interpretation of design rules for dangerous goods road vehicles that are not consistent. On top of this we have differing registration practices for tankers that only add cost with no safety dividend. Whilst the Competent Authorities Panel or “CAP” plays a coordinating role, this group has no mandate to create any national outcomes.
With the establishment of the National Heavy Vehicle Regulator (NHVR) it is
time that we also now committed to the introduction of a National Dangerous Good Regulator. The NHVR is up and running and now provides a platform and a process where dangerous goods can also achieve nationally consistent treatment.
The benefits of a national approach are self evident. The introduction of a National Heavy Vehicle Inspection Manual for heavy vehicles has obvious parallels when extended to dangerous goods vehicles. “Its time to think national and act national,” said the Executive Director of the NBTA, Rob Perkins.
The NBTA will be seeking meetings with the National Transport Commission and NHVR and also the Competent Authorities Panel to put its view to these organisations.
At the conclusion of Bulk Tanker Day 2015, Justin Keast, Chairman of the NBTA called for a national approach to tanker safety. Below is the release the NBTA has made on this issue:
The National Bulk Tanker Association's annual Bulk Tanker Day on the 30th September drew more than 250 attendees to Sandown this year. It's a practical event with emergency response demonstrations as well as maintenance workshops and panel sessions and well supported by industry operators, suppliers and a number of jurisdictions. The panel sessions featured regulators and enforcement personnel from RMS NSW, EPA NSW as well as WorkSafe Victoria, the NTC and VicRoads. According to NBTA Chairman Justin Keast "there is no doubt that the working relationship between the NBTA and the fire agencies through AFAC, as well as with some of the east coast regulators is working very well. At this years conference we have started to see some interesting numbers in terms of incidents that can only help in the development of more evidenced based strategy, he said. However what we lack is information on incidents and the sharing of root cause analysis work that should be done and shared after dangerous goods incidents. No one agency seems to have data on the number of incidents let alone the capability to share the outcomes of these incidents. Without this sharing it becomes very difficult to share lessons and improve outcomes. It is time to have a serious discussion with responsible authorities around the data that is needed to lead this industry into a safer future," he said.
The day also highlighted the move by individual States to adopt positions on standards for vehicles that are not being picked up at the national level. Whilst this is within the rights of each jurisdiction, it will lead to increased costs and the risk that those States with lesser regulations receiving the cast off equipment from other jurisdictions.
"It is disappointing and frustrating that we don't have a national position on roll stability systems for tankers. The NBTA has publicly supported the introduction of these systems for over 4 years yet only NSW has acted to bring this about. We also now face the possibility of NSW enacting tanker testing that will again not be a national condition. If its not a national position it will add to the challenges of all jurisdictions, and also add cost to industry at a time where we want that focus to be on safety and not juggling different State driven schemes," said Mr Keast. The next twelve months will see a move to rework the existing Bulk Tanker Standard AS2809 and this could prove the opportunity to achieve the national outcomes that our industry seeks, said Mr Keast.
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