Goodaye all. Submissions for the NHVR Electronic Work Diary proposal close on the 30th January. I will publish my submission here.
TRUCKRIGHT ABN 17426245866
TRUCKRIGHT Industry Vehicle (TIV) 2018.
Rod Hannifey, Road Transport and Road Safety Advocate, TIV Driver and Operator. Telephone: 0428 120560 Email: email@example.com Website: http://www.truckright.com.au
TRUCKRIGHT Awarded Highly Commended, 3M ACRS Diamond Road Safety Awards 2015. Finalist 3M ACRS Diamond Road Safety Awards 2016, Green Reflector Marking Informal Truck Bays. Awarded Churchill Fellowship 2016.
EWD Submission from Rod Hannifey January 2018.
The current logbook when introduced by the NTC suggested that 10 minutes was sufficient for a break or change of activity, but due to the logbook being in 15 minute increments, it was agreed to have that time as the minimum. If EWDs are to record to the minute as I understand, then it must be agreed how time will be counted. The authorities have long had their way saying that rest time less than 15 minutes is not rest and work time less than 15 minutes is 15 minutes work. That means we can be robbed of time or lose it and cannot get it back. That could mean if I work for 5 minutes, but show 15, I can lose 10 minutes, and for four times, that is 40 minutes and if I need that time to achieve any objective, it is lost and you will fine me severely for working over hours. Similarly, if I stop for 25 minutes, currently I can only record 15 minutes rest and lose 10 minutes, four times that, another 40 minutes lost, so over an hour I cannot control or use to the best intent of my fatigue and comfort.
I propose that any work time be counted and tallied by the minute, so 18 minutes work time is 18 minutes and that rest, where I agree that 2 minutes rest is not reasonable, that rest from 10 minutes or over be counted as the time involved. I have been led to believe that the current intent is for a 20 minute break, to only count 15 minutes rest, but start the next period from the 20 minutes. If this is how you propose to cheat us of our time, then no one that has to deal with customers who do not value or pay for our time, will voluntarily fit an EWD. (I have just been informed at a meeting with NHVR that they cannot change the law to accept 10 minutes as rest, but will be counting rest time above 15 minutes as rest, so 25 minutes rest will be 25 minutes rest.)
WA rules allow that a walk around the truck is a change in activity, yet if I look at a tyre, in other states that is work. Not only is this impossible to control or monitor, it leaves us open to more litigation.
The next step from that is work time, loading etc. When I arrive at a site, I will hit rest. No one will run backwards and forwards to the truck, each time they change activity and we have no control over times on site, let alone delays. Do you really think that a forkie or anyone will wait for my 15 minutes rest to roll over, before I move the truck or a gate etc, or that we will happily be on site for an hour and give all that time away when my physical loading time may be only 20 minutes. Until such time as COR solves this issue or we get paid for any time on site above a prearranged loading time, then I seek to have the ability to log work time after loading. I cannot guess how long or badly I will be screwed around on site and you will then argue I lied, if I put time down and then want it back. For a driver who does 3 or 4 drops in a day, he could be cheated of well over 2 hours.
I have an EWD device fitted to help with what we need and to find problems. I have contacted my supplier with issues regarding how it can better help me with information displayed, warnings of upcoming breaks etc, but there are two big issues. Once the clock starts for each period, I am running to meet the next time deadline, whether a break or hours maximum. I have spoken to other drivers with fleet systems and they too complain of this and drivers in the USA regularly complain of this minute monitoring and its effect on stress and compliance. If I am two minutes late with a logbook, it is not an issue, nor is it in any way a safety issue, but with an EWD, it could be.
I have previously asked for a 30 minute tolerance, even if only twice a week for those days when everything goes bad and all of those things are beyond my control. I am aware of the proposed 8 minute tolerance and also that authorities wanted not one second allowed and if that does not show they are in it for the money and not safety, I don’t know what does. I do not run to maximum hours every day. I never intend to run to maximum hours, but there are times when those hours allow me a better place to eat or sleep. There are still times now, 90% caused by customers or others over who I have no control, that I have to decide on a decent meal, a shower, or another hours sleep.
Allowing the 30 minutes twice a week would recognise that I cannot control others, that COR is yet to reach all and if I go beyond that, then you will fine me as you do now. For drivers who do not deal with customers etc, it will not matter, but for those of us who do, you will be making us criminals due to the simple lack of empathy for truck drivers by others.
My view is that you must meet us somewhere in the middle or no one will want an EWD. For some jobs, it will be an improvement, for others, it has all ready cost them lost earnings and substantial stress as companies use the device to cover themselves for hours etc. Until we have suitable and sufficient rest areas and customers will be held responsible for delays, then you must have some understanding of the job. Currently the laws and penalties are designed, implemented and policed by those who do not have to live by them, who have every facility available to them within reach, yet we live on the road where those facilities can be rare and are at the mercy of customers who do not care if we wait hours for them. Distribution centres who give you a 15 minute window in which to arrive from nearly 1000 kilometres away and yet then expect you to happily be stuffed about for up to 4 hours. This must be fixed before you completely take away our flexibility. Thank you, Rod Hannifey.
I add this here not to influence you or suggest you should resend it as is. I add it to cover my thoughts and hope you will consider other issue you see and raise them now! Once it is law, it is too late and it is hard enough to get heard before, but after it is law, good luck on getting any changes through.
My meeting with the NHVR was fruitful and has allayed but not completely removed some of my concerns. However, I am sure most of you have seen the Toll letter and the comments from some about making EWDs mandatory. Of course by those who will never have to live under them. Yes, we have to do more and there are some truckies that should not be, but the rest of us should not be punished and micromanaged to the tiniest degree, because of them. It is like saying because one politician did the wrong thing, so all should be controlled more. Is that the answer, no.
Please make your thoughts and comments known to the NHVR by contributing a submission and perhaps, we will get a better result. I have just got home from filming our next issue of TRUCK That and tomorrow should have the ABC 7.30 report coming for a trip from Dubbo to Toowoomba, hopefully to better see and feel things from our seat.
Thanks to VicRoads for finally overlaying the northbound section of the Hume at Erreys Road, it has taken nearly 4 years to get that bit done, but only a 7 out of 10 for the job, still some minor undulations there which I fear, will again become bigger over time.
I would also hope many pollies read Steve Shearers comments on the issues raised from the crashes of the last couple of weeks. Let is hope we get good improvements in safety for all, not just knee jerk reactions form those who want to be seen to do something, even if that something makes things worse. Safe Travelling, Rod Hannifey.