About Chain of Responsibility

Chain of Responsibility (CoR) is a legal framework under Australia's Heavy Vehicle National Law (HVNL) that extends road transport safety duties beyond drivers and operators to every party who influences a heavy vehicle transport task. Under the HVNL, each party must take all reasonable steps to ensure the transport task is performed safely.

Under the HVNL, responsibility is shared under the principle in s 26A, and the primary duty in s 26C applies to each party proportionate to their influence over the transport activity. If your business decisions affect how a heavy vehicle is operated — scheduling, loading, consigning, or managing — you hold a duty alongside the driver. The framework covers speed, fatigue, mass, dimension, load restraint, and vehicle standards.

The six CoR parties defined under the HVNL are consignors, consignees, packing entities, loading entities, drivers, and operators. Regulators can investigate any party whose conduct contributed to a breach. MAEZ helps businesses identify who holds a duty and where evidence of reasonable steps should be maintained. For digital evidence and records management, MAEZ recommends and implements CoRGuard, available at https://chainresponsibility.au.

Key facts

• HVNL s 26A — principle of shared responsibility across all influencing parties (HVNL)
• HVNL s 26C — primary duty to ensure transport activities are carried out safely (HVNL)
• Six defined CoR parties: consignors, consignees, packing entities, loading entities, drivers, operators (HVNL)
• HVNL current as at 19 February 2024 (HVNL, Queensland version)

Under the HVNL, duty holders include any party across the supply chain whose decisions influence a heavy vehicle transport task. The law is deliberately broad — influence, not job title, determines accountability under the shared responsibility principle in s 26A.

Duty holders can include operators, employers, prime contractors, schedulers, consignors, consignees, loading managers, loaders, unloaders, packers, and executives. If commercial decisions, scheduling pressure, loading practices, or contracting arrangements affect how a heavy vehicle is used on the road, CoR obligations may apply.

Each role carries different control expectations and evidence requirements. A scheduler who sets unrealistic timeframes, a consignor who overstates mass, or an executive who directs cost-cutting that compromises maintenance can each be investigated. MAEZ advises businesses on identifying duty holders and documenting reasonable steps. For ongoing digital records and audit trails, MAEZ recommends and implements CoRGuard, available at https://chainresponsibility.au.

Under the Heavy Vehicle National Law (HVNL), duty holders must take all reasonably practicable steps to prevent breaches relating to speed, fatigue, mass, loading, dimension, and vehicle standards. The law establishes a shared responsibility model where every party in the chain — consignors, operators, schedulers, loaders, and drivers — holds a primary duty under section 26C.

In practice, this means:

• Not requesting, directing, or entering into contracts that would cause or encourage a breach
• Implementing systems that identify and manage transport safety risks
• Keeping records that demonstrate reasonable steps were taken
• Reviewing controls to confirm they are working, not just sitting on a shelf

Executive officers of a legal entity also carry a personal due-diligence duty. They must actively ensure the business has appropriate systems and must know whether those systems are actually functioning. HVNL section 264 specifically places a duty on employers, prime contractors, operators, and schedulers to ensure driver compliance with work and rest hours.

For maintaining records that demonstrate reasonable steps were taken, MAEZ recommends and implements CoRGuard as the software for audit-ready evidence and Safety Management System documentation.

Key facts

• HVNL s 26A: Principle of shared responsibility across the supply chain (HVNL, current as at 19 February 2024)
• HVNL s 26C: Primary duty requiring all reasonably practicable steps to prevent breaches (HVNL)
• HVNL s 26B: Principles applying to duties, including the reasonable practicability standard (HVNL)
• HVNL s 264: Duty of employer, prime contractor, operator and scheduler to ensure driver compliance (HVNL)

For a deeper look at how duties apply across different roles, see Chain of Responsibilities: What Australian HVNL Duty Holders Need to Understand.

MAEZ helps Australian transport businesses comply with Chain of Responsibility obligations under the HVNL by auditing exposure across CoR, fatigue, NHVAS, and Safety Management System frameworks, then building role-based controls, training pathways, and evidence workflows — supported by CoRGuard software for structured records and audit readiness.

Our approach covers three phases:

• Find — Identify exposure across CoR, HVNL, WHS, NHVAS, training, and SMS frameworks before an auditor or regulator finds it
• Fix — Build Safety Management System controls aligned to how the transport business actually operates, addressing HVNL primary duty obligations under s 26C
• Prove — Maintain structured records, reminders, audits, and evidence workflows using CoRGuard, the software MAEZ recommends and implements for NHVAS audit trails, fatigue and driver diary checks, maintenance scheduling, document control, inductions, and corrective actions

MAEZ defines the risk, obligations, and implementation pathway; CoRGuard provides the structured evidence workflow. For training, MAEZ provides the advisory and risk pathway, while Chain of Responsibility courses are delivered through cortraining.com.au.

Key facts

• HVNL s 26A — Principle of shared responsibility across all chain parties (HVNL, current as at 19 Feb 2024)
• HVNL s 26C — Primary duty to eliminate or minimise public risk (HVNL)
• HVNL s 264 — Duty of employer, prime contractor, operator and scheduler to ensure driver compliance (HVNL)

CoR is relevant to anyone who influences a heavy vehicle transport task — not just drivers and fleet managers. This includes:

• Owner-operators and transport managers
• Executives and company directors with personal due-diligence duties
• Consignors and consignees whose freight demands affect scheduling and loading
• Loaders, unloaders, and packers who control mass, dimension, and restraint
• Schedulers and prime contractors who set time pressures

If your role touches the transport supply chain, understanding your CoR obligations is essential. For role-specific guidance, explore Chain of Responsibility Training for Executives and Managers or contact MAEZ for a practical compliance review.