MAEZ insight
How to Implement Chain of Responsibility
A visiting truck sales person injured, resulted in Holcim (Australia) Pty Ltd agreeing to an enforceable undertaking, having a total expenditure of $1,294,100. Critically, the external audit by a safety representative was never completed at an operational level to ascertain if the current traffic management was suitabl

Managers need a clear view of gaps before audit or enforcement pressure arrives.

Contractor controls should be verified before the work starts.

Receiving windows, site rules, and unloading delays can all shape the transport task.

Unloading decisions can affect safety, scheduling, and responsibility.
Consignors
Role-based Chain of Responsibility controls, evidence, and SMS expectations.
Consignees
Role-based Chain of Responsibility controls, evidence, and SMS expectations.
Loaders
Role-based Chain of Responsibility controls, evidence, and SMS expectations.
Managers
Role-based Chain of Responsibility controls, evidence, and SMS expectations.
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How to Implement Chain of Responsibility
CASE STUDY: SafeWork NSW vs Holcim (Australia) Pty Ltd A visiting truck sales person injured, resulted in Holcim (Australia) Pty Ltd agreeing to an enforceable undertaking, having a total expenditure of $1,294,100. Background It was alleged by SafeWork NSW that Holcim (Australia) Pty Ltd failed to discharge its duty as a persons conducting a business undertaking, in that it did not ensure the health of its workers so far as reasonably practicably. A visiting truck salesperson who was visiting a Holcim site was injured when struck by a B-Double truck delivering aggregate to the site, at a plant located in Sydney NSW. Holcim had a working WHS management system at the time, which was audited externally by a legal team and internal auditors, working externally, every two years. Holcim stated that it is committed to complying with its obligations under the WHS act and regret the incident which took place on the 13th of May 2016. Agreed activities Holcim (Australia) Pty Ltd will undertake to include: Safety leadership training to all front line and senior members in Holcim’s NSW concrete business; An external traffic management audit of five NSW concrete manufacturing sites; Hosting an industry forum to provide best practice reference material to manage risk associated with vehicle and pedestrian traffic management on worksites; A community safety awareness campaign creating awareness of the risks to pedestrians when interacting with heavy vehicles; and A truck advertisement campaign promoting safety awareness messages. Rectifications and implementation of controls after the incident at the Caringbah plant totalled $70,960, but company-wide, the costs with improved traffic management control totalled over $4,000,000, along with the undertaking expenditure, estimated alone at $1,294,100. Some of the traffic management implementations included; An independent pedestrian and vehicle audit Entrance redesign with new front gate Implementation of flashing lights Line marking & floodlighting Segregated walkways Pedestrian crossings, handrails, signage & gates Improvements to car parks Lobbying of the council to change parking notices at the site entrance The businesses also made a commitment that the behaviour across the business would not occur. It would take all reasonably practicable steps to prevent this type of occurrence again. The investment and real measures at Holcim sites, post-incident, demonstrates Holcim’s real commitment to ensuring a similar incident will not occur. What does this mean? It was deemed with this enforceable undertaking that Holcim that the alleged contravention “does not appear to be a section 31 Reckless conduct category 1 offence”. If this were the case, it would preclude the proposed undertaking from being accepted. It would also have instigated lengthy and costly legal costs, along with the possibility of jail for the duty holders directly responsible. It would have also included much larger fines and as you may expect the rectification costs listed herein already, would still have been included by Holcim as required works to ensure a safe workplace. Critically, the external audit by a safety representative was never completed at an operational level to ascertain if the current traffic management was suitable. Training of the companies duty holders was also not completed and added to the list of items to ensure were rolled out to improve safety at the front line. MAEZ has also helped dozens of businesses address risks found through Gap Analysis that would have exposed the businesses to serious financial penalties by not adequately implementing Chain of Responsibility , easily exceeding the costs Holcim faced. With the limitations of available in house training, MAEZ also has targeted training for front line staff and executives, who carry a Chain of Responsibility within an organisation, under the Heavy Vehicle National Law. Implementing Chain of Responsibility and ensuring a safe workplace is not an easy task. You should always include outsourced expertise to ensure that you and your business has made sure it has every opportunity to ensure safety. Chain of responsibility awareness training will ensure that front line staff and executives with prime duties carry out their duties with safety in mind at all times. It is critical that you assess your risks and comply with the relevant legislations in Australia, that require a PCBU to ensure training for all high risk tasks. MAEZ critically promotes training within the transport sector when it comes to Chain of Responsibility, as Truck driving is regarded as one of the most dangerous jobs in Australia.
How this connects to MAEZ now
MAEZ helps Australian businesses turn Chain of Responsibility, HVNL, WHS, transport safety, and chartered risk obligations into practical training, advisory, audit, and implementation pathways. Where software is the right next step, CoRGuard at chainresponsibility.au supports the evidence workflow.
Operational message set
Find the gaps. Fix the system. Prove the controls.
MAEZ helps transport operators deal with the compliance risk they already know is there. We help get the Safety Management System in order, protect NHVAS accreditation, reduce fine exposure, and connect training, evidence, and CoRGuard workflows where software is needed.
Find
Identify what is exposed before an auditor or regulator does.
Fix
Build the SMS controls around how the transport business actually runs.
Prove
Use CoRGuard where records, reminders, diaries, audits, and evidence need structure.
Evidence path
From MAEZ advice to a working Safety Management System
Advisory work should leave a practical implementation trail. These examples show how CoRGuard supports records, fatigue and driver diary checks, maintenance, audits, document control, inductions, corrective actions, and evidence review after MAEZ identifies the gaps.

Training records
Connect training completion from cortraining.com.au to evidence and follow-up.

Driver diary checks
Connect fatigue and driver diary review back to manager visibility.

Corrective actions
Turn audit findings, hazards and incidents into tracked actions.
Frequently asked questions
Questions people ask about this topic
What is the purpose of How to Implement Chain of Responsibility?
A visiting truck sales person injured, resulted in Holcim (Australia) Pty Ltd agreeing to an enforceable undertaking, having a total expenditure of $1,294,100. Critically, the external audit by a safety representative was never completed at an operational level to ascertain if the current traffic management was suitabl
Who should read this page?
This page is useful for owner-operators, transport managers, executives, consignors, consignees, loaders, schedulers, contractors, and anyone who influences a heavy vehicle transport task.
What does MAEZ help transport businesses fix?
MAEZ helps Australian transport and supply-chain businesses identify Chain of Responsibility, HVNL, WHS, NHVAS, training, audit, document-control, and Safety Management System gaps, then turn those gaps into practical controls and evidence.
Is Chain of Responsibility training handled on this website?
MAEZ provides the advisory and risk pathway, but Chain of Responsibility training is delivered through cortraining.com.au. Where software is needed, CoRGuard supports the Safety Management System evidence workflow.
How does CoRGuard fit with MAEZ consulting?
MAEZ helps define the risk, obligations, controls, and implementation pathway. CoRGuard is the SaaS Safety Management System platform used when the business needs structured records, reminders, audits, maintenance, driver diary checks, inductions, corrective actions, and evidence reporting.
