14 November 2023
Paul Olendrowsky, Director National Services Transition 
National Heavy Vehicle Regulator 
Dear Mr Olendrowsky

Re:  Discussion Paper – Risk Based Heavy Vehicle Inspection Scheme  

AgForce is a peak organisation representing Queensland’s cane, cattle, grain and sheep & wool producers.  The cane, beef, broadacre cropping and sheep & wool industries in Queensland generated around $8.4 billion in on-farm value of production in 2020-21.  AgForce’s purpose is to advance sustainable agribusiness and strives to ensure the long-term growth, viability, competitiveness and profitability of these industries.  Over 6,400 farmers, individuals and businesses provide support to AgForce through membership.  Queensland producers provide high-quality food and fibre to Australian and overseas consumers and contribute significantly to the social fabric of regional, rural and remote communities as well as stewardship of the state’s natural environment. 

Thank you for the opportunity for AgForce to provide feedback on the Risk Based Heavy Vehicle Inspection Scheme Standard and Assurance Framework discussion paper.  AgForce have a strong membership base of primary producers, many of which are owner operators or conduct business as contractors.  There are not many aspects of agriculture that do not intersect with heavy vehicle use.  

AgForce generally supports the spirit of the risk based heavy vehicle inspection scheme and is encouraged by the intent to reduce administrative burdens for those operating across multiple states and who do the right thing.   

Please find below responses to Appendix 1: Discussion Paper Questions 
Question Responses 
Risk Criteria 
Inspection Frequency  Defined RBHVIS inspection frequencies are appropriate.  
Outer limit for inspections  Suggestion the outer limit should be 3 or 4 years. 
Time elapsed since last inspection 
If zero intercepts or random sampling on that vehicle has been done within 3 years, is there potential to put them in the pool of strategic sampling to ensure there is compliance and operational standards being met.  
Yes, everyone should be subject to RBHVIS inspections.  
Random sampling 
Recommend more consultation to understand how random sampling should be implemented. 
Maintenance-related defect notices 
We support major defect notices being entered into an operator’s risk profile.  We also would support serial offenders (poor maintenance practices) of minor defect notices being entered into an operator’s risk profile.  Perhaps consider a gateway system before being flagged, to ensure a single unforeseen defect does not adversely affect a ranking.   
Detection of defects during scheduled inspections 
A timeframe to resolve the defect and perhaps a way to prove the defect has been rectified without having to return to an inspection site, given geographical distances many people need to travel.  Video call via mobile, report signed off by local mechanic, proof of purchase and photos of installation etc.  
Performance Monitoring and Continuous Improvement 
Recommend more consultation to understand performance monitoring indicators for this sort of scheme.  
Standards  Current Inspection standards seem appropriate 
10  Consistency   
11  Performance Metrics 
Recommend more consultation to understand performance monitoring indicators for this sort of scheme. 
12  Training & Qualification  Training & Qualification 
Preference for industry knowledge and skills over qualifications. Mechanical/diesel fitters are always well received.  
Maintenance & Upkeep  No feedback 
14  No feedback  
Types of Evidence  Scheduled services vs reactive services or repairs.  
16  Evidence Submission  Online platform is likely to be the most efficient, but there should be scope for face to face or phone meetings for those who don’t have internet or the technology to support online uploads 
17   Risk Criteria Detail  Risk Factor Categories  No suggestions to enhance methodology used 
18  Risk Factor Category & Category Variable Weighting Summary 
  1. We do not support heavy vehicle age being the sole baseline of the risk factor category weight.  It should be weighted as significant, in conjunction with vehicle servicing, sector and defect history.  Not in isolation.  
  2. As outlined above.  
19  Age of Heavy Vehicle or Trailer 
  1. Age should still be considered but if it is coupled with a high-quality service schedule and little to no defects, age should become a lesser factor.  
  2. We have no additional data to provide 
20  Vehicle Type 
  1. For long haul interstate fleet type operations, emerging technologies could be considered a tool to minimize your risk ranking.  
  2. No suggestions 
21  Vehicle Servicing Arrangement 
  1. Unsure of existing agreements with manufacturers. 
  2. We recommend that self-servicing or local servicing be recognised. Many regional, rural and remote owner operators within agriculture often service their own farm heavy vehicles and have the skills to do so. We implore the framework not to restrict servicing to dealerships or mechanics from large centres.  
22  Operating Environment 
  1. Heavy vehicles operating in rural and remote could potentially be considered lower risk if servicing and inspections are met.  The term regional reflects locations like Toowoomba, Cairns and Sunshine Coast and would be hesitant to consider those low-risk locations as they are quite populous.  
  2. If vehicles are operating within a short distance of the enterprise’s registered location, this could also be considered a lower risk to long haul interstate operation.  
23  Industry Sector 
Should be considered. Many farming operations are seasonal, therefore heavy vehicle use is seasonal.  Many heavy vehicles are only utilised for a few months of the year.  This should be considered as part of the risk criteria.  
24  Operator Defect History 
  1. Yes.  
  2. Defect history could be utilised to effectively establish overall risk profile.  
  3. AgForce supports exploration of different mechanisms and strategies to establish fair and accurate risk profiles.  
25  Operator Compliance History 
  1. Willingness to rectify defects.   
  2. A pattern of noncompliance is exactly that, noncompliance.  It implies that no actions or reasonable actions have been taken to improve the vehicles mechanical safety within a timely manner.  
26  Operator Accreditation  
Accreditation schemes can be overly burdensome with paperwork and do not necessarily reflect the operating nature of the heavy vehicle.  AgForce preference is for good servicing and low defect notices over an accreditation scheme.  
27  Safety Management Systems 
  1. Broader consultation may be required to establish what can be provided to demonstrate an effective SMS.  
  2. The proof of good safety and risk management can be found within servicing records and log books which already are in place.  
For further information or to discuss this submission in more detail please contact Ruth Thompson, Policy Director, via email: or by phone:  0427 472 467. 
Yours sincerely
Michael Guerin 
Chief Executive Officer