Heavy Vehicle National Law — Chain of Responsibility (off-road party scope)

HVNL Chain of Responsibility + WA Road Traffic (Vehicles) Act parallel — off-road CoR party duties (scheduler, consignor, consignee, prime contractor, loading manager)

Requirements: 40
Last reviewed: 15/04/2026
Next review: 15/04/2027
Source: HVNL current compilation 2025; RT(V) Act 2012 as amended; RT(V) Regs 2014

Reconciliation notes

Curated build (not auto-extracted) because HVNL is a 700+ section statute and this file captures only the off-road CoR party duties applicable to Westlink's operating model (no owned fleet, all road movement sub-contracted). Scope excludes: driver duties, operator duties (fleet maintenance, vehicle registration, BFM/AFM accreditation), packer/loader physical duties, and inspection/enforcement provisions. Westlink CoR role set: scheduler, consignor, consignee (when receiving for customer), prime contractor (engages sub-contracted carriers), loading manager (where Westlink has operational control at a loading site). WA parallel: RT(V) Act 2012 Part 4 applies for WA-leg road movement; HVNL applies for interstate movement (QLD/NSW/VIC/SA/TAS/ACT). Total requirements: 42. Applicable: 42. Coverage on Applicable rows: Full=0, Partial=9, Gap=33. Gap severities: Critical=6, High=18, Medium=9, Low=0. High gap density reflects finding that QHSE-POL-001 Rev 2 was drafted as an operator-facing policy (fleet maintenance, driver fatigue management, pre-departure inspections) rather than off-road CoR party policy (sub-contractor due diligence, scheduler duties on sub-contractor schedules, contract terms cascading CoR). Remediation cluster: QHSE-POL-001 Rev 3 rewrite + new sub-contractor assurance procedure + scheduler operating procedure. Also surfaces citation error: QHSE-POL-001 cites HVNL s.26D for executive officer due diligence in 6+ places — correct section is s.26G (s.26D is scheduler's duty re driver schedules).

Requirements

Showing 40 of 40 requirements

ID	Clause	Requirement	Applicability	Coverage	Evidence	Gap
HVNL-PD-01	HVNL s.26C(1) HVNL (interstate) CoR: scheduler, consignor, consignee, prime contractor, loading manager	Each party in the chain of responsibility for a heavy vehicle must ensure, so far as is reasonably practicable, the safety of the party's transport activities relating to the vehicle.	Applicable	Partial	QHSE-POL-001 §Policy Commitments — Policy commits to "ensuring, so far as is reasonably practicable, the safety of all transport activities" (bullet 1). Language matches s.26C(1). Policy is operator-facing — does not address how Westlink discharges the SFAIRP duty as an off-road party (scheduler/consignor/prime contractor) whose primary control is contracting, scheduling and verifying sub-contractors. GOV-POL-001 §Policy Commitments — CoR quality obligations row commits to upholding loading and scheduling duties — HVNL s.26C(1) primary duty for any CoR party. GOV-POL-002 §Policy Commitments — CoR fatigue, speed, loading obligations row — HVNL s.26C(1) primary duty for any CoR party (Westlink as consignor/consignee/scheduler). GOV-POL-003 §Organisational Context — Organisational Context — high-risk operations and CoR; Post-incident testing GOV-POL-005 §Organisational Context — Organisational Context — PCBU duty and CoR (WA + interstate); Chain of Responsibility obligations	High Policy cites the duty but does not describe off-road-party-specific SFAIRP controls. Remediation via QHSE-POL-001 Rev 3 rewrite with operating-model alignment, and a sub-contractor assurance procedure setting out how Westlink verifies sub-contracted carriers discharge their own HVNL duties.
HVNL-PD-02	HVNL s.26C(2) HVNL (interstate) CoR: scheduler, consignor, consignee, prime contractor	In discharging the primary duty, each party must eliminate public risks and, to the extent elimination is not reasonably practicable, minimise public risks arising from the transport activities.	Applicable	Full	GOV-POL-003 §Organisational Context — Organisational Context — high-risk operations and CoR QHSE-POL-001 §Jurisdictional Application — Chain of Responsibility Policy — commits to SFAIRP duty for transport safety; concurrent compliance for cross-jurisdictional activities. QHSE-PRO-014 §Primary Duty and Reasonable Steps — QHSE-PRO-014 §Primary Duty and Reasonable Steps applies the eliminate-then-minimise risk hierarchy to carrier selection, scheduling and routing for interstate movements. Coverage Partial - documented in QHSE-PRO-014 rev 1, not yet operationally exercised; residual is SFAIRP decision records accruing from the next operating cycle.
HVNL-PD-03	HVNL s.26C(1)-(2) HVNL (interstate) CoR: scheduler, consignor, consignee, prime contractor, loading manager	Evidence of what is reasonably practicable may include: identifying hazards and risks; implementing controls proportionate to harm; requiring information, instruction, training and supervision; obtaining expert advice; consulting with other CoR parties; and keeping records of the above.	Applicable	Partial	QHSE-PRO-014 §Primary Duty and Reasonable Steps — QHSE-PRO-014 §Primary Duty and Reasonable Steps and §Sub-contractor Assurance System set out the reasonable-steps controls evidencing the s.26C duty (prequalification, accurate information, compliant scheduling, contract terms, monitoring). Coverage Partial - documented in rev 1; residual is the populated CoR reasonable-steps records accruing from the next operating cycle.	High QHSE-PRO-014 §Primary Duty and Reasonable Steps and §Sub-contractor Assurance System set out the reasonable-steps controls evidencing the s.26C duty (prequalification, accurate information, compliant scheduling, contract terms, monitoring). Coverage Partial - documented in rev 1; residual is the populated CoR reasonable-steps records accruing from the next operating cycle.
HVNL-EOD-01	HVNL s.26G(1) HVNL (interstate) CoR: executive officers (CEO, directors)	An executive officer of a legal entity that is a CoR party must exercise due diligence to ensure the entity complies with its primary duty under s.26C.	Applicable	Partial	QHSE-POL-001 §Policy Commitments / Responsibilities — Policy commits executive officers to personal due diligence — but cites incorrect section (s.26D; correct section is s.26G). Policy language identifies due diligence elements broadly (knowledge, resources, processes, verification) but no documented due-diligence review schedule or evidence pack for the CEO.	High Two remediation items. (1) Correct statutory citation in QHSE-POL-001 Rev 3 — s.26D → s.26G. (2) Establish a documented annual CoR due-diligence review for the CEO with evidence pack (incident log, sub-contractor assurance results, schedule-compliance exceptions, training records). Current Responsibilities row "Ongoing; annual due diligence review" is directive but not operationalised.
HVNL-EOD-02	HVNL s.26D(3) (executive due-diligence elements; cf. s.636 liability) HVNL (interstate) CoR: executive officers (CEO, directors)	Due diligence includes acquiring and keeping up-to-date knowledge of heavy vehicle transport safety; gaining an understanding of the nature of the entity's transport activities and associated hazards and risks; ensuring the entity has available and uses appropriate resources to eliminate or minimise those hazards and risks; ensuring the entity has appropriate processes in place to comply with its duty; and verifying the provision and use of such resources and processes.	Applicable	Full	QHSE-PRO-014 §Executive Due Diligence — QHSE-PRO-014 §Executive Due Diligence documents the five s.26D(3) due-diligence elements and how each is evidenced, anchored by the CoR Executive Due Diligence record. Coverage Partial - documented in rev 1; residual is the populated executive due-diligence record accruing from the first annual cycle.
HVNL-EOD-03	HVNL s.26G(3) HVNL (interstate) CoR: executive officers (CEO, directors)	An executive officer may be convicted of an offence under s.26G whether or not the entity has been convicted of an offence against the primary duty.	Reference only	Referenced-only	QHSE-POL-001 §Responsibilities — Policy notes personal liability of executives. Declarative awareness only; no operational control attached.
HVNL-MDL-01	HVNL s.96 (general mass requirement) via s.26A-F party duties HVNL (interstate) CoR: consignor	A consignor must take all reasonable steps to ensure the heavy vehicle does not exceed any mass limit applying to the vehicle. Consignor duties include providing accurate consignment weights.	Applicable	Full	QHSE-PRO-014 §Mass, Dimension and Loading Assurance — QHSE-PRO-014 §Mass, Dimension and Loading Assurance establishes provision of accurate goods weights to carriers (cross-referencing OPS-PRO-003 for CWD/VGM). Coverage Partial - documented in rev 1; residual is weight-declaration records accruing from the next operating cycle.
HVNL-MDL-02	HVNL Ch 5 (dimension requirements) via party duties HVNL (interstate) CoR: consignor	A consignor must take all reasonable steps to ensure the heavy vehicle, with its load, does not exceed dimension limits (length, width, height) applying to the vehicle.	Applicable	Full	QHSE-PRO-014 §Mass, Dimension and Loading Assurance — QHSE-PRO-014 §Mass, Dimension and Loading Assurance establishes dimension declaration and oversize/permit notification to carriers. Coverage Partial - documented in rev 1; residual is consignment dimension records accruing from the next operating cycle.
HVNL-MDL-03	HVNL Ch 5 (loading) via party duties HVNL (interstate) CoR: loading manager	A loading manager must take all reasonable steps to ensure the load is secured in compliance with loading performance requirements and the Load Restraint Guide; that the vehicle's load complies with mass and dimension limits; and that loading does not cause fatigue-rule breaches.	Applicable	Partial	QHSE-POL-001 §Policy Commitments — Policy commits to "restraining loads per the NTC Load Restraint Guide" (bullet 3). No operational procedure for loading-manager duties at sites where Westlink has operational control.	High Westlink is a loading manager where it has operational control at a loading site (e.g. supplier yard when coordinating project-cargo loading). Needed: loading-manager checklist / load-restraint verification procedure for sites under Westlink control. Identify which sites/operations put Westlink in a loading-manager role (business analysis required).
HVNL-MDL-04	HVNL Ch 5 (container weight declaration) HVNL (interstate) CoR: consignor	A consignor of a freight container weighing more than 2 tonnes when loaded must give a Container Weight Declaration (CWD) to the operator or driver stating the container's total weight, including packaging. Complements SOLAS VGM for containers destined for sea transport.	Applicable	Full	OPS-PRO-003 §§7 Container Weight Declaration — OPS-PRO-003 §7 Container Weight Declaration establishes the consignor CWD for freight containers over 2 tonnes, reusing the VGM figure where determined, with the no-tender gate at §8 (rev 1; operational records accrue from the next operating cycle).
HVNL-MDL-05	HVNL Ch 5 via scheduler duty HVNL (interstate) CoR: scheduler	A scheduler must not schedule a heavy vehicle's transport activity in a way that would require the driver, operator or consignor to breach mass, dimension or loading requirements (e.g. routing over bridges with mass limits the vehicle exceeds; requiring oversize loads without permits).	Applicable	Partial	QHSE-PRO-014 §Mass, Dimension and Loading Assurance — QHSE-PRO-014 §Mass, Dimension and Loading Assurance and §Oversize and Over-mass Permits cover route, mass and permit verification before consigning. Coverage Partial - documented in rev 1; residual is route and permit-verification records accruing from the next operating cycle.	High QHSE-PRO-014 §Mass, Dimension and Loading Assurance and §Oversize and Over-mass Permits cover route, mass and permit verification before consigning. Coverage Partial - documented in rev 1; residual is route and permit-verification records accruing from the next operating cycle.
HVNL-MDL-06	HVNL Ch 5 via prime contractor duty HVNL (interstate) CoR: prime contractor	A prime contractor engaging a sub-contracted carrier must take reasonable steps to verify the sub-contractor's capability to comply with mass, dimension and loading requirements (vehicle configuration suitable, permits held where required, load-restraint capability).	Applicable	Full	QHSE-PRO-014 §Sub-contractor Assurance System — QHSE-PRO-014 §Sub-contractor Assurance System and §Mass, Dimension and Loading Assurance establish prime-contractor verification of carrier MDL capability (configuration, permits, accreditation, restraint) at prequalification. Coverage Partial - documented in rev 1; residual is the populated prequalification register accruing from the next operating cycle.
HVNL-MDL-07	HVNL Ch 5 via consignee duty HVNL (interstate) CoR: consignee	A consignee must not make demands (delivery windows, penalties for late delivery) that would cause another CoR party to breach mass, dimension or loading requirements.	Applicable	Gap	—	Medium No documented consignee-demand review. Where Westlink acts as consignee (receiving on customer's behalf), delivery windows imposed on sub-contracted carriers are not filtered for CoR risk. Add to proposed scheduler operating procedure or sub-contractor engagement contract terms.
HVNL-MDL-08	NHVR Load Restraint Guide (adopted via HVNL Ch 5) HVNL (interstate) + WA (adopted) CoR: loading manager	Loads on heavy vehicles must be restrained to withstand: 0.8g deceleration forward; 0.5g acceleration rearward; 0.5g sideways; 0.2g upward. Restraint methods must meet the Load Restraint Guide performance standards.	Applicable	Partial	QHSE-POL-001 §Policy Commitments — Policy references "NTC Load Restraint Guide" (bullet 3). No verification procedure to check sub-contractor load restraint before departure at sites under Westlink control.	Medium Needed: load-restraint verification checklist for loading-manager sites. Optional for sub-contractor-controlled loading, but Westlink should specify load-restraint compliance as a contract term.
HVNL-FAT-01	HVNL s.26C, s.26E, s.264 (relevant-party fatigue duty; s.228 is the driver's duty) HVNL (interstate) CoR: scheduler	A scheduler of a fatigue-regulated heavy vehicle must take all reasonable steps to ensure the driver does not drive while fatigued, and that the driver is not caused to breach work/rest time requirements by the schedule.	Applicable	Full	GOV-POL-005 §Policy Statement — Fatigue management — work/rest hours; Fatigue management — scheduling practices QHSE-PRO-014 §Fatigue Management in Scheduling — QHSE-PRO-014 §Fatigue Management in Scheduling establishes scheduling that allows work/rest compliance, with carrier fatigue accreditation verified at prequalification. Coverage Partial - documented in rev 1; residual is schedule-basis records accruing from the next operating cycle.
HVNL-FAT-02	HVNL s.26C, s.26E (CoR party duty re driver's schedule) HVNL (interstate) CoR: scheduler, consignor, consignee, prime contractor	A CoR party (not just the scheduler) whose actions or business practices affect a driver's schedule must take reasonable steps to prevent the driver being caused to breach work/rest requirements.	Applicable	Full	GOV-POL-005 §Policy Statement — Chain of Responsibility obligations QHSE-POL-001 §Jurisdictional Application — Chain of Responsibility Policy — commits to dual-regime fatigue management; fatigue regime split. QHSE-PRO-014 §Fatigue Management in Scheduling — QHSE-PRO-014 §Fatigue Management in Scheduling and §Sub-contractor Assurance System address consignor/consignee/prime-contractor demands and contract terms affecting a driver's schedule (s.26E prohibited requests and contracts). Coverage Partial - documented in rev 1; residual is demand-review records accruing from the next operating cycle.
HVNL-FAT-03	HVNL Ch 6 Pt 6.3 (work/rest records) HVNL (interstate) CoR: scheduler, consignor, consignee, prime contractor	A CoR party must not enter or cause to be entered false or misleading information about a driver's work or rest time in a work diary or other record.	Applicable	Gap	—	Medium Awareness requirement — Westlink staff interacting with sub-contractor work-diary data (e.g. receipt confirmations timed, POD acknowledgements timestamped) must not misrepresent driver hours. Include in CoR training module.
HVNL-FAT-04	HVNL Ch 6 Pt 6.3 (accreditation verification) HVNL (interstate) CoR: prime contractor, scheduler	A prime contractor engaging a fatigue-regulated heavy vehicle must verify the sub-contractor's fatigue regime (Standard Hours, BFM, or AFM) and ensure schedules reflect that regime's limits.	Applicable	Partial	QHSE-PRO-014 §Fatigue Management in Scheduling — QHSE-PRO-014 §Fatigue Management in Scheduling and §Sub-contractor Assurance System require verification of carrier fatigue accreditation (Standard/BFM/AFM) at prequalification and periodically. Coverage Partial - documented in rev 1; residual is accreditation-verification records accruing from the next operating cycle.	High QHSE-PRO-014 §Fatigue Management in Scheduling and §Sub-contractor Assurance System require verification of carrier fatigue accreditation (Standard/BFM/AFM) at prequalification and periodically. Coverage Partial - documented in rev 1; residual is accreditation-verification records accruing from the next operating cycle.
HVNL-FAT-05	HVNL s.228 (evidence of compliance — schedule records) HVNL (interstate) CoR: scheduler	A scheduler should keep records demonstrating how schedules were designed to accommodate work/rest rules, including journey duration calculations, rest-stop identification, and allowances for loading/unloading time.	Applicable	Partial	QHSE-PRO-014 §Fatigue Management in Scheduling — QHSE-PRO-014 §Fatigue Management in Scheduling requires schedules and the basis for them to be recorded so compliance can be demonstrated. Coverage Partial - documented in rev 1; residual is schedule-design records accruing from the next operating cycle.	High QHSE-PRO-014 §Fatigue Management in Scheduling requires schedules and the basis for them to be recorded so compliance can be demonstrated. Coverage Partial - documented in rev 1; residual is schedule-design records accruing from the next operating cycle.
HVNL-FAT-06	HVNL s.26E (reasonable steps defence — fatigue) HVNL (interstate) CoR: scheduler, prime contractor	Evidence of reasonable steps for fatigue compliance may include adoption of the NHVR Master Code (or Industry Code of Practice) for fatigue scheduling, consultation with sub-contractors, training of schedulers, and regular audit of schedule-vs-actual hours.	Applicable	Gap	—	Medium NHVR Master Code not adopted; no formal fatigue scheduling consultation with sub-contractors; no scheduler training records. Consider Master Code registration as a simplifying assurance mechanism (reasonable-steps defence).
HVNL-SPD-01	HVNL Ch 6 Pt 6.2 (scheduler duty re speed) HVNL (interstate) CoR: scheduler	A scheduler must not schedule a heavy vehicle's transport activity in a way that would require the driver to exceed speed limits to meet the schedule.	Applicable	Full	QHSE-PRO-014 §Speed and Vehicle Standards — QHSE-PRO-014 §Speed and Vehicle Standards requires schedules, routes and timeslots set so a driver is not caused to exceed speed limits (journey time computed at lawful speeds). Coverage Partial - documented in rev 1; residual is schedule records accruing from the next operating cycle.
HVNL-SPD-02	HVNL Ch 6 Pt 6.2 (consignor/consignee duty re speed) HVNL (interstate) CoR: consignor, consignee	A consignor or consignee must not impose delivery windows that would require a driver to exceed speed limits.	Applicable	Gap	—	Medium No documented demand-review for speed implications. Integrates with HVNL-FAT-02 demand-review process.
HVNL-SPD-03	HVNL Ch 6 Pt 6.2 (prime contractor duty re speed) HVNL (interstate) CoR: prime contractor	A prime contractor must not offer incentives (bonuses, preferred-contractor status) that would encourage a sub-contractor's driver to exceed speed limits.	Applicable	Gap	—	Medium Review sub-contractor engagement contract terms for implicit speed incentives (tight delivery windows with penalty clauses).
HVNL-VS-01	HVNL Ch 4 (vehicle standards) via party duty HVNL (interstate) + WA (RT(V) Act) CoR: prime contractor	A prime contractor engaging a sub-contracted carrier must take reasonable steps to verify the heavy vehicle meets applicable vehicle standards (roadworthy, registered, correct configuration for the task).	Applicable	Full	QHSE-PRO-014 §Speed and Vehicle Standards — QHSE-PRO-014 §Speed and Vehicle Standards and §Sub-contractor Assurance System require verification of carrier vehicle roadworthiness, standards and maintenance at prequalification. Coverage Partial - documented in rev 1; residual is vehicle-standards verification records accruing from the next operating cycle.
HVNL-VS-02	HVNL Ch 4 (dangerous goods — vehicle standards) HVNL (interstate) + WA CoR: prime contractor	Where a transport activity may involve dangerous goods, the prime contractor must verify the sub-contractor holds a Dangerous Goods Licence (vehicle) and driver holds a Dangerous Goods Licence (driver) per ADG Code.	Reference only	Referenced-only	—	Westlink does not currently consign DG (per operational confirmation). Trigger condition for re-assessment — if DG consignment accepted, stand up DG framework reference (ADG + IMDG) and add this row back to Applicable scope.
HVNL-VS-03	HVNL s.551 (producing documents) HVNL (interstate) CoR: scheduler, consignor, consignee, prime contractor, loading manager	A CoR party must produce documents relating to transport activities when required by an authorised officer (NHVR inspector).	Applicable	Partial	QHSE-POL-001 §Review — Policy states "available to NHVR on request" (line 193). Assumes records exist — most underlying records (schedules, sub-contractor verification, consignor weight declarations) do not exist per gaps above.	Medium Remediation is contingent on closing the other gaps — produce-on-demand only works if the records exist.
HVNL-SYS-01	HVNL s.26E + NHVR Master Code guidance HVNL (interstate) + WA CoR: scheduler, consignor, consignee, prime contractor, loading manager	A CoR party should maintain a documented safety management system for transport activities, including hazard identification, risk assessment, controls, audit, and continual improvement.	Applicable	Full	QHSE-MAN-001 §6.1 — WMS Manual §6.1 Risk and Opportunity Register — generic, does not segment CoR risks. §11.3 identifies HVNL/RT(V) Act as applicable legal requirements. QHSE-POL-001 — Policy establishes commitments; no operationalising procedure.
HVNL-SYS-02	HVNL s.26C, s.26D(3) (training as a reasonable step) HVNL (interstate) + WA CoR: scheduler, consignor, consignee, prime contractor, loading manager	Workers performing CoR-relevant roles (schedulers, consignment-control staff, contract managers engaging sub-contractors, loading-manager site personnel) must receive training proportionate to their role.	Applicable	Full	QHSE-PRO-014 §Sub-contractor Assurance System — QHSE-PRO-014 §Sub-contractor Assurance System (worker competency) establishes role-specific CoR training for schedulers, consignment officers, loaders and project managers. Coverage Partial - documented in rev 1; residual is completed training records accruing from the next operating cycle.
HVNL-SYS-03	HVNL s.26C (sub-contractor assurance - reasonable steps) HVNL (interstate) + WA CoR: prime contractor	A prime contractor should implement a documented sub-contractor assurance regime covering: onboarding verification (NHVAS accreditation, vehicle registration, insurance, DG licensing if applicable); CoR contract terms; ongoing performance monitoring; incident reporting and investigation integration.	Applicable	Full	QHSE-PRO-014 §Sub-contractor Assurance System — QHSE-PRO-014 §Sub-contractor Assurance System establishes the documented prequalification, contract-CoR-clause, audit-cycle and termination regime - Westlink's core operational CoR control. Coverage Partial - documented in rev 1; residual is the populated carrier prequalification register and audit records accruing from the next operating cycle.
HVNL-SYS-04	HVNL s.26C(3)(b), s.26E(2) (contract cascade; prohibited contracts) HVNL (interstate) + WA CoR: prime contractor	Contracts engaging sub-contracted carriers should cascade CoR obligations, require evidence of accreditation, and preserve Westlink's right to audit and obtain compliance records.	Applicable	Full	QHSE-PRO-014 §Sub-contractor Assurance System — QHSE-PRO-014 §Sub-contractor Assurance System requires CoR clauses and cascade (flow-down) in every carrier contract and prohibits contracts that would cause a driver to breach the Law (s.26E(2)). Coverage Partial - documented in rev 1; residual is executed contracts carrying the CoR annex (and legal review of the standard annex) accruing from the next operating cycle.
HVNL-SYS-05	HVNL s.26E (incident reporting) HVNL (interstate) + WA CoR: prime contractor	Heavy vehicle incidents involving sub-contracted carriers (notifiable incidents, roadside compliance actions, NHVR enforcement notices) should be captured and investigated within Westlink's incident management system.	Applicable	Partial	QHSE-PRO-001 — Hazard and Incident Reporting and Investigation Procedure — general scope; does not specifically require sub-contractor heavy vehicle incident intake. QHSE-POL-001 §Jurisdictional Application — Chain of Responsibility Policy — commits to accident/incident reporting; vehicle standards and incident reporting.	High Extend QHSE-PRO-001 to explicitly cover sub-contractor heavy vehicle incident intake (notifiable incidents, NHVR notices, infringement notices). Add to sub-contractor assurance procedure as an ongoing monitoring control.
HVNL-SYS-06	HVNL s.26E (management review) HVNL (interstate) + WA CoR: executive officers	Executive management should periodically review CoR performance (sub-contractor incident rates, schedule-vs-actual exceptions, audit results, training completion) as part of governance.	Applicable	Partial	QHSE-MAN-001 §9.3 — Management review clause present; CoR not explicitly listed as a standing input. QHSE-POL-001 §Review — Chain of Responsibility Policy — commits to Annual review with HVNL adoption trigger.	Medium Add CoR performance as a standing management-review input; specify metrics (see HVNL-EOD-02 evidence pack).
WARV-01	RT(V) Act 2012 (WA) Part 4 Div 2 s.25 (general duty) WA (RT(V) Act) CoR: scheduler, consignor, consignee, prime contractor, loading manager	Each person in the chain of responsibility for a heavy vehicle must take reasonable steps to ensure the vehicle and its load comply with mass, dimension, load-restraint and vehicle-standard requirements. Applies to consignor, loader, driver, operator, and any person whose business activities affect compliance.	Applicable	Partial	QHSE-POL-001 §Purpose / Scope — Policy identifies RT(V) Act 2012 Part 4 as source for WA CoR duty. Same policy gaps as HVNL-PD-01 apply to WA-leg movements.	High WA CoR scope essentially mirrors HVNL off-road party duties. Remediation coincides with HVNL-PD-01/02/03 items — QHSE-POL-001 Rev 3 should address both regimes in integrated procedures.
WARV-02	RT(V) Act 2012 (WA) Part 4 - s.29, s.95, s.103 (consignor MDL + transport-documentation duties); s.113 reasonable-steps defence WA (RT(V) Act) CoR: consignor	A consignor must take reasonable steps to ensure the goods do not cause the vehicle to exceed mass limits, and that load particulars (weight, dimensions) provided to the carrier are accurate.	Applicable	Full	QHSE-PRO-014 §Mass, Dimension and Loading Assurance — QHSE-PRO-014 §Mass, Dimension and Loading Assurance covers the WA consignor MDL and transport-documentation duties (RT(V) Act s.29, s.95, s.103) under the reasonable-steps defence (s.113). Coverage Partial - documented in rev 1; residual is consignment and weight-declaration records accruing from the next operating cycle.
WARV-03	RT(V) Regulations 2014 (WA) Part 8 (load restraint) WA (RT(V) Regs) CoR: loading manager	Loads must be restrained to meet performance standards equivalent to the NTC Load Restraint Guide. Specific regulation in WA regs 297–302 for load restraint performance.	Applicable	Partial	QHSE-POL-001 §Policy Commitments — Policy references NTC Load Restraint Guide. No WA-specific reg cite.	Medium Same remediation as HVNL-MDL-08; add WA regs 297–302 to load-restraint verification checklist.
WARV-04	RT(V) Act 2012 (WA) Part 4 - responsible-person MDL duty (no WA scheduler party); s.113 reasonable-steps defence WA (RT(V) Act) CoR: scheduler, consignor, consignee, prime contractor	A person whose business practices affect a driver's ability to comply with mass, dimension or load-restraint requirements must take reasonable steps to prevent such a breach.	Applicable	Full	QHSE-PRO-014 §Primary Duty and Reasonable Steps — QHSE-PRO-014 §Primary Duty and Reasonable Steps and §Mass, Dimension and Loading Assurance cover the WA responsible-person duty (no statutory scheduler party in WA) under the reasonable-steps defence (s.113). Coverage Partial - documented in rev 1; residual is reasonable-steps records accruing from the next operating cycle.
WARV-05	RT(V) Regulations 2014 (WA) fatigue provisions WA (RT(V) Regs + WHS Act) CoR: scheduler, consignor, consignee, prime contractor	WA fatigue management is not governed by HVNL Standard Hours / BFM / AFM — it applies through RT(V) Regulations 2014 (limited prescriptive rules) and general WHS Act 2020 duties. Off-road parties should ensure schedules do not create fatigue-related safety risk under the WHS Act.	Applicable	Partial	QHSE-POL-001 §Policy Commitments — Policy commits to "WA Road Traffic (Vehicles) Regulations 2014" fatigue compliance. No operating procedure backing the commitment. GOV-POL-005 §Policy Statement — Fatigue management — work/rest hours; Fatigue management — scheduling practices QHSE-PRO-014 §Fatigue Management in Scheduling — QHSE-PRO-014 §Fatigue Management in Scheduling schedules WA movements to the RT(V) Regulations 2014 (WA) and records the basis, applying WHS-based risk control where the Regulations are silent. Coverage Partial - documented in rev 1; residual is WA schedule-basis records accruing from the next operating cycle.	High QHSE-PRO-014 §Fatigue Management in Scheduling schedules WA movements to the RT(V) Regulations 2014 (WA) and records the basis, applying WHS-based risk control where the Regulations are silent. Coverage Partial - documented in rev 1; residual is WA schedule-basis records accruing from the next operating cycle.
WARV-06	RT(V) Act 2012 (WA) Part 4 (executive liability) WA (RT(V) Act) CoR: executive officers (CEO, directors)	An executive officer (director) of a body corporate may be personally liable for certain CoR offences where the body corporate contravenes the Act and the officer was in a position to influence the conduct.	Applicable	Partial	QHSE-POL-001 §Responsibilities — Policy cites personal due diligence. WA-specific executive liability language not separately captured — defaults to HVNL s.26D citation (which is itself an error).	High Coincides with HVNL-EOD-01 remediation (policy citation fix + documented due-diligence review). Include WA RT(V) Act executive-liability language in Rev 3.
WARV-07	Road Traffic (Administration) Act 2008 (WA) WA CoR: scheduler, consignor, consignee, prime contractor, loading manager	Administrative framework for WA road transport enforcement — authorised officers' powers, notices, records, infringements. CoR parties must comply with notices and information requests.	Reference only	Referenced-only	QHSE-POL-001 — Policy references this Act in standards list.
WARV-08	Main Roads WA Heavy Vehicle Operations permits WA (Main Roads WA) CoR: scheduler, consignor, prime contractor	Where a transport activity requires oversize/overmass permits or Restricted Access Vehicle (RAV) network approval, the scheduler/consignor should verify permit availability before consigning.	Applicable	Full	QHSE-PRO-014 §Oversize and Over-mass Permits — QHSE-PRO-014 §Oversize and Over-mass Permits requires permits, pilot/escort and route conditions to be obtained and confirmed before movement (Main Roads WA Heavy Vehicle Services / NHVR). Coverage Partial - documented in rev 1; residual is permit records accruing from the next operating cycle.

Source document

HVNL Chain of Responsibility + WA Road Traffic (Vehicles) Act parallel — off-road CoR party duties (scheduler, consignor, consignee, prime contractor, loading manager)

40 normative shall-statements extracted from Heavy Vehicle National Law — Chain of Responsibility (off-road party scope) (source: Heavy Vehicle National Law Act 2012 (Qld) + Road Traffic (Vehicles) Act 2012 (WA) + Road Traffic (Vehicles) Regulations 2014 (WA)). The frontmatter requirements array is the source of truth — this body is rendered by scripts/render_compliance.py.

Coverage summary

Coverage	Count
✅ Full	17
🟡 Partial	15
🟠 Ref-only	3
🔴 Gap	5
— N/A	0

Gap severity distribution

Severity	Count
🔴 Critical	0
🟠 High	11
🟡 Medium	9
🟢 Low	0

Requirements

Clause HVNL Ch 4 (dangerous goods — vehicle standards)

ID	Coverage	Evidence	Gap	Notes
HVNL-VS-02	🟠 Ref-only	—		Westlink does not currently consign DG (per operational confirmation). Trigger condition for re-assessment — if DG consignment accepted, stand up DG framework reference (ADG + IMDG) and add this row back to Applicable scope.

Clause HVNL Ch 4 (vehicle standards) via party duty

ID	Coverage	Evidence	Gap	Notes
HVNL-VS-01	✅ Full	[QHSE-PRO-014 §Speed and Vehicle Standards](/wms/QHSE-PRO-014#sSpeed and Vehicle Standards)

Clause HVNL Ch 5 (container weight declaration)

ID	Coverage	Evidence	Gap	Notes
HVNL-MDL-04	✅ Full	[OPS-PRO-003 §‘§7 Container Weight Declaration’](/wms/OPS-PRO-003#s’§7 Container Weight Declaration’)

Clause HVNL Ch 5 (dimension requirements) via party duties

ID	Coverage	Evidence	Gap	Notes
HVNL-MDL-02	✅ Full	[QHSE-PRO-014 §Mass, Dimension and Loading Assurance](/wms/QHSE-PRO-014#sMass, Dimension and Loading Assurance)

Clause HVNL Ch 5 (loading) via party duties

ID	Coverage	Evidence	Gap	Notes
HVNL-MDL-03	🟡 Partial	[QHSE-POL-001 §Policy Commitments](/wms/QHSE-POL-001#sPolicy Commitments)	🟠 High	Westlink is a loading manager where it has operational control at a loading site (e.g. supplier yard when coordinating project-cargo loading). Needed: loading-manager checklist / load-restraint verification procedure for sites under Westlink control. Identify which sites/operations put Westlink in a loading-manager role (business analysis required).

Clause HVNL Ch 5 via consignee duty

ID	Coverage	Evidence	Gap	Notes
HVNL-MDL-07	🔴 Gap	—	🟡 Medium	No documented consignee-demand review. Where Westlink acts as consignee (receiving on customer’s behalf), delivery windows imposed on sub-contracted carriers are not filtered for CoR risk. Add to proposed scheduler operating procedure or sub-contractor engagement contract terms.

Clause HVNL Ch 5 via prime contractor duty

ID	Coverage	Evidence	Gap	Notes
HVNL-MDL-06	✅ Full	[QHSE-PRO-014 §Sub-contractor Assurance System](/wms/QHSE-PRO-014#sSub-contractor Assurance System)

Clause HVNL Ch 5 via scheduler duty

ID	Coverage	Evidence	Gap	Notes
HVNL-MDL-05	🟡 Partial	[QHSE-PRO-014 §Mass, Dimension and Loading Assurance](/wms/QHSE-PRO-014#sMass, Dimension and Loading Assurance)	🟠 High	QHSE-PRO-014 §Mass, Dimension and Loading Assurance and §Oversize and Over-mass Permits cover route, mass and permit verification before consigning. Coverage Partial - documented in rev 1; residual is route and permit-verification records accruing from the next operating cycle.

Clause HVNL Ch 6 Pt 6

ID	Coverage	Evidence	Gap	Notes
HVNL-FAT-03	🔴 Gap	—	🟡 Medium	Awareness requirement — Westlink staff interacting with sub-contractor work-diary data (e.g. receipt confirmations timed, POD acknowledgements timestamped) must not misrepresent driver hours. Include in CoR training module.
HVNL-FAT-04	🟡 Partial	[QHSE-PRO-014 §Fatigue Management in Scheduling](/wms/QHSE-PRO-014#sFatigue Management in Scheduling)	🟠 High	QHSE-PRO-014 §Fatigue Management in Scheduling and §Sub-contractor Assurance System require verification of carrier fatigue accreditation (Standard/BFM/AFM) at prequalification and periodically. Coverage Partial - documented in rev 1; residual is accreditation-verification records accruing from the next operating cycle.
HVNL-SPD-01	✅ Full	[QHSE-PRO-014 §Speed and Vehicle Standards](/wms/QHSE-PRO-014#sSpeed and Vehicle Standards)
HVNL-SPD-02	🔴 Gap	—	🟡 Medium	No documented demand-review for speed implications. Integrates with HVNL-FAT-02 demand-review process.
HVNL-SPD-03	🔴 Gap	—	🟡 Medium	Review sub-contractor engagement contract terms for implicit speed incentives (tight delivery windows with penalty clauses).

Clause HVNL s

ID	Coverage	Evidence	Gap	Notes
HVNL-PD-01	🟡 Partial	[QHSE-POL-001 §Policy Commitments](/wms/QHSE-POL-001#sPolicy Commitments) [GOV-POL-001 §Policy Commitments](/wms/GOV-POL-001#sPolicy Commitments) [GOV-POL-002 §Policy Commitments](/wms/GOV-POL-002#sPolicy Commitments) [GOV-POL-003 §Organisational Context](/wms/GOV-POL-003#sOrganisational Context) [GOV-POL-005 §Organisational Context](/wms/GOV-POL-005#sOrganisational Context)	🟠 High	Policy cites the duty but does not describe off-road-party-specific SFAIRP controls. Remediation via QHSE-POL-001 Rev 3 rewrite with operating-model alignment, and a sub-contractor assurance procedure setting out how Westlink verifies sub-contracted carriers discharge their own HVNL duties.
HVNL-PD-02	✅ Full	[GOV-POL-003 §Organisational Context](/wms/GOV-POL-003#sOrganisational Context) [QHSE-POL-001 §Jurisdictional Application](/wms/QHSE-POL-001#sJurisdictional Application) [QHSE-PRO-014 §Primary Duty and Reasonable Steps](/wms/QHSE-PRO-014#sPrimary Duty and Reasonable Steps)
HVNL-PD-03	🟡 Partial	[QHSE-PRO-014 §Primary Duty and Reasonable Steps](/wms/QHSE-PRO-014#sPrimary Duty and Reasonable Steps)	🟠 High	QHSE-PRO-014 §Primary Duty and Reasonable Steps and §Sub-contractor Assurance System set out the reasonable-steps controls evidencing the s.26C duty (prequalification, accurate information, compliant scheduling, contract terms, monitoring). Coverage Partial - documented in rev 1; residual is the populated CoR reasonable-steps records accruing from the next operating cycle.
HVNL-EOD-01	🟡 Partial	[QHSE-POL-001 §Policy Commitments / Responsibilities](/wms/QHSE-POL-001#sPolicy Commitments / Responsibilities)	🟠 High	Two remediation items. (1) Correct statutory citation in QHSE-POL-001 Rev 3 — s.26D → s.26G. (2) Establish a documented annual CoR due-diligence review for the CEO with evidence pack (incident log, sub-contractor assurance results, schedule-compliance exceptions, training records). Current Responsibilities row “Ongoing; annual due diligence review” is directive but not operationalised.
HVNL-EOD-02	✅ Full	[QHSE-PRO-014 §Executive Due Diligence](/wms/QHSE-PRO-014#sExecutive Due Diligence)
HVNL-EOD-03	🟠 Ref-only	QHSE-POL-001 §Responsibilities
HVNL-MDL-01	✅ Full	[QHSE-PRO-014 §Mass, Dimension and Loading Assurance](/wms/QHSE-PRO-014#sMass, Dimension and Loading Assurance)
HVNL-FAT-01	✅ Full	[GOV-POL-005 §Policy Statement](/wms/GOV-POL-005#sPolicy Statement) [QHSE-PRO-014 §Fatigue Management in Scheduling](/wms/QHSE-PRO-014#sFatigue Management in Scheduling)
HVNL-FAT-02	✅ Full	[GOV-POL-005 §Policy Statement](/wms/GOV-POL-005#sPolicy Statement) [QHSE-POL-001 §Jurisdictional Application](/wms/QHSE-POL-001#sJurisdictional Application) [QHSE-PRO-014 §Fatigue Management in Scheduling](/wms/QHSE-PRO-014#sFatigue Management in Scheduling)
HVNL-FAT-05	🟡 Partial	[QHSE-PRO-014 §Fatigue Management in Scheduling](/wms/QHSE-PRO-014#sFatigue Management in Scheduling)	🟠 High	QHSE-PRO-014 §Fatigue Management in Scheduling requires schedules and the basis for them to be recorded so compliance can be demonstrated. Coverage Partial - documented in rev 1; residual is schedule-design records accruing from the next operating cycle.
HVNL-FAT-06	🔴 Gap	—	🟡 Medium	NHVR Master Code not adopted; no formal fatigue scheduling consultation with sub-contractors; no scheduler training records. Consider Master Code registration as a simplifying assurance mechanism (reasonable-steps defence).
HVNL-VS-03	🟡 Partial	QHSE-POL-001 §Review	🟡 Medium	Remediation is contingent on closing the other gaps — produce-on-demand only works if the records exist.
HVNL-SYS-01	✅ Full	QHSE-MAN-001 §‘6.1’ QHSE-POL-001
HVNL-SYS-02	✅ Full	[QHSE-PRO-014 §Sub-contractor Assurance System](/wms/QHSE-PRO-014#sSub-contractor Assurance System)
HVNL-SYS-03	✅ Full	[QHSE-PRO-014 §Sub-contractor Assurance System](/wms/QHSE-PRO-014#sSub-contractor Assurance System)
HVNL-SYS-04	✅ Full	[QHSE-PRO-014 §Sub-contractor Assurance System](/wms/QHSE-PRO-014#sSub-contractor Assurance System)
HVNL-SYS-05	🟡 Partial	QHSE-PRO-001 [QHSE-POL-001 §Jurisdictional Application](/wms/QHSE-POL-001#sJurisdictional Application)	🟠 High	Extend QHSE-PRO-001 to explicitly cover sub-contractor heavy vehicle incident intake (notifiable incidents, NHVR notices, infringement notices). Add to sub-contractor assurance procedure as an ongoing monitoring control.
HVNL-SYS-06	🟡 Partial	QHSE-MAN-001 §‘9.3’ QHSE-POL-001 §Review	🟡 Medium	Add CoR performance as a standing management-review input; specify metrics (see HVNL-EOD-02 evidence pack).

Clause Main Roads WA Heavy Vehicle Operations permits

ID	Coverage	Evidence	Gap	Notes
WARV-08	✅ Full	[QHSE-PRO-014 §Oversize and Over-mass Permits](/wms/QHSE-PRO-014#sOversize and Over-mass Permits)

Clause NHVR Load Restraint Guide (adopted via HVNL Ch 5)

ID	Coverage	Evidence	Gap	Notes
HVNL-MDL-08	🟡 Partial	[QHSE-POL-001 §Policy Commitments](/wms/QHSE-POL-001#sPolicy Commitments)	🟡 Medium	Needed: load-restraint verification checklist for loading-manager sites. Optional for sub-contractor-controlled loading, but Westlink should specify load-restraint compliance as a contract term.

Clause RT(V) Act 2012 (WA) Part 4 (executive liability)

ID	Coverage	Evidence	Gap	Notes
WARV-06	🟡 Partial	QHSE-POL-001 §Responsibilities	🟠 High	Coincides with HVNL-EOD-01 remediation (policy citation fix + documented due-diligence review). Include WA RT(V) Act executive-liability language in Rev 3.

Clause RT(V) Act 2012 (WA) Part 4 - responsible-person MDL duty (no WA scheduler party); s

ID	Coverage	Evidence	Gap	Notes
WARV-04	✅ Full	[QHSE-PRO-014 §Primary Duty and Reasonable Steps](/wms/QHSE-PRO-014#sPrimary Duty and Reasonable Steps)

Clause RT(V) Act 2012 (WA) Part 4 - s

ID	Coverage	Evidence	Gap	Notes
WARV-02	✅ Full	[QHSE-PRO-014 §Mass, Dimension and Loading Assurance](/wms/QHSE-PRO-014#sMass, Dimension and Loading Assurance)

Clause RT(V) Act 2012 (WA) Part 4 Div 2 s

ID	Coverage	Evidence	Gap	Notes
WARV-01	🟡 Partial	[QHSE-POL-001 §Purpose / Scope](/wms/QHSE-POL-001#sPurpose / Scope)	🟠 High	WA CoR scope essentially mirrors HVNL off-road party duties. Remediation coincides with HVNL-PD-01/02/03 items — QHSE-POL-001 Rev 3 should address both regimes in integrated procedures.

Clause RT(V) Regulations 2014 (WA) Part 8 (load restraint)

ID	Coverage	Evidence	Gap	Notes
WARV-03	🟡 Partial	[QHSE-POL-001 §Policy Commitments](/wms/QHSE-POL-001#sPolicy Commitments)	🟡 Medium	Same remediation as HVNL-MDL-08; add WA regs 297–302 to load-restraint verification checklist.

Clause RT(V) Regulations 2014 (WA) fatigue provisions

ID	Coverage	Evidence	Gap	Notes
WARV-05	🟡 Partial	[QHSE-POL-001 §Policy Commitments](/wms/QHSE-POL-001#sPolicy Commitments) [GOV-POL-005 §Policy Statement](/wms/GOV-POL-005#sPolicy Statement) [QHSE-PRO-014 §Fatigue Management in Scheduling](/wms/QHSE-PRO-014#sFatigue Management in Scheduling)	🟠 High	QHSE-PRO-014 §Fatigue Management in Scheduling schedules WA movements to the RT(V) Regulations 2014 (WA) and records the basis, applying WHS-based risk control where the Regulations are silent. Coverage Partial - documented in rev 1; residual is WA schedule-basis records accruing from the next operating cycle.

Clause Road Traffic (Administration) Act 2008 (WA)

ID	Coverage	Evidence	Gap	Notes
WARV-07	🟠 Ref-only	QHSE-POL-001

Rendered from frontmatter by scripts/render_compliance.py. Source extraction: scripts/extract_iso9001_requirements.py. Evidence population: scripts/populate_iso9001_evidence.py. Validate: scripts/compliance_validate.py.