Key takeaways

• Transport risk becomes harder to manage when operating conditions change faster than oversight.
• Point-in-time approvals don’t give you enough visibility into drivers, vehicles, subcontractors, and routes over time.
• Generic compliance models can miss the transport specific indicators that matter most.
• Stronger programs combine transport specific standards, expert review, and continuous visibility.
  

Road transport risk can remain high even in a regulated environment. The next question is why that happens so often in Australia, even when organisations believe they have the right controls in place.

A major part of the answer sits with Chain of Responsibility (CoR).

CoR is one of the most significant transport safety and governance obligations facing Australian businesses today because it extends legal responsibility beyond the driver and carrier. If your organisation influences transport work in any meaningful way, your duties don't start and end with selecting a provider and collecting the right documents. They extend to how transport activities are planned, managed, monitored, and verified in practice.

That's what makes CoR so important, and why it’s often misunderstood.

Under CoR, parties in the road transport supply chain must, so far as is reasonably practicable, ensure the safety of their transport activities. That includes addressing risks linked to areas such as speed, fatigue, loading, vehicle standards, maintenance, and scheduling pressures. It also means businesses can't rely on contractual distance as a defence if the way work is structured contributes to unsafe outcomes.

In practical terms, your organisation may hold duties if it sets delivery expectations, controls site access, manages loading practices, influences timeframes, selects transport providers, or creates commercial conditions that affect how transport work is carried out.

This is where transport risk often slips through the cracks.

Many oversight models still focus on onboarding, insurance checks, inductions, and periodic document reviews. Those controls matter, but they aren't enough on their own to demonstrate that CoR duties are being actively met. A provider may appear compliant at the point of approval while meaningful risk continues to develop across scheduling, subcontracting, fleet use, and day-to-day delivery decisions.

For example, a business may have a compliant carrier on paper but still create pressure through unrealistic delivery windows, poor loading coordination, or limited visibility into subcontracted legs of a journey. In those situations, the legal and operational risk doesn't sit with the driver alone. It can extend across the broader chain of responsibility.

That's why static compliance models aren't a strong fit for CoR obligations. CoR requires active risk management, not passive reliance on paperwork.

So what does stronger practice look like?

It starts with understanding where your organisation influences transport work and where legal duties attach. From there, stronger programmes usually focus on three areas:

• Clear transport specific standards that go beyond broad contractor compliance and assess the conditions that directly affect road transport safety
• Better visibility into how transport work is actually being delivered, including subcontracting arrangements, route exposure, scheduling pressures, and vehicle or driver-related risk factors
• Ongoing review and verification, so your organisation is not assuming controls are working but checking whether they remain effective over time

This matters across functions.

If you work in HSE or risk, it helps strengthen assurance that legal duties are being translated into practical controls. If you work in procurement, it helps you understand carrier risk without treating supplier approval as the end of the process. If you work in operations, it helps reduce the likelihood that planning or delivery decisions unintentionally create transport exposure.

Most importantly, it helps your organisation shift from a narrow compliance mindset to a stronger CoR governance approach.

In the final blog, we’ll look at why CoR isn’t simply a driver issue, why executive verification matters, and what organisations should do now ahead of the 1 August 2026 HVNL reform.

Want to understand where your transport risk programme may have gaps today?
Our team of transport experts can help you identify risks and what good could look like for your organisation.