Chain of Responsibility
Luxwood manufactures and installs structures, equipment and electronic systems for small through to large scale modular buildings.
Luxwood uses road transport to transport goods to clients’ sites, which causes participation in the chain of responsibility legislation. The following roles are involved:
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Consigning - commissioning the carrying of goods
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Packing - placing goods in packages or containers or on pallets
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Loading - placing or restraining the load on a vehicle
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Driving - the physical act of driving a commercial vehicle
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Operating - operating a business which controls the use of a commercial vehicle.
Luxwood acknowledges that it has obligations not to coerce, induce or encourage a breach of road transport laws. In addition to ensuring compliance with road laws, Luxwood has to take reasonable steps to make sure that it does not pass on to other parties any false or misleading information about a vehicle or its load.
Specific Roles Consignor / Receiver
Where Luxwood is the consigner or receiver of product to be transported, as a consignor or receiver, Luxwood has a responsibility for ensuring that any demands made do not require a truck driver to:
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Exceed permitted driving hours
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Fail to have minimum rest periods
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Exceed the speed limit.
Under legislation, Luxwood will also have a responsibility for ensuring that goods carried on its behalf:
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Do not exceed vehicle dimension limits
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Do not cause vehicle mass limits to be exceeded
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Are appropriately secured.
Loader / Packer
Where Luxwood is involved in the loading or packing of product to be transported, packers and loaders will have a responsibility for ensuring that the vehicles load:
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Does not exceed dimension limits
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Does not cause vehicle mass limits to be exceeded
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Is placed so that it does not become unstable, move or fall off the vehicle.
Packers will have a responsibility for ensuring that documentation about the vehicles load is not false or misleading.
Packers will also need to make sure that any goods packed in a freight container do not cause the containers gross weight or safety approval rating to be exceeded.
Drivers
Where Luxwood engages workers who are truck drivers, the drivers are responsible to ensure that:
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Driving-hours regulations (time spent driving and working) are adhered to
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Required rest breaks are taken
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Records of driving hours are kept
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The vehicle does not exceed mass limits
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The vehicle and load do not exceed dimension limits
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The load is appropriately restrained
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They do not exceed the speed limit
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They do not tamper with any equipment required to be fitted to the vehicle.
The load should be checked to ensure it is properly restrained, even if the driver is not the person who loaded the vehicle. The driver should check the adequacy and condition of restraining equipment (chains, ropes, straps etc.).
Operator / Manager / Scheduler
Where Luxwood operates, manages or schedules road transport, its responsibilities include ensuring that:
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Rosters and schedules do not require drivers to exceed driving-hours regulations or speed limits
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Vehicle speed limiters are functioning
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Vehicles do not exceed mass or dimension limits
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Appropriate restraint equipment is provided and loads are appropriately restrained
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Records are kept of drivers’ activities, including driving, work and rest times.
As an operator, or an employee of an operator, Luxwood needs to make sure that the business’ conduct does not compromise road safety or involve breaking the law.
The following controls will be introduced to manage the risk of non-compliance:
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Implement systems to ensure that the mass of each vehicle is assessed and recorded for each trip
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Have an auditable system for rostering and scheduling drivers so that they do not exceed the regulated hours of driving and work or any speed limits, and that they have sufficient opportunity for rest and sleep to avoid fatigue
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Have work practices in place so that vehicles and equipment are kept in good condition and all loads are properly restrained
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Ensure that, if speed limiters are fitted to the vehicles, they are operating properly
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Keep records of drivers activities including driving, working and resting, and check that they are complying with the regulations
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Include compliance assurance conditions in relevant commercial arrangements with other responsible persons
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Ensure that employees have the necessary information, instruction, training and supervision to enable compliance with relevant laws.
Where Luxwood main activity is transport operations it will develop a separate, and business specific, “Chain of Responsibility Management Plan” to ensure compliance with the legislation.
All staff and subcontractors have individual responsibility for understanding and applying this Chain of Responsibility Policy in the performance of their tasks. Company management is fully committed to this Chain of Responsibility Policy through an active focus on understanding and managing Chain of Responsibility risks and leadership by example.