How can small operators meet Chain of Responsibility obligations?
TLDR: Effective Chain of Responsibility compliance doesn't have to involve expensive or complicated safety management systems. For small operators, a good starting point is documenting the safety checks and processes they already have in place, comparing them with the guidance in the 2026 Master Code and addressing any gaps over time.
The new Master Code covers 45 transport activities and more than 500 suggested controls. While this is only intended as a guide for businesses, for small operators without dedicated safety or compliance teams, knowing where to start or where the time is worth it can seem daunting. But effective safety management doesn't necessarily require extensive resources or complicated systems.
“If a business has been operating for a while, and hasn't had infringements, notices, an accident, or a prosecution, or an investigation, chances are they're probably doing things safely,” says Marla Cartmill, Supply Chain Technical Specialist at CoRsafe. “Often, the gap isn't in what they're doing, it's in how consistently those activities are documented, communicated and evident.”
Closing that gap can protect your business if something does go wrong, and it takes less time than most operators expect.
What changed for Chain of Responsibility in 2026?
Two important changes took effect in 2026.
First, the new Master Code replaced the 2018 version in January. While the previous Code organised its guidance around supply chain roles, the new one focuses on the transport activities a business undertakes or influences, whatever its role, and identifies 45 of them with more than 500 suggested controls.
“I don't think there are many businesses in Australia that would do all 45 transport activities,” Marla says, “but it’s not uncommon for transport operators to have more than 70% of these apply, and there are at least 10 that apply to most parties in the chain.”
The Code doesn't introduce any new legal duties. Instead, it provides practical guidance on how businesses can meet their existing Chain of Responsibility obligations.
“The Code is not exactly the law,” Marla says, “but it's the yardstick of what best practice looks like.”
Businesses may adopt controls that differ from those outlined in the Code, provided they can demonstrate those controls are equally or more effective in managing the relevant risks.
“If you adopt something different, then you need to ensure that it's as good, if not better [than those described in the Code],” Marla says.
Second, amendments to the Heavy Vehicle National Law (HVNL) became law on 1 August. Businesses renewing or applying for Heavy Vehicle Accreditation (HVA) now need a safety management system (SMS) covering their whole operation as a core requirement of HVA.
For other operators, a formal safety management system isn’t a legal requirement, but is considered a strong approach to managing risks, even if you aren’t accredited, because it documents what you do.
“A safety management system doesn't need to be complex,” Marla says. “In fact, the simpler it is, the better.”
Most of the necessary safety practices may already be part of a business's daily routine.
“If you're an owner-driver and you've paid for that truck, I bet you are checking that truck every morning,” Marla says. “You're checking the dials, you're checking the tyres. But are these checks being recorded?”
If not, write them down. It could be as simple as a printed checklist you use every morning.
What “good” looks like in a small operation
Documented procedures only work if everyone does the job the same way. That gets harder the moment you take on your first employee, and harder again as you grow.
“Safety culture makes quite a difference,” Marla says. Part of that is involving the people who do the work when you write a procedure, making sure everyone’s been shown how it works, and making it easy for someone to tell you when it isn’t working in practice.
“If you’ve got a policy that says you’re doing something and it’s not working, it’s not going to hold up,” she says. “And often it’s not helping your team operate safely either.”
Expectations need to be just as clear outside your business. A written agreement setting out who manages which safety risks protects you if something goes wrong, and it answers customers who want to know how you operate.
Keeping up with alerts and updates
Industry newsletters, like the CoRsafe one, cover most of what changes, and signing up takes minutes. The regulator has their own one too, and monitoring both types will help businesses keep across what they ought to know.
Where to start improving safety management
For small operators, finding the time to improve safety processes can be a challenge.
“Operators are time poor,” Marla says. “It's a 24-hour game.”
Marla stresses that you don't have to do everything at once. “If you've got no safety management system today, and tomorrow you've got a tiny part of it documented, you're probably in a better position than you were today.”
“Write down everything you do over the course of the day or the week,” Marla says. “For example, we get alerted that we've got a job, we accept the job, we allocate a driver, the driver arrives on site. Those are four examples of activities within a transport task.”
Next to each one, note what could go wrong, and what you’re already doing to manage the risk.
Removing the guesswork
CoRsafe can also help you work out where to start.
Our free self-assessment tool asks questions about your operation, helping you identify potential gaps in your existing safety processes and see how your business compares with similar operators. Marla recommends completing the assessment with someone who can bring a fresh perspective to the business and spot things that might otherwise be overlooked.
CoRsafe has also included some powerful supporting tools to help businesses improve their processes and educate their teams, with training, templates and guidance included in the CoRsafe Starter package.
Your safety management system is everything you do to manage risk — your people, your procedures and your records. CoRsafe doesn’t replace that, but our tools help you build and document it.
Start small, then build
Effective safety management doesn't have to happen overnight.
“An SMS is a great line of defence should anything happen,” Marla says. “And it's your engine room: how you treat your people, how you train your people, how you make your business safer.”
Learn how CoRsafe's Starter package can help you develop practical safety processes for your business and train your team.
This article is provided for general information purposes only and does not constitute legal, regulatory, compliance, safety, insurance, financial or other professional advice. The information and suggestions discussed in this article are intended as general guidance and should not be relied upon as a substitute for professional advice tailored to your business, operations and circumstances. Use of CoRsafe, this article, or any tools, templates, resources, recommendations or suggested controls referred to in this article does not guarantee any particular compliance, safety, accreditation or legal outcome. You should obtain independent professional advice before acting on any information contained in this article.
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