What a Digital Vehicle Inspection Has to Record
A digital vehicle inspection has to record what was checked, by whom, on which vehicle, at what time, with a photograph against the item that failed, and what was decided about it. Under the Heavy Vehicle National Law the Chain of Responsibility puts a primary duty on the operator, the scheduler, the loader, and the consignor, so the pre-start record is evidence of your own duty, not paperwork the driver owes you.
A pre-start check is the only inspection in most businesses that happens every single day. It is also the one most often treated as the driver’s paperwork rather than the operator’s evidence, which gets the duty exactly the wrong way round.
The fleets I have watched get this right are not the ones with the longest checklist. They are the ones where the record answers four questions without anyone reconstructing anything: what was checked, who checked it, what was wrong, and what was decided about it. That last one is where most systems go quiet.
What the Chain of Responsibility Puts on You.
The Chain of Responsibility is the part of the Heavy Vehicle National Law that makes parties other than the driver responsible for the safety of a heavy vehicle on the road. Everyone from the business that employs the driver or owns the vehicle to the business that sends or receives the goods is accountable for the safety of the vehicle, its driver, and its load, right through the journey.1
The NHVR names 10 functions that make you a party: employer, prime contractor, operator, scheduler, consignor, consignee, packer, loading manager, loader, and unloader. You are a party because of a function you perform, not because of a job title or the words of a contract, and more than half of those functions belong to businesses that neither own nor drive a heavy vehicle. The rule of thumb the regulator offers is simple: if your business sends or receives goods by heavy vehicle, you are in the chain.2 Driving is not one of the functions; drivers carry other duties under the law.2
Every party carries the same primary duty: to ensure, so far as is reasonably practicable, the safety of its transport activities. The NHVR describes it as the same shape as a work health and safety duty, and the steps are the same too: identify the risks, assess them, eliminate them, and where they cannot be eliminated, minimise them as far as possible.4
Two facts about where this law runs are worth getting right before you write a policy on it. The NHVR administers one set of laws for heavy vehicles over 4.5 tonnes gross vehicle mass, and the HVNL commenced on 10 February 2014 in the Australian Capital Territory, New South Wales, Queensland, South Australia, Tasmania, and Victoria. It has not commenced in Western Australia or the Northern Territory, although it applies to vehicles from those jurisdictions once they cross into a state or territory where it has, and some requirements bite before the border.3 The law also changed on 1 August 2026, bringing in a new Heavy Vehicle Accreditation scheme, fatigue changes, and simplified work diary record-keeping.3
The Pre-Start Is Named as a Control, So Treat It Like One.
The NHVR lists five main risks the HVNL is built around: fatigue, speeding, excessive mass or dimension, poorly restrained loads, and unsafe vehicles.5 For that last one, the widely-used control measures it sets out include three that describe a pre-start program exactly: inspections are carried out according to the manufacturer’s recommendations or more frequently if needed, vehicles are checked at the start of each journey, and drivers are trained to identify and report indications of maintenance issues.5
So the record has to carry all three. Which vehicle and trailer, by rego rather than by a nickname. Which driver, by name. The date and the time, captured rather than typed. A result against each item. And a photograph attached to the item that failed, not to the form, so the workshop can see the crack rather than read the word “crack”. A checklist item should open findings, a photograph, a priority, a due date, and a responsible person without the driver leaving that item.8
The Defect, and the Decision to Take It Off the Road.
This is the part that separates a real system from a digital version of a paper book. A defect noted with no decision against it is not a neutral record. It is evidence that the fault was known about and the vehicle went out anyway.
So build the out-of-service call into the form. A failed item on a safety-critical check should ask, then and there, whether the vehicle is fit to depart, record who made that call, and notify someone other than the driver. The driver should not be the last line of decision-making on a brake fault at 4am.
Your internal thresholds should sit above the regulator’s, not at them. Under the HVNL there are three categories of defect notice, aligned to risk. A major defect notice applies where continued use poses an imminent and serious safety risk; a minor defect notice where there is a safety risk that is not imminent and serious; and a self-clearing notice where there is no safety risk, or a number plate is obscured.6 A vehicle under a major notice can only be moved in the way and to the locations the notice states, or once the repairs are done. Where the risk is imminent and serious the vehicle is repaired immediately or it does not go on the road, and if it cannot be repaired it is carried or towed.6
One detail catches operators out regularly: a driver who is not the owner or operator must give the defect notice to them as soon as practicable, and no later than 14 days after it was issued.6 If your only copy of that notice lives in a cab, you have a 14 day gap in your own knowledge.
The Maintenance Record Behind the Check.
The pre-start is a filter, not a maintenance system. What it feeds is the record that shows an asset has been looked after over time, and that is where WHS law meets the transport law for anyone running plant on a workplace as well as on the road.
Regulation 213 of the model WHS Regulations requires the person with management or control of plant at a workplace to ensure maintenance, inspection and, if necessary, testing is carried out by a competent person, in line with the manufacturer’s recommendations, or a competent person’s recommendations where there are none, or annually where neither is reasonably practicable.7 For plant that must be registered, the record of tests, inspections, maintenance, commissioning, decommissioning, dismantling and alterations is kept for as long as the plant is used or until control is relinquished, kept available for inspection, and handed to whoever takes control of it next.7
The practical test of your system is whether a defect raised on a pre-start becomes an action with an owner and a due date, and then closes with a comment, a date, and a photograph of the repair attached.12 A defect list that only ever grows is a maintenance backlog in disguise, and it reads to an investigator as a list of things you knew about.
Two Minutes, in the Dark, on a Shared Device.
Everything above is design. This is adoption.
The person doing the pre-start is standing in a yard before dawn, in gloves, holding a torch, with a run to start. If the check takes longer than the walk around the vehicle, it will be completed from the cab with a thumb, and you will have a clean record of an inspection that did not happen. That is a worse outcome than paper, because it looks better.
Three things make the difference. Start from the vehicle rather than from a menu: a QR code on the cab that finds the asset, shows its details, and opens the template configured against it means no one is hunting through a list of 80 registrations in the dark.9 Let the whole thing work with no signal, since yards, sheds, and remote depots rarely have any, and hold the record on the device until the sync goes through.8 And support a shared device, because in a depot there is one tablet and 12 drivers: in ComplyFlow that means choosing your name, confirming your date of birth, and the app checking your competency records before the inspection opens, with your name then recorded as the person who conducted it and set as the default owner of anything that failed.10 The mobile apps carry that behaviour; it is not something to bolt on afterwards.
Why This Is Worth the Effort.
Safe Work Australia recorded 188 worker deaths from traumatic injury in Australia in 2024. Vehicle incidents were the largest single mechanism at 42%, or 79 deaths. At least one vehicle was directly involved in 66% of all worker deaths that year, 124 people, and of those, half involved at least one truck. Transport, postal and warehousing recorded the highest number of any industry at 54 deaths, 29% of the total, at a rate of 7.4 deaths per 100,000 workers.11
Not every one of those is a maintenance failure, and it would be dishonest to imply it. What they do establish is where the exposure sits. For a transport and logistics business, and for anyone in operations who loads, schedules, or receives a truck, the daily check is the highest-frequency control you own.
Count the Defects Your Fleet Raised Last Month.
Pull the last month of pre-starts and count the defects raised. If the number is close to zero across a working fleet, the checklist is not being answered, it is being dismissed. Then take every defect you did find and see whether each one has a decision recorded against it and a repair that closed. The gap between raised and closed is the number to take to your next toolbox talk.
The rest of your inspection program runs on the same machinery. How the app itself should behave is in How to Choose a Site Inspection App, and setting the interval for anything that is not a daily check is in How to Build an Inspection Schedule That Holds. If you want to see a pre-start that a driver can finish in the time it takes to walk around the truck, book a demo.
Sources
- Chain of Responsibility (CoR)
- Parties in the CoR
- Heavy Vehicle National Law and Regulations
- The Primary Duty
- Complying with your Primary Duty obligations
- Heavy vehicle defects
- Model Work Health and Safety Regulations
- Mobile Application Inspections
- Scanning a QR Code to Start a Plant Inspection
- Shared Device for Plant Inspection
- Key Work Health and Safety Statistics Australia 2025
- Closing Out Actions
Written by
Mitchell BourneManaging Director, ComplyFlow
Mitch has run ComplyFlow since 2009 and has spent that time inside the contractor, site, and safety problems of Australian operators. He writes about where compliance actually fails, and what the people responsible for it can do about it.
Writes about: Contractor compliance, WHS duty and proof, Running a compliance program
Questions
Questions People Ask About This.
Does the Heavy Vehicle National Law apply in every state?
No. The HVNL commenced on 10 February 2014 in the Australian Capital Territory, New South Wales, Queensland, South Australia, Tasmania, and Victoria, each of which adopted or duplicated it in its own law. It has not commenced in Western Australia or the Northern Territory, but it applies to vehicles from those jurisdictions when they cross into one where it does, and some parts, such as work diary requirements, can apply before the border.
Who is responsible for a defective heavy vehicle under Chain of Responsibility?
Every party in the chain, to the extent they can control it. The NHVR lists 10 functions that make a business a CoR party, including operator, scheduler, consignor, consignee, packer, loader, unloader, and loading manager, and each one carries the same primary duty to ensure the safety of its transport activities so far as is reasonably practicable. Driving is not one of the functions; drivers hold other duties under the law.
What should a driver's pre-start check record?
The vehicle and trailer identifiers, the driver, the date and time, a result against each item, a photograph attached to anything that failed, and what was decided about it. The decision is the part most systems skip: a defect noted with no action and no out-of-service call is a record that the fault was known about and the vehicle went out anyway.
Can a heavy vehicle be driven while a defect notice is in force?
It depends on the category. A vehicle under a major defect notice can only be moved in the way and to the locations stated in the notice, or once the repairs are done. For a minor defect notice an authorised officer can permit continued use, usually with conditions and a time limit. The notice itself sets out the time allowed and any conditions.
How long do vehicle inspection and maintenance records need to be kept?
It depends which duty you are meeting, so check the requirement that applies to your fleet rather than assuming one answer. Under the model WHS Regulations, for plant that must be registered, the record of tests, inspections, maintenance and alterations is kept for as long as the plant is used or until control is relinquished, and is handed to whoever takes control. Heavy vehicle record-keeping obligations under the HVNL sit separately and vary by the type of record.
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