Interesting to see the impacts of the increased uptake of Electronic Work Diaries (EWDs) including Supervisory Intervention Orders being issued by the courts that include drivers using  an EWD. One of the impacts of the increased use of EWDs is in who is responsible for providing the Electronic Work Diary.  

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With a traditional paper based work diary the driver would obtain it from a service centre and the security number of the work diary would be associated with the driver’s licence. Now a driver can download a phone app themselves or use an EWD provided by someone else. In this case it is the Unique Driver Identifier (UDI) in the EWD that associates the driver and the electronic records.

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This means that the procurement of the Work Diary can be undertaken by multiple parties and this is where the gaps can start to develop inside management systems that have not been updated to meet the current challenges.

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Early adopters 

A good percentage of drivers will fall into the early adopters category and have already moved to electronic work diaries as a way of reducing paperwork in the cab of the vehicle. However, they may not necessarily understand that they still have some of the same obligations as when using a paper based diary. 

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An example would be an owner driver working for a head contractor under the head contractors National Heavy Vehicle Accreditation Scheme Basic Fatigue Management Accreditation (NHVAS BFM). Because the driver is working under the accreditation they must complete a work diary every day that they work and they must provide copies of these records to the NHVAS Accredited company within 21 days of the work being undertaken.

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We have seen many instances of the above where the driver has obtained an EWD and not informing the accredited company. Clearly the head contractor who is now not receiving any work diary records for the driver is in breach of their obligations.

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Record Keepers and Electronic Work Diaries

Under the Heavy Vehicle National Law, if the driver is working under an operator’s BFM or AFM accreditation, the operator is the record keeper.

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If the driver is working under standard hours or exemption hours, then, for an employed driver, the employer is the record keeper and for a self-employed driver, the driver is his/her own record keeper.

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The EWD framework requires that the records from an EWD are transferred at least once per day to the record keeper, so that the record keeper can fulfil their legal obligations. Most EWD providers assume that the record keeper has access to the administration side of the EWD system and therefore comply with this requirement. 

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In scenarios where the drivers are providing the Electronic Work Diaries and the head contractor is the record keeper this can become problematic especially when there are multiple EWD systems being used.

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Unavin to the rescue

Unavin is designed from the ground up to allow transport operators to have multiple telematics and other digital systems seamlessly integrated into one place, allowing the simplification and automation of complex administration and compliance tasks.

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