A safety system needs to work in the yard, not just sit in a folder
Story · October 5, 2026
Belinda Hughes' interview raises a practical question for operators: can the business show how its safety arrangements work?
By Chris Smith
A transport business may have a folder labelled safety management system. The more important operating question is whether the people loading, maintaining, scheduling and driving its vehicles understand and use the controls inside it.
Belinda Hughes, principal lawyer at Hughes Law and a former NHVR Director of Prosecutions, raised concerns about safety-management expectations in her WWTG interview.
Her distinction was between a general safety obligation and the formal SMS requirements associated with accreditation. Operators need to understand which requirements apply to their business rather than treat every reference to an SMS as the same instruction.
That starts an everyday business question: what happens when a safety problem is found?
Follow one issue through the operation
Take a defect report as an example of an operating process, rather than a report about a particular fleet. Who receives it? Who decides the vehicle's status? How is a repair recorded? How does dispatch know when the vehicle is available again?
Similar questions can be asked about loading concerns, route restrictions and driver feedback.
The value lies in being able to trace the issue from identification to a decision and a completed action. A policy that cannot be connected to what staff actually do leaves an important part of that story missing.
Make responsibilities clear
Hughes' interview emphasised the consequences when operators and regulators have different understandings of what is required.
A business can reduce internal confusion by making responsibilities and escalation clear. Drivers need to know whom to contact. Dispatch needs to know who can change a plan. Managers need to know how unresolved issues are brought to their attention.
That is an operating approach, not a guarantee that a particular set of documents meets an accreditation standard.
Understand the applicable requirement
An operator seeking heavy vehicle accreditation needs an SMS meeting the applicable standard. Existing participants should check their transition arrangements. Outside accreditation, the general safety duties still require the business to manage the public risks of its transport activities.
NHVR’s current SMS guidance distinguishes general safety duties from the SMS Standard required for heavy vehicle accreditation. In its 23 September response to WWTG, the regulator said its focus was the underlying risk and how it was managed.
The practical point common to the discussion is that the system needs to be capable of explanation. The business should be able to show how a concern changes the work, who is responsible and how the result is checked.
A folder is a starting point. A working process is what makes it useful to the fleet.