Safety Management System

Taxi and booking service providers are required to identify, record and address safety risks associated with the provision of passenger service through the development of a Safety Management System.

Determining ways to eliminate or minimise risks as well as compiling a register of risks, will ensure a safer journey.

Taxi and booking service providers have a duty of care to ensure, so far as is reasonably practicable, the health and safety of drivers, passengers and others in connection with the provision of their passenger service. Action can be taken by the Point to Point Transport Commissioner against a business and/or its officers if they do not comply with their safety duty or fail to meet safety standards.

What is a Safety Management System?

A Safety Management System details how a taxi or booking service provider identifies, records and manages any risks associated with the provision of services, and how the required safety standards will be met. 

A Safety Management System must be tailored to the specific business. The level of detail will depend on the size of the business, the types of services provided and the risks identified.

A provider’s Safety Management System(s) can be audited by the Point to Point Transport Commissioner’s compliance team to determine whether the provider is meeting its legal obligations to provide the safest possible passenger services.

Who is responsible for the Safety Management System?

All service providers must develop a Safety Management System.

Officers, who are involved in making decisions affecting all or a substantial part of the services (e.g. booking services, taxi services or related security services), need to take part in developing and maintaining the Safety Management System. Other people, such as drivers and vehicle owners should also be consulted, and records of these conversations must be kept.

Elements of a Safety Management System

A Safety Management System is required to identify and record:

  • any reasonably foreseeable hazards that could give rise to risks to the health and safety of drivers, passengers and others,
  • the control measures being taken to eliminate or minimise those risks, and
  • what is being done to maintain those control measures.

The scenario below provides an example of how a service provider’s Safety Management System identifies, assesses and records the risk of driver fatigue to mitigate that risk.

1. Identify risks to safety

You must identify potential risks to safety and who might get harmed. For example, driver fatigue is a common risk to safety in the point to point transport industry. It can lead to accidents resulting in injury to the driver, passengers and/or other road users. Similarly, in your Safety Management System you must identify all other potential risks to safety. Once you have identified all risks, the next step is to assess every risk as explained in the next step.

2. Assess the risk

Once a risk has been identified you should take steps to understand the nature of the harm, how serious the harm could be, and the likelihood of it happening. You can assess a risk more effectively when you consult with those who are exposed to the risk.

For example for driver fatigue, you should assess this risk by consulting with your drivers and other relevant staff (if any). You should discuss with your driver/s on how fatigue affects their driving and document this conversation. You must keep a record of any decisions that you make on how you would control or minimise the risk in future.

3. Control the risk

After identifying and assessing a safety risk, you should look at how to eliminate or minimise the impact of the risk by implementing control measures. For example, for driver fatigue you minimise risk by ensuring drivers take breaks after a set number of hours. You must record this control measure in your risk assessment document.

You must also maintain control measures by regularly reviewing and updating them.

Record keeping requirements

Records must be kept that document how the required safety standards are being met when implementing the Safety Management System.

The Safety Management System needs to be documented and regularly reviewed in consultation with others who have a safety duty that relates to the service, such as drivers, affiliated providers and vehicle owners. Records must be kept of these consultations.

If a serious incident does occur, it must be reported to the Point to Point Transport Commissioner. The incidents which require notification are called Notifiable Occurrences. Click here to find out more.

Record keeping requirements for Sydney Metropolitan Taxi Service Providers

By law, all taxi service providers need to keep a record of the registration number of all taxis in their fleet in a form approved by the Commissioner. As of 1 July 2019, it has been mandatory for taxi service providers to upload and keep current the registration number (e.g. T1234) in the Driver Vehicle Dashboard (DVD) for all taxis used to provide services in the Sydney Metropolitan Transport District.

What elements of your Safety Management System will be considered in an audit?

Your Safety Management System forms the basis of an audit and the audit will take into account the specifics of your business. The following elements of your Safety Management System will be considered:

Safety policy, commitment and objective What is the objective of the Safety Management System and who is tasked with ensuring that the Safety Management System meets these objectives
Management accountabilities, responsibilities and communications Who is accountable for the service provider’s safety responsibilities?
Risk management How are risks identified, eliminated or minimised?
Procedures and documentation Is the Safety Management System documented and accessible for all employees, contractors and drivers?
Employee, contractor and driver monitoring How does the service provider ensure that each individual meets their legal obligations?
On-boarding, training and education How are new employees, contractors and drivers made aware of the safety procedures?
Incident management and monitoring If an incident does happen, are there appropriate methods of recording and reporting the incident?
Review and evaluation Is the Safety Management System reviewed and updated regularly?

Review the safety audit tool to make sure you, as a service provider, meet the standards that auditors check against.