"A substantial number of work-related trips are conducted using vehicles not owned by the employer,” says Matt Butterworth, Senior Work Health and Safety Practitioner at CCIWA. 

“For these grey fleets, safety risk management can remain inadequately addressed, simply due to the inherent nature of vehicles being used, ie. that they are not in the direct control of the organisation or workplace.” 

Butterworth defines a 'grey fleet driver' as any employee, including unpaid volunteers, contractors or those invoicing the company for their time, who operates a personal vehicle for work purposes. It’s irrelevant if they claim mileage. 

A grey fleet includes: 

• Personal vehicles 
• All forms of private leases 
• Client vehicles 

Have a policy in place 

According to a 2021 report from Safe Work Australia, 41% of Australia’s workplace fatalities involved a vehicle. 

Butterworth says it is important every company has an effective grey fleet management policy in place. 

“From a reputational management perspective, having a policy demonstrates that commitment to safety which enhances your organisation's reputation,” Butterworth told a 100-strong audience at CCIWA’s WHS Live event at Beaumonde on the Point in September 2023. 

“Also from an environmental impact perspective, promoting effective and efficient driving practices can reduce fuel consumption and also carbon emissions. 

“So, that risk mitigation is very, very important.” 

Providing a safe working environment 

Workers using their own private vehicles for business do not absolve an organisation from duty-of-care responsibilities. This includes: 

• Ensuring grey fleet drivers drive safely and within legislative requirements. 
• Checking a grey fleet driver has a valid driver’s licence that is appropriate for the vehicle being driven. 
• Ensuring the grey fleet vehicle is safe and adequately maintained (ie. roadworthy) with regular servicing. 
• Checking a grey fleet driver has the correct car insurance for business travel. 

Additional duty of care responsibilities may include: 

• Providing appropriate information to grey fleet drivers about their safe driving obligations. 
• Having clear and concise company policies and procedures to ensure grey fleet drivers know what is expected of them. 
• Undertake grey fleet driving risk assessments, which include simple checks and preventative measures to ensure drivers are safe and compliant. 
• Provide education and training to grey fleet drivers so they understand the risks and are capable of mitigating them to reduce accidents and offences. 
• Undertake regular team meetings, which give workers the opportunity to peer assess the grey fleet vehicles through visual checks. This ensures grey fleet vehicles are maintained to a high safety standard and workers know what to look for when ensuring the safety of a vehicle. 
• A pre-start check can be undertaken at time intervals proportionate to level of use and include:
  1. Good tyre condition and correct tyre pressure (based on user manual)
  2. All lights (headlights, brake lights, reversing lights and indicators) are working
  3. Windscreen wipers and washers working
  4. Appropriate fluid levels (oil, coolant, etc.)
  5. Windscreen and windows are free of cracks, damage and dirt. 

Evaluating vehicle safety 

Butterworth suggests companies use ANCAP (Australian New Car Assessment Program) to evaluate a vehicle’s safety. ANCAP provides an independent assessment, using a score of 1-5 stars, based on criteria such as the likelihood of serious injury of drivers, front seat passengers and pedestrians, and the vehicle’s capability to avoid a collision. 

The Transport Accident Commission’s (TAC) howsafeisyourcar.com.au website provides information to examine the ANCAP safety rating of a used car. By searching a car’s make, model and age you can access: 

• Used car safety report;
• Base model safety features;
• Driver protection rating (the ANCAP star rating); and 
• Protection for other road users rating. 

This information can help show whether a vehicle is suitable for use within the grey fleet (based on your organisation’s minimum safety requirements). 

Develop an action plan 

Butterworth suggests businesses follow a clear action plan. An example might be: 

1. Develop a policy for the minimum ANCAP safety rating of vehicles in your grey fleet.
2. Collect the age of grey fleet vehicles and break down by vehicle type.
3. Collect ANCAP safety ratings and date stamp of vehicles in the grey fleet.
4. Compare the evaluation criteria for the ANCAP rating for the year of manufacture to the minimum safety requirements for vehicles in your grey fleet.
5. Educate your workers on the importance of ANCAP safety ratings and consider strategies to help modernise the grey fleet.
6. Develop a grey fleet report for all employees to view, making everyone aware of the safety level of the grey fleet and increase understanding of the need to modernise over time. 

Our qualified Workplace Health and Safety experts provide cost-effective solutions to manage your WHS needs, reduce the risk to your workers and help you meet WA’s WHS laws. Email [email protected] or call (08) 9365 7746.