Alternative Compliance Hours (HVNL Reforms)
Flexible Fatigue Management with Operator-Specific Work and Rest Schedules
The HVNL reforms introduces Alternative Compliance Hours — a flexible approach to fatigue management that replaces BFM and AFM. The NHVR is expected to offer 8 pre-defined rule sets covering around 90% of current industry AFM usage, allowing operators to simply select a rule set that fits their operations. Hubfleet will implement all 8 rule sets, ensuring they are configured and ready to go for operators from day one. For operators with unique requirements, bespoke rule set applications will also be available.
Pre-Defined Rule Sets | Bespoke Applications | Schedule Enforcement | NHVR-Ready

Why Operators Choose Hubfleet for Alternative Compliance
What is Alternative Compliance?
- Standard Hours: Fixed work/rest limits for all operators
- BFM: Basic flexibility with prescribed schedules
- AFM: Advanced flexibility with approved variations
- Baseline: Standard work/rest limits (similar to current Standard Hours)
- Alternative Compliance: Choose from 8 pre-defined NHVR rule sets (including one similar to current BFM), or apply for a bespoke rule set — all within outer safety limits
- Operators still need NHVR approval for flexible schedules
- Risk-based approach to fatigue management
- Work diary requirements and GPS cross-checking
- Breach monitoring and corrective actions
- Evidence of systematic fatigue management
- 8 pre-defined rule sets available covering 90% of current industry AFM usage
- Operators select a pre-defined rule set or apply for a bespoke rule set
- Bespoke applications assessed using RCSM (Risk Classification System Matrix)
- Split rest only for emergency use
- Absolute outer limits (15.5hr work, 6hr min rest block) that no rule set can exceed
- Evidence-based demonstration of safety
Baseline vs Alternative Compliance
- Operators with simple, predictable schedules
- Operations within standard work/rest limits
- No need for schedule flexibility
- Maximum 12 hours work in 24-hour period
- Minimum 7 hours continuous rest
- Standard work week limits
- Basic SMS covering fatigue management
- GPS cross-checking of work diaries
- Breach monitoring and reporting
- Simple compliance requirements
- Minimal administrative burden
- Suitable for most operations
- Easy to implement and maintain
- Operators needing schedule flexibility
- Specialised industries (mining, agriculture, construction)
- Operations with variable workloads
- Long-distance or remote work
- Pre-defined rule sets: Choose from 8 NHVR rule sets covering 90% of industry needs — simplified application and faster approval
- Bespoke rule sets: Apply for custom schedules if pre-defined options don't fit your operations
- Maximum 15.5 hours work in 24-hour period
- Minimum 7 hours continuous rest (5hr minimum per block if split)
- These are hard ceilings — no rule set can exceed them
- Each rule set defines its own specific limits within these maximums
- Everything from Baseline, plus:
- NHVR-approved Alternative Compliance application (pre-defined or bespoke)
- Enhanced monitoring and controls
- Split rest tracking (emergency use only)
- Fit for duty checks for shift workers
- Pre-defined rule sets simplify transition from AFM
- Bespoke option for unique operational needs
- Better alignment with business needs
- Competitive advantage in specialised industries
- Driver satisfaction with realistic schedules
Two-Up Driver Provisions
HVNL includes specific provisions for two-up driving — where two drivers share driving duties on the same vehicle during the same trip. Two-up arrangements allow extended work periods because the non-driving driver can rest while the other drives.
- Both drivers must hold valid fatigue accreditation
- Rest must be taken in an approved rest facility within or attached to the vehicle
- The non-driving period counts as rest only if the driver has access to a suitable sleeping berth
- Each driver's hours are tracked independently
- Two-up drivers are not eligible for split rest provisions
- Independent hour tracking — each driver's work and rest is monitored separately against the 14hr/5hr limits
- Real-time alerts — drivers and managers are notified as limits approach
- Audit evidence — complete trail showing which driver was driving at any point, with GPS verification
Choosing Your Rule Set:Pre-Defined or Bespoke
- Review the available NHVR rule sets
- Select the rule set that best matches your operations
- Apply to NHVR referencing your chosen rule set
- Activate your approved rule set in Hubfleet — all 8 pre-defined rule sets will be pre-built in and ready to use
- Simplified application process
- Faster NHVR approval (rule sets are pre-assessed)
- Covers the most common industry work/rest patterns
- Lower administrative burden than bespoke applications
- Easier transition for operators currently on AFM
- Operators whose current AFM schedules align with a pre-defined rule set
- Operators transitioning from BFM (one pre-defined rule set is expected to closely match current BFM)
- Operations with common industry work patterns (long-haul, line-haul, metro delivery, etc.)
- Design operator-specific schedules based on your operational needs
- Conduct a comprehensive risk assessment
- Score proposed schedules against the RCSM
- Submit a bespoke application to NHVR with supporting evidence
- Implement approved schedules and monitor effectiveness
- Your operations don't fit any of the 8 pre-defined rule sets
- You have unique industry requirements (specialised mining, remote operations, etc.)
- You need specific schedule configurations not covered by standard options
- Your current AFM approval has highly customised parameters
- Operator-specific schedule design within outer limits
- Detailed risk assessment for each schedule
- RCSM scoring with safety case if thresholds exceeded
- Documented controls and monitoring plan
- Consultation evidence with drivers and Health and Safety Representatives (HSRs)
- Maximum 15.5 hours work in a 24-hour period
- Minimum 8 hours continuous rest (minimum 6-hour block if split rest is used by a solo driver in an emergency)
- Split rest for solo drivers only, emergency use only
- 14-hour work day with 10-hour rest break
- 5 days on, 3 days off
- Controls: driver fatigue self-assessment, trip planning
- 12-hour shifts with 12-hour rest
- 7 days on, 7 days off (FIFO)
- Enhanced rest facilities
- Controls: pre-shift fitness checks, shift handover protocols
- Variable hours based on site mobilisation schedules
- Extended rest periods between deployments
- Unique risk profile requiring tailored controls
- Controls: additional breaks, rotation schedules, enhanced monitoring
Managing Work Beyond Rule Set Limits (Within Outer Limits)
- Outer limits are the absolute maximums set by law — 15.5 hours work and minimum 6 hours continuous rest block (8 hours total). These cannot be exceeded under any circumstances.
- Rule set limits are the specific work/rest parameters defined by each pre-defined or bespoke rule set. These are typically stricter than the outer limits.
- Unexpected delays on long-haul routes
- Emergency response situations
- Remote site mobilisation taking longer than planned
- Seasonal peak demand periods
- Alerts the driver and supervisor
- Triggers an incident record if limits are reached
- Documents the circumstances and any contributing factors
- Captures corrective actions to prevent recurrence
Rule Set: Pre-defined rule set allowing 14-hour maximum work days
Scenario: Driver encounters unexpected delays and approaches the 14-hour rule set limit
- System alerts driver and supervisor as the 14-hour limit approaches
- If rule set limit is reached, an incident is automatically created
- Incident captures: circumstances, delay reasons, GPS location, and timestamps
- Manager reviews incident and documents corrective actions
- Pattern analysis identifies recurring causes (e.g., specific routes, loading delays)
- Corrective actions implemented to prevent recurrence
- Complete audit trail for NHVR
Understanding the RCSM (Risk Classification System Matrix)
- More than two high risks
- Two high risks and any medium risks
- One high risk and more than two medium risks
- More than three medium risks
- Any element exceeding the high-risk description in the RCSM
- Enforces your NHVR-approved schedule limits in real time via EWD
- Monitors compliance against your approved work/rest parameters
- Tracks breaches and near-misses with automated alerting
- Generates the ongoing SMS evidence that NHVR expects to see at audit — proving your approved schedules are being followed and your controls are working
- Feeds fatigue data into your risk register for continuous improvement reporting
- Dimension 1 — Work Related Rest Breaks: Breaks from driving within a work opportunity to reduce time-on-task impairment
- Dimension 2 — Recovery Breaks: Sleep opportunities between work opportunities to allow sufficient recovery
- Dimension 3 — Reset Breaks: Breaks in sequences of work to prevent cumulative fatigue build-up
Split Rest Controls
- Medical emergency (driver illness)
- Vehicle breakdown requiring immediate rest
- Extreme weather conditions
- Other unforeseeable safety circumstances
- Routine schedule planning
- Operational convenience
- Meeting delivery deadlines
- Making up for delays
- At least one block must be 6 hours continuous
- Total rest must be at least 7 hours in 24 hours
- Both blocks must be genuine rest periods
- Reason for split rest (must be emergency/unforeseeable)
- Time and location of each rest block
- Driver explanation and circumstances
- Management review and approval
- Track frequency of split rest use per driver
- Flag excessive use for management review
- Investigate patterns of split rest
- Corrective actions if misused
- Split rest for non-emergency reasons is a breach
- May affect Alternative Compliance approval
- NHVR audit finding
- Potential accreditation suspension
- Request Extended Fatigue Hours button is only available based on the driver's rule set and fatigue history
- Trip planning cannot pre-schedule extended fatigue hours or split rests
- Requests require compliance manager approval before the driver can proceed
- Pattern detection for frequent extended fatigue hours use
- Driver taps Request Extended Fatigue Hours in the app
- Driver selects the type of request: extended work hours or reduced rest (split rest)
- Compliance managers are notified in real time and can review the request
- Compliance manager approves or denies the request within the incident
- Once approved, the driver may use the extended fatigue hours
- If denied, the driver must cease work and take the required rest
- Management dashboard showing all split rest uses
- Flagging when driver exceeds threshold (e.g., 3 per month)
- Quarterly review of split rest patterns
- Corrective actions for inappropriate use
- Evidence bundle for NHVR audits
Hubfleet's Incident-Based Approach to Rule Set Breaches and Split Rest Management
- If a driver reaches or breaches their rule set limit, Hubfleet automatically creates an incident report
- For extended fatigue hours, the driver taps Request Extended Fatigue Hours, selects extended work or reduced rest (split rest), and completes the incident report form
- Key fields are auto-filled (driver details, current shift data, location, timestamp)
- Driver enters the circumstances and contributing factors
- Compliance manager receives a real-time notification with the incident details
- Incident is visible in the compliance manager's dashboard
- For extended fatigue hours requests, the compliance manager reviews and approves or denies the request before the driver can proceed
- Compliance manager investigates and documents root cause (e.g., unexpected delays, loading issues, weather)
- Risk rating assigned based on severity
- Corrective actions documented to prevent recurrence
- Corrective actions tracked through to closure
- Pattern analysis identifies systemic issues
- Feeds into quarterly reviews and continuous improvement
- Rule set breaches mean a driver has exceeded their approved rule set limits, requiring investigation into contributing factors
- Split rests indicate an emergency/unforeseeable circumstance affecting normal rest
- Both require immediate documentation and management review
- Both need root cause analysis and corrective actions
- Both feed into continuous improvement and NHVR audit evidence
- Every rule set breach and split rest is identified as a fatigue risk event
- Systematic capture ensures no exceptional events are missed
- Automatic incident creation prevents reliance on manual reporting
- Standardised risk assessment for each event
- Consistent risk matrix application
- Risk ratings feed into unified risk register
- Root cause analysis identifies control failures
- Control effectiveness tracked per incident
- Failed controls trigger corrective actions
- Controls library updated based on learnings
- Complete audit trail for all rule set breaches and split rests
- Usage patterns tracked and analysed
- Quarterly effectiveness reviews
- Management review of high-risk events
- Trend analysis for continuous improvement
- Every rule set breach and split rest documented as incident
- Timestamps, GPS location, and circumstances recorded
- Root cause and corrective actions attached
- Post-event outcomes tracked
- Evidence bundle export for NHVR audits
- Structured workflow ensures consistent process
- No undocumented breaches or exceptions
- Root cause analysis when patterns emerge
- Corrective actions for recurring issues
- Continuous improvement demonstrated
- Incidents automatically link to CAR if issues identified
- Corrective actions tracked through to closure
- Effectiveness verification required
- Prevents recurrence of problematic patterns
- Shows systematic approach to improvement
- Present: Documented process for rule set breaches and split rests
- Suitable: Risk-based approach appropriate for operations
- Operating: Real-time incident records prove active use
- Effective: Trend analysis shows risk management working
NHVR Approval and Compliance
- Do you need flexibility beyond Baseline limits?
- Are your operations suitable for Alternative Compliance?
- Can you implement required controls?
- Do you have SMS capability?
- Review the 8 pre-defined NHVR rule sets — if one fits, select it
- If no pre-defined rule set suits your operations, develop a bespoke application
- For bespoke: design schedules, conduct risk assessment, score against RCSM
- Document controls and demonstrate SMS readiness
- Complete Alternative Compliance application
- Provide supporting evidence
- Include risk assessments and controls
- Show consultation with drivers
- Configure approved schedules in Hubfleet
- Train drivers and schedulers
- Monitor compliance and effectiveness
- Maintain SMS evidence
- Review schedule effectiveness
- Update controls based on learnings
- Prepare for NHVR audits
- Operator-specific schedules documented
- Risk assessment for each schedule type
- Controls matched to identified risks
- Consultation with drivers and Health and Safety Representatives (HSRs)
- NHVR-approved rule set or bespoke application on file
- Controls matched to identified risk levels
- Safety case documentation retained (if applicable for bespoke applications)
- Emergency use only (not routine scheduling)
- Minimum rest block validation
- Usage tracking and pattern monitoring
- Management review of all split rest uses
- KPI tracking for Alternative Compliance
- Incident analysis related to fatigue
- Schedule effectiveness reviews
- Continuous improvement evidence

How Hubfleet Supports Alternative Compliance
- Create work schedules and check they comply with your approved rule set
- Validate schedules against rule set limits before assigning to drivers
- Ensure planned schedules stay within approved parameters
- Monitors driver hours against NHVR-approved limits in real time
- Alerts drivers and managers as limits approach
- System blocks work beyond approved limits
- GPS cross-checking of work diary entries
- Early warning alerts as rule set limits approach
- Automatic incident creation on breach
- Absolute outer limits always enforced
- Breach severity classification
- Breaches generate NCRs for formal investigation
- Root cause analysis and contributing factors documented
- Corrective actions assigned and tracked to closure
- Manager review and sign-off
- Pattern and trend analysis over time
- Button available based on rule set and driver history
- Driver selects extended work or reduced rest (split rest)
- Incident report form completed by driver
- Compliance manager approves or denies in real time
- Cannot pre-schedule extended hours or split rests
- Availability controlled by rule set and fatigue history
- Pattern detection and flagging
- Compliance manager review for excessive use
Common Questions
- All 5 SMS outcome areas explained
- Implementation timeline & milestones
- Fleet preparation checklist
- Gap assessment framework
- Change summary from current HVNL
- Gap analysis template (5 outcome areas)
- Pre-audit readiness checklist
- SMS implementation tracker
- PSOE evidence mapping
- Implementation timeline template
- Common auditor questions by outcome area
- Direct answers showing where evidence sits in Hubfleet
- PSOE framework explained
- Audit-day preparation checklist
- Real auditor scenarios
Navigate HVNL reforms fatigue flexibility with Confidence
Related Resources
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