Brett Lemin, Executive Director of the Waste Contractors and Recyclers Association of NSW, explains why the National Heavy Vehicle Regulator Code of Practice matters.
Every day, thousands of waste and recycling trucks roll through our suburbs, regional towns, and city streets. They collect bins, transport loads, and feed materials into recycling and disposal facilities.
This work is essential to public health, urban amenity, and our circular economy ambitions. But it is also one of the most high-risk logistics sectors: heavy vehicles manoeuvring in tight environments, unpredictable loads, frequent interactions with the public, and now the added challenge of emerging hazards such as lithium-ion batteries.
That’s why the registration in June 2024 of the Waste and Recycling Industry Code of Practice under the Heavy Vehicle National Law (HVNL) is so significant.
Developed in consultation with industry and formally registered by the National Heavy Vehicle Regulator (NHVR), this Code is not just another compliance document. It is a practical roadmap that turns the broad obligations of Chain of Responsibility (CoR) into clear, sector-specific guidance.
For the first time, the waste and recycling industry has a national reference point that defines what good practice looks like in our unique operating environment.
The HVNL sets out duties for all heavy vehicle operators, but waste and recycling is not like general freight. We operate in confined streets, outside households, inside busy depots, and through community spaces. Our loads are rarely uniform; they are unpredictable, variable, and often volatile. Generic transport codes can’t capture this complexity.
The new Code changes that. It:
- Clarifies the primary duty by setting out what each party in the chain, such as councils, waste producers, transport operators, contractors, processors must do to meet their CoR obligations.
- Identifies both known and emerging hazards, from well-understood risks such as vehicle-pedestrian interaction to new threats such as battery fires.
- Provides practical control measures across every stage of operations, including bin restraint, site traffic management, and emergency response.
- Establishes a consistent national baseline so operators large and small can align with best practice.
- Strengthens defensibility by giving businesses a recognised benchmark if regulators or courts scrutinise their systems.
Few industries operate so close to the public as waste. Trucks reverse in cul-de-sacs, cross footpaths, and enter crowded depots. The Code places strong emphasis on speed management, separation of people and vehicles, defined exclusion zones, and route planning to reduce these high-risk interactions.
Unlike palletised freight, waste loads are irregular. They shift with liquid content, compaction, and uneven distribution. The Code includes an appendix with detailed guidance on securing bins and stabilising loads, a critical but often overlooked safety factor.
The waste stream is changing. Lithium-ion batteries discarded in household bins or mixed loads can ignite with catastrophic consequences. The Code explicitly calls out this risk and sets out safe handling, detection, and fire-response practices. Few issues demonstrate better why a modern, living code is necessary.
The Code makes it clear: responsibility doesn’t stop at the truck cabin. Councils procuring services, facility operators receiving loads, and contractors managing subcontractors all carry obligations.
By mapping responsibilities across the chain, the Code reduces the old “someone else’s problem” mindset.
From collection and sorting to transport and unloading, the Code provides structured controls. These include safe route planning, driver fatigue management, unloading procedures, spill management, and interface requirements at third-party facilities. It embeds safety into every phase of the operation, not just the driving task.
Importantly, the Code looks beyond compliance checklists. It requires incident reporting, investigation, auditing, and performance monitoring. Safety is not static; it evolves, and so must our systems.
The importance of this Code goes beyond its technical content. It arrives at a moment when the industry faces three converging pressures:
- Public interface and reputational risk: Waste vehicles operate where people live, work, and walk. Every incident is visible to the community. Safety failures damage trust in the industry.
- Growing complexity of waste streams: New materials, electronics, and batteries mean hazards that were rare ten years ago are now routine.
- Regulatory scrutiny and liability: Courts and regulators are enforcing CoR more actively. Demonstrating alignment with a registered code provides a defensible position and reduces liability exposure.
In short, the Code is timely, necessary, and a platform for raising industry standards.
But a code alone doesn’t change behaviour. Its real impact depends on whether operators, councils, contractors, and facility managers understand it, apply it, and embed it in daily operations. That requires awareness, skills, and a cultural shift.
This is why Waste Contractors and Recyclers Association of NSW and ACT (WCRA) and Waste Recycling Industry Association of Queensland (WRIQ) are working on a joint initiative, with the support and funding of the NHVR, to develop and deliver a national training program based on the new Code of Practice. The course will translate the Code’s requirements into practical learning: real case studies, tools, and frameworks that safety managers, supervisors, and frontline operators can immediately implement.
It will ensure the industry not only understands its duties but also has the competence and confidence to meet them.
The Waste and Recycling Industry Code of Practice is more than a regulatory milestone; it is an opportunity. It gives us a nationally recognised standard, shaped with industry input, that directly addresses the unique risks of our sector.
Now it is up to all of us – contractors, councils, processors, and suppliers – to make it real.
Related stories:
National regulator calls for more education to help prevent waste truck fires
WorkSafe inspections put spotlight on waste transport harm




