After close to 60 years of being in and around the business of trucking, supply chain management and freight logistics, I am speechless that the Minister of Transport (DOT) could put pen to paper announcing the intention to implement Regulation 318A to prohibit goods vehicles with a gross vehicle mass (GVM) that exceed 9 000 kilograms from operating on public roads for a total of six hours a day.
The proposed restrictions will apply between Monday and Friday and will be split into two three hour periods from 06h00 to 09h00 and from 17h00 to 20h00 hours.
Such ingenuousness – or should I say naiveté – as to how road freight transport operates begs the question: “Who comes up with such impractical and senseless wish lists?” I believe the current Minister of Transport, Dipuo Peters, is sincere and committed to achieving a meaningful reduction in traffic related accidents and incidents. However, why does she listen to people who have little or no meaningful knowledge or experience of the fundamentals of traffic flows, congestion and differential speed limits.
Not so long ago, some transport consultants with apparently limited local knowledge or experience encouraged the DoT to introduce an 8-ton axle mass limit for vehicles plying “secondary” roads but retaining the 9-ton axle mass limit for vehicles travelling on national roads.
There were no suggestions as to how vehicles transporting loads across both typologies were to operate legally and/or efficiently when moving from one typology to another. Click here for the article I wrote in FleetWatch at the time on that. Also click here for the industry’s reaction to that proposal at the time.
Now we are being faced with Regulation 318A. If ever this is implemented, it will do little to reduce traffic congestion or accidents. It will, however, be seriously damaging to the economy in terms of the cost and efficiency of freight logistics as it applies to just about every value chain that makes up our local production and manufactured products, imports and exports. Let’s briefly consider just a few examples:
- Daily collection of raw milk from dairy farmers. Milk tankers take to the road from 04h00 hours in order to collect fresh milk that has been milked and stored in the farmer’s silo. This process takes most of the morning as the tanker travels from farm to farm until it is fully loaded. Tankers, depending how far they are from the dairy, return to base by early afternoon. Losing three hours from 0600 hours creates a massive challenge for the dairy to process and pack the milk that must move to distribution centres, warehouses and retail outlets not to mention the hospitality industry. You can add to this a reduced speed limit and all kinds of overtime to get the job done after the evening ban comes into effect at 17h00 hours.
- Similar situations would be compromised when we think of distributing and delivering animals for daily slaughtering and then distributing the slaughtered meat. Extend this thought to poultry where several million chickens must be slaughtered, processed and packaged and delivered far and wide. Imagine the chaotic situation on the roads to cope with this? Fresh fruit and vegetables present similar challenges for agricultural logistics
- It is well-known that exporting fruit out of the Durban port is fraught with inefficiencies and delays. Kevin Martin, CEO of Freightliner transport and recently retired chairman of the Durban Harbour Carriers Association, has warned that the port’s ability to cope with the number of containers going out and coming into the port will be reduced by 25%. This he sees as a major catastrophe for the port authorities and truck operators – not to mention the owners of the produce, and shippers. This, according to Martin, will result in the Transnet Port Authority having to acquire 25% more handling equipment and employing 25% more people to get the job done. Inevitably, exporters and shippers will be looking towards Mozambique and Namibia as viable alternatives to Durban and other South African ports.
- And what will be the impact on farmers, airlines, thousands and ‘home-based’ fuel dispensers by keeping petrol and diesel deliveries from pipeline to country wide fuel depots and airports. Bakeries, another value chain, will also be affected as they must receive the raw materials and deliver the daily production in the early hours of each day. Demand for bread and other pastry fades quickly if it is not available shortly after shops open for business
Take a look at the accompanying table – The Cost of Lost Time – which demonstrates how expensive it is for owners and the economy when road transport is unnecessarily delayed.
It is based on May 2015 market related benchmarks for a 7-axle Interlink covering 200 000 kilometres a year working 286 days a year. Assume the vehicle is delayed on average just two hours a day. The assumed consequence is the vehicle travels an average of 50 km a day less than was expected when figuring the transport rate. The lost revenue and unrecovered fixed costs is horrendous and absolutely unacceptable.
Should Regulation 318A be implemented – and add to that Regulation 330 A-D (consignor/consignee which is already implemented) – the consequence will be serious delays which will wreck transport companies, supply chain and logistics service providers. More vehicles will be required to cope with getting goods and perishables delivered whether local, export or imported.
Another proposed change from the Minister is to Reg 292 with the intention to amend general speed limits to 40 km/hr in urban areas, 80 km/h outside urban areas, 100 km/h on freeways that pass through residential areas and120 km/h on freeways.
Speed limits were introduced in Germany when the OPEC oil producers hiked the price of oil way back in the late 1970s. However, after about six months, the speed limits were repealed as traffic had progressively increased the average speed of traffic. In South Africa, around the same time, we had a speed limit of 60 km/h which soon after was raised to 80 km/h and then again to 120 km/h with the well-known speed limit of 80 km/h for large trucks.
In the Minister’s bid to reduce roads accidents, she is contemplating the fitting of speed-limiters for taxis and trucks. South Africa has no definitive studies on which to provide a meaningful response to this notion. We should, however, look at the current situation in the United States of America where the transport authorities are considering enforcing speed-limiters for trucks. The Owners and Owner and Owner Operator Drivers Association (OOIDA) has objected strongly to this intention.
Based on several definitive studies carried out by competent organisations in the USA, the OOIDA is in a position to demonstrate that the research confirms there will be more accidents when there is a speed differential between passenger cars and light vehicles compared to the maximum speed trucks are to maintain. The reason why? Motorists become frustrated by the slower speed of heavy vehicles and invariably end up crashing into the rear of trucks. Truck drivers confirm motorists become aggressive and arrogant.
In addition to all this, the truckers and fleet owners are still waiting for the DoT to sign off the maximum driving hours applicable to PrDP licensed drivers. While this is a welcome development when seen against the background of the above intended regulations, the cost of significant increases in delays that will be inevitable is bound to have a notable impact on the cost of road transport with consequences for food prices and export markets.
A major concern around all of this is the protracted decision making process that we have come to expect from the DoT. This is especially so when considering the Minister’s frank and sincere concept document released a few months ago announcing her decision to form a National Transport Forum (NTF) with the objective of simplifying, finalising and implementing aspects of the National Transport Master Plan (NTMP) and other long delayed regulations such as the AARTO Act.
In this document, the Minister acknowledges the DoT does not have the experience, expertise or capacity to achieve her objectives of making our roads safer for all users and improve the efficiency of our road freight industry. She makes a strong appeal for the private sector to join with the DoT to ensure the NTF will succeed. There is an open invitation for persons and organisations with experience and expertise – whether academic, technical, operational, or financial – to come forward even if on an ad hoc basis where their respective knowledge and experience can be helpful.
To the best of my knowledge, the planned inaugural meeting did not take place as planned and nothing else has to date transpired. The road transport industry in all of its diversity should not miss this opportunity to be active participants in the DOT’s endeavour to get it right – but it needs to happen from the DoT’s side.
South Africa needs to follow the objectives articulated in the National Transport Policy in so much that our transport strives to achieve ongoing efficiency improvements with ongoing cost reduction. With this in mind, we need to identify and define the causes of the problems and challenges we currently have across the transport of freight on our roads. We need to stop trying to cure the symptoms but rather focus on the cause.
The big question is: Why do we have so many accidents with passenger cars, buses and trucks? To answer this, we must identify:
- How many traffic law enforcement officers do we need? Why they are not selected and trained to a national standard of competence? Proven corruption should meet with dismissal.
- In terms of the NRTA, SABS is mandated to inspect and audit vehicle test stations at regular intervals to ensure the equipment is correctly calibrated and vehicle tester are trained and competent to a required standard. Is this being done?
- Implement proper on-road roadworthy inspections and follow up with visits to vehicle owners who are found to be operating unroadworthy vehicles on public roads. This should include inspection of maintenance records.
- Applicants for an operator’s card should be obliged to undergo a prescribed programme of training to gain a proper understanding of the responsibilities of the operator, the driver and vehicle fitness. I think the Road Transport Management System is perhaps a possible method to achieve and manage this. Without basic training, the failure rate of BBBEE endeavours could be unacceptable.
- Speed limits do not reduce accidents to any decent extent unless it is properly and predictably implemented. Take steps to stamp down on corruption of any kind.
- Audit the driving licence base at eNatis to identify expired and fake licenses.
- Achieve a better standard of driver training at all accredited and in-house training facilities.
- The private sector and DoT must step up to the plate and work together as well as with other relevant authorities. Let’s negotiate and not have slanging matches. The world over confirms that transporters and drivers need to be managed. Trucking is a highly entrepreneurial business and needs basic disciplines applied on a daily basis. Look to the history of RTMS and DoT should review how trucking is regulated in Australia, New Zealand, UK, EU and USA. Compare accident statistics, road deaths, overloading and roadworthiness in these countries. Working together is the only way we can achieve the desired and necessary standards we need to compete and take our place in the region and the continent. We are not the only country where more than 70% of freight is transported on roads.
It is time to step up to the plate and get it right if we are to have growth, jobs, economic prosperity and a better life for all.