In Australia, the regulating entity for heavy vehicles, the National Transport Commission (NTC), works with peak industry bodies and government to develop land-transport policy and is responsible for many safety and compliance issues, including the review of medical standards for assessing fitness-for-duty for commercial vehicle drivers (Table 1). NTC commercial vehicle driver standards apply to bus, taxi and small bus drivers, chauffeurs and those authorised to carry bulk dangerous goods. The 2012 national Work Health and Safety Regulations cover workplace hazardous substances and dangerous goods under a single framework which includes the NTC’s Australian Dangerous Goods Code Road and Rail [11]. Additionally, each Australian State and Territory has its own local vehicle and driver registration agency and OHS regulator.

In 2001, a landmark review of long-haul trucking recommended increased harmonisation between road transport and OHS legislation and greater interagency cooperation to address serious concerns about trucking safety [12]. Subsequent reforms to national road-transport laws introduced requirements that hold all those with control over a heavy-vehicle user’s ability to comply with relevant regulations both accountable and responsible if they fail to discharge that responsibility. In addition to drivers and employers, this ‘chain of responsibility’ includes organisers of trip schedules, consignors, importers, retailers and primary producers [13]. In 2012, a single national system framework, the Heavy Vehicle Regulatory Reform, was put in place to regulate all vehicles over 4.5 gross tonnes [14].

Under the Australian Work, Health and Safety Act 2011, vehicles used for the purpose of work are classified as a ‘workplace.’ To date, however, this national legislation has not been fully adopted by all states in Australia [15]. Employer obligations to ensure a safe place of work apply to potential risks within the work-vehicle environment and the roads on which employees are driving. All at-work drivers must comply with jurisdictional road safety legislation including requirements relating to speeding, mobile-phone use, seatbelt-use, alcohol and drugs. In addition, there are obligations under all Australian OHS Acts to ensure workers are fit to drive, both cognitively and physically, including requirements to report any ongoing illness likely to affect the ability to drive safely. If a driver is impaired, formal assessment of fitness to drive is undertaken according to two sets of medical standards: commercial vehicle driver standards, or private driver standards, which apply to all other motorists [16]. Other than generic vehicle requirements for roadworthiness and registration, and responsibilities for the transport of Dangerous Goods [11], there are no specific standards prescribed for light vehicles; the standard for light vehicles is the possession of a current driving licence, regardless of driving competence, experience or the work context.

Since the Second World War, various Transport Acts have regulated the heavy-truck and bus sectors, focusing on areas such as vehicle weights, drivers’ hours and licencing, and certification of professional competence. Lighter vehicles used for work purposes, including cars and vans, have remained relatively unregulated beyond the Highway Code and general rules of the road. The OHS agency, the Health and Safety Executive (HSE), was created by the 1974 Health and Safety at Work (HSW) Act. The HSE does not exercise its jurisdiction for crashes on public roads, nor does it include them in its data collection on work-related injuries. Generic concepts within the HSW Act are nonetheless relevant to WRRS, notably ‘duty of care,’ which charges an employer to ‘ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees’ (Part I, Section 2 (1)) [17]. This provision has been used to argue that employers’ responsibility to provide a safe work environment ought to extend to all workplaces, including motor vehicles.

Because HSE regulations are not directly enforced for at-work driving, basic legislation under the Department for Transport (DfT) has become the de facto source of law for work-related driving in the UK. The Road Transport Act (RTA) of 1988 covers licencing for all classes of drivers, manufacturing standards, seat-belt use, impaired and reckless driving, vehicle inspections, fitness to drive, and loading of goods vehicles. Other RTA provisions hold employers and other parties partially responsible for certain road infractions [18]. Since the UK joined the European Union (EU), regulations for heavy vehicles have increasingly been intertwined with EU initiatives covering areas such as working time, driver licencing and driver training via the Certificate of Professional Competence (CPC). To date, EU directives and regulations have not explicitly included the significant numbers of light vehicles being driven for work. However, the 1989 ‘Framework Directive’ for OHS emphasised the employer’s responsibility to ‘evaluate the risks to the safety and health of workers, inter alia in the choice of work equipment, the chemical substances or preparations used, and the fitting-out of work places’ (Article 6(3)a) [19]. As a directive, this EU legislation charged member states to develop conforming national legislation.

Several high-profile transportation disasters in the 1990’s drew the attention of UK policymakers and the public to WRRS. In 1996 and 1997, the Royal Society for the Prevention of Accidents (RoSPA) organised stakeholder meetings around the question of whether employer ‘duty of care’ under the HSW Act should extend to work-related driving. Arguments in favour of employers taking responsibility for managing WRRS for light as well as heavy vehicles were bolstered by the EU Framework Directive’s requirement that employers conduct comprehensive risk assessments. The RoSPA-sponsored meetings led to a consensus that businesses ought to institute policies and procedures to manage road risk and participants signed a declaration to that effect [20].

In response, a broad-based committee convened by the government recommended that employers manage at-work road risk within the framework that should already be in place for managing all other OHS risks [21]. In 2003, the HSE and DfT jointly issued a guidance document called Driving at Work [22]. Although this did not have the force of regulation, it was nonetheless symbolically important because it represented an official entrance into the WRRS policy area by HSE. Moreover, it has come to be accepted as setting core requirements to be followed by organisations, and it applies to all vehicles used for work purposes irrespective of type, size or ownership.

More recently, the 2007 Corporate Manslaughter and Homicide Act allowed criminal negligence lawsuits against businesses when management’s failure to exercise its ‘duty of care’ results in death. The law is intended to complement other legal remedies, including OHS regulations. Lawsuits brought under this law are handled as criminal cases, not labour action [23]. Today, a number of British government agencies under the DfT have responsibilities relevant to WRRS. Many have dual responsibility for managing the same issues for work-related driving and the general motoring public (Table 2).

A growing body of collaborative research from the UK has established risk factors associated with driving for work, the importance of identifying at-risk drivers, and the role of fleet management programs in reducing crash rates. Government-sponsored research [24–27] has allowed the government to be indirectly involved in building the knowledge base for WRRS without imposing new government mandates. Purpose-of-journey data from transportation statistics have identified crash-involved work vehicles by type, which may lead to more effective targeting of interventions [28]. Organisational-level research has focused on driver assessment and improvement to help develop a culture of safe driving and reductions in crash rates and costs via a comprehensive fleet safety program [29, 30]. Although a systems-based approach is widely advocated in the UK, researchers have also noted the challenges of assessing the effects of ‘packages’ of individual interventions [31].

In the U.S., workplace driving takes place in two distinct settings: the U.S. Department of Transportation (DOT) regulatory regime that covers large trucks and buses, and the largely unregulated operation of light vehicles driven for work. Regulations to promote safe operation of large trucks and buses have been part of U.S. federal policy since the 1930’s. Today, this regulatory responsibility is carried out by the Federal Motor Carrier Safety Administration (FMCSA) in the U.S. Department of Transportation. FMCSA’s primary mission is to ensure the safe operation of large trucks and buses, primarily by promulgating and enforcing safety regulations (http://www.fmcsa.dot.gov/rules-regulations/rules-regulations.htm). Although development and oversight of these regulations occurs at federal level, licencing under the Commercial Driver’s License (CDL) program and most enforcement activities are carried out by the states. FMCSA also supports research and non-regulatory safety initiatives related to new technology, management practices, and driver behaviour (Table 3).

In contrast, there are no corresponding regulations applicable to U.S. workers who drive light vehicles for work purposes. At-work driving falls under the Occupational Safety and Health Administration (OSHA) ‘general duty clause,’ which requires an employer to provide ‘employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees’ [32]. OSHA has issued regulations covering some aspects of mobile equipment operation in construction, logging, marine terminals and agriculture. OSHA has no regulations for operation of motor vehicles on public roadways that cover a wide range of vehicles, drivers and work situations (Table 3). The OSHA policy response to occupational risks of light-vehicle operation has included voluntary initiatives, guidance documents, ad hoc advisory committees and a recent enforcement initiative on distracted driving that uses the ‘general duty clause’ as the basis for action [33]. Operation of most vehicles in the U.S. workplace is in effect governed by traffic laws, augmented by employer policies. In the U.S., laws related to mobile-phone use, seat belts, speed limits, age of licensure, and licence renewal are the responsibility of individual states. Inconsistency in laws and regulations from state to state can complicate road safety management for organisations that operate in multiple states.

Fatality risk is consistently highest in the truck transportation sector. For this reason, the vast majority of U.S. literature on WRRS addresses known and hypothesised risk factors for truck drivers, including driver fatigue and hours of service [34–36], medical conditions [37–40] and use of mobile devices [41, 42]. Published research on the safety of light vehicles driven for work is limited. Reports published in the last decade have addressed MVCs among law enforcement officers [43]; home healthcare workers [44]; workers operating agricultural equipment on public roadways [45, 46]; and workers in the oil and gas extraction industries [47]. One of the few U.S. studies to assess the effectiveness of behavioural interventions was a series of related experiments conducted over many years among pizza delivery drivers [48].