What Queensland's Safety Management Framework means for childcare services operating or using transport

Queensland's Department of Transport and Main Roads has introduced a strengthened Safety Management Framework (SMF) for road-based passenger transport operators, a development that may have implications for early childhood education and care (ECEC) providers that operate transport services or engage third-party transport operators.

The framework establishes minimum safety, risk management and compliance requirements for organisations involved in providing passenger transport services.

While long day care, kindergarten, outside school hours care (OSHC) and family day care (FDC) services are not specifically regulated under the SMF, transport arrangements are becoming increasingly common across the sector. Centre-owned buses, school pick-up services and organised transport programs mean some providers may need to consider whether the framework applies to their operations.

The full framework is available on the Queensland Government website.

When the framework may apply

The SMF is most relevant to ECEC providers in two scenarios.

Services operating their own transport

Providers that operate centre-owned vehicles for activities such as:

• daily pick-up and drop-off services
• regular community transport
• excursions
• OSHC shuttle services

may need to determine whether they are considered passenger transport operators under Queensland legislation.

Where the framework applies, operators may be required to implement documented safety management systems that address:

• risk and hazard identification and management
• incident reporting and investigation
• driver competency, training and monitoring
• vehicle maintenance, inspections and safety checks
• continuous safety improvement processes.

These requirements sit alongside existing obligations under the National Quality Framework (NQF), including transportation risk assessments, supervision arrangements and procedures for the safe embarkation and disembarkation of children.

Services engaging third-party transport providers

Many services rely on external transport providers for excursions, school transport programs or specialised transport services.

In these circumstances, the transport operator may have obligations under the SMF. However, ECEC providers still retain responsibilities under the NQF to ensure children's health, safety and wellbeing during transportation.

Approved Providers should consider whether existing procurement, contractor management and risk assessment processes provide sufficient assurance that transport operators are meeting relevant safety obligations.

Why transport governance matters

Transport remains one of the higher-risk operational activities undertaken by ECEC services.

In recent years, regulators have increased their focus on transportation arrangements, particularly in relation to risk assessments, supervision, vehicle safety and child accountability procedures.

Queensland's SMF adds another layer to this evolving regulatory landscape by reinforcing the importance of:

• robust transport policies and procedures
• documented driver training and competency checks
• effective vehicle maintenance systems
• clear contractor oversight processes
• strong governance and risk management practices.

For Approved Providers, transport safety extends beyond operational considerations and forms part of broader governance responsibilities.

Actions services may wish to consider

Queensland providers that operate transport services, or regularly engage transport operators, may wish to:

• review existing transport arrangements
• determine whether any activities fall within the scope of the SMF
• assess transport policies and procedures against contemporary safety management practices
• review contractor due diligence processes
• ensure transportation risk assessments remain current and fit for purpose
• update governance and compliance documentation where required.

Providers operating centre-owned vehicles may also benefit from undertaking a transport safety review to ensure alignment with both NQF requirements and any applicable transport legislation.

Increasing overlap between transport and ECEC regulation

As more services introduce centre-operated buses and transportation programs, regulatory frameworks outside the NQF are becoming increasingly relevant to ECEC operations.

Road safety legislation, passenger transport requirements and workplace health and safety obligations now intersect more frequently with traditional ECEC compliance requirements.

Queensland's Safety Management Framework highlights this growing overlap and serves as a reminder that transport safety requires the same level of governance, planning and oversight applied to other critical areas of service operation.