Effective 13 September 2026
Safety Management System
17 — Safety Management System
Effective Date: 13 September 2026 Prepared by: OZ Ride Pty Ltd (ABN 52 694 735 487), the provider of the associated booking service that operates the Rideshare Service and the Taxi Service under an association arrangement with OOHA Pty Ltd (trading as OOHAI), the provider of the principal booking service and holder of On-Demand Booking Service authorisation #1012130. See clause 1.2 for what this structure means in practice. Audience: Primarily internal (OZ Ride management, safety, and compliance personnel) and OZ Ride's Drivers, for whom this document must be readily accessible. Published as version-controlled content per this framework's practice; regulator-facing where the WA Department of Transport requests it. Governing law: Western Australia. Defined terms: Capitalised terms not defined in this document have the meaning given in 00 — Definitions.
0. Relationship to our existing safety records
This document did not start from a blank page. Before writing it we reviewed the safety material OZ Ride already maintains:
- A live, database-backed hazard register already in production in the OZ Ride admin console (Compliance → SMS Hazard Library), recording hazard type, description, risk level, and control measures per hazard, with full create/read/update/delete functionality for our safety and compliance personnel.
- A library of prebuilt SMS template documents (Safety Policy, Fatigue Management Policy, Drug & Alcohol Policy, Driver Code of Conduct, Emergency Response Procedure, Incident Reporting Procedure, Vehicle Defect Reporting, Risk Assessment Matrix, Hazard Identification Checklist, Annual Safety Audit Checklist, Driver Induction Checklist) available in the same admin console, intended as generic starting text for an operator to adapt — not yet adopted, not signed, and in places (for example, its fatigue-limit numbers) inconsistent with the limits our platform actually enforces today (see clause 5.1 below, and compare the Fatigue Management Policy). This document builds on (1) and (2) rather than starting from nothing — the hazard categories in clause 3 below are the same categories already tracked in the live hazard register, and the section structure follows the same document set already assembled in the admin console. Where the prebuilt template text in (2) contained a number or a claim that conflicts with what our platform actually does, we corrected it here rather than repeating the conflict — a safety document that states an unenforced limit as if it were enforced is a false control, which we treat as worse than an honest gap. This document is the single authoritative written Safety Management System for regulation 14 purposes; the admin-console template library remains a useful internal drafting resource but is not itself the regulation 14 document.
1. Purpose, scope, and accountability
1.1 Statutory basis. Regulation 14 of the Transport (Road Passenger Services) Regulations 2020 (WA) requires the provider of an On-Demand Booking Service authorisation to prepare and maintain a Safety Management System that: identifies reasonably foreseeable hazards to Drivers, Riders, and other persons; includes procedures to eliminate or minimise those hazards so far as reasonably practicable; is in writing and readily accessible to persons using it; and is reviewed as soon as practicable after any new hazard is identified. A failure to comply is an offence under regulation 15, carrying a penalty of up to $40,000 for a body corporate. OOHA Pty Ltd, as the holder of ODBS authorisation #1012130, is responsible under regulation 39(2)(a) of the Regulations for ensuring this duty is met in relation to the on-demand booking services OZ Ride Pty Ltd provides as the associated booking service under their association arrangement — see clause 1.2. OZ Ride Pty Ltd prepares, operates, and keeps this document current in practice. This document is that Safety Management System.
1.2 Scope — the two-entity structure. OZ Ride Pty Ltd (ABN 52 694 735 487) provides the Rideshare Service (OD-C) and the Taxi Service (OD-RH) as the provider of an associated booking service, operating under an association arrangement (Transport (Road Passenger Services) Act 2018 (WA) s. 27(2)–(3); Regs r. 5) with OOHA Pty Ltd (trading as OOHAI), the provider of the principal booking service and holder of On-Demand Booking Service authorisation #1012130. This is a deliberate, lawful structure under the Act, not an inconsistency: OZ Ride Pty Ltd is who you contract with — every operational document in this framework (this Safety Management System, the Driver Service Agreement, the Rider Terms of Service, the Payment Terms, and the Complaints Handling Procedure) is between you and OZ Ride Pty Ltd. OOHA Pty Ltd holds the ODBS authorisation, and — because it is the principal booking service — is responsible under regulation 39(2) of the Regulations for ensuring a Safety Management System (this document), driver/vehicle/booking records (regulations 57–58), and a complaints resolution procedure (regulation 62, records under regulation 63) are in place covering the services OZ Ride Pty Ltd provides; OZ Ride Pty Ltd prepares, operates, and maintains all of these in practice. This Safety Management System accordingly covers OZ Ride Pty Ltd's on-demand passenger transport operations under ODBS authorisation #1012130, and every hazard reasonably foreseeable to Drivers, Riders, and other persons in connection with those operations.
Where WA law requires the ODBS identity to be disclosed, both entities are named: advertising for the service must state that an association arrangement exists and cite OOHA Pty Ltd's authorisation number, name, or business name "OOHAI" as published on the DTMI section 41 public list (regulation 61(2)); fare receipts must show OZ Ride Pty Ltd's own name and at least one of OOHA Pty Ltd's authorisation number, name, or business name as published on that list (regulation 131(2)). See clause 7.4 of the Payment Terms for the receipt content and clause 21 of the Driver Service Agreement for the WA Schedule's regulatory-identity summary.
1.3 Accountability. OZ Ride's officers (directors) are personally responsible for ensuring the company complies with its safety duties under Part 2 of the Transport (Road Passenger Services) Act 2018 (WA), including the primary duty of care in section 16 to ensure the health and safety of Drivers and other persons engaged in providing the service, and passengers and other persons in connection with it. OZ Ride maintains a register of Responsible Officers for this authorisation, including at least one Responsible Officer ordinarily resident in Western Australia, as regulation 48 requires. Consistent with this document's practice of not publishing individual names in a public-facing Safety Management System, the named Responsible Officer(s) and the residency/criminal-record-check evidence supporting this clause are held in OZ Ride's internal compliance records rather than in this published document; they are produced to the WA Department of Transport on request.
2. How this document is organised
For each hazard we have identified (clause 3), we describe: the risk it presents; the control measures we use to eliminate or minimise it so far as reasonably practicable; and where the control measure is enforced by the Platform's own systems, rather than by policy or training alone, we say so and describe how.
3. Hazard register
3.1 Driver fatigue
Risk. A fatigued Driver presents an elevated risk of a road-traffic incident to themselves, their passengers, and the public.
Control measures. OZ Ride enforces a hard limit — not merely an advisory one — on a Driver's online hours: a Driver reaching 12 hours online within a rolling 24-hour window is blocked from going online again, and from accepting a new Trip, until a mandatory 6-hour offline period has elapsed. This is enforced at two separate points in our systems — the point at which a Driver attempts to go online, and the point at which a Driver attempts to accept a Trip — precisely because a Driver who is already online when the 12-hour threshold is reached must still be stopped from accepting further work, not only from logging back in later. The full policy, including how the limit is calculated and what happens if you are close to it, is published in the Fatigue Management Policy. Secondary-employment disclosure is also collected at Driver onboarding and periodically thereafter, consistent with DTMI's fatigue-management guidance.
3.2 Assault and passenger/driver safety
Risk. Physical or verbal assault, harassment, or threatening conduct directed at a Driver, a Rider, or another person in connection with a Trip.
Control measures. An in-app SOS function is available to both Drivers and Riders, described in full in the Safety and Insurance Disclosure. Reported conduct of this kind is treated as a serious matter under clause 9.3 of the Driver Service Agreement and clause 6 of the Acceptable Use Policy, triggering immediate suspension pending investigation. Where the conduct amounts to alleged driver conduct affecting a Driver's suitability, it is separately reportable to the WA Department of Transport within 48 hours under regulation 106 of the Transport (Road Passenger Services) Regulations 2020 (WA) — see clause 3.7 below.
3.3 Driver distraction
Risk. A Driver's attention being diverted from the safe operation of the Vehicle, including by the Driver App itself, a Player Tablet where fitted, or a passenger.
Control measures. Clause 7.5 of the Driver Service Agreement and clause 3(a) of the Acceptable Use Policy require Drivers to drive safely and lawfully at all times. Where a Vehicle is equipped with a Player Tablet, it is mounted in a fixed position specified in the Player installation guide and is not intended to require Driver interaction during a Trip. Riders are prohibited from interfering with a Driver's safe operation of the Vehicle under clause 4(g) of the Acceptable Use Policy.
3.4 Driver competency
Risk. A Driver lacking the training, licensing, or (for wheelchair-accessible vehicle work) the specific competency the role requires.
Control measures. Every Driver must hold a current Passenger Transport Driver (PTD) authorisation before being approved (clause 2 of the Driver Service Agreement). At onboarding we check the PTD directly against the WA Department of Transport's on-demand industry system rather than relying on a document the applicant supplies, and the authorisation number, its status, and its expiry date are held against the Driver's compliance record. After approval, the Platform re-checks every Driver's PTD against the Department's systems every two hours, and every Vehicle's PTV every twelve hours, on a running basis (this continuous check has operated since 27 August 2026). A Driver whose PTD status is not in good standing is stopped by the Platform's compliance gate from going online, at every point where a Driver goes online.
Drivers must complete OZ Ride's driver education modules and any required in-person inductions before approval (clause 2.1(j) of the Driver Service Agreement). Induction completions, including any secondary-employment disclosure, are recorded against the Driver with the version of the induction content they acknowledged; if that version is not the version currently in force, the Platform refuses the record rather than accepting an acknowledgement of superseded content.
Control gap we are open about. One part of this control is not yet where it needs to be, and clause 6 tracks it: for wheelchair-accessible vehicle work, the additional driver competency regulation 35 requires is a condition of doing that work under clause 2 of the Driver Service Agreement but is not yet enforced as an automatic dispatch gate. (An earlier gap — PTD currency re-confirmed only at onboarding — was closed on 27 August 2026 and is recorded as SA-1 below.)
3.5 Vehicle mechanical failure
Risk. A Vehicle defect causing a breakdown, a loss of control, or an unsafe operating condition.
Control measures. Every Vehicle must hold a current Passenger Transport Vehicle (PTV) authorisation, be roadworthy, and pass any inspection OZ Ride requires (clause 5 of the Driver Service Agreement); OZ Ride may require an inspection at any time and suspends a Vehicle that fails to satisfactorily complete one within seven days. Drivers must report a Vehicle defect and any incident involving Vehicle damage within 24 hours (clause 6.4 of the Driver Service Agreement).
3.6 Passenger safety generally
Risk. A Rider's safety and wellbeing during a Trip, beyond the specific hazards already listed — including seatbelt use, child restraints, route deviation, and in-Trip emergencies.
Control measures. These are addressed in full in the Safety and Insurance Disclosure, which this Safety Management System incorporates by reference for passenger-facing detail.
For wheelchair-accessible vehicle (WAV) bookings specifically: a booking that requires a wheelchair-accessible vehicle is only ever offered to a wheelchair-accessible vehicle. The Platform will not substitute a non-WAV vehicle on any dispatch path — direct dispatch, re-matching, a Rider's preferred Driver, or an administrator's manual assignment — so the failure mode of a wheelchair user being sent a vehicle they cannot use does not arise. Where a WAV booking is waiting in the re-matching queue, it is placed ahead of other waiting work.
On the taxi (on-demand rank or hail) lane specifically, regulation 141 of the Regulations places a duty on both the driver of a wheelchair-accessible vehicle and on the booking service to ensure that vehicle is used to attend first to any request for service for a passenger who uses or requires a wheelchair — a $10,000 penalty for a body corporate. That is a rule about how a wheelchair-accessible vehicle is allocated, and it does not extend to on-demand charter (rideshare) bookings. The Driver-side duty is stated in clause 21.7 of the Driver Service Agreement; the corresponding competency requirement in regulation 35, which does apply to all WAV work rather than rank or hail alone, is at clause 3.4 above. Making the booking-service side of regulation 141 a property of the first-pass dispatch, which today ranks candidates by proximity, is tracked in clause 6.
3.7 Misuse of camera surveillance recordings
Risk. Unauthorised viewing, copying, downloading, editing, or misplacement of a Camera Surveillance Unit (CSU) recording from an OD-RH taxi vehicle.
Control measures. Every OD-RH vehicle must be fitted with a working CSU meeting the Camera Surveillance Unit Standards 2020, with signage inside and outside the vehicle. That is a condition of driving an OD-RH vehicle on the Platform and is imposed on the Driver by clause 21.4 of the Driver Service Agreement. Access to a CSU recording is restricted to the purposes regulation 107 of the Regulations authorises; a Driver must not view, download, copy, play, or edit a recording outside those purposes, and must report any misplacement or suspected misuse to OZ Ride within 24 hours. Any misplacement or unauthorised use of a recording is itself a notifiable occurrence under regulation 104(g), reportable to the WA Department of Transport as soon as practicable under regulation 105.
We record CSU fitment, whether it meets the 2020 Standards, the certificate, and the interior and exterior signage against each taxi vehicle, and our compliance staff can see and audit that record. Two control gaps follow, and clause 6 tracks both: that record is not yet a gate that stops an unfitted vehicle being used, and access to recordings is controlled by who holds the recording rather than by a purpose-logged access module inside the Platform.
This is a separate camera system from the audience-measurement cameras described in the Computer Vision Privacy Disclosure — see that document for the CV-camera-specific analysis.
3.8 Fraud affecting Trip or fare integrity
Risk. Manipulation of GPS/distance data, fake trips, collusive trips, or other conduct that compromises the integrity of a Trip or a payment.
Control measures. Automated fraud-detection gates operate on live Trips, including a distance-based check on the taxi meter-end action; conduct of this kind is a serious breach under clause 14.2(f) of the Driver Service Agreement and clause 15 of the Payment Terms, which may result in suspension and payout withholding pending investigation.
4. Incident and complaint management
4.1 Every notifiable occurrence — a crash reportable to police, an injury requiring ambulance or hospital treatment, a collision or mechanical fault preventing a journey being completed, an incident resulting in a police complaint alleging sexual assault, indecent exposure, assault or intimidation, a driver charged with a serious driving-related offence, or misuse of a CSU recording — is reported to the WA Department of Transport as soon as practicable, in the manner regulation 105 requires. Any allegation of driver conduct that a reasonable person would consider affects a Driver's suitability is reported within 48 hours under regulation 106, independently of and without waiting for any internal investigation or the process under the Suspension & Deactivation Policy to conclude.
4.2 How reporting happens today. An incident is recorded by OZ Ride compliance staff in our incident register, which classifies it and computes the regulation 106 forty-eight-hour deadline from the time the occurrence happened. The report to the Department is then made by a person, and the Department's reference number is recorded against the incident — we record that a report was made only when we hold that reference number, so this register never shows a report as filed unless it was. There is no automated transmission to the Department and no automatic escalation when a deadline approaches; both are tracked in clause 6. Meeting the deadline is a duty on us either way, and it does not depend on that tooling existing.
4.3 General complaints (not rising to a notifiable occurrence) are handled under the Complaints Handling Procedure, which is itself part of this Safety Management System's control for the hazards in this register that a complaint might reveal.
5. Training and induction
Every Driver completes OZ Ride's driver education modules and any required in-person inductions before approval. Where induction content changes (for example, to reflect an update to this Safety Management System after a hazard review), the version of the content a Driver acknowledged is recorded against their training record.
6. Open safety actions
Regulation 14 requires this document to describe the controls that eliminate or minimise each hazard so far as is reasonably practicable. It does not require us to claim a control is stronger than it is, and a safety document that describes an unenforced control as though it were enforced is worse than one that is honest about the gap: it stops the gap being fixed. The following actions are tracked here. A closed action stays listed so the record shows what changed and when. Each open action is reviewed under clause 7.
| # | Hazard | The gap | What closes it |
|---|---|---|---|
| SA-1 | 3.4 Driver competency | Closed 27 August 2026. PTD currency was confirmed at onboarding only | Scheduled re-verification against the Department's systems now runs every two hours for Drivers and every twelve hours for Vehicles, with an automatic block on going online when a lapse is detected |
| SA-2 | 3.4 Driver competency | No automatic gate preventing WAV work being dispatched to a Driver without regulation 35 competency evidence | Capture the competency evidence against the Driver and gate WAV dispatch on it |
| SA-3 | 3.6 Passenger safety | WAV bookings take precedence in the re-matching queue but not in first-pass dispatch, so the regulation 141 booking-service duty rests on allocation rules and staff procedure rather than on the dispatch ranking itself | Extend WAV precedence to the primary dispatch ranking on the rank or hail lane |
| SA-4 | 3.7 CSU misuse | CSU fitment is recorded but does not gate a vehicle being put into service | Make the equipment record a condition of vehicle approval |
| SA-5 | 3.7 CSU misuse | No purpose-logged, role-restricted access module for recordings inside the Platform | Build that module, with an access log that records who viewed what and why |
| SA-6 | 4. Incidents | The 48-hour regulation 106 deadline is computed and visible, but nothing escalates automatically as it approaches | Automated escalation on an approaching or breached deadline |
Until an action is closed, the control is carried by the policy and staff procedure described in the relevant clause above, and the obligation itself is unaffected.
Some of the work behind these actions is built but not yet switched on. A control that has been built and a control that is operating are not the same thing, and this register tracks the second. Switching one on changes what clause 3 should say about it, so this register and the clauses it refers to are re-checked whenever a control's operating state changes — not only on the annual cycle in clause 7.
7. Review
7.1 This Safety Management System is reviewed at least annually, and — as regulation 14(3) requires — as soon as practicable after any new hazard is identified, whether that hazard is identified through an incident, a complaint, a Driver report, a regulatory change, or an internal audit.
7.2 Every review is logged with the date, the reviewer, and a summary of any change, so the review log itself is evidence of an active, maintained system rather than a document published once and left static.
8. Related documents
- Fatigue Management Policy
- Safety and Insurance Disclosure
- Complaints Handling Procedure
- Data Breach Response Plan — for the camera-surveillance-misuse hazard's data dimension
- Computer Vision Privacy Disclosure
- Driver Service Agreement
End of Safety Management System.