The Private Motor Truck Council of Canada (PMTC) has been involved in consultations with Transport Canada and the Canadian Council of Motor Transport Administrators (CCMTA) on electronic logging devices (ELDs) for many years and have come out in favor of them on numerous occasions.
We were extremely pleased when the announcement was made in June 2019 that the ELD regulation was posted in Canada Gazette Part 2, and would come into force for federally regulated carriers on June 12, 20201. However, the removal of the grandfather clause and the timeline for full compliance concerned our organization at the time.
Our concerns over the timelines have only been exasperated as we have moved closer to the implementation date, and we now believe it is not possible for industry to meet this compliance date without confusion. If we stick to June 12 2021 it will, in our view, be a chaotic rollout and cause many issues for carriers, enforcement and ELD manufacturers, alike.
In early 2018 the PMTC requested an 18-month compliance date after the Gazette 2 posting, while remaining with the two-year grandfather provision for electronic recording devices (ERDs).
We also communicated that it was of vital importance that third-party certification testing procedures were nailed down prior to any Canada Gazette 2 posting. We felt posting the regulation without this process ready to roll would mean the timelines for compliance would be problematic, as many carriers, understandably, would not want to research devices until a list of certified ELDs was approved.
Ultimately, the posting occurred without the certification process complete, with a two-year compliance window, and no grandfather provision for previously installed devices. We are now less than one year from the compliance date, and we still have no accredited certification body, although we have heard one is likely to be announced shortly.
Once a certification body or bodies are announced, ELD manufacturers will only then be able to submit their devices for certification, which as we understand it, will be a minimum of a four- to six-week process. This being the case, we are likely looking at the end of July, at the earliest, before we can expect to see even one certified device hit the marketplace.
This “best-case” scenario timeframe only leaves a carrier 10 months to research devices on the market, make a purchasing decision, schedule installs, train all staff, and possibly have to integrate it into a fleet program software already in place.
The PMTC has been on record from the start saying for an ELD implementation to be conducted properly will require a minimum 12-month process to ensure a smooth rollout and transition. I have previous experience in transitioning a fleet to ELDs and can confirm this is roughly the timeline we had from start to finish.
Carriers who already have an ERD in place, which ends up not getting certified as an ELD, will have an even harder time trying to comply with the current deadline, as they will need to remove current systems that may already be integrated into fleet software, then research and replace the devices and retrain all staff. Some current ELD suppliers have already indicated that because of changes they need to make to devices to meet Canada’s technical specifications, they do not plan to submit for certification until early this fall. That means some carriers who have devices installed may have to wait until late 2020 before they even find out if their current device will be certified, leaving six months to rectify a problem they did not create.
The PMTC believes Transport Canada must act quickly to address this situation. ELD suppliers and industry will require sufficient time to transition, and Transport Canada’s actions can remove most of our concerns as it relates to a hectic and confusing rollout.
PMTC also understands the Covid-19 pandemic has significantly affected work for all levels of governments. However, the pandemic has also showcased the important collaborative work between governments and industry partners.
For example, throughout the pandemic, Transport Canada has held regular calls with industry associations, including the PMTC, as well as other government departments and provincial/territorial road safety administrators to identify and work collaboratively to address issues as they emerged.
Through this ongoing engagement with a diverse road safety community, Transport Canada has developed many safety guidance materials to protect commercial drivers to help limit the spread of Covid-19 in commercial vehicle operations.
We worked together to address rest stops and border crossing issues as well as the lack of sanitation locations for commercial drivers. Keeping a collaborative approach and recognizing the importance of the ELD mandate for our members and all Canadians, PMTC is willing to work with Transport Canada and other relevant stakeholders through the CCMTA to find an appropriate solution ahead of the June 12, 2021 deadline.
PMTC has always enjoyed a strong collaborative relationship with Transport Canada and believe we can once again work together to come up with a fair solution for the time crunch the industry is now facing with the ELD compliance deadline.
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