Regular readers of this blog will be fully aware of the Private Motor Truck Council of Canada’s (PMTC) concerns on electronic logging device (ELD) timelines and our concerns over Transport Canada’s refusal at this point to address these concerns as the compliance deadline continues to rapidly approach.
The PMTC is not a lone voice in the woods here, as at least five other Canadian transportation industry associations have raised similar concerns, as well as our U.S. counterpart, the National Private Truck Council. This is an important topic and as the deadline continues to approach, with no certified devices available, it will cause major chaos and disruption to the trucking industry.
To be clear, the PMTC has always been a strong supporter of ELDs, and was one of the first groups to encourage the adoption of third-party certification, so we are glad to see that FPInnovations was recently approved to be the first ELD certification body.
While the announcement of the first certification body is an important step, it was too long coming, and we continue to have concerns about the implementation timelines. In order to ensure we have a smooth transition and rollout, the PMTC believes a minimum six-month enforcement deferral from the June 12 2021 timeline would be appropriate.
Industry consensus, especially for larger fleets, is that it takes one year from the time you begin researching ELDs until you have them fully implemented into your fleet. The steps include researching providers, purchase, installation, and training all drivers, IT and operational staff. To rush this causes a chaotic rollout.
Some have argued researching of devices could have begun well before a certification body was announced, so when devices were approved, that part of the implementation process would be completed. The PMTC agrees.
What we cannot accept is the notion that a carrier, who may currently not have a device or who has one that may not get approved, should be willing to purchase a device and begin installing it into their fleet prior to being guaranteed it will be compliant. The only way to ensure it will be compliant is to see it on the approved list of certified devices. It is not the industry’s fault it took regulators almost 17 months to put a certification process in place, and fleets should not pay the price for this with an unreasonably short timeline.
Transport Canada launched a regulation with the Canada Gazette 2 posting on June 12 2019, indicating fleets must install an ELD that is on Transport Canada’s approved list of providers. Yet, almost 17 months later, we have no certified devices on the list and none are expected to be there until late this year or early 2021 at the earliest.
On Oct. 26, Transport Canada announced changes to the testing procedures that will be used to certify devices, which also required a change to the technical standard. These changes hinder the ability for any ELD provider to submit their device for certification, as they will need to make programming changes to their devices.
Many providers have publicly indicated they do not intend to submit for certification until early 2021, meaning it will be March or April before many devices land on the approved list, leaving carriers only two or three months to ensure the device they have is compliant. This will also likely result in a truncated list of suppliers to select from. Some ELD providers have also indicated they will not be submitting all of their models for certification, meaning some carriers will need to purchase different models than they currently have, even if they stay with the same supplier. Remember, an ELD supplier is not approved, but rather the device they submit is. If they have numerous models, each one will need to be approved. Not all models will be submitted.
Carriers who operate in the U.S. had to install an FMCSA-compliant device to comply with U.S. regs by December 2017. There are more than 600 devices on the FMCSA list. It has been widely speculated that only 15 to 30 manufacturers will be approved for Canada, meaning we will likely see over 500 current devices not approved for use here.
While we believe this is a good thing, as many of these devices would not be compliant if properly vetted, it will nonetheless still create a large problem for carriers. If these devices are not approved, it will be early next year before a carrier is even aware of this, leaving them a very short time to research, remove and replace their device, through no fault of their own.
These carriers will be in worse shape than a fleet that chose to do nothing. If these carriers find out in early 2021 that the device they are using is not approved in time or submitted for certification, they will need to research an approved device, from what will likely be a very short list, install it and remove the previous device, train their drivers, and turn it on – all in less than six months.
With only one certification body in place, we may see a backlog in the certification process, meaning carriers may not be able to select an ELD as a result of the device not completing the certification process before June 12, 2021.
In addition to all the above points, I think it is fair to say Covid-19 has placed undue stress and hardship on everyone, and redirected resources into dealing with the many issues that arose as a result. This only exasperates the issues we have raised. The PMTC fails to see how providing an enforcement deferral of six months will place the public’s safety in danger. We are not asking for an indefinite deferral, just a short deferral with a clearly defined end date to allow industry and suppliers sufficient time to transition. If you share the PMTC’s concerns, we encourage you to provide your concerns to Transport Canada by submitting your concerns in writing to email@example.com.
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