Okay, maybe it’s because I became an official senior citizen a few weeks ago, but I really can’t let this Ontario senior drivers thing go. And judging from the calls and e-mails I’m swamped with daily, a lot of you share my concern.

Like everyone else, I was pleased when Ontario Transportation Minister Bob Chiarelli decided to re-open discussions on the licence renewal process for senior commercial drivers. We were prepared to explain to this new crop of bureaucrats and politicians how the discriminatory regulation is not only costly and time-consuming, but useless as a tool for catching drivers with failing faculties.

Stakeholders were hastily brought together for a meeting at Queen’s Park where the Ministry tabled a proposal. While stubbornly maintaining that a renewal system for commercial drivers aged 65-79 is making our roads safer, MTO is considering a number of amendments to regulation 340/94 that you can see on the Regulatory Registry (ontariocanada.com/registry); scroll down to ‘Current regulatory proposals’ and find ‘Commercial Driver Licence Renewal (for drivers aged 65+).’ The posting is open for public comment until Apr. 11.

In a nutshell, MTO is prepared to: Scrap the annual age-based road test in favour of a driving test triggered by a “poor driving record”; change the written test from annual to every five years; align the written air brake test with the written knowledge test and require a practical air brake test only when a road test is required; and extend these requirements to Class D drivers.

So what’s my problem? We should be overjoyed, especially with the age discrimination factor out of the equation, right? Maybe so overjoyed that we’ll overlook the shortcomings of the proposal on the table?  

Before I get too carried away, let’s step back and put this in context. When we left off discussion four years ago, there was support on all sides for changes that took certain key principles into consideration: retaining medical reporting requirements, removing age-based road testing, a longer renewal cycle from age 65, poor driving record as the trigger for a road test, and uniform testing for all commercial drivers. The Ministry has let us down sorely on the last two principles, and that’s got me riled.

First of all, MTO’s definition of a poor driving record is absurd: Three demerit points or an at-fault collision, with absolutely no consideration for a senior driver’s past record, which most likely spans several decades and millions of miles. Clearly more discussion is warranted to make “driving record” a meaningful barometer of the Ministry’s stated objective to identify and test drivers engaged in “high-risk behaviour.”

Secondly, the concept of a uniform testing policy for all commercial licence classes, including D, is apparently out the window, particularly with respect to medical fitness to drive.

And lastly, there’s a lot of bobbing and weaving in MTO’s justification of the changes that leaves me scratching my head. On the Regulatory Registry you’ll find a document under ‘Additional information’ that gives details on the current requirements, the proposed changes, and the Ministry’s rationale for the amendments.

What you won’t find in this document is a claim that the Ministry’s data shows an increased risk of collision due to age-related factors. That claim, in fact, was made when the proposal first appeared on the Web site. When I challenged it, asking what analysis was done, and by whom, to attribute collisions to “age-related factors” I was told they’d “get back to me.” No phone call yet, but the document has been quietly revised. Oops.  

The reference to “age-related factors” becomes critical when you consider MTO’s justification for the senior driver renewal process in the first place, ie., “the Canadian Council of Motor Transport Administrators has recommended that aging factors be taken into account when considering licensing privileges (ie. slowed reaction time and reduced physical strength, eyesight and hearing).”

What they neglect to say is these are medical standards intended as a guide in establishing minimum medical qualifications for all drivers. And yes, the standards recommend the above aging factors be taken into account, but by a physician during a medical examination, not by a CERCO employee administering a road test.

Uniform testing? Under the proposed changes, Class D drivers would be subject to the same testing with respect to the written and driving tests, but incredibly, there is no requirement for a Class D driver to undergo any medical examination until age 80. This, by the way, is contrary to the recommendation of annual medical testing for both Class A and D drivers under the same CCMTA medical standards the Ministry is using to justify testing of old Class A drivers.

So if an old Class D driver doesn’t need an annual medical to check for “aging factors” why are they testing Class A drivers? To put this in perspective, in 2010 there were 2,224 Class A licence holders in Ontario age 65 and over, compared to 74,175 Class D drivers in the same age group. Ironically, there’s probably a good number of those Class D licence holders who are actually Class A drivers who either “failed” or didn’t bother to renew their licence.    

And forgive my senior’s moment, but did I miss MTO’s explanation of how the current entry level road test is going to make those old codgers with three demerit points safer?

Watch ‘The Age Page on OBAC’s Web site (obac.ca) for our official comments, and if you share my concern, let MTO know through the “public comment” process.

– Joanne Ritchie is executive director of OBAC. Eh? What’s that she’s saying? E-mail her at jritchie@obac.ca or call toll-free 888-794-9990.