TORONTO — The Canadian Council of Motor Transport Administrators was hoping to solicit feedback on a potential electronic on-board recorder (EOBR) mandate and Canada’s leading carrier group responded.

The CCMTA issued a discussion paper in late-February, in preparation for a possible Canadian rule on EOBR usage. The paper highlights issues of compliance, data requirements and implementation, and how they apply to a carriers’ business.

Following a "project charter" drafted last fall, this paper includes a brief discussion on each issue associated with EOBR compliance and concludes with questions to guide carriers’ input.

While the Canadian Trucking Alliance would like to see a mandate requiring all carriers to use electronic on-board recorders (EOBRs), the group would like to see some issues addressed before Canada moves forward.

The current paper log book system, says CTA, is antiquated, easy to abuse and difficult to enforce, which contributes to non-compliance with the hours of service rules and can contribute to driver fatigue.

“The lack of effective enforcement of the hours of service rules has not only created potentially unsafe situations and created an unlevel playing field between carriers, but it has also denigrated the credibility of the regulators and sustained a negative mythology about the trucking industry’s compliance record,” states the CTA in a news release. “A universal EOBR mandate would improve the effectiveness of both the enforcement effort and compliance with the hours of service regulations.”

However, CTA concedes a number of key issues need to be addressed before a mandate could become a reality:

Enforcement Policy – It is essential that a reasonable, common sense, enforcement approach be established as part of the introduction of an EOBR policy and that it is uniformly adopted across jurisdictions and shared with industry.

U.S.-Canada Harmonization – Given the level of integration between the supply chains of the two countries, the pursuit of a common U.S.-Canada approach to EOBRs must be a priority. However, that does not necessarily mean the U.S. and Canadian rules need to be identical. It would be extremely important that Canada and the U.S. harmonize in terms of the technology, data standards and driver identification.

Privacy – EOBR technology shall be used solely for hours of service recording purposes. The type, amount, format and frequency of data that governments shall have access under an EOBR mandate to needs to be determined in concert with industry. Governments must commit to updating their data management systems to ensure they have integrity and are secure.

Technology – Instead of prescribing specific technologies, an EOBR mandate should concentrate on what data is required and in what format and allow carriers the flexibility to determine which EOBR technology is best suited to their specific business.

Costs – Cost concerns and financial implications can be managed by a combination of establishing a realistic and reasonable timeframe for full implementation of the mandate and by providing meaningful incentives (tax, grants, rebates, and/or credits) to encourage and assist accelerated investment in the technology. There will never be an ideal time for a mandated investment, and credit is currently very tight, but a fair and incentivized transition would significantly reduce opposition on those grounds.

The CCMTA working group is expected to submit its final report to the Council of Deputy Ministers of Transportation in October 2010.