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With the ELD mandate in full effect in the United States, the Government of Canada has unveiled a draft of its own ELD plan north of the 49th parallel. As you will note below, the proposed regulations on electronic logging devices has a number of similarities with the U.S. mandate in terms of the overall purpose and specifications.

For specifics, please click here.

Much like the case with the U.S. ELD rules, the electronic logging regulations in Canada will apply to federally regulated motor carriers and commercial drivers of trucks and buses.

Some provincial jurisdiction may adopt the federal rules by reference, or may elect to follow the strategy of some U.S. States by adopting an ELD mandate at a later date. No further information is known on such timelines at time of writing.

Transport Canada announced the new regulations on December 18, 2017, which coincidentally occurred on the same day that ELD compliance formally came into effect in the U.S. The Federal Motor Carrier Safety Administration (FMCSA) has also allowed a phased in compliance based on specific circumstances.

As you know, ELDs will eventually become mandatory in the U.S. for all drivers as of December 16, 2019, unless otherwise exempt.

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Cost-Benefit Analysis


The upcoming ELD proclamation by Transport Canada had been widely anticipated by the industry since the Regulatory Impact Analysis Statement was published by Transport Canada December 16, 2017. Unfortunately, movement on the Canadian ELD mandate has proceeded much slower than anticipated.

Click here to access the complete Regulatory Impact Analysis Statement.

 

Stakeholder groups such as the Canadian Trucking Association and some provincial associations have also been aggressively lobbying Transport Canada for an ELD mandate here.

In the December 2017 release, Transport Canada estimated that the combined savings in benefits to have a total value of $255.4 million, annualized at $36.4 million.

The cost savings and benefits are expected to be yielded from the following:

  • Safety benefits by reducing property damage, injuries and fatalities.
  • Drivers spending less out-of-service detention time due to HOS violations.
  • An overall time savings, resulting in reduced administrative costs felt by the carriers, and provincial and territorial governments by way of more efficient audits and inspections.
  • Lowered administrative costs related to managing a paper-based daily log system for motor carriers.


Included below are some additional facts and assumptions based on various research conducted in the Canadian industry:

 

Basic Industry Data


  • GDP from Canadian transportation services totals about $58 billion, or about 3.7% of total GDP, with trucking accounting for the largest share of the transportation total at 30.7%.
  • 83.2% of shipments transported by Canadian trucks are domestic, with the remainder being cross-border shipments to or from the US and Mexico
  • Trucks transport 45.1% of Canadian exports to the US (by value) and 73.5% of US imports.
  • The total Canadian trucking industry (for-hire, private, owner-operator and courier) includes about 56,800 firms.
  • Small trucking carriers (100 or fewer employees) represent 98.7% of all carriers.


A. Trucks


  • There are about 750,000 heavy trucks operating in Canada (defined as any truck over 4500 kg).
  • About 80,000 Canadian CMVs operate into the United States on a regular basis.
  • The trucking fleet will grow at an annual rate of 3.1% over the next 5 years
  • The average life span for a power unit where driver would maintain logbook is 6 years.
  • The average annual cost per CMV is estimated at $355,000 based on annual travel distance of 100,000 km at the cost of $3.55 per km.


B. Drivers


  • There are 1.2 drivers for every truck based on single and teams environments.
  • The industry employs about 201,108 company drivers.
  • There about 54,000 owner-operators.
  • The overall turnover rate for truck drivers in Canada is 6.7%.
  • A wage rate of $30 per hour for truck drivers is assumed including an overhead rate of 25%
  • About 170,400 truck drivers will be covered by the Canada ELD mandate.


C. Trucks Covered by ELD Mandate


  • There are 170,000 federally regulated trucks operating in Canada.
  • About 84.5% of for-hire trucks are equipped with fleet management systems with ELD capacity.
  • 56.5% have operational ELDs.
  • Approximately 30% of the ramp up for the mandate was completed in 2016 and 70% in 2017 due to U.S. rule.
  • On average, the proposed Canada ELD rule would cost a motor carrier approximately $1,193 per year for a small carrier, versus $46,685 for a large carrier.


D. ELD Costs


  • ELDs at an entry or mid-level range from $300 to $900 per unit.
  • Likelihood that mobile ELD applications will push the costs down even further.
  • Associated installation cost is $220 per device and activation fee is about $15 per unit.
  • Monthly monitoring service fee is estimated to be $30 per month.
  • Average driver training costs $48 per hour
  • Average inspector/auditor training is about $457 per person.


E. Savings from ELDs


  • Driver time saving from maintaining paper logbooks is estimated at 4.5 minutes to 23 minutes per day.
  • Time spent forwarding daily logs by drivers to carriers will save about 5 minutes about 25 times per year.
  • In total drivers will save about 20.08 hours per year currently being spent administering paper logs.
  • Clerical employees take about 3.5 minutes to file each paper log received from each driver.


F. Road Safety/HOS Compliance/ELDs


  • Motor vehicle collisions were the cause of 1,923 deaths and 165,306 personal injuries; 226 fatalities and 4,512 injuries involved a semi-truck.
  • Although police reports tend to estimate the contribution of fatigue at below 5% of crashes, there is established consensus amongst the world’s leading experts in the field that fatigue is more likely responsible for about 15% to 20% of crashes.
  • 300 (all types of vehicles) crashes occur in Canada each year where fatigue or falling asleep is a contributing factor and this is likely understated.
  • It is estimated that 42 such crashes involving the 146,300 federally-regulated CMV operators subject to an ELD mandate occur annually.
  • A 10% effectiveness rate in reducing these types of crashes is assumed.
  • Percentage of drivers/carriers exceeding allowable HOS limits is estimated at 5% to 10%.


G. Inspectors/Auditors


  • There are about 1,052 roadside inspectors in Canada with an average of 282,587 daily log inspections conducted in Canada each year.
  • There are about 102 auditors with 1,166 facility audits completed annually.
  • Of the total inspections, it is estimated about 102,156 annual inspections correspond to the in-scope CMVs.
  • It is estimated 976 audits are conducted annually of the 146,300 in-scope CMVs.
  • Hourly wage rates of inspectors and auditors are $57 and $58, respectively.

 

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U.S. & Canada ELD Mandate Potential Similarities


  • ELD synchronizes with the vehicle’s engine, and includes GPS tracking.
  • ELD captures driving time automatically, including unidentified driving.
  • ELD lets drivers use special driving statuses, Yard Move (YM) and Personal Conveyance (PC).
  • ELD has a mechanism to verify logs and agree to edits.
  • ELD has an on-screen display to show inspectors at roadside.
  • Both jurisdictions can generate an output file for inspectors, but will be displayed in different formats.
  • Pre-2000 vehicles are exempt from the mandates.

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U.S. & Canadian ELD Mandates Potential Differences


There are some functional requirements that are different. Specifically, the Canadian ELD mandate:

  • Does not include a central system for inspectors to use at roadside like the eRODS system in the US. This means each province will be responsible for developing and deploying their own inspection mechanism.
  • There may be an option to email driver logs via an output file to an officer’s email to view during an inspection (province specific), in addition to showing the screen at roadside.
  • Does not require capturing the VIN number.
  • There is no self-registration/certification process for ELDs.
  • An exemption is included for rental vehicles used for less than 30 days.
  • Requires the ELD to accurately and concisely track and manage deferred OFF Duty time.
  • Requires the ELD allow a mechanism to enter hours captured elsewhere (for example, driving done for another company).
  • Requires the ELD to include HOS cycle details and allow drivers a mechanism to switch between them.

With the rules on electronic logging sharing many specifications in both countries, drivers who currently use an ELD in the U.S. will likely have little difficulty adapting to the Canadian counterpart.

ELD manufacturers such as Fleet Complete should also benefit from similarities between these two mandates. This should also Fleet Complete to produce solutions at a much faster rate compared to the U.S. implementation of ELD.


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ELD Mandate Exemptions for Canada


There are four main exemptions from ELDs listed in Canada Gazette Part 1.

Commercial motor vehicles will be exempt if:

  • They are operating under a permit from a provincial or territorial HOS director;
  • Have a statutory exemption;
  • They are subject to a rental agreement with terms being under 30 days;
  • They are operating a vehicle manufactured before 2000.


Potential Timeline


To accommodate the time required for carriers and other affected parties to implement the technology and train staff, the Canadian government has considered a 2-year, phased-in compliance period.

  • 2020 – Canadian ELD Rule compliance deadline. ELDs meeting National Safety Code technical standard become mandatory.
  • 2022 – Extended compliance date for those already using compliant electronic logging devices with the Federal rules.

To prepare for the upcoming regulations, provinces and territories will be tasked with outlining their individual enforcement programs and training staff, which may include developing software.

Fleet Complete staff will review the final specifications when published. Transport Canada will start development to meet the regulations well before the implementation date, which will be no earlier than two years after their publication in Canada Gazette 2.

Canadian carriers should take advantage of what will likely be a quick roll-out from ELD providers, and implement early so that drivers are trained and comfortable with the device prior to the final compliance date in Canada.

 


Official Sources
I. Regulations Amending the Commercial Vehicle Drivers Hours of Service Regulations (Electronic Logging Devices and Other Amendments). Canada Gazette. Part 1: Vol. 151, No. 50 — December 16, 2017. Click here to access the official source.

II. CCMTA ELD Working Group and B. Vincent. (2017 May). Technical Standard for Electronic Logging. Canadian Council of Motor Transport Administrators. Click here to access the official source.

About the Author: Marc Moncion

Marc Moncion

Marc is the Head of Safety, Compliance & Regulatory Affairs for Fleet Complete. Marc is an author and industry subject matter expert that has worked in numerous senior transportation management roles for over 25 years, including an Inspector for the MTO. Marc sits on several Federal/State/Provincial regulatory bodies, and frequently provides commentary on emerging technology, best practices and regulatory affairs. In addition, Marc is a commercial driver’s licence (CLD) holder, and can drive all types of commercial vehicles in North America.