Recently Canada’s Transport Minister, the Honourable Lisa Raitt, came out in the press of being in favour of Electronic Logging Devices. The PMTC has responded, and is also in favour of the concept of ELD’s, with the assurance that certain safeguards and standards are in place.
The PMTC and its members are of the view that paper logs are an old and out dated way of tracking driving hours in today’s day and 
times. We also acknowledge that logging in this manner allows a driver and operator an opportunity to more easily falsify their records, and consequently this may allow unscrupulous operators to extend their day beyond the legal limits of the Hours of service rules. While ELD’s will never completely eliminate abuse of Hours of Service Regulations, their implementation will make it easier to verify compliance, and make it much less likely that an operator will be able to skirt the rules. In our view, a mandated ELD requirement, properly implemented and enforced, will level the playing field for all CMV operators, and will help to remove unsafe and non-compliant operators from the road ways. While PMTC does support the concept of mandatory ELD implementation, a number of key issues must be addressed and covered off in any mandated requirement
US-Canada Harmonization
As the economy of the two countries are undeniably linked, and many operations operate on both sides of the border, we must ensure our two countries work together and ensure ELD’s are mandated and harmonized across our two great nations. We must ensure the ELD regulations in both countries closely mirror each other, and we need to ensure that the same technology and systems will be legal to operate on both sides, as having to purchase two separate systems would be too onerous, and unrealistic.
Privacy and Enforcement
We need to ensure enforcement across the two countries is consistent. If officers in some jurisdictions refuse to accept the e-log technology, and require logs to be reproduced on paper, the gains and efficiencies intended by the policy will not be fully recognized, and will lead to significant frustration by drivers and operators alike. Officers in all jurisdictions must be fully educated on the systems and the regulations, and it must be clearly understood what their requirements are when enforcing the policies for ELD usage.
We must also ensure that ELD’s are used solely for the purpose of gathering Hours of service compliance. Privacy of personal and competitive information must be protected.
Costs-Grandfather-Phase in period
There will be an undeniable cost associated with ELD’s. We need to ensure that any implementation policy has a reasonable phase in, grandfather period, to allow companies and owner operator’s time to research and install the proper system for them. PMTC suggests a 2 to 3 year period. We believe incentives should be provided to help reduce the financial burden to installing the systems, in the form of tax grants, rebates or credits. As many carriers have already installed the systems in the past, a rebate of some sort should be offered to companies who can verify the costs they have already invested to voluntarily go to ELD’s prior to the regulations.
In the long term, we do believe a payback period will be realized through increased compliance, better utilization of driver hours, and a reduction in the driver’s time required to complete their logs, however these up-front costs still need to be taken into consideration in any implementation policy.
Technology
Many carriers have already invested in ELD’s, and many suppliers have robust platforms already that should be investigated to ensure that existing technologies will comply with the ELD regulations, (we acknowledge a great deal of this leg work has already been completed) thus avoiding companies that have already made a significant investment having to replace or upgrade systems currently in use. If existing technologies need to be replaced or upgraded, the same 2 or 3 year grandfather period should be used for the phase in period, as well as incentives to perform the upgrade, similar to what is being suggested earlier in this document in the costs statement.
In closing, the PMTC is in favour of the concept of mandatory ELD’s, however we must ensure the regulations are harmonized across
Canada and the US, and the areas of concern raised in this letter are captured and addressed
About the Author
“Mike has 25 years’ of wide ranging experience in the trucking industry, performing such duties as a livestock and grain hauler for 3
years, followed by 5 years of long haul across North America hauling refrigerated and general freight. Mike was also a full time certified driver trainer for 2 years, and then transitioned into Safety and Compliance for 2 years, and then spent over 12 years as a Fleet manager for a Private Fleet. Mike is now the President of the Private Motor Truck Council of Canada, Canada’s only National Association that represents the views and interest of today’s Private Fleets.” Mike can be reached at trucks@pmtc.ca
