The Canadian electronic logging device mandate's similarities the U.S. ELD rule are on the order of about 75%-80%, said Scott Stofer, director of product development for the Orbcomm company. One big part of that difference is that Canadian regulators elected to wrap up Canada's hours of service rules (which vary a bit from U.S. rules) within the same regulation. In the U.S., ELD regs and HOS regs are two different rules that work in tandem.
Stofer, speaking to an online audience for a Truckload Carriers Association webinar held February 12, pointed out a significant difference where the rubber meets the road -- what operators and carriers should be ready to experience when it comes to roadside log checks.
Unlike in the U.S., come June 12 in Canada, the currently scheduled date for enforcement of the mandate, there will be no central software analogous to the U.S. eRODS system for analyzing electronic logs. "In Canada, ELDs will have a 'CSV' file," Stofer said, referring to the output file type that, in the U.S., is sent to a central system when conducting a web transfer. But, he added, given "there won't be an eRODS-type system available" early on, ELDs in Canada are being required to generate a static PDF as well, or the electronic equivalent of a piece of paper, showing the graph grid and other data.
The Canadian ELD rule only required a single method of transfer to roadside, too -- email. Unlike the central email that many U.S. drivers send to for web transfers, which then allows a roadside officer to pull the log from eRODS with analysis, though, "the driver will be required to enter an email address specified by the inspector," Stofer said. That's a significant difference from how most U.S. drivers experience email-initiated transfer today.
It's important for operators to be aware of this difference when the Canadian mandate goes live, Stofer emphasized. No "soft enforcement" period, unlike what happened in the U.S., is expected in Canada.
"In the last couple years we experienced some issues with training around email transfer," Stofer said. "What we ran into [was] inspectors would stop a driver and try to a get the driver to transfer to their own email," previously common under the prior AOBRD standard. "It caused confusion at roadside. It’s improved drastically now – I've only seen one [such instance] in the last six months or so."
Yard Moves, an on-duty, not-driving status in both the U.S. and Canadian rules, also will differ significantly in Canada in that at 32 kph, about 20 mph, ELDs are required to automatically switch the operator to the drive line, Stofer emphasized along with a variety of other differences Overdrive noted in prior reporting.
Perhaps the biggest of those differences, Stofer pointed out, has to do with the process for certifying ELDs themselves -- a single third-party certification body, affiliated with a U.S. company that did voluntary certifications for ELD providers in the U.S., is currently approved by Canadian regulators. As reported earlier in the week, there is still no approved ELD on Canada's registry for devices, with just five months left before the deadline.
That leaves both Canadian and cross-border U.S. carriers with plenty legwork to do to ensure their own compliance. Despite the efforts of advocates like Mike Millian of the Canadian Private Motor Truck Council, among others, regulators at Transport Canada have as of yet shown no willingness to delay the enforcement date, Stofer said.
Millian, speaking in January, noted his group favored "a six to twelve-month enforcement delay [to be] announced by Transport Canada, and we want it announced soon. Carriers will not be able to pick the device of their choice otherwise. What if the device they purchase is not certified and they have to remove it in June? ... Do the proper thing, do the right thing. It’s not going to be Armageddon if we have a six to twelve-month delay," which could come in the form of an announced enforcement deferral, he said.
Stofer focused things more practically, given where the deck is stacked currently, presenting an uncertain situation for U.S. carriers. While there are upward of 300 providers of more than 600 ELDs self-certified on the Federal Motor Carrier Safety Administration's ELD registry, he cited estimates made by a major Canadian trucking association that just between 5 and 20 percent of those providers will look to certify in Canada. "I will say, third-party certification is a good thing, [as it] ensures that everybody’s protected – your investment, safety and compliance are protected." Given the relatively small number of certifications expected, carriers are asking, "Will my provider be one to go?"
Major providers, it's likely, are moving in that direction now, as is Orbcomm, Stofer said, but you can't know unless you ask. "We have to expect [the mandate] will be here on [June] 12th and we’re going to plan for it," he said.
He recommended carriers of all shapes and sizes do so, too, by putting these questions to their providers.
Will the provider attempt Canadian certification?
Of the 360-plus providers in the U.S., "will yours be one fo the 15-45" to certify in Canada?" he asked. "Get with the provider and have that discussion."
When will the provider attempt certification?
Estimates from the third-party certifying body have been that it takes around six weeks for every device certified to go through all of the testing in their process. If certification attempts aren't started in plenty of time ahead of June 12, there's a likelihood cross-border operations could be affected. As Dzmitry Kukharau of the HOS 247 ELD provider put it earlier this week, for this reason, he felt, ""We may be looking at the major cross-border logistics disruptions if the [June 12] deadline is not extended."
How many ELDs does the provider have?
Given a single certifying body, "you have to dig a little bit deeper," Stofer said. In an attempt to be fair to providers, the body is allowing only three devices from any single provider to be certified at one time. "If the provider has six, maybe eight" devices -- he made reference to a couple providers with "up to 17 or 18," even -- "where is your ELD prioritized? Is it one of the first three or the second round? Third round?"
More about Canada's ELD mandate, including how it's expected to treat the pre-2000 model year exemption, and how Canadian 75-km limit on personal conveyance is expected to play out. Readers can keep tabs on Canada's ELD device registry via this link.