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Canadian ELD Mandate

As the ELD Mandate came into effect in the United States on December 18th, 2017, the Canadian government published its proposal to make the use of electronic logging devices (ELDs) mandatory. ELDs help carriers and drivers comply with Commercial Vehicle Driver Hours of Service Regulations thereby lessening the negative impacts of non-compliance. According to Transport Canada, in addition to improving road safety, regulations will save carriers time and money associated with the administrative burden of paper logs.

Impacts on operations

Using ELDs offer many advantages. However, implementing such technology will require a transition period. “Beyond choosing a compliant solution, carriers will have to revise their operational processes. Whether for administrative personnel, dispatchers, or compliance officers, day-to-day work methods will be revised to adapt to this new reality,” stated engineer Benoit Vincent, who worked as a consultant on the development of the Canadian standard.

Training will be crucial during the transition to ensure that everyone uses the technology to its full potential, and to optimize productivity and performance. Guidance and support during the deployment of a solution will be key considerations when choosing an ELD provider. Day-to-day technical support for solution users will also be part of the equation.

Differences between Canada and the United States

In developing its regulations, Transport Canada took American regulations into account. To minimize repercussions for Canadian cross-border operators, ELD requirements were for the most part aligned with those of the United States. Such alignment will ease operations and avoid posing a hindrance to trade. Carriers will be able to use a single solution in both countries and remain compliant.

Nonetheless, there are some distinctions between Canadian and American regulations. According to Vincent, the main differences are as follows:

  • In accordance with hours of service regulations, ELDs must enable carriers operating in Canada to keep information logged for the current day and the preceding 14 days, while the American requirement calls for 7 days.

  • Based on the technical specifications of Canadian regulations, ELDs must enable calculations for driving timetable scheduling both north and south of the 60th parallel north.

  • To meet Canadian hours of service regulation requirements, ELDs must also allow for cycle management, changes in jurisdiction, and off-duty time deferral.

  • During roadside inspections, ELDs must make it possible for drivers to provide reports in PDF format, either by email, fax, or with a USB drive. Data files will not be validated, like is the case in the United States by the FMCSA.

Next steps

Industry members have 60 days starting on the proposal’s publication date in the Canada Gazette, on December 16th, 2017, to submit comments in writing directly to Andrew Spoerri, Senior Research Analyst for Transport Canada.

Suggestions and concerns will then be studied and regulations amended if necessary. New regulations on the mandatory use of ELDs will come into effect one or two years after the date of publication in Part II of the Canada Gazette. The enforcement date will depend on the duration of the transition period of either one or two years.

2018 Unified Carrier Registration

Today the federal government released the reduced 2018 registration year fees for the Unified Carrier Registration Plan (UCR). The Federal Motor Carrier Safety Administration (FMCSA), which has oversight of UCR, published the final rulemaking (https://www.fmcsa.dot.gov/newsroom/fees-unified-carrier-registration-plan-and-agreement). The new fees, set forth below, go into effect immediately.

 

UCR registrants (i.e. interstate motor carriers, freight forwarders, and brokers) that register for UCR through the national UCR online registration system administered by the Indiana Department of Revenue should be able to register for the 2018 registration year later today. The Indiana website, which UCR registrants based in any state may use to register, is: www.ucr.in.gov. On the other hand, UCR registrants that register through one of the state run UCR systems may have to wait a few more days before the state system is ready to process the 2018 registration. UCR registrants registering through one of the state run UCR systems should consider checking with the state administrator to confirm when that state’s UCR system will be ready to process 2018 registrations.

 

Because the 2018 registration was delayed several months, the UCR Board is requesting that states delay enforcement for 90 days after the fees go into effect; that is, until April 5, 2018. That said, there is no guarantee that state enforcement officers will adhere to this request and as such UCR registrants may want to consider promptly submitting their 2018 registration to avoid any UCR enforcement issues arising.

 

2018 UCR Registration Year – Fees

 

Bracket Fleet Size Annual Fee
1 0-2 $69
2 3-5 $206
3 6-20 $410
4 21-100 $1,431
5 101-1,000 $6,820
6 1,000+ $66,597

 

Interstate brokers and interstate freight forwarders not operating commercial motor vehicles are only required to pay the minimum $69 annual UCR fee.

FMCSA Announces 90 Day ELD Waiver for Ag Haulers

FMCSA grants a limited 90-day waiver from the Federal hours-of-service (HOS) regulations pertaining to electronic logging devices (ELDs) for the transportation of agricultural commodities.   Details are here.  

The exemption expires March 18, 2018.  Carriers who haul agricultural commodities and farm supplies (as defined in 49 CFR 395.1(k)(1) have until that date to implement an ELD.

Carriers must have a satisfactory safety rating, and must carry a copy of the notice in each truck.