On June 12, 2021, the electronic logging device (ELD) mandate went into effect in Canada. Similar to its U.S. counterpart, the regulation is aimed at helping reduce fatigue-related accidents and making it more difficult for fleets to operate without complying with Hours of Service (HOS) regulations.
At Trimble, we actively work with our customers to transition to ELDs and submitted our product for certification ahead of the June 12 deadline. But, just as was the case with the U.S. ELD mandate in 2019, making a successful move to ELDs is more than just flipping a switch.
They say that knowledge is power and whether you are already operating on ELDs today or don’t even know where to begin, here are a few points about the mandate that will be important for your fleet to consider:
Who Is Required to Migrate?
Much like the U.S. ELD mandate, the Canadian regulation has criteria for what types of fleets need to migrate to ELDs to remain compliant. More specifically, fleets that are subject to this regulation include those with:
Vehicles operating outside a radius of less than 160 km from their home base of operations (same as today)
Vehicles that are model year 2000 or newer
Lease or rental agreements of more than 30 days
Fleets are also required to comply with this new rule if they do not have any existing HOS permits/exemptions pertaining specifically to oil fields and certain other regimes operating outside the standard.
How Are ELD Vendors Certified?
In the U.S., the Federal Motor Carrier Safety Administration followed a self-certification process for third-party ELD providers to register and certify their devices. The Canadian mandate works differently, with Transport Canada partnering with Standards Council of Canada (SCC) to identify certification bodies (CBs) that will certify all ELDs for their use.
As part of this process, Transport Canada created an Electronic Logging Device Certification Stakeholder Advisory Committee to work with the Standards Council of Canada. According to Transport Canada, this committee is focused on:
maintaining an open and transparent process
informing the certification scheme as it's being developed and put in place
acting as a forum for stakeholders such as device providers, accredited certification bodies, the Standards Council of Canada, and Transport Canada
discussing and solving issues related to testing and certification
As noted above, we engaged in the certification process ahead of the June 2021 deadline.
Key Considerations in Migrating to ELDs
As noted above, transitioning from either paper logbooks or from Automatic Onboard Recording Devices (AOBRDs) involves more than just a simple flip of the switch. A change of this magnitude is likely to impact workflows throughout your fleet and a successful transition will hinge on how you manage this change for you and your employees.
Fortunately, developing a roadmap to ELD compliance can empower you to get all parts of your fleet prepared for this change before you roll out ELDs across your driver base. Four key areas to focus on include:
1. Training Your Drivers and Back Office Personnel
While ELD training is not required by the Canadian mandate, teaching your fleet’s personnel about this new technology is an important part of ensuring their success, not only for their productivity but for your continued compliance.
For drivers, this means understanding the look and feel of the device’s user interface, including how to perform key functions like logging in and out and how to change duty statuses. Drivers should also be aware of how special driving categories like Personal Conveyance (more on that below) may or may not apply to them.
It is also crucial to educate back office personnel on the change to ELDs. This includes getting a feel for the back office ELD software, including how to view driver HOS data and generate reports. Safety and compliance teams should also be aware of how to edit and annotate a driver’s record if a mistake is made in their ELD record.
2. Updating Company Policies and Procedures
Reviewing any existing company policies and procedures is a crucial part of the ELD migration process. Some key safety and compliance-related procedures to examine include:
Use of trucks by drivers while off-duty: While professional drivers operating their trucks for personal reasons is nothing new, does your company have a policy related to this off-duty use? If so, should it be updated?
Unassigned driving time: This concept pertains to any truck movement an ELD may capture while no one is logged in. Each of these events must be reviewed by the driver and, if rejected, must be reviewed by carrier staff. Do you have a policy and procedure on how this review process will work? Do you have policies to limit the frequency of these unassigned driving events?
Editing ELD records: With any digital technology, typos or other errors can occur and the ELD rules allow both drivers and carriers to make any necessary corrections to a record. Do you have a policy in place around making these corrections and how quickly they should be made?
ELD malfunctions: ELDs are computers and computers can occasionally not work properly. In these cases, drivers are required to notify a carrier of any malfunctions in writing within 24 hours. Drivers can operate on paper records during this time, with the rules requiring that malfunctioning ELDs be fixed or replaced within eight days. Do you have a procedure in place to cover these new requirements? Have you considered compiling a “safety stock” of devices for more rapid replacement of any malfunctioning equipment?
Keeping some of these procedural aspects in mind can help you prepare even before installing a single ELD in your fleet.
3. Understanding the Personal Conveyance Duty Status
As mentioned above, the ELD regulation allows for personal use (personal conveyance or PC) of a company truck while a driver is off duty. If this is a practice your fleet utilizes, it is important to note how this special driving category fits into the ELD rules.
In most cases, the ELD software will include a functioning PC soft button on the display. When drivers use the PC category, they must change their duty status from “Off Duty” to “PC”. Once the truck starts moving, the ELD will automatically place this off-duty driving time on line 1 of the ELD record, as opposed to the line 3 driving line.
When a driver is finished using the truck for PC, they must deselect “PC” by once again pressing the soft button on the display.
4. Navigating Enforcement Procedures
It is critical that you and your drivers also know how this new regulation will be enforced, particularly during roadside inspections.
For State and Canadian Provincial enforcement, the Commercial Vehicle Safety Alliance (CVSA), an organization dedicated to improving the uniformity of roadside inspection and enforcement efforts throughout North America, added ELD-related information to its North American Out-of-Service (OOS) Criteria, which details the pass/fail criteria for all vehicle inspections.
By taking a look at this documentation, you and your drivers can get a better sense of how to potentially avoid violations or defects that could result in you being placed out of service.
How Trimble Can Help You Transition to ELDs
We recognize that a transition to a compliant ELD platform can be a challenge, but by keeping in mind some of the key points above, you can help ensure a smooth transition for your fleet.
Whether your fleet is operating on ELDs in the U.S. today or is looking to make the switch ahead of schedule, Trimble is committed to compliance with the Canadian ELD standard in advance of the upcoming deadline.
Do you have additional questions about ELDs and how Trimble can help you maintain compliance? Contact us today to learn more about our ELD solution and how we can help you migrate to ensure continued compliance and safety in the months and years ahead.