Our Two Cents

Canadian Standard for ELD Use and Proposed Amendment to Federal Hours of Service

OBAC is currently involved in the process of reviewing and preparing comments on the Canadian standard for ELD use as well as a proposed amendment to federal Hours of Service. If you are interested in being involved in this process as part of the OBAC team, please review the following documents and contact us at info@obac.ca.


1. Draft Canadian Standard for ELD Use


The final U.S. rule on Electronic Logging Devices (ELDs) released in December 2015 by FMCSA will become mandatory for all carriers, Canadian and American, operating in the U.S. as of December 18, 2017.  


Also in 2015, Transport Canada announced it would mandate ELDs for all federal carriers operating extra-provincially.


A Working Group of the Canadian Council of Motor Transport Administrators (CCMTA) was tasked with reviewing the draft Canadian standard for ELD use (originally prepared in a 2013) to ensure that it is aligned with the final U.S. rule for interoperability purposes.


The first iteration of changes is now complete and the Working Group is seeking OBAC’s input to the proposed changes.


Click here for a brief summary of the Working Group’s approach and methodology. A comprehensive working document that is a side-by-side comparison of the final U.S. rule and the proposed Canadian ELD standard is also available. If you wish to be part of the OBAC team reviewing the document and providing feedback, please contact us at info@obac.ca


2. Proposed Amendment to Federal Hours of Service


Transport Canada is proposing to amend the federal Hours of Service (HOS) regulations to require the use of ELDs by federally-regulated motor carriers and commercial vehicle drivers to electronically track HOS and demonstrate compliance with the regulations.


The department is seeking comments from interested stakeholders as per this notice, specifically on the six questions within the consultation document.


Please note that this is not the formal regulatory consultation (Canada Gazette Part 1) required by the Treasury Board Secretariat, rather a pre-consultation exercise intended to inform the formal process. Details to submit comments directly to Transport Canada are contained within the document OR you can submit your comments to info@obac.ca no later than September 10, 2016 for inclusion in OBAC’s response.


3. Cost-Benefit Analysis (CBA) for Electronic Logging Devices (ELDs)


Click here to see the updated Cost-Benefit Analysis (CBA) for Electronic Logging Devices (ELDs) for commercial drivers prepared by Transport Canada.


The original analysis was completed in the summer of 2015 and subsequently updated pursuant to the issuance of the final U.S. ELD rule. As such, it now outlines two outcomes: (1) an initial analysis accounting for all Canadian-domiciled federally-regulated logbook drivers (including those operating into the U.S.), and (2) federally-regulated logbook drivers that operate exclusively within Canada.


These outcomes are both presented since the proposed U.S. compliance date for ELDs is December 2017 while the exact compliance date for the Canadian federal ELD regulatory proposal has not been established.


In addition, an addendum is included for comparative purposes with a cost-benefit statement associated with a 1-year implementation timeframe.


As this document is being shared for information purposes and is not part of the formal regulatory process that will follow, any comments received will be taken into consideration but responses will not be issued.