Regulatory Affairs
December 21, 2017

Proposed Amendments Mandate Use of Electronic Logging Devices

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On December 16, 2017, Regulations Amending the Commercial Vehicle Drivers Hours of Service Regulations (Electronic Logging Devices and Other Amendments) were published in the Part I of the Canada Gazette.

Issues: The current Commercial Vehicle Drivers Hours of Service Regulations (the Regulations) require drivers of commercial buses and trucks to self-report their on-duty time, off-duty time and driving time in a paper-based daily log, and also permit the use of an electronic recording device (ERD). An ERD is a first-generation device that is subject to few technical specifications. The information generated from these daily logs can be falsified, incomplete, duplicated or missing altogether in an effort to avoid accountability for non-compliance with the Regulations. It can be difficult and frequently impossible for roadside enforcement or the motor carrier to detect non-compliance by the driver simply by viewing the daily logs. Non-compliance with hours of service requirements by a motor carrier or driver can significantly increase crash risk and provide the non-compliant operator with a competitive advantage over those motor carriers that comply with the Regulations.

Description: The proposed amendments would, in alignment with U.S. requirements, mandate the use of electronic logging devices (ELDs), by drivers who are currently maintaining a daily log and establish more specific requirements for supporting documents (e.g., bills of lading) that must be kept by the driver and motor carrier. The proposed amendments would also incorporate by reference a technical standard to establish minimum performance and design specifications for ELDs. Other incidental amendments are being proposed to improve conformity with legal drafting standards and to harmonize the Regulations with updates that have been made to Standard 9 — Hours of Service of the National Safety Code for Motor Carriers.

Comments on the proposed regulations must be submitted, in writing, by January 8 and cite the Canada Gazette, Part I, the date of publication of this notice (December 16, 2017), and be addressed to Andrew Spoerri, Senior Research Analyst, Motor Vehicle Safety Directorate, Department of Transport, 330 Sparks Street, 9th Floor, Ottawa, Ontario K1A 0N5 (email:

The CPA would also like to receive a copy of your comments. Please send them to Melanie Levac, CPA’s Vice-President, Regulatory Affairs and Safety, at


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