Regulatory Affairs
February 1, 2018

Opportunity for Waiver – Ontario Hours of Service

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The Canadian Propane Association (CPA) has been working with the federal and provincial governments during this period of extreme weather conditions on the possibility of obtaining a waiver to the Hours of Service regulation (Ontario Regulation 555/06) for member companies that may require one. Propane delivery in parts of Ontario has bottlenecked due to a recent period of extreme cold weather combined with treacherous driving conditions, road closures, and trains running with smaller loads that are causing backlogs.

The CPA met with Jim Kirchner from the MTO who confirmed that Section 3.4 and 3.4.1 can be referenced for carriers to request a limited time waiver from Ontario Regulation 555/06: Hours of Service. For a waiver from the regulations for a brief period to address the backlog, each carrier must send a letter of request to the Deputy Registrar of Motor Vehicles, Sean Doussett. The CPA has prepared a template letter as a guide  for members that wish to apply for a waiver. The carrier must put forward a solid rationale for requesting a waiver, including:

  • why the waiver is necessary;
  • the risk of not issuing a waiver;
  • what other measures the carrier has tried to alleviate the situation within the current Hours of Service parameters;
  • how they will mitigate the safety risks taken on by extending hours;
  • the specific time frames (from January X to February X); and
  • the geographic locations where the waiver is needed.

This letter is to be addressed to the Deputy Registrar of Motor Vehicles, Sean Doussett. It can be emailed through Jim Kirchner at or sent by mail to:

Sean Doussett
Deputy Registrar of Motor Vehicles
Ontario Ministry of Transportation
3rd Floor, 301 St. Paul
St. Catharines, Ontario, L2R 7R4


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