Safety Corner

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The Federal Hours of Service Regulation SOR/2005-313, and by default deployment of Electronic Recording Device (ERD) in Canada and eventually an Electronic Recording Device (ELD) when the rule-making is finalized, will likely apply to all extra-provincial motor carriers operating commercial vehicles in Canada.

There may be other exemptions likely available when the final rule-making is proclaimed as described below, but this is what we know so far.

A commercial motor vehicle is defined as a vehicle that:

  1. Is operated by a motor carrier and propelled otherwise than by muscular power; and
  2. Is a truck, tractor, trailer or any combination of them that has a gross vehicle weight in excess of 4,500 kg, or a bus that is designed and constructed to have a designated seating capacity of more than 10 persons, including the driver.


A commercial motor vehicle does not include the following, and by default will likely not require ERD and eventually ELD:

  1. A two or three-axle commercial vehicle being used for
    1. Transporting the primary products of a farm, forest, sea or lake, if the driver or the motor carrier is the producer of the products, or
    2. A return trip after transporting the primary products of a farm, forest, sea or lake, if the vehicle is empty or is transporting products used in the principal operation of a farm, forest, sea or lake;
  2. An emergency vehicle;
  3. A vehicle engaged in providing relief in the case of a public welfare emergency, as that expression is defined in section 5 of the Emergencies Act; and
  4. Exemption in this section was Repealed, SOR/2009-157, s. 1
  5. A commercial vehicle when driven for personal use, if
    1. The vehicle has been unloaded,
    2. Any trailers have been unhitched,
    3. The distance traveled does not exceed 75 km in a day,
    4. The driver has recorded in the logbook the odometer reading at the beginning and end of the personal use, and
    5. The driver is not the subject of an out-of-service declaration under regulation.
  6. The driver operates or is instructed by the motor carrier to operate a commercial vehicle within a radius of 160 km of the home terminal;
    1. The driver returns to the home terminal each day to begin a minimum of 8 consecutive hours of off-duty time;
    2. The motor carrier maintains accurate and legible records showing, for each day, the driver’s duty status and elected cycle, the hour at which each duty status begins and ends and the total number of hours spent in each status and keeps those records for a minimum period of 6 months after the day on which they were recorded; and
    3. The driver is not driving under a permit issued under these Regulations.

Exemptions likely to included in the Canada ELD Rule-making, but awaiting official confirmation when the Canada Gazette Part 2 is published:

  1. If a driver is not currently required to complete an hours of service log (i.e. 160 Km radius as described above).
  1. While operating under a rental agreement of no more than 30-days.
  1. While operating under an exemption permit.
  1. While operating under a statutory exemption.
  1. Commercial motor vehicles that were manufactured before the year 2000.

The above information is for informational purposes only, and should in no way be relied upon as legal advice.

  Jun 03, 2019     Marc Moncion

Ask the expert - Marc Moncion (Safety, compliance and regulatory affairs expert)


Marc Moncion linkedin2

Lead Expert - Fleet Complete

Marc is the Head of Safety, Compliance & Regulatory Affairs at Fleet Complete. He is an author and industry subject matter expert who has worked in numerous senior transportation management roles for over 25 years, including an Inspector for the MTO. Marc sits on several Federal/State/provincial regulatory bodies and frequently provides commentary on emerging technology, best practices and regulatory affairs. In addition, Marc is a commercial driver's licence (CDL) holder and can drive all types of commercial vehicles in North America.

Get to know Marc here!



Ask The Expert - Guy Broderick (Driver trainer)


Guy Broderick linkedin2

Guest Expert - APPS Transport Group

Guy is a Driver Recruiter/Training Supervisor and Social Media Specialist at APPS Transport Group. Certified under the WSIB guidelines and a member of JHSC, Guy is an integral force behind the company's impeccable driving record. The APPS Safety Team has achieved the highest rating of Commercial Vehicle Operator Registration (CVOR) given by the Ministry of Transportation in Ontario. Since 2010, Guy has written for and contributed to numerous publications and associations, as well as has been elected as Chair of Ontario College of Trades Tractor Trailer Driver Trade Board, recently re-elected as Chair for the TTSAO Carrier Group, has sat on numerous provincial industry committees and is a Award Winning Driver recognized on both sides of the border.



Ask The Expert - Brayn Levi Gomez (professional installer)


Brayn Gomez  linkedin2

Guest Expert - Certified Professional Installer

Brayn transformed his passion and hobby of installing multimedia devices and car kits in luxury vehicles into a career in 2004. Since then, Brayn has installed thousands of electronics and GPS systems in a variety of vehicles and machines with or without a power source, even on bicycles. Bryan provides professional installation, re-installation and on-site technical services to Fleet Complete customers. Throughout his career, Brayn has encountered the effects of improper GPS system installation on the integrity of the vehicle and driver's safety, and offers his insights and tips to help ensure fleet managers and technicians are using best practices to install GPS equipment in their vehicles.