Marc Moncion, our Vice President of Safety, Compliance & Regulatory Affairs, was invited by Chris Harris from Safety Dawg Inc. to his podcast to discuss Fleet Complete’s successful ELD certification with Transport Canada – as well as iron out some finer details of the mandate itself.
This is Marc’s second appearance on the podcast, discussing the Canadian ELD mandate that is coming into full enforcement in the summer of 2022.
If you’re driving or walking and would like to listen to the full podcast, please click on the YouTube link that you see appear here. Otherwise, you can read the transcribed interview below.
Chris Harris: Congratulations on being approved.
Marc Moncion: Thank you very much for your very kind words, Chris.
Everyone on the Fleet Complete team is elated that our BigRoad ELD device is now certified according to the Canadian Council of Motor Transport Administrators’ technical requirements.
Fleet Complete now has the responsibility to compliantly service the Canadian transportation marketplace.
I am very proud to say that our BigRoad ELD device is also posted on Transport Canada's list of certified ELD Vendors.
Go have a look when you have a chance!
This represents a long collaborative effort with FPInnovations to go through the entire ELD Certification process from start to finish.
CH: How did the process go?
MM: From the time that Marc Garneau, Canada’s Minister of Transport, said on June 13, 2019, that Canada was mandating the use of ELDs by federally regulated commercial truck and bus operators, Fleet Complete was – all systems go!
The original implementation period was supposed to be 24-month; therefore, enforcement would come into force on June 12, 2021.
The amendment to the Commercial Vehicle Drivers Hours of Service Regulations (Electronic Logging Devices and Other Amendments) SOR/2019-165 would replace paper-based daily logbooks in Canada, unless otherwise exempt.
As you know, the ELD requirements were built on the regulatory proposal that was published in Canada Gazette, Part I on Dec. 16, 2017.
CH: What was different this time around with Canada ELD compared to what you experienced with ELD on the U.S. side?
MM: What was the unique with this ‘Made in Canada’ approach was the requirement for ELDs to be third-party certified.
This was quite different than the self-certification model in the U.S.
After it was announced in October 2020 that FPInnovations was approved as an Accredited/Certifying body, it was all-hands-on-deck at Fleet Complete.
Since FPInnovations was the only one at the time, it became a first-come, first-serve process for all ELD vendors.
Fleet Complete and other ELD vendors likely submitted their ELD Certification Application Form to FPInnovations at around the same time to get the process underway.
I say that because none of the ELD vendors were privy to who was where in the priority queue.
This was privileged and confidential information to FPInnovations.
So, it essentially became a hurry-up-and-wait scenario period for all.
CH: Were there any unexpected challenges on the regulatory side of things?
MM: Funny you mention that, Chris.
At around the same time FPInnovations was announced, the Canadian Council of Motor Transport administrators amended the Canadian Technical Standards for ELD, based on discussions with the ELD Working Group, which I was a member of.
This kind of caught everyone off guard including Fleet Complete, because it was announced with little fanfare by Transport Canada.
The end result was that FPInnovations had to retool their audit protocol.
Most, if not all ELD vendors including Fleet Complete, also had to go back to the drawing to a certain degree to ensure that our rules engine remained compliant with the amended Technical Standards.
In the case of Fleet Complete, we had to tweak some of our requirements, which slowed our application process down.
CH: So you get that done. What happened next?
MM: We then had our kickoff meeting with the FPInnovations leadership team to understand how the certification process would unfold after we signed our ELD Certification Agreement.
We then sent our entire package of collateral to them.
This included 4 samples of all of the devices, hardware, connectors, and any other peripherals, etc.
We also assigned technical personnel at Fleet Complete to verify that the ELDs that would be tested were properly installed on for the Bench and Vehicle Testing.
FPInnovations staff were also given full access to our web portal, and we created user accounts and passwords for their evaluation of the ELD.
Essentially, FPInnovations were replicating being a new driver operating a CMV, but in a lab, and a road test with a CMV.
We also sent pictures and screenshots of our ELD, along with an English & French user's manual, describing how to operate the ELD.
We also had to describe all the supported data transfer mechanisms and step-by-step instructions for a driver to transfer ELD records to an authorized safety official at roadside and during a Facility Audit.
CH: How is this different between the two countries?
MM: As you know this process was different then the U.S.
In the U.S., they use a Data Transfer Protocol, where in Canada, we simply had to send a PDF of the logs for the day in question and the previous 14 days to a Safety Official.
Finally, we sent a summary description of ELD diagnostics and malfunctions and alerts.
The last item is a very important item since we had to send our total fee for the testing and certification before anything would get underway.
After this milestone was complete, we had a series of ongoing meetings with the FPI Tech Leads to go through the 10 functional areas of the Technical Standards.
4.1. ELD User Accounts
4.2. ELD-Vehicle Interface
4.3. ELD Inputs
4.4. ELD Processing and Calculations
4.5. ELD Recording
4.6. ELD’s Self-Monitoring of Required Functions
4.7. Special Purpose ELD Functions
4.8. ELD Outputs
4.9. Data Transfer Capability Requirements
4.10. Communications Standards for the Transmittal of Data Files from ELDs
CH: Any further hiccups along the way?
MM: As was likely the case with other ELD vendors, we did have a few alleged non-conformance issues in some of the test requirements.
These we either explained to FPI or were corrected to meet the Technical Requirements.
All this took place in an environment where multiple ELD vendors were concurrently being tested by FPI, until two additional ELD vendors were added to the Accredited and Certified to the test ELD devices.
CH: I imagine Fleet Complete must have started getting a little nervous, as we were getting closer to the June 12, 2021, enforcement date?
MM: For sure.
It was only when Transport Canada realized that there would be no ELD vendors certified by the June 12, 2021, enforcement date, and they announced on Mar 02, 2021, a new Canada ELD timeline, based on 12-Month ELD Progressive Educational Enforcement, effective June 12, 2022.
You can say that there was a collective sigh of relief, not only with motor carriers, ELD vendors, but drivers, Safety Inspectors and others.
The entire ELD certification start to finish was supposed to take approximately 6 weeks from start to finish.
Well, you know the Law of Supply and Demand.
In this case, too much Demand and not enough Supply, so here we are some 1.5 years later.
Not laying blame on any specific party, but the reality is that we are all against the clock, so very ecstatic that we are now Certified.
CH: What is next now that Fleet Complete is certified as a Canada ELD Vendor?
MM: We are posted on Transport Canada’s List of Certified Electronic Logging Device (ELD) Vendors.
We now market our BigRoad device as ELD Compliant in Canada.
What many stakeholders may not know is that all ELD vendors, including Fleet Complete, will have to maintain our ELD Certification through annual surveillance of the ELD.
These ELD certification scheme surveillance activities include re-testing a minimum of 25% of the test procedures on each device annually, with no repeat tests over the course of a 4-year period.
These surveillance activities for the certified ELDs are conducted by FPInnovations under a separate agreement – and, of course, at an extra cost.
So, this may be why some ELD vendors have made a conscious decision to not service the Canadian marketplace.
Too much time, money, and renewal costs, as well as association administration to maintain the ongoing certification.
At Fleet Complete, we’re are all in.
Ready, willing, and able to service the industry going forward – and for years to come.
CH: How will this affect North-South Movement of Goods across borders?
MM: As you likely know, for North-South motor carriers going to the U.S., Fleet Complete is on the AT&T 3G platform.
This technology on 3G will then be sunset on February 22, 2022.
Canadian telecom providers have issued a delayed approach to the 3G sunset, allowing more time for Fleet Complete to make the transition.
The listed dates that are being rumoured in the market is December 2025, however, Canadian telecom providers are hinting the shutdown may happen earlier.
What motor carries in Canada have to keep in mind, if your vehicles travel across the Canadian and U.S. border, you’ll need to follow the U.S. 3G sunset dates to ensure your devices can communicate.
We at Fleet Complete are all over the 3G migration, and there should be no transition issues with our clients and data providers.
The next big milestone afterwards is the full ELD enforcement date in June 2022.
I hope that motor carrier don’t follow the U.S. experience, where many waited until the last minute.
If that happens again, there will be significant challenges to meet the demand, especially if the availability of microchips doesn’t improve.
Unlike in the U.S., there will be no AOBRD Grandfather Clause to buffer to a later date.
Therefore, unless Transport Canada announces a change of date, June 12, 2022, is the firm enforcement date.
CH: Anything you want to share with our audience as a best practice going forward?
MM: For motor carriers, if you don’t have a plan in place to deploy ELD in your fleets – the clock is definitely ticking.
Please don’t wait till the last minute to order your ELD devices; get them installed, train all your staff, pay particular love and attention to your drivers.
If you wait till the last-minute scramble to get ahead of the ELD queue, you may meet a perfect storm to meet the deadline.
Look, I was there back when the U.S. ELD mandate was proclaimed with the Grandfather Clause.
It was all hands-on deck 24/7 trying to get the devices installed before the Witching Hour.
So, let’s not make the same mistake again in Canada.
CH: What about motor carriers that have ELDs deployed in Canada?
MM: For motor carriers that are already aligned with an ELD vendor, say like Fleet Complete’s BigRoad ELD solution, it is just a matter of enabling your current devices to meet the Canada ELD requirements while in Canada.
What I expect will be an eye opener is if a motor carrier is deploying an ELD from a U.S. or Canadian vendor, who has not been or have no intention to be ELD-compliant in Canada.
That will become someone’s real problem, as they will simply not be compliant in Canada.
CH: Why should a trucking company choose Fleet Complete?
MM: Trusted, mature brand. A Canadian-born company with global span.
Multi-language support 365/24/7.
Professional, courteous, knowledgeable staff.
We have Ask The Expert section on our website for tailored assistance, or if an issue occurs with a regulator.
Being an industry leader in GPS Tracking and Fleet Management solutions, means we can provide the technology along with support and solutions to an ever-changing industry.
We are on a mission to bring transformative solutions to any fleet-owning business – big or small.
We strive to provide the best-in-class customer service.
We focus on challenges our customers face every day to give them access to a connected mobility platform that suits their needs best.
Whether it’s vehicles, mobile workers, cargo, stationary assets, or all of the above, we help you connect to it all.
This is why we continue to innovate in the field, and not just ELD.
Our goal is to develop meaningful partnerships with mobile carriers, original equipment manufacturers (OEMs), and third-party integrations for optimal user experience.
CH: How ca we get more info on Fleet Complete?
You can also visit our www.bigroad.com webpage.
You can contact any one of our Regional Sales Managers at the location where you operate Commercial Vehicles.
You can also reach out to me and leave a message at Ask the Expert.
The above information is for informational purposes only, and should in no way be relied upon as legal advice.
Dec 21, 2021 Marc Moncion