I need information about the electronic log mandatory in June 2021.
My vehicles are plated Quebec IRP (IFTA), and I don't drive more than 160km as the crow flies from my starting point.
So, do I have to install an electronic log in each truck even if I go to Ontario?
The Canada ELD mandate that comes into effect on June 12th, 2021 is a federal rule governed by SOR/2005-313.
As you alluded to in your question, although you do not travel outside the 160 kilometre radius, you travel extra provincially from Quebec to Ontario, which means that you are an extra provincial carrier governed by the federal rules.
Therefore, when traveling within the 160 kilometre radius of your principal place of business, your drivers are exempt from the requirement to provide a record duty status such as a paper log or electronic logging device to a safety official at roadside upon request.
SOR/2005-313 does not exempt you under section 81 from the requirement to have accurate records for all of your drivers that operate commercial vehicles on your behalf.
Compliance with the above requirement will then be confirmed if your fleet is ever subject to a facility audit.
If a facility audit ever occurs, one of the first questions the auditor will ask is the scope of your operations. Specifically, if you make the statement that you move goods in a commercial vehicle outside the province of Quebec to Ontario or to the United States, the auditor will inform you that you must comply with the Canada ELD mandate since you are deemed to be a federally regulated motor carrier.
Also, to highlight, Transport Canada recently announced a 12-month enforcement educational period. Check out this blog that offers more details on what this announcement means to you as a motor carrier in Canada.
The above information is for informational purposes only, and should in no way be relied upon as legal advice.
Mar 19, 2021 Marc Moncion