Frequently Asked Questions About ELDs in Canada2021-05-20T09:59:42-04:00

Frequently Asked Questions About ELDs in Canada

The following are frequently asked questions concerning different aspects of the Canadian ELD regulation varying from how to be compliant to its everyday use.

Last update: May 20, 2021

Becoming ELD Compliant


As a motor carrier, how can I be sure an electronic logging device (ELD) is compliant?2021-06-07T10:52:21-04:00

Transport Canada will maintain a list of electronic logging devices (ELD) certified by an accredited certification body at the following website: List of certified electronic logging devices (canada.ca)

How can we ensure a successful transition?2021-05-20T09:49:43-04:00

Transitioning to an ELD that complies with the Canadian ELD regulation is a project that varies in scope depending on what you are currently using to log hours of service. Preparing and establishing a well thought out plan as of now is key. Make sure you understand the impact the change will have on your operations and drivers.

Success also lies in having open and regular communication with everyone on your team impacted by this change. You cannot over communicate when you need to manage change.

Reassure your drivers that there are no changes to the basic hours of service regulations. Canadian ELD regulation requirements only change the way the software interacts with the driver.

Training and communications are important parts of your path to success. Plan for training and support for the office staff and drivers. Peer training has often proven successful with drivers.

Are all motor carriers required to comply with the ELD regulation? Do I need to equip all my vehicles with an ELD?2021-05-20T09:49:45-04:00

The federal regulations stipulate that a motor carrier governed by federal regulations shall ensure that each commercial vehicle that it operates is equipped with an ELD that meets the requirements of the Technical Standard. Some exceptions apply. We invite you to consult the federal regulation exceptions to better answer this question.

Make sure to read your provincial regulations as they will also play a role in determining if you are required to become compliant. According to your fleet’s operation, you need to determine if the upcoming Canadian ELD regulation applies to you.

Are there exceptions that exempt a vehicle from being equipped with an ELD that complies with the Canadian ELD regulation?2021-06-09T09:13:23-04:00

There are 4 exceptions allowing a vehicle not to be equipped with a compliant ELD. Exemption is granted for commercial vehicles that are:

  • operated by a motor carrier under a permit issued by Federal, Provincial or Territorial authorities;

  • operated by a motor carrier to which an exemption has been issued under the Act; the commercial motor vehicle is driven within a 160 km radius of home terminal for drivers returning to the home terminal every night (drivers can continue with their simplified log);

  • the subject of a rental agreement of no longer than 30 days that is not an extended or renewed rental of the same vehicle;

  • manufactured before model year 2000.

Outside these exceptions, a motor carrier shall ensure that each commercial vehicle that it operates is equipped with an ELD that meets the requirements of the Technical Standard, and shall ensure that it is mounted in a fixed position during the operation of the commercial vehicle and is visible to the driver when the driver is in the normal driving position.

NOTE: This rule covers exemptions for Canadian ELD regulation compliance but does not exempt in any way the driver from completing a logbook when required.

Do I need to worry about the installation of the ELDs?2021-05-20T09:49:44-04:00

Yes. Motor carriers shall ensure that the ELD is mounted in a fixed position during the operation of the commercial vehicle and is visible to the driver when the driver is in the normal driving position and must not obstruct the driver’s view. The ELD must not be installed over an airbag deployment area or cover any important instruments.

When must we be compliant to the Canadian ELD regulation?2021-05-20T09:49:46-04:00

Transport Canada has announced the effective date of June 12th, 2021, although it recently announced progressive enforcement of regulation. As of May 5th, 2021, the Canadian Council of Motor Transport Administrators (CCMTA) said in a statement: “Jurisdictions plan to support the mandate through a period of progressive enforcement without penalties, including elevated education and awareness.”

The terms of the progressive enforcement will become available as the different authorities publish them. You must be vigilant/alert to a new announcement from the federal and provincial/territorial authorities on this matter as some of them have their own regulations.

Subscribe to our blog to make sure you don’t miss out on changing regulations and news from the transportation industry.

Is my province adopting the same position as Transport Canada?2021-05-20T09:49:46-04:00

Federal authorities have announced a progressive reinforcement of the regulations.

Each provincial authority must now decide the next step for their province.

Note that even if your province does not enforce ELD compliance in June 2021, you must still comply with the rules in effect in all the other provinces you service.

As provincial and federal authorities move towards the end of the progressive implementation, all interprovincial motor carriers will have to comply with ELD regulations. Intra-provincial carriers must refer to their provincial regulations.

Do I need to change any equipment?2021-05-20T09:49:45-04:00

If you are an ISAAC user, you do not need to make any changes to your equipment. The existing ISAAC equipment will remain functional with the over the air software update and when you activate Canadian ELD compliance for your drivers.

Activating ELD compliance for drivers


Which drivers can be exempted from the Canadian ELD regulation?2021-05-20T09:49:47-04:00

You must keep in mind that the rules requiring a driver to maintain a logbook have not changed with the arrival of the Canadian ELD regulation. A driver that was required to complete a logbook before the ELD regulation will now have to complete their logbook on the ELD. Make sure you consult the federal and/or provincial regulation that applies to your company to determine which drivers must complete a logbook.

However, the Canadian ELD regulation stipulates that a motor carrier shall ensure that each commercial vehicle that it operates is equipped with an ELD that meets the requirements of the Technical Standard, with the exception of commercial vehicles that are

  • operated by a motor carrier under a permit: this is meant for specific permits issued by Federal or Provincial authorities

  • operated by a motor carrier to which an exemption has been issued under the Act: 160 km radius from home terminal for drivers returning home every night (drivers can continue with their simplified log)

  • under a rental agreement of no longer than 30 days that is not an extended or renewed rental of the same vehicle

  • manufactured vehicle before model year 2000.

If a driver is not subjected to the Canadian ELD regulation, can they still complete their logs in an electronic logbook?2021-05-20T09:49:47-04:00

With the objective of standardizing and facilitating follow-ups, you could still decide to activate ELD compliance for all your drivers.

Otherwise, you could activate the HoS option without making the driver ELD compliant.

If you activated the ELD option by mistake, you can exempt your driver.

Note that even if you exempt your driver, the following applies: 4.3.3.1.2 d) (2) – The ELD must continue to record ELD driving time but suspend detection of missing data elements.

What happens if a driver starts the day on the 160 km exemption, but needs to go further than the 160 km radius or cannot return to the home terminal?2021-05-20T09:49:47-04:00

It is the carrier and driver’s responsibility to make sure they identify the cases where a driver will not respect the conditions of the 160 km radius from the home terminal exemption. In the case where they did not identify it, the driver will need to use the option below to add the additional hours worked for the current day and in the previous 14 days.

Additional hours – not required to maintain a logbook immediately before the beginning of the day. How does it work?

Option 2 allows drivers to manage additional hours not recorded since they were not required to keep a logbook immediately before the beginning of the day.

Drivers will have the ability to enter the beginning and end of shift as well as the duration of their on-duty time.

My highway driver will become a local driver in 3 months. Will this driver have to remain ELD compliant?2021-05-20T09:49:48-04:00

If the work of a local driver does not require a logbook, the driver can be exempt from ELD compliance in the driver file.

Connecting to the ELD


What documentation must drivers keep in the vehicle?2021-05-20T09:49:48-04:00

The motor carrier shall ensure that each commercial vehicle that it operates carries an ELD information packet containing a current version of the following documents:

(a) a user’s manual;

(b) an instruction sheet for the driver describing the data transfer mechanisms supported by the ELD and the steps required to generate and transfer the data with respect to the driver’s hours of service to an inspector;

(c) an instruction sheet for the driver describing the measures to take if the ELD malfunctions; and

(d) a sufficient number of records of duty status to allow the driver to record the information required under section 82 for at least 15 days.

Behaviour when the driver stops the vehicle


Is there a change in behaviour when drivers stop the vehicle? What happens when they pull the parking brake or stop the vehicle?2021-05-20T09:49:48-04:00

If drivers do not confirm they are no longer driving, an additional 6 minutes of driving could be added to their logbook.

When a vehicle stops after a driving segment, the duty status remains driving and a message appears asking the driver to confirm they have stopped driving and their new duty status. If the driver does not respond and the vehicle has not been in-motion for 5 consecutive minutes, the ELD must prompt the driver to confirm continued driving status or enter the proper duty status. If the driver does not respond to the ELD prompt within 1-minute after receiving the second prompt, the ELD must automatically switch the duty status to on-duty not driving. The time thresholds for purposes of this provision must not be configurable.

Why do we see on-duty time after each driving segment in a driver’s logbook?2021-05-20T09:49:49-04:00

If the driver does not respond to the ELD prompt within 1-minute after receiving the prompt asking him to confirm his status, the ELD must automatically switch the duty status to on-duty not driving.

Driving


Will the ELD record driving as soon as the wheels start turning or is there a speed threshold to reach before driving is activated?2021-05-20T09:49:49-04:00

An ELD must automatically determine whether a vehicle is in motion and the threshold for determination of the in-motion state must not be configurable to greater than 8 km/h.

If there is a speed threshold, can it be set?2021-05-20T09:49:49-04:00

You cannot prevent the ELD from activating the driving when the vehicle exceeds 8km/h because an ELD must automatically determine whether a vehicle is in motion and the threshold for determination of the in-motion state must not be configurable to greater than 8 km/h.

If movements are performed by a commercial vehicle within a terminal, depot or port and that is not on a public road, a driver could use Yard Move. Driver’s duty status will change to on-duty for the duration of the Yard Move activity or until the vehicle exceeds the speed limit threshold of a maximum of 32km/h.

What happens if a driver does not sign in to the ELD before the vehicle is in motion?2021-05-20T09:50:36-04:00

Drivers will receive an alert asking them to stop and log in the ELD as regulation demands that if a driver has not authenticated into the ELD, as soon as the vehicle is in motion, the ELD must provide a visual or visual and audible warning reminding the driver to stop and log into the ELD.

The ELD will generate Non-Authenticated (unassigned) driving that will be assigned to an Unidentified Driver. The carrier must make sure all recorded driving is assigned to its true and correct owner.  If there is unassigned driving recorded on an ELD, the driver will be notified and asked to accept or reject the driving segment.

What should drivers do if asked to move their vehicle while in sleeper berth status?2021-05-20T09:50:37-04:00

Unlike in the U.S. ELD regulation, the Canadian ELD regulation does not allow Personal Conveyance for such a case.

Your driver could use Yard Move if HoS regulations are met which limits Yard Move to movements performed by a commercial vehicle within a terminal, depot or port and that is not on a public road. Driver’s duty status will change from sleeper status to on-duty.

If Yard Move is not activated for the driver, the system will record driving as soon as the vehicle reaches 8 km/h.

Yard Move


Are there limitations to the use of Yard Move?2021-05-20T09:51:05-04:00

HoS Regulations limit Yard Move to movements performed by a vehicle within a terminal, depot or port and that is not on a public road. There is no limit in distance or time allowed in Yard Move but there is a configurable maximum speed limit of 32 km/h which means that if the speed limit is exceeded, the ELD will deactivate Yard Move and automatically record driving.

How do drivers activate / deactivate Yard Move?2021-05-20T09:51:18-04:00

If a carrier allows for Yard Move, an ELD must provide the means for a driver to indicate the beginning and end of a period in Yard Move. The ELD must also require drivers to confirm if they want to remain in Yard Move following a power off cycle. If not confirmed and the vehicle is in motion, the ELD will automatically record driving.

What will the status of the HoS be if a driver activates Yard Move?2021-05-20T09:50:37-04:00

The driver’s log will show on-duty for the duration of the Yard Move.

What if my driver forgets to deactivate Yard Move before going on the road?2021-05-20T09:50:38-04:00

If a vehicle exceeds the set threshold speed (32 km/h by default), the ELD will deactivate Yard Move and it will automatically register driving.

Can we modify the driving time registered if the driver forgot to activate Yard Move?2021-05-20T09:50:38-04:00

No. If a vehicle exceeds the set limit speed of 8 km/h, the duty status will change automatically to driving and neither you nor the driver will be able to adjust the driving time under Yard Move as an ELD must not allow automatically recorded driving time to be shortened.  You can annotate the driving segment and explain why this segment should be considered as Yard Move.

Personal use of a vehicle (Personal Conveyance)


Are there limitations for Personal Conveyance?2021-06-07T11:00:55-04:00

Yes. There are quite a few limitations. HoS Regulations limits Personal Conveyance to 75 km/day and it must be done with an unloaded vehicle (straight body, etc.) or unhitched trailer and must not be used for business of the motor carrier or if the driver is the subject of an out-of-service declaration issued by an inspector.

During a period when a driver indicates authorized personal use of vehicle, the ELD must also prevent the driver from selecting any event category, except to indicate the end of authorized personal use.

Because of all the limitations, it is unlikely that a driver will meet the requirements to be allowed to use Personal Conveyance when asked to move the vehicle when in sleeper berth status. It is the driver’s responsibility to make sure the requirements are met before deciding to use this option.

Is there a limit to the use of Personal Conveyance in a shift, day, cycle?2021-05-20T09:50:39-04:00

The only limitation is that the accumulated distance driven in Personal Conveyance in one day does not exceed the maximum distance allowed under current HoS regulations (which is currently set at 75 km). If the vehicle exceeds the 75 km distance, the ELD will deactivate Personal Conveyance and it will automatically register driving.

How will drivers know that they have reached the limits prescribed by the regulation?2021-06-11T11:54:21-04:00

An ELD must notify drivers when the cumulative distance driven for Personal Conveyance throughout the day exceeds the maximum distance allowed under current HoS regulations, set to 75 km/day.

ISAAC InControl displays in real-time, the remaining distance available for personal use of the vehicle and it will warn the driver within 5 km of the daily limit so the driver can take action, if necessary. When the driver reaches the daily limit, the ELD will automatically change the duty status to driving.

The ELD must not allow drivers to indicate the beginning of a period for authorized Personal Conveyance once they have reached the maximum distance allowed per day.

When can drivers use Personal Conveyance?2021-05-20T09:50:39-04:00

Personal Conveyance is set to a maximum 75 km/day and must be done with an unloaded vehicle (straight body, etc.) or unhitched trailer. Personal Conveyance cannot be activated if a vehicle is used during the business of a motor carrier or if the driver is the subject of an out-of-service declaration issued by an inspector.

Once the vehicle reaches the maximum distance allowed per day, the ELD will automatically change the duty status to driving and it must not allow the driver to indicate the beginning of a period for authorized Personal Conveyance once the maximum distance allowed per day has been reached.

What will the status of the HoS be if a driver activates Personal Conveyance?2021-05-20T09:50:39-04:00

The driver’s log will show off-duty for the duration of the Personal Conveyance.

Can my drivers set Personal Conveyance when asked to move the vehicle when in sleeper status?2021-05-20T09:50:40-04:00