OTTAWA — Hoping to solicit feedback from the trucking industry, the Canadian Council of Motor Transport Administrators has authored a discussion paper on electronic on-board recorders (EOBRs).

In preparation for a possible Canadian rule on EOBR usage, the paper highlights issues of compliance, data requirements and implementation, and how they apply to carriers’ business.

Following a "project charter" drafted last fall, this paper includes a brief discussion on each issue associated with EOBR compliance and concludes with questions to guide carriers’ input.

Harmonization with the U.S., is perhaps the most critical point for discussion. Arguably, impending EOBR legislation is driving a Canadian mandate and with close to ten million truck trips a year across the border, Canadian authorities want to be careful of not drafting a rule in isolation of how U.S. authorities approach the issue.

CCMTA acknowledges that the U.S.’s final is expected to be broader in scope than originally proposed, and a subsequent rule is expected later in 2010 that would capture a wider population of carriers.

Among the other topics covered:

Exclusion under 160 km radius?: While commercial drivers must comply with the applicable Hours of Service regulations regardless if they operate long-haul or within the 160 km radius, drivers typically operating within this radius do not
have to maintain logbooks.

In-scope Vehicles: What is the cost-benefit of applying an EOBR requirement to all commercial vehicles or only those above a certain weight threshold? Making this determination is influenced by the HOS compliance rate of various vehicle classes.

Chronic Offenders only?: HOS conviction data is readily available in most jurisdictions. However, the paper notes that the viability of this option is predicated on the ability of enforcement personnel to detect non-compliance. "The extent to which noncompliance goes undetected is unclear."

Inspection process: With the advent of electronic devices, there are now many different ways that the information previously written in a logbook can be displayed and officers may find the presentation of the data difficult to examine. "There is a desire to have enforcement applied in a uniform manner that would maintain a level playing field for industry.

Economic Considerations: The paper notes two major economic considerations with respect to EOBRs: Cost and competitiveness. While cost of EOBR technology is a major concern for some carriers, particularly for smaller carriers and owner-operators, costs of EOBRs appears to be declining as the technology evolves and as the market for it continues to expand.

At the same time, the costs to smaller carriers will be proportionally higher than the larger companies, although many in the latter camp who currently use EOBRs insist that without a mandate the competitive advantage swings toward those who falsify paper logs.

Data Requirements vs Privacy: In order to ensure privacy concerns are addressed, CCMTA wants to ensure certain policies, practices and procedures in place that ensure the driver’s personal privacy — including non HOS information stored in EOBR systems — is effectively protected while allowing enforcement officials to do their job auditing HOS.

The discussion paper and carrier response guidelines can be accessed by clicking the pdf link in the top right corner of the article.