Canada’s ELD Data System Flaws and the Role of TPA Audits

This high-level overview outlines the core issues surrounding Electronic Logging Devices (ELDs), how ELD data is generated, transmitted, and displayed, and why the current Third-Party Auditor (TPA) system in Alberta is fundamentally flawed.

Key Terminology

• ELD – Electronic Logging Device
• ECM – Electronic Control Module
• RODS – Record of Duty Status
• HOS – Hours of Service
• CSV – Comma-Separated Value
• PKI – Public Key Infrastructure
• TC – Transport Canada
• CCMTA – Canadian Council of Motor Transport Administrators
• TPA – Third-Party Auditor
• Department – Alberta Transportation

High-Level Points

• Federal drivers must use an ELD instead of a paper logbook to track work hours.
• HOS regulations define the rules, while the Technical Standard explains how an ELD must collect and record data to comply.
• There is no official interpretation guide explaining how ELD-collected data relates to HOS regulations.
• Paper logs are easily falsified—ELD data is not.
• ELD data is retained for six months and cannot be erased or altered.
• ELDs connect to a truck’s ECM via hardwire or Bluetooth to collect data.
• ELDs generate RODS in PDF format that comply with Schedule 1 of the HOS.
• ELD data is viewable as either PDF or CSV—but only these formats include all required information.
• The PDF and CSV files transmitted via PKI and unencrypted are the only formats considered fully compliant.
• TPAs do not possess encryption keys (PKI) and are not trained in using CSV data.
• TPAs rely on printed PDFs from carrier dashboards, which may be incomplete or editable.
• Audit outcomes—based on this flawed data—are used to determine if a carrier is safe or unsafe.
• Unsafe carriers are receiving satisfactory ratings based on incomplete data.
• Alberta Transportation has known about these problems for years but failed to act, largely due to leadership's lack of technical understanding.

Background: A Game of Thrones Bureaucracy

The U.S. implemented its ELD mandate first, with self-certification by ELD providers. In contrast, Canada requires third-party certification. There are hundreds of providers in the US and Canada has less than 50 because the majority of the US devices won’t meet the Canadian standards because they allow driving time to be manipulated. The US is currently revoking the licences of ELD providers that don’t meet the Technical Standard.

Canadian ELD enforcement began fully on January 1, 2022, after a soft rollout in 2021. The workshift rules of HOS didn’t change—only the requirement to log time electronically did.

While Transport Canada and CCMTA created the regulations and standards, they provided no implementation training—to either industry or government. The ELD providers did what was asked, they built the device as per the specs. The Feds and CCMTA did what they were supposed to, they wrote the regulations, and they gave the standards to follow. This failure is 100% on the provincial jurisdictions, by adopting the Federal regulation Alberta Transportation has a obligation to explain what those regulations mean to its constituents and failed to do so.

ELDs and the Technology Gap

ELDs collect data from the ECM—engine sensors, tires, GPS, and time. The data is stored on the device and in the cloud. These devices are always powered and continuously monitor and log driver activity.

All certified ELDs function similarly; the only difference is the appearance of the PDF RODS. The only legally recognized output files that meet the full data requirements are:

• Unencrypted PDFs transmitted via PKI
• CSV files

TPAs don’t use these. They lack:

• PKI encryption keys
• Training in reading or interpreting CSV data

Instead, they audit printable dashboard PDFs, which can be missing data or altered. As a result, TPA audits are fundamentally flawed.

A Real-World Example

Imagine doing your taxes with a T4 that leaves out key earnings. You get a refund, then face a CRA audit and a large fine. You find out:

• Your employer gave you an incomplete T4 from an editable PDF
• CRA blames your employer for not following the standard

This is what’s happening with TPAs and ELD audits. 95% of audits in Alberta are conducted by TPAs—and they’re based on incomplete, inaccurate data.

Why It Matters

• Satisfactory ratings from flawed audits are used by insurers, shippers, and regulators to judge company safety.
• These ratings affect insurance rates and licensing decisions.
• When a mis-rated carrier causes an accident, insurers pay out claims they wouldn’t have under proper data review—and those costs are passed to all of us.
• In past crashes, liability was pinned on the driver. With ELDs, there's data proving the company knew the driver was in violation. That data should be legally admissible.
• When this issue reaches the insurance industry and the public, the fallout could be massive—political accountability and lawsuits are inevitable.

Supporting Regulatory Language

From the Federal HOS Regulations:

Section 98(2): Drivers must transmit RODS using the method supported by the ELD and identified by the inspector.
Section 99(2): Carriers must transmit the RODS in the format and method prescribed in the Technical Standard.

From the ELD Technical Standard:

• 4.8.2: ELDs must generate a secure and consistent output file (CSV and PDF).
• 4.8.2.1: The output must match a specific data format.
• 4.10.1.2: Email-transferred data must be encrypted using PKI and formatted using RFC standards (RFC 5321, 5322, 5751, etc.).

Without following this encrypted, standard process, any audit or review lacks legitimacy.

It’s Not Just Me, Industry Voices & Ongoing Issues

June 22, 2022, the CTA (Canadian Transportation Association) released information via email regarding the PKI system:

Encryption of Record of Duty Status Email Files

The process for establishing the encryption of records of duty status (known as PKI) for email transfer to Roadside officials is the responsibility of Transport Canada. The process for implementing the Transport Canada work is the responsibility of each provincial and territorial jurisdiction, which includes submitting email addresses of enforcement officials who will be engaged in hours-of-service enforcement. The requirements and format for ELDs to produce the encrypted record of duty status are contained in the ELD technical standard, which is the result of a collaborative effort between Transport Canada, representatives from all provincial and territorial governments and ELD vendors. Devices certified through the Transport Canada and Standards Council of Canada process will meet the required format for record of duty status.

https://www.freightwaves.com/news/trucking-association-raises-concerns-over-canadas-eld-mandate

“We still want to see ELD enforcement going forward in January, but there’s issues that people are not talking about that are serious issues that still need to be addressed, and the biggest one is the PKI system,” Mike Millian, president of PMTC, told FreightWaves.

Challenges in transferring ELD data to law enforcement officers on the side of the road appear to be “smoothing out”, he said, referring to previous delays with the public key technology (PKI) system, and enforcement officers who lacked encryption codes.

Conclusion

This is not just a trucking problem—it’s a systemic data failure that threatens public safety, insurance reliability, and government credibility. The ELD system was designed to bring accountability and transparency. But without proper training, implementation, and audit processes, we’re back to the same risks paper logs created—just with digital lipstick.

Until audits are conducted using fully encrypted CSV or PDF files via PKI, no TPA result should be considered valid.