With 2024 in the rearview mirror, it’s time to cautiously look ahead to 2025, a year poised for changes in commercial transportation. Regardless of political affiliations, we can all agree that commercial transportation and driver safety demand urgent attention. While the first few months of the year may bring little change due to political transitions, the groundwork laid this year could shape the future of the industry. Here’s what I foresee for 2025.

Regulatory Changes and Leadership Appointments

Transport Canada, the Canadian Council of Motor Transport Administrators (CCMTA), and the Ontario Ministry of Transportation (MTO) are all gearing up for potential shifts. A new federal transport minister will likely be appointed by summer, and their effectiveness will depend on their ambitions. A proactive minister could drive reforms, while a placeholder appointment might maintain the status quo.

The MTO’s search for an Assistant Deputy Minister, Commercial Transportation Safety and Enforcement, is a promising sign. Similarly, the CCMTA’s hiring of a Data Administration and Compliance Manager indicates that the long-standing issue of enforcement data transfer are finally being addressed. By mid-year, we may see serious discussions among these organizations about tackling industry challenges, including driver training school compliance and road safety.

2025: The Year of Enforcement

This year will mark a shift in enforcement practices. The Alberta Sherriffs and Saskatchewan Marshalls are investing in new enforcement personnel. Alberta will have full trained 240 officers in commercial vehicle inspections by February. Weigh stations will be fully staffed, and temporary scales will see more blitzes. Enhanced patrols at US ports of entry and southern highways will further emphasize compliance.

Insurance companies will begin to leverage data from Electronic Logging Devices (ELDs), in-cab cameras and Engine Control Modules (ECMs) to assess liability in accidents. By fall, compliance will no longer be optional—carriers with poor safety records will face mounting consequences, from tickets, increased insurance premiums to audits.

ELD Updates: Slow but Necessary Progress

In August 2024, the CCMTA introduced draft revisions to ELD technical standards (version 1.3). Two key changes stand out:

  1. Drivers will no longer be able to log in as both the driver and co-driver using the same credentials.
  2. Diagnostic events will now self-clear once resolved, eliminating the need for manual intervention.

While these updates address critical issues, the process of implementation will be lengthy. ELD providers must program their devices to meet the new standards, undergo testing, and achieve re-certification—a process that could take years. I predict in 2025 there will still be no interpretation guide or ELD monitoring policy from Alberta Transportation Compliance and Oversight but, administrative penalties to carriers will continue to be written for failing to monitor drivers ELDs.

Immigration, Drivers, and the Labour Shortage

The federal government’s tightening of Labour Market Impact Assessments (LMIAs) and Permanent Residency (PR) criteria this spring aims to control immigration. However, these changes won’t solve the immediate problem of untrained and inexperienced drivers. Canada needs a balanced approach that supports the drivers already in the system.

Instead of punishing drivers who were brought here through flawed programs, we should offer them legitimate MELT training, Driver Red Seal training and pathways to PR if they meet the other requirements. Enforcement efforts should focus on holding exploitative immigration brokers, driving schools, and trucking companies accountable. Government is sending mixed signals with regards to commercial drivers. Saskatchewan has a class 1 driver recruitment program that allows drivers from certain countries to drive on the class 1 licence of their home country in the agricultural sector. This is government talking out of both sides of its face, removing drivers and restricting immigration on one side but recruiting for drivers in the agriculture sector on the other side.  Nothing is going to happen this year and expect the status quo for a couple of years.

My Wish List for 2025

  1. Addressing Driver Inc.: Transport Canada, the CCMTA, and the CRA must establish policies to end the exploitation of drivers under the Driver Inc. model.
  2. Tackling Chameleon Carriers: Provinces must work together to identify and enforce penalties against carriers that rebrand to evade compliance.
  3. Clear ELD Guidelines: Alberta needs to produce an interpretation guide and a monitoring policy for ELDs to ensure consistent enforcement across the industry.

Collaboration Is Key

Real progress in 2025 requires cooperation between federal ministries, provincial regulators, industry groups, and stakeholders. Leadership at every level must work collaboratively to develop a clear plan for reform. Change won’t happen overnight, but figuring out who is in charge is a first step. We are all in this together and we need accountability from our elected leadership for a safer and more efficient commercial transportation industry.

Drivers of commercial motor vehicles are subject to roadside inspections and NSC Standard 15 audit inspections. If a driver or vehicle is placed out of service, the driver and/or carrier would be subject to a written warning, tickets and/or points on the Carrier Profile. If the non-compliance is serious the driver and/or vehicle would be placed Out Of Service (OOS) until corrected. These are considered HOS violations. Not all provinces and territories follow the Federal Contraventions Regulations (Schedule XVIII): SOR/2023-137, which means that penalties for violations can vary depending on where the violation occurs. The penalties outlined in the contravention regulations are different for the driver and carrier involved in the violation. Specifically, carrier penalties are set at double the amount of driver penalties in order to ensure that responsibility is appropriately distributed between the driver and carrier. 

My top 5 common and avoidable driver ELD (Electronic Logging Device) HOS violations: 

  1. ELD device not mounted in view of the driver (roadside detected violation)

77 (1) 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. Contraventions Regulations (Schedule XVIII): SOR/2023-137 suggested penalty is $1000.00. 

How to avoid: Install a $20.00 magnetic cell phone holder if the ELD is on the driver’s phone and not a wired connection. 

  1. Missing ELD information packet (roadside detected violation)

77 (7) The motor carrier shall ensure that each commercial vehicle that it operates carries an ELD information packet. Contraventions Regulations (Schedule XVIII): SOR/2023-137 suggested penalty is $600.00. 

How to avoid: Ensure each CMV contains an information packet that contains; (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 in the event that 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.

  1. Unidentified driving time (audit and roadside detected violation)

77 (8) The motor carrier shall ensure that the driver records the information related to their record of duty status and the driver is required to record that information in a complete and accurate manner.

78.1 A motor carrier shall create and maintain a system of accounts for ELDs that is in compliance with the Technical Standard and that (a) allows each driver to record their record of duty status in a distinct and personal account; and (b) provides for a distinct account for the driving time of an unidentified driver.

Technical Standard 4.1.5 Non-Authenticated Driving of a CMV

87 (1) A motor carrier shall monitor the compliance of each driver with these Regulations.

Contraventions Regulations (Schedule XVIII): SOR/2023-137 suggested penalty 77(8) is $500.00 for the driver $1000.00 for the carrier. 78.1 suggested penalty is $1000.00 for the carrier. 87(1) suggested penalty is $2000.00 for the carrier.

How to avoid: Carrier to assign all unidentified time.

  1. Data Diagnostic Events (roadside and audit detected violation)

Technical Standard 4.6.1 Compliance Self-Monitoring, Malfunctions and Data Diagnostic Events Table 4 

86 (3) No motor carrier shall request, require or allow any person to, and no person shall, disable, deactivate, disengage, jam or otherwise block or degrade a signal transmission or reception, or re-engineer, reprogram or otherwise tamper with an ELD so that the device does not accurately record and retain the data that is required to be recorded and retained.

Contraventions Regulations (Schedule XVIII): SOR/2023-137 suggested penalty 86 (3) is $2000.00 for the carrier.

Data diagnostic events: Table 4 Technical Standard

(Code 1) Power Data Diagnostic Event: Problem ELD is not fully powered/functional within one minute of the vehicle’s engine receiving power. How to avoid: Plug the ELD in.

(Code 2) Engine Synchronization Data Diagnostic Event: Problem the ELD loses ECM connectivity to any of the required data sources and can no longer acquire updated values for the required ELD parameters within five seconds of the need. Connectivity must be maintained while the vehicle is powered on. How to avoid/ fix the connectivity where the ELD loses ECM connectivity to the required data sources, you can try the following steps:

(Code 3) Missing Required Data Elements Data Diagnostic Event: Problem there are missing data elements (like GPS location) in the ELD event record. How to avoid: Instruct drivers to input missing information when ELD prompted.

(Code 4) Data Transfer Data Diagnostic Event: Problem the internal monitoring of the data transfer test fails and is unable to send the output file data. How to correct: consult with technical support

(Code 5) Unidentified Driving Records Data Diagnostic Event: Problem there is over 30 minutes of unidentified driving time for the vehicle over the last 24 hours. Unidentified Driving Records Data Diagnostic Events will clear when the cumulative time for unidentified driving is less than 15 minutes. How to correct: Assign all unidentified driving time.

  1. Malfunctions (roadside and audit detected violation)

Technical Standard 4.6.1 Compliance Self-Monitoring, Malfunctions and Data Diagnostic Events Table 4 

(Code P) Power Compliance Malfunction 

(Code E) Engine Synchronization Malfunction 

(Code L) Positioning Compliance Malfunction 

(Code T) Timing Compliance Malfunction – Drivers using a smartphone as a device must disable the Automatic Time Zone Detection or Automatic Time Zone Adjustment.

(Code R) Data Recording Compliance Malfunction

(Code S) Data Transfer Compliance Malfunction 

How to avoid: Malfunctions occur when Data Diagnostic Events are not corrected, fix the data, avoid the Malfunction. When a Malfunction is detected, the driver is to stop, switch to paper logs and follow the Malfunction criteria 78 (2)(3)(4). 

That’s my top 5 and the easiest to avoid and correct. In my experience 75% of issues are driver training and safety officers not understanding how ELDs work. It’s not the device, the ELD records data, the ELD does not interpret what that data means. With ELDs providing a digital record of a driver’s activity it is important for carriers to recognize the level of liability that entails if your driver is involved in a serious incident. 

A ELD (electronic logging device) is a device that automatically records information using the CMV (commercial motor vehicle) ECM (Electronic Control Module), truck sensors and GPS trilateration to automatically record driving time. Fun fact, February is Black History Month and we need to acknowledge GPS was invented by mathematician Gladys West who was the second black woman to be hired to work as a programmer for the US Navy. As a CMV is moving the ELD is receiving information from the ECM and comparing that information to GPS position to monitor compliance to the Federal Hours of Service HOS (SOR/2005-313) and the Technical Standard. 

How does it work? 

A driver’s day in ELD sequence.  

What information does an ELD record?

The ELD records all the required information from the Federal Hours of Service HOS (SOR/2005-313) and additional device compliance health monitoring in the Technical Standard. The data collected is related to: carrier identification, driver identification, vehicle identification, driver location information at prescribed intervals and each change of duty status, a running and cumulative odometer and engine hours total, duty status totals and ELD identification information. 

The drivers’ daily, workshift, cycle and off-duty requirements are continuously monitored, and a driver is alerted within 30 minutes of reaching a duty status limit. 

The ELD continuously monitors the device functionality and alerts the driver if any data is missing or there is a connectivity issue. Drivers are prompted to provide missing information if data is not automatically recorded. Drivers are alerted to uncertified RODS and missing data elements. Unidentified driving records must be accepted or rejected by the driver and no other information can be entered until unidentified driving time is resolved, Technical Standard 4.1.5 3).

The data from the ELD is shared between the drivers in-truck device and a dashboard or portal for the motor carrier to monitor the entire fleet. All the data is stored on the cloud for 6 months and can be retrieved by the carrier for inspection. The motor carrier is expected to monitor the drivers continuously using the information generated from the ELD. A driver should never be in a out of service condition for HOS because as soon as the driver is alerted to a problem the driver is supposed to immediately stop and alert the carrier. The driver and carrier are supposed to work together to resolve the issue and if the issue cannot be resolved follow the OOS criteria. The data doesn’t lie and the data doesn’t go away.

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