The Government of Alberta announced changes to the MELT Class 1 Mandatory Entry Level Training program, turning the program into an apprenticeship model. These changes are urgently needed today but, it will take time to launch the program and is expected March 1, 2025. Currently MELT drivers pay upwards of $10,000.00 to obtain a Class 1 drivers licence and then most can’t find a job because insurance companies require two years of over the road experience. This apprentice model should fulfill the insurance company requirements and hopefully open federal funding for new students.
All of this is great stuff but, the reality is Alberta will produce quality, well trained drivers and put them to work in an industry that is a disaster. It is like raising Kobe beef only to sell it to Burger King. If commercial driving is going to be a trade, then it is time to hold the road transportation industry to that trade standard.
Transport Canada and the provinces and territories need to take a hard look at the road transportation sector and make some changes. There is zero accountability for trucking companies that utilize questionable practices like Driver Inc to circumvent taxes, immigration and human rights regulations. Driver Inc is a model based on commercial drivers, who do not own/lease or operate their own vehicle. These drivers are becoming incorporated and not paying source deduction like income taxes or Employment Insurance. The prevalence of chameleon carriers operating across Canada highlights the need for greater oversight and enforcement measures. A chameleon carrier is a trucking company that, if cited or closed down for a marginal safety record, quickly changes its name and address and restarts operations.
Chameleon carriers operate unchallenged across Canada, in Alberta the penalty for lying on a Safety Fitness application to fraudulently obtain a Safety Fitness Certificate is $1000.00 and the company is allowed to keep operating. To compare, also in Alberta, the penalty for not stopping for an invasive species boat inspection is $4200.00. Why does Alberta Transportation and Economic Corridors (TEC) not take road safety as serious as Alberta Environment takes protecting our lakes?
Alberta does not have accurate enforcement information from all jurisdictions, see my blog, Don’t look behind the curtain! unveiling the Alberta Transportation safety scam. Unless the provincial jurisdictions specifically contact each other about unsafe carriers potentially moving into other jurisdictions, a tragedy is usually the first notification. There is not a central transportation regulatory body in Canada that collects safety data as there is in the United States, the broken carrier profile system all we have in Alberta.
These sketchy chameleon carriers also can be self-insured. Because of this they can cause mayhem, then go bankrupt and start over with zero consequence. Trucking company insurance minimum requirement in Alberta is $10 million dollars. How much do you think a bridge or infrastructure strike costs to repair? British Columbia recently substantially increased the fines and jail time for drivers that hit structures. What about the trucking company that employs the driver? It may be the driver’s fault but, it is the carrier’s responsibility.
The lack of support systems for both rookie and experienced drivers exposes them to exploitation and mistreatment within the industry. Drivers have zero complaint options, even after being abused, unpaid, disrespected, forcibly dispatched and worse. Complaint procedures in Alberta are convoluted and inadequate, leaving drivers without effective recourse when faced with issues such as unpaid wages or unsafe working conditions. Alberta TEC, Compliance and Oversight department complaint procedures are an offense to the rights of workers that need urgent protection. The complainant is sent a witness statement via email. The issue is that the document it is a non-fillable PDF, so the driver needs to print it, physically fill it in, sign it, scan it, and email it back. How does that help or support the driver? Consider a driver that finally gets the courage to complain to the government and gets told to fill out a form. Drivers in a Driver Inc. situation working for chameleon carriers that go bankrupt and leave unpaid wages are not eligible for employment benefits because they are not employees. As a Driver Inc driver the only option is to get a lawyer and sue. Kobe beef cattle has more protections than drivers in Canada.
The qualified driver shortage is a real safety problem, and more training and experience is better for drivers and everyone on the road. Changes must be made in conjunction with large-scale fundamental improvements to the carriers and industry that employ these drivers. Commercial driving is dangerous and lonely with poor pay, no wage guarantees, terrible working environments with limited rest areas and parking. Unless you fix systemic issues, these red seal drivers will leave the industry or die on the highway trying. Make commercial driving a trade that people aspire to undertake the training and time to become a red seal, anything less is another waste of drivers’ time of money.
What is a Tractor Protection System? And what does it do?
The tractor protection system is like a parachute. If the trailer becomes separated or the air system fails, the trailer brakes engage so the trailer doesn’t continue traveling like a missile and kills people. The tractor protection system works with the air system to control the trailer. When the air supply to the trailer is cut off, the tractor protection valve closes, which activates and applies the brakes on the trailer.
The tractor protection system has 2 valves:
The trailer supply valve (TSV)
The trailer supply valve (TSV) is a a push/pull red button on the dashboard and the glad hand on the trailer is also red.
The other is the tractor protection valve (TPV)
The tractor protection valve (TPV) is a a push/pull yellow button on the dashboard. The TPV is also called a ‘towing vehicle’ protection valve and the glad hand on the trailer is blue.
When there is no trailer, the driver opens (pushes in) the tractor supply valve (TSV). When a trailer is being towed the driver opens the trailer supply valve (TSV) (pushes in). The trailer supply valve (TSV) can also be used to set the trailer parking brakes.
In my experience doing level 1 inspections, the Roadside Inspection/Test Procedures for the Tractor Protection System can be a difficult concept to explain to some drivers. Most drivers learn this in school and never use it again until they get pulled over for a level 1. It’s a good idea to have a refresher in Roadside Inspection/Test Procedures in real life not just a email to all the fleet before Roadcheck. Any super truckers in your fleet should be teaching this, leverage that knowledge and experience.
Conducting the tractor protection system test
The goal of this test is to confirm that the Towing Vehicle Protection System is functioning properly in the event of a trailer separation. This test is done under pressure with the engine off and is conducted as follows:
trailer supply valve TSV – red button and tractor protection valve TPV – yellow button.
1. The system must be working at normal operating.
2. Wheels chocked and all brakes must be released, push the red and yellow buttons on the dash in.
3. Remove gladhand couplings to simulate a trailer separation. Driver will remove the gladhands and put them on the deck.
4. Air will start to escape immediately from the gladhand line. In most cases the air will stop escaping immediately and in some cases the air will escape and then stop. The tractor protection valve TPV should close once the gauge pressure (on the dashboard) drops to 20 psi (138 kPa). If the tractor protection valve TPV fails to close before pressure gets below 20 psi (138 kPa), the power unit is defective and that is an OOS condition.
5. When the gladhands are disconnected, the trailer emergency (spring) brakes must also apply automatically. If the trailer emergency (spring) brakes do not engage the trailer breakaway system is defective. The trailer is in an OOS condition.
6. When the gladhands are disconnected, the trailer system must close automatically. Check the gladhand on the trailer for air bleeding back. Air leaking from the gladhand on the trailer indicates that the trailer spring brake control valve is defective. The trailer has a violation but, not an OOS.
7. When the air has stopped the driver will apply the brakes and hold it.
8. Any air escaping from either gladhand line the Towing Vehicle Protection System is defective. This is an OOS condition.
9. If there is air escaping from either the supply/emergency or service/control gladhand line of any vehicle equipped to tow an airbrake equipped trailer indicates the unit has a defective tractor protection system and is an OOS condition.
Conclusion:
Take the time to refresh your driver’s skills with this inspection process because it is very easy to get an Out of Service for a air leak.
Table 4: Data Diagnostic Events and Malfunctions
Data diagnostic events and malfunctions are a continuous source of annoyance for carriers and drivers. Without an interpretation guide from Alberta Transportation industry must refer to the Federal Hours of Service Regulation and the Technical Standard.
ELD Refresher
ELDs record and transmit data, that is it. ELDs are programmed with parameters to account for real life and allow for little variances. For example, the ELD will start recording when the vehicle reaches 8 kms a hour. ELDs are required to record certain pieces of data that are regulated in the Technical Standard. If any pieces of data are missing, and the driver does not manually input the missing data the ELD will record a data diagnostic event.
Connection Concerns
The majority of data diagnostic events are due to connectivity issues. ELDs rely on technology and technology can fail. ELDs can be hardwired or connected via Bluetooth. We all have cellphones that rely on the existing cellular network. Think about a ELD like a cellphone. When you fly to Mexico for vacation you turn off your phone or go into airplane mode for the duration of the flight. Your life does not disappear for those 5 hours, your still getting text messages and comments on your Instagram. The phone holds on to the data in the cloud and when you land and reconnect to a network all the data is waiting. ELDs work the exact same way. When a ELD reconnects to the network and data is missing or the data isn’t correct the ELD will record a data diagnostic event.
Carrier Due Diligence and Accountability
Data diagnostic events turn into malfunctions when not resolved. The driver and the company are aware of data diagnostic events and malfunctions due to:
Data diagnostic events can self-clear if conditions are met. Example the ELD has a period of no connection to Bluetooth. The device will record a data diagnostic event and when the device is reconnected the event is cleared. It is still recorded as a data diagnostic event because the event happened but, the event will be cleared and it is no longer a compliance issue.
The Federal Hours of Service Tampering:
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.
A ELD that is unplugged or disconnected from the internet is not accurately recording or retaining the data that is required to be recorded and retained as per the Hours of Service 86(3)
Table 4: Compliance Malfunction and Data Diagnostic Event Codes:
P Power compliance malfunction
E Engine synchronization compliance malfunction
T Timing compliance malfunction
L Positioning compliance malfunction
R Data recording compliance malfunction
S Data transfer compliance malfunction
O Other ELD detected malfunction
1 Power data diagnostic event
2 Engine synchronization data diagnostic event
3 Missing required data elements data diagnostic event
4 Data transfer data diagnostic event
5 Unidentified driving records data diagnostic event
6 Other ELD identified diagnostic event
Code 1: Power Data Diagnostic Event
Problem: The ELD is not fully powered/functional within one minute of the vehicle’s engine receiving power. “Fully powered” requires that the driver connect to the vehicle with the ELD within one minute of the vehicle powering on.
Solution: Ensure that the driver connects the ELD to a vehicle within one minute of the vehicle powering on.
Code P: Power Compliance Malfunction
Problem: The ECM connection is unplugged from the ELD and there is driving time over 30 minutes over 24-hour period.
Solution: Ensure that the ELD is connected to the vehicle ECM whenever the vehicle is in motion. Drivers should follow the Malfunction criteria in the Hours of Service 78.
Code 2: Engine Synchronization Data Diagnostic Event
Problem: The ELD has lost ECM connectivity and can no longer acquire data within five seconds. Connectivity must be maintained between the ELD and the ECM while the vehicle is powered on.
Solution: Ensure that the ELD remains connected to the vehicle ECM while the vehicle is powered on.
Code E: Engine Synchronization Malfunction
Problem: The ELD loses connection to the vehicle ECM for a cumulative 30+ minutes of missing data: GPS, VIN, date/time, engine hours.
Solution: Ensure that the ELD remains connected to the vehicle while the vehicle is powered on. Engine Synchronization Malfunctions will clear on their own after 24 hours have passed since the last logged malfunction. Drivers should follow Malfunction criteria in the Hours of Service 78.
Code T: Timing Compliance Malfunction
Problem: The time on the ELD varies more than 10 minutes from the designated home terminal time.
Solution: The ELD will automatically resync its local clock to the GPS time once it becomes valid. If the driver is using the ELD on a cellphone disable the Automatic Time Zone Detection or Automatic Time Zone Adjustment function. Drivers should follow Malfunction criteria in the Hours of Service 78.
Code L: Positioning Compliance Malfunction
Problem: The ELD cannot obtain a valid GPS position within five miles of the last valid position for over 60 minutes of driving in a 24-hour period.
Solution: Ensure a satellite GPS connection. Try moving the ELD near a clear, unobstructed view to the sky. Reboot the ELD to re-establish a satellite GPS connection. Enter locations manually, manual locations will indicate a M in the latitude and longitude fields of the RODS and the CSV.
Positioning Compliance Malfunctions will clear after 24 hours have passed since the last logged malfunction. Drivers should follow Malfunction criteria in the Hours of Service 78.
Code 3: Missing Required Data Elements Data Diagnostic Event
Problem: There is missing data: GPS, VIN, date/time, engine hours in the ELD event record.
Solution: Ensure that the ELD remains connected to the vehicle while the vehicle is powered on.
Code R: Data Recording Compliance Malfunction
Problem: The ELD can no longer record new event data due because it is full.
Solution: Ensure there’s an active internet connection before using Bluetooth to connect the ELD with the ECM. Keep the driver ELD app open for the data to transfer to the server. Do not force close the ELD app. Drivers should follow Malfunction criteria in the Hours of Service 78.
Code 4: Data Transfer Data Diagnostic Event
Problem: The internal monitoring of the data fails and is unable to send the output file data.
Solution: Ensure there’s an active internet connection before using Bluetooth to connect the ELD with the ECM. Keep the driver ELD app open for the data to transfer to the server.
Code S: Data Transfer Compliance Malfunction
Problem: When a ELD records a data transfer data diagnostic event, the ELD increases the frequency of the monitoring to check every 24-hour period. If the ELD stays in the unconfirmed data transfer mode following the next three consecutive monitoring checks, the ELD must record a data transfer compliance malfunction.
Solution: Ensure there’s an active internet connection before using Bluetooth to connect the ELD with the ECM. Keep the driver ELD app open for the data to transfer to the server. Do not force close the ELD app. Drivers should follow Malfunction criteria in the Hours of Service 78.
Code 6: Other ELD identified diagnostic event
Technical Standard 4.6.1.8 Other Technology-Specific Operational Health Monitoring. In addition to the required ELD monitoring the ELD provider may implement additional, data diagnostic detection and may use the ELD’s data diagnostic status indicator to alert the ELD’s non-compliant state to the driver.
Solution: Ensure that the ELD remains connected to the vehicle while the vehicle is powered on.
Code O: Other ELD detected malfunction.
Technical Standard 4.6.1.8 Other Technology-Specific Operational Health Monitoring. In addition to the required ELD monitoring the ELD provider may implement additional, malfunction detection and may use the ELD’s malfunction status indicator to alert the ELD’s malfunction or state to the driver.
Solution: Ensure that the ELD remains connected to the vehicle while the vehicle is powered on. Drivers should follow Malfunction criteria in the Hours of Service 78.
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. If the vehicle is moving and there is no driver logged in, the ELD records that time separately.
Solution: The solution for unidentified driving is for the carrier to assign unidentified driving time. Unidentified driving data diagnostic events will clear when the cumulative time for unidentified driving is less than 15 minutes for the current day plus the last 7 or 14 previous days. That means once all the unidentified time is cleared up the malfunction clears up. A truck driving down the street with no driver behind the wheel would be considered a problem, why is a ELD recording a truck with no driver behind the wheel not a problem?
Unidentified Driving Records Data Diagnostic Events will clear when the cumulative time for unidentified driving is less than 15 minutes for the current day plus the last 7 or 14 previous days.
The Federal Hours of Service Tampering:
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.
A ELD that is unplugged or disconnected from the internet is not accurately recording or retaining the data that is required to be recorded and retained as per the Hours of Service 86(3)
Contraventions Regulations (ScheduleXVIII): SOR/2023-137
86(3) (a) Tamper with ELD $1000.00 – driver
86(3)(b) Request, require or allow person to tamper with ELD – $2000.00 carrier
The Humboldt incident, which tragically highlighted the need for better driver training in the operation of commercial vehicles, prompted Alberta Transportation and other jurisdictions to introduce MELT (Mandatory Entry Level Training) to bridge this knowledge gap. MELT, as the name suggests, is entry-level training aimed at equipping individuals new to the field with essential skills, knowledge, and competencies necessary for safe and competent driving. This crucial training encompasses formal instruction, on-road training, mentoring, and assessments, laying the foundation for growth and development behind the wheel.
Most individuals undergo driver education in high school and then gradually build experience by driving. Most new drivers did not get a class 5 go home and hook up a trailer and drive in the mountains the next day. It is the same thing for MELT, it is entry level, why is it okay for a MELT driver to graduate and the next day load up a set of super B’s and go trucking? It isn’t and that is the carrier training component of AR314/2002 Section 41(1)(h)(i). to provide ongoing training related to vehicle operation and compliance with safety laws even after a driver has completed MELT.
Recognizing that experience plays a vital role in ensuring safe driving practices, Alberta Transportation is set to roll out an apprenticeship program starting in 2026. This program aims to transition drivers from entry-level to experienced while being closely monitored, akin to how pilots accumulate hundreds of flight hours before flying passengers. This underscores the importance of hands-on experience and continuous learning to mitigate risks and enhance safety standards in the commercial driving sector.
What do we do until 2026? Train the drivers!
What are the regulatory requirements for carrier driver training?
A Carrier Safety program in regards to driver training; According to section 40(1) of the Alberta Commercial Vehicle Certificate and Insurance Regulation (AR314/2002), a carrier must create policies that discuss these subjects in their safety program:
Carriers are required by law to make sure all employees are trained in and knowledgeable of all applicable safety laws: Traffic Safety Act - including, but not limited to those related to: Hours of Service, Cargo Securement, Rules of the Road, Use of Safety Equipment, Weights and Dimensions, Vehicle Maintenance and DVIR and Record Keeping.
Carrier Orientation and Training:
Carriers must also choose the ways they will inform all new employees about the company’s policies and procedures. They may also provide training to ensure the effective and safe operations of their commercial vehicles. Carriers may develop and deliver suitable training material within their own company or they may use public training courses. They may also hire a consultant to provide customized training, or they may use a combination of these options to train their employees.
Can I train drivers in house? This is the guidance from Alberta Transportation to auditors;
Answer yes if, There is a record of all related training on file (e.g. tests, certificates, course attendance lists, certificate of completion or list of all training completed), including training identified in the carrier’s Safety Program. It is expected that a driver receives training (such as: hours of service, trip inspection, load securement, weights and dimensions, DG as applicable, etc.) in all areas with respect to the operation of a commercial vehicle, if applicable. It is acceptable if this information is contained in a separate “training” file, computer or other system viewable by the User provided the carrier could easily produce training information for an individual driver verifying that applicable training was taken. Also answer “Yes” if evidence is found that drivers have been adequately instructed by their previous employer, then evaluated and accepted by their current employer. A written record of the evaluation must be present. User may accept any training that the carrier can demonstrate is adequate for their drivers given the type of job, vehicle, etc. that the employees operate. Alberta Transportation’s Education Manual was not created or intended to be used as formal training.
Can I use the Alberta Transportation Education Manual?
No, Education Manual disclaimer:
The material in this document is not intended to represent a full training course in any subject area covered. However, it may form part of a carrier’s larger training program. The reader is invited to reproduce all or part of this document, however, at no time should the information contained here be altered in any way nor used in a manner that would change the intended meaning of the material or its accuracy.
What records do I need to document driver training?
This is the guidance from Alberta Transportation to auditors: Does the carrier instruct drivers for: Hours of Service; Trip inspection; load securement; applicable safety law requirements; have an ongoing eval of driving skills?
Regulation: AR314/2002 Section 40 (1)(c) & (e).
Carrier has a written policy and any applicable training materials (may include evidence of instruction or examination from an external source/provider) clearly specifying the training required for drivers and an ongoing program for evaluating driving skills. Examples of training material that would be acceptable include tests, course materials and instructional videos. User may accept any written training policy that the carrier says they feel is adequate for their drivers given the type of job/ vehicle the employee operates. User should comment if they feel the training material is poor or requires updating. An example of what would be expected in order to be answered yes might include: The carrier’s program states “All drivers will be trained in Federal hours of service, trip inspections, load securement (commodity specific), weights/dimensions and must successfully pass a road test with the Safety Officer prior to being authorized to drive an NSC vehicle. Each driver will be required to re-certify in the vehicle every 24 months and pass a driver qualification review every 12 months.” For the purposes of answering this question only, actual proof of training is not required to answer “yes”; it must be in their program and, if it is, there should be training material available to support this. User may ask the carrier to see this material if it is not readily available. This question is asking what is the carrier doing with their drivers AFTER they have hired them and authorized them to drive in the first place (i.e. we don’t want a carrier hiring a driver and then never check up on them for as long as they work there). There is no measurement of what is acceptable and what is not acceptable, only does the carrier have a program in place to actually check on their drivers periodically to ensure they are still good drivers. This can be nearly anything, but it must still be reasonable.
Driver training is a endeavor that demands ongoing commitment and diligence from carriers to uphold standards and promote the professional development of drivers. By adhering to regulatory guidelines, implementing comprehensive training programs, and embracing the value of experience, carriers can avoid penalties as a result of an audit or investigation. Untrained drivers expose a carrier to increased liability in a serious on road incident.
