Part 2 - Safety Is a Data Architecture Problem
When the Minister identified safety as a systemic issue in Canada’s trucking sector, the instinctive response is to call for stricter enforcement.
But Canada does not lack enforcement tools.
Canada lacks integrated enforcement architecture.
Under the National Safety Code framework, motor carriers receive:
Safety events — inspections, collisions, convictions — are shared through the Carrier Data Exchange (CDE), coordinated by the Canadian Council of Motor Transport Administrators.
However, the exchange system was built more than twenty years ago.
As CCMTA President Linda McAusland testified before the Standing Committee on Transport, Infrastructure and Communities, the system is limited, formatting-dependent, and long overdue for modernization. Information must match exactly in field structure and sequencing in order to transfer. Some jurisdictions still rely on spreadsheet-based systems. Others operate advanced enterprise platforms. Where data doesn’t match, data is manually entered.
Safety data exists. It does not move seamlessly.
Structural Lag and Enforcement Reality
When enforcement depends on:
Carrier domicile and operational changes can occur faster than regulatory systems reconcile them.
If enforcement visibility is tied to provincial domicile and data does not move seamlessly, it should not surprise us that regulatory positioning becomes part of strategic decision-making.
This is not a criticism of individual regulators. It is a structural observation.
A public example illustrates the point.
On April 6, 2018, a collision involving a semi-truck and the Humboldt Broncos bus resulted in the loss of 16 lives. The carrier involved, subsequently had its Safety Fitness Certificate suspended by Alberta Transportation.
In June 2018, media reports identified that a numbered company connected to the suspended carrier had begun operating from the same Calgary address. Alberta Transportation indicated that it became aware of the overlap following media inquiries. Conditions were later attached to the new entity’s certificate.
This sequence is part of the public record. The point is not about individuals. It is about timing.
Humboldt exposed not only personal tragedy, but structural lag within enforcement architecture.
PKI, ELDs and Technology in Silos
Canada’s Electronic Logging Device (ELD) regime includes encrypted Public Key Infrastructure (PKI) transfers for regulatory inspections. PKI was included in the Technical Standard to protect a driver’s privacy.
The system works in the context it was designed for.
But:
Technology layered onto fragmented governance creates blind spots.
The lesson is not that ELDs failed.
The lesson is that systems must be built with interoperability and cross-context enforcement in mind.
The Rewrite of NSC 7, 14 and 15
The review of:
is the first meaningful opportunity in decades to modernize the safety fitness framework.
If modernization focuses only on rewriting standards — without rebuilding data interoperability, identity linkage, and cross-jurisdiction comparability — Canada risks reconstructing a 21st-century policy on 20th-century architecture.
Safety is not merely about rules.
It is about systems engineering.
The Bottom Line
Canada does not need more safety regulation.
It needs:
Safety is a data architecture problem. Until that architecture is modernized collaboratively, enforcement will always be reactive rather than predictive.
