The Canadian Recreational Vehicle Association (CRVA), RVIA, and RVDA of Canada are working together to exempt the RV industry from Transport Canada’s 2019 regulation mandating electronic logging devices for commercial carriers in Canada. This regulation includes companies engaged in the “Drive-Away/Tow-Away” industry for motorhome and towable RV deliveries from U.S. and Canadian manufacturers to RV retailers located in Canada.
Electronic logging devices are equipment that automatically records driving time in commercial motor vehicles.
According to Transport Canada, these devices would replace paper-based daily logbooks and mitigate driver fatigue risk with the mandate to take effect in June 2021. The decision has been postponed twice and is now scheduled for January 1, 2023.
After hearing the concerns of industry stakeholders, the CRVA, with the support of the RVDA of Canada and the RVIA, submitted an exemption request in January 2022.
Approving the request is in the interest of Canadian RV retailers and their consumers who would experience severely delayed RV shipments into Canada with a diminished number of carriers should the exemption not be approved, the organizations said.
Their argument included supporting historical facts and information received from several transportation companies who state that an electronic logging devices mandate exemption for the “Drive-Away/Tow-Away” industry would not impact public safety, RVIA said.
Specifically, the CRVA, RVDA of Canada, and the RVIA recommended the Canadian electronic logging devices mandate (SOR/2019-165) mirror the United States Department of Transportation RV-industry-specific electronic logging device exemption granted within Section 31137 (b) of Title 49, United States Code which reads:
(3) “Exception. – A motor carrier, when transporting a motor home or recreation vehicle trailer within the definition of the term “drive-away/tow-away operation” (as defined in section 390.5 of Title 49, Code of Federal Regulations), may comply with the hours-of-service requirements by requiring each drive to use,
(A) a paper record of duty status form; or
(B) an electronic logging device”
On August 19, the CRVA and the RVDA of Canada met with the Executive Director and other representatives from Transport Canada to discuss the exemption request. During the meeting, their efforts were partially successful, as Transport Canada produced a draft document titled “Driveaway and towaway industry— exemption from having to use an electronic logging device to monitor compliance with the Commercial Vehicle Drivers Hours of Service Regulations,” RVIA said.
Transport Canada still needs Canadian provincial authorities’ support to move forward with its approval.
During the meeting, it was disclosed that four provinces do not favor the exemption. These provinces have implied that public safety would be impacted if the exemption were granted, RVIA said.
Transport Canada has asked the CRVA and RVDA of Canada for information to further the exemption request that they could present to the four provinces.
On August 31, the team sent a secondary document to the Transport Canada Executive Director’s attention. A separate copy was sent to each minister of transportation and staff in the disfavoring four provinces asking for support of the exemption request.
Transport Canada and the provincial authorities are expected to respond in the next 30 days.
