Dawg On-It Trucking Pawedcast

22. Marc Moncion, FleetComplete; Talking Electronic Logging Devices (ELDs) Are They Coming To Canada

July 10, 2020 Chris Harris, The Safety Dawg Season 1 Episode 22
Dawg On-It Trucking Pawedcast
22. Marc Moncion, FleetComplete; Talking Electronic Logging Devices (ELDs) Are They Coming To Canada
Dawg On-It Trucking Pawedcast
22. Marc Moncion, FleetComplete; Talking Electronic Logging Devices (ELDs) Are They Coming To Canada
Jul 10, 2020 Season 1 Episode 22
Chris Harris, The Safety Dawg

Marc's Contact Info:
Email address: [email protected]
Phone:   (647) 945-6977
Website:  www.fleetcomplete.com
Twitter:  https://twitter.com/FleetComplete
LinkedIn: https://www.linkedin.com/company/fleet-complete/
Facebook Company Page: https://www.facebook.com/FleetComplete/
ASK THE EXPERT: https://blog.fleetcomplete.com/safety-corner

Keeping it Safety Dawg Simple!
#HOS, #ELD, #FleetComplete, #BigRoad,  #AskTheExpert,  #MarcMoncion

Show Notes Transcript

Marc's Contact Info:
Email address: [email protected]
Phone:   (647) 945-6977
Website:  www.fleetcomplete.com
Twitter:  https://twitter.com/FleetComplete
LinkedIn: https://www.linkedin.com/company/fleet-complete/
Facebook Company Page: https://www.facebook.com/FleetComplete/
ASK THE EXPERT: https://blog.fleetcomplete.com/safety-corner

Keeping it Safety Dawg Simple!
#HOS, #ELD, #FleetComplete, #BigRoad,  #AskTheExpert,  #MarcMoncion

Marc Moncion (1s):
I'm known in the industry within the company as a subject matter expert, I have my own, I have my own button on the, on the big road fleet, complete website, which I'm really proud of. And it's basically called ask the expert.

Chris, Safety Dawg (15s):
Yes. Ask the expert. That was Mark Moncion from FleetComplete. And he's my guest on this. Week's the Dawg On-It Trucking Pawedcast And Mark and I get talking about Canadian ELD when they might get implemented the new us hours of service rule changes that might or might not get implemented this year and all the complexities of LDS and hours of service. So join us. Let's get on with the show.

2 (45s):

3 (51s):
Welcome to Dawg On-It Trucking Pawedcast. I'm your host, Chris Harris Safety Dawg. And when it comes to trucking safety, that dawg is 0n-it. Please. If you would show your appreciation for the podcast by leaving a thumbs up a comment, a rating, it would help me so much. Well, thank you very much. I appreciate you now. Let's get on with it.

2 (1m 14s):

Chris, Safety Dawg (1m 22s):
A welcome to the Dawg On-It Trucking Pawedcast. How will the heck are you my friend

Marc Moncion (1m 27s):
Doing very well, Chris, nice to have you on your call here. This is fantastic. Thank you for inviting me.

Chris, Safety Dawg (1m 32s):
Oh, not a problem. I think you've got a lot of great information that we need to share and get out to the public, especially Bodhi, LDS, and hours of service and everything. But before we get into all that kind of stuff, can you give us a bit of a background on you? I first met you a long time ago when you were working for the MTO.

Marc Moncion (1m 52s):
Exactly. Yeah. Well, essentially, as you likely know, like I, I literally eat, breathe and sleep safety. It's in my DNA. Like I come from the trucking background, my dad was in the industry and he's the one that got the diesel fumes and axle grease in my DNA. So I actually full, licensed CDL older as well, but I come from like a different background. So I have a law degree and I also have a logistics designation from the CITT.

Chris, Safety Dawg (2m 22s):
So I'm sorry. You're actually a lawyer.

Marc Moncion (2m 25s):
Well, I have an honors BA in law. I didn't go off to law school. I ended up getting married and having kids instead. And then I went on to get a CITP designation, which I'm really proud of the graduating year. I got the highest Mark of the class and I got this beautiful rhinoceros heirloom on my fireplace. I sat on the board as well as with CITP. So I've worked in the, in the private and the public sector for about 30 years now.

Chris, Safety Dawg (2m 52s):
Sorry, before you leave, CITT that's an acronym. Can you explain that for our viewers and listeners?

Marc Moncion (2m 58s):
Sure. So that's the Institute of traffic and transportation. It's, it's a multi-year program that it takes several years to complete. So I did that all online and this is going back to my days with MTO. So when I was on the road, away from my family and my hotel room, I was just taking online courses and eventually finished it off. And I have CIT CIT next to my name. And I'm proud to say that.

4 (3m 25s):
That's cool. What roles did you have when you were working for MTO?

Marc Moncion (3m 30s):
I've had several roles since 1988. So when I first started, I was, it was kind of interesting. I had just finished university and my wife and I over a cup of coffee. I was reading the Toronto star and they had the next generation of postings for enforcement officer's throat, Ontario. And so there were several jobs across the province and my wife and I were both from Timmins, Ontario, which is in the great white North. So there was a posting in Timmins. And I said to my wife, you know, I think I'm going to apply for this job. And this is going back to 1988.

Marc Moncion (4m 2s):
So it was, it was a very long process in order to, to actually be hired as like five interviews. And, but anyway, I was selected, then I became a transportation enforcement officer, which was an on-road enforcement officer. The interesting thing about Northern Ontario compared to the South is in the North. You have to really be a generalist because there's not a lot of personnel. So you have to learn everything from weighing trucks, to inspecting vehicles, to dangerous goods, to cargo security, to opening and closing inspection stations, to, you know, just, I had to learn everything, which in hindsight was great because in the South they earmark you for specialties based on what you're good at.

Marc Moncion (4m 48s):
So one would be the dangerous goods specialists. The other one would be the CVSA specialists and other one would do investigations while in the North, you had to do everything. So I did that for, you know, 1988 until 1994. And then they created the facility audit program in which was essentially you're, you know, you've got a bigger stick. So you're going from on-road enforcement talking to drivers, to off-road enforcement, where you're talking to company owners. And what was the interesting things when I would use to be on the road, the drivers would say, my company is forcing me to do that.

Marc Moncion (5m 23s):
And you know, I'm sorry, I'm overloading, or, you know, I'm working too long or my vehicle is not well maintained if the company's fault. Well, when you look at the flip side, I'm now interviewing the company owners, and they're saying it's the driver's fault. If those guys would only do proper, pre-trip do a better job at that. So, but there's this essentially carrying a bigger stick. And then in the late nineties, if you recall, Weil started flying off trucks.

4 (5m 49s):

Marc Moncion (5m 49s):
Vincent. And there was just one, actually a few days ago. I don't know if you saw that on the news on the 401k.

4 (5m 55s):
Yes. Excellent.

Marc Moncion (5m 58s):
Yeah. So when that happened, I had finished my law degree and I had finished my CITB designation and the director of the compliance branch at back in the day invited me to work on a secondment, which was basically rewriting all of the truck safety violations, which I did. So I made a lot of new friends with these increased spines and all these new new programs and policies. And eventually I was promoted to the carrier sanctions and investigations office. So that was in, in 1998.

Marc Moncion (6m 31s):
And then I moved on, I was an administrator writing a lot of policies and programs dealing with industry, getting to know stakeholders in the industry, meeting Chris Harris. I think that's when we first met. And then thereafter, I went into a team lead function with the ministry, and basically I was leading the team writing of the policies and programs. And I was doing a lot of speaking engagements and there was one speaking engagement. I was talking about CVOR and other initiatives with the government and the largest trucking insurance company, a CEO was in the audience.

Marc Moncion (7m 7s):
And after the speaking engagement came to see me and said, we need to hire someone like you to work in head our safety programs with this insurance company, which I ended up doing, did that for about three years, then the economy took a bit of a dive and they ended up consolidating the company under like four companies under one umbrella. A lot of people ended up being outsourced from the roles. So I got into a little bit of consulting work. I wrote three books with the Canadian trucking Alliance and Quebec.

Marc Moncion (7m 40s):
I wrote their transportation of dangerous goods manual in English and French, and also hours of service and thereafter, I ended up working for probably the largest waste management company in North America. I started with a role strictly in Ontario, and then I got promoted to all of Canada. And then I was promoted to all of North America. So I was the international director of safety for waste management. And then there was, our company was acquired after the company was acquired the same kind of thing with this insurance company where they ended up consolidating.

Marc Moncion (8m 13s):
There was two of me, one was an incumbent with the company. The other one was me. So we ended up parting ways. And it's around that same time where the largest three PL in Canada reached out to me to be their head of safety. And that kind of worked out well because I was traveling a lot with this waste management company. Like I was gone three weeks a month. I was hardly ever home. And that was very difficult. Like I'm a very strong family oriented person. I was gone three weeks a month. And so I was kind of the moons aligned with that.

Marc Moncion (8m 43s):
I ended up working pretty well strictly in Canada, but I had a team of about 50 people across Canada on the safety front. We did some recruiting up in Jamaica, some Jamaican drivers working of all places in Northern Alberta, you know, that, that was kind of the mandate there. And I spent a bit of time up in Europe as well, recruiting some drivers in Europe. And, you know, then ELD started emerging in the marketplace and Lez, you know, Chris, I'm very active in all social medias and there were after the head of fleet, complete human resources reached out to me and said, similarly to what had happened with the insurance company.

Marc Moncion (9m 25s):
We don't have anybody with your kind of background. Like we have a lot of superstars that do product development, research and development, you know, we don't have, and that's where I kind of fit in. So I started off with fleet complete as the product owner where I oversaw the hours of service product. And then as the company continued to grow and through acquisitions, we've now gone worldwide. We have offices worldwide. I evolved into a head of safety compliance and regulatory affairs.

Marc Moncion (9m 57s):
And we had the acquisition of big road, which I spent a lot of time with the big road folks. And we just kept on growing. And I took on a more corporate role. And eventually like as of last year, I moved into an executive role and I'm now the vice president of safety compliance and regulatory affairs. So I'm really proud of that. I'm known in the industry within the company as a subject matter expert. I have my own, I have my own button on the, on the big road fleet, complete website, which I'm really proud of.

Marc Moncion (10m 29s):
And it's basically called ask the expert. So I get asked questions from all different capacities, all around the world in different languages. And there's a team that helps sort of cue these questions to me. And I, I respond back whether you're a client or a non-client or a prospect, you know, if you want to know something about a truck, a bus, a truck driver, a bus driver, anything involving regulations, you know, you can reach out to me. And it's my pleasure to answer those types of questions.

Marc Moncion (10m 59s):
I have well over a hundred blogs that I've written, both fleet complete and big road. It's on the ask the expert sites. So you just have to click the button. I touch pretty well. Every department at athlete complete and big road. I don't have staff actually working for me, but I interact with the salespeople, the tech support people, business developments. I'm kind of like the, the acid test. Whenever the company is trying to put something new out into the marketplace, they'll push it out to me and say like, you know, w what do you think about this?

Marc Moncion (11m 31s):
What would this resonate with our customers or not? So I've helped reshape a lot of the programs, the product to make it very, very user friendly. So I'm really becoming an advocate for a lot of our customers. I get a lot of calls. I'm on a lot of calls where customers have now deployed ELD, and I've come to find that there's a lot of misinformation, lack of knowledge, in terms of hours of service. So when people used to work in the, in the paper world, but now under ELD there's violations or unsure what these violations are, why they're happening, they don't know how to use this.

Marc Moncion (12m 10s):
Yeah. They don't know how to use the sleeper berth functions properly. The rules are different. As you know, Chris Kennedy, the United States are very complicated East the West, even, there's a lot of nuances and it keeps the safety dog busy and it keeps the Merck most, you know, busy as well. So, yeah, I'm, I'm having a lot of fun. I get to tell you, it's like a, it's like a second wind, you know, I'm doing things that I really enjoy doing. So it's, it's gone very well.

Chris, Safety Dawg (12m 38s):
It's cool. I mean, obviously with the advent of LDS in the States that created, I mean, there was always a need before that happened for electronic logging devices, but then when they mandated that, of course there was a lot of holdouts that all of a sudden companies like fleet complete, I got a lot more customers.

Marc Moncion (12m 59s):
Yep. I go back to the day, if you recall, where we were getting close to the milestone date in the United States, and people were always of the mindset that at the 11th hour, they would just resend the rule. Well, you should've seen the mad dash at the 11th hour. Like we had people, you know, all hands on deck at fleet, complete people working 24 seven people being pulled from other capacities to answer questions, to help with the onboarding I was flooded with, with, with stuff. But you know, it all worked out really well.

Marc Moncion (13m 30s):
And now in Canada, there's not going to be the grandfathering clause.

Chris, Safety Dawg (13m 35s):
No, I was going to say work. We're going to do the same stuff here in Canada. Just about, yeah.

Marc Moncion (13m 40s):
It's going to be a little bit different though. I think in Canada, because for the better part, as you know, a lot of the movement of goods is North South. So a lot of the allergic careers are already ELD compliant with the United States where the catch is going to be. And as you know, it's the third party certification process of which I'm on the stakeholder committee with transport Canada and the Canadian council of motor transport administrators. The self certification is going to be quite different. And you're going to see a lot of US-based motor carriers that are using noncompliant Elda, wanting to come into Canada.

Marc Moncion (14m 14s):
They're gonna, these guys are gonna just like, sorry, we were not certified by the, by the, by transport Canada. We can't service you in Canada. So that's, it's going to create an issue. I think the other thing is,

Chris, Safety Dawg (14m 27s):
Or the American, the American carriers.

Marc Moncion (14m 30s):
Yes. Yeah. That is the other thing. Yeah. And that, and the other thing I think is probably going to happen is, as I alluded to earlier, the rules are different candidate than us. There's, there's a lot of nuances like in Canada, our rules for the better part are much more flexible than the United States. The exception is the personal conveyance requirements, as you know. Yeah. So you're going to have motor carriers in the United States using personal conveyance. And as soon as they cross the border into Canada and they're pulling a trailer or they're carrying a load, they're going to stay to the officer at the scale I'm using personal conveyance.

Marc Moncion (15m 6s):
And the officer's going to say, well, sorry, you can't use personal conveyance in that fashion in Canada, but it's going to be problematic.

Chris, Safety Dawg (15m 14s):
I think there's three videos I've completed about one, about the personal conveyance rule in the States. And then two more about how Canadians are getting tickets because they're legally using personal conveyance in the States, but when they cross the border, as you say, they're not legal now.

Marc Moncion (15m 33s):
Exactly. That's problematic. And as a former regulator, I always wish governments would get on the same page. It's easy for me to say that now that I'm in private industry, I couldn't say that when I was with the ministry, but even within the provinces, you don't have, you don't have agreement. You know, like the Western Canada doesn't want the cycles in the East. They want more flexibility. It's just all over the place. Now you you're adding the United States, the mix, it's just, it CA it creates so much complexity.

Marc Moncion (16m 5s):
Like even within the company I work for, I'm constantly educating staff about, you know, these new rules and how it's gonna affect them and how the rules engine has to be tweaked Canada and the United States. So that that's been very interesting for me.

Chris, Safety Dawg (16m 20s):
Well, and the whole process. Now, I really wonder, as you already said, there's a lot of carriers who have ELD. Most of these ELD systems come from the U S and not all of them are large competitors of fleet complete. There are some really small people, and I really questioned whether some of those smaller companies even know that there is a mandate to get them themselves certified, to be legal in Canada.

Marc Moncion (16m 53s):
It's going to be a real challenge if you're not on, on, on par, like you take, for example, in the United States and the federal motor carrier safety administration website, the list of certified EOB vendors, if you've ever gone on that site, you can see like ours, as an example, we have everyone is obliged to post their, their user manual. Well, you got some user manuals there that are like 10 pages long. You know, th the, the rulemaking is like over 500 pages, you know, like, don't tell me you've done all of the functional requirements within the rules engine with a page 10 page, user guide, you know?

Marc Moncion (17m 27s):
So, so that's going to be, that's going to be pretty interesting, I think as we, as we move forward. So looking forward, looking forward to that, I'll be very busy again with this, this next phase in Canada.

Chris, Safety Dawg (17m 38s):
Well, when I understand that the they've opened up, or they put out the request for ELD providers to submit their devices now, so that they can be certified here in Canada. Is that true?

Marc Moncion (17m 52s):
Yeah. So they're working through, there's a, there's a process that hasn't been, I would have hoped like a little more engaging, you know, you compare it to the United States. We get flooded with information in Canada. Like they don't have the team that they have in the United States. They have a much smaller group of people, but they've done things such as putting, you know, have you seen their FAQ on the, on the transport Canada's website? They have an Epic queue that, yeah. You should maybe go on there.

Chris, Safety Dawg (18m 19s):
Okay. Can you send me the link? And I'll put it in the show notes so that, yeah.

Marc Moncion (18m 25s):
Yeah. So it's, it's transport, Canada created an ELB, which you need to know web link and on it, it's got the Canadian ELD standards. It's got the FAQ, there's another, there's an info byte on there as well. And they've been engaged, they've engaged vendors and myself on behalf of fleet, complete big road. I've sent them a whole list of comments and questions, because again, the functional requirements in the United States are different than the functional requirements in Canada. I was hoping they'd be the same, but they're not, you know, just there's the Canadian flavor of the day part of it.

Marc Moncion (18m 58s):
So it's keeping me gainfully employed. I can tell you that it's keeping me busy to, yeah. There are some, some changes that people will have to be aware of.

Chris, Safety Dawg (19m 9s):
So in Canada, I mean, one of the big differences between Canada and the U S rule is that ELD is, have to be certified so that we don't get into the mess that I read an article in the States that they figure somewhere between 25 and 50% of the ELD that are on the FMC essay website actually don't meet the standard.

Marc Moncion (19m 33s):
Exactly. Yeah, you're correct. You're correct. That's probably it maybe even be higher. I don't know, but what's happening is, is ELD vendors are become decertified all either voluntarily or what's typically happening is when the trucker gets stopped at roadside. The officer asks for the ELD output file to be displayed. And it's very prescribed what the output file must look like. It's much different than your standard log. And if it doesn't have these additional parameters, it actually flags the officer at roadside that this is a noncompliant device.

Marc Moncion (20m 7s):
The other is when they do the ELD data transfer with the rod system. If it doesn't transmit correctly, according to the parameters of the dut, that's another flag that would then get escalate to FMCSA, and that would trigger the decertification process. And the other, the other thing is the ELD information packet that has to be surrendered the driver card. Now in Canada, it's gonna be different because we're not following the EAD rod data transfer.

Chris, Safety Dawg (20m 37s):
Yeah. I mean, the Canadian devices have to do the rod data transfer. And for the listeners, what we're talking about is how does your roadside enforcement officer get your information from the electronic logging device? That transfer system is what we're talking about. Yep. And so there's a certain protocol that all the ELD do now, but in Canada you just said, we're not going to follow the same thing.

Marc Moncion (21m 3s):
We're not, Nope. There's not going to be any raw data transfer process. It's basically the driver is going to be asked to PDF the actual logs, either the log for the in question or the log and the previous 14, which in Canada is 14. Whereas in United States, it's seven. And it's simply going to be [email protected] just email that PDF to me. So it doesn't go to like a, a third party repository and gets bounced back to the officer at the, at the roadside or the scale.

Chris, Safety Dawg (21m 39s):
I mean, that sounds really good, except for if I was running Northern Ontario where we know, and I mean, Canada just doesn't have the cell phone network that other countries may have. There's a lot of areas that aren't covered yet.

Marc Moncion (21m 52s):
Exactly how that's going to be captured. Chris is basically in regulation. The officer's going to say, okay, do we have coverage for you to email me the via the PDF? If the cell service isn't there, then the regulation says you must know being in a position to display it to me. So display it on the tablet or on the phone. And where another thing that's getting challenging is the third option being printing, not every trucker has a printer in their truck.

Marc Moncion (22m 23s):
So what is also challenging is officers are not going to go into the cab of the truck. So there is some technology where the device is actually hardwired, tethered to the truck. So then the driver's saying, well, mr. Officer just come up on my running boards and I'm going to show you my, my device while the officer some will get on the running board, some are going to say, no, you have to actually physically give it to me. And, and there are some drivers and companies being charged in the United States for that very thing.

Marc Moncion (22m 54s):
If they cannot physically give the device to the officer. Now, the other thing that's kind of interesting. Something talking about features with, with our product to make it user friendly. When I was working with big road, I said, you know what? We gotta do. We gotta lock in like the actual inspection mode lock that in, because not that officers are going to start purposely going through someone's personal records, but if you don't lock it in and just show the logs that the requesting an officer couldn't inadvertently start looking at other things, right?

Marc Moncion (23m 27s):
So, so I've, I've got this system where the driver will lock into inspection mode and all the officer can see are the logs for the Dane question. And also the, if they want to review their DBIR, their driver vehicle inspection report, we have that capability as well. But the officer cannot go on a tangent and start looking at family pictures and, you know, looking at other things, et cetera. So that's just another user-friendly thing I tried to do for the truckers with fleet complete and big road.

Chris, Safety Dawg (23m 55s):
Yeah, no, yeah. I mean, privacy, we all know privacy is hugely important and you know, we're still in the midst of COVID when they're talking about tracking devices for people who are infected or became infected and, you know, privacy, it just, I'm not sure where all that's gonna go and I'm not sure that truck drivers understand how much information big data has on, on everybody.

Chris, Safety Dawg (24m 26s):
You know, and now a lot of it is there's no name associated with it, but there's an awful lot of information.

Marc Moncion (24m 32s):
You're certainly as certainly as even with this, COVID like at fleet complete, our businesses really, really boost it up because we do a lot of work with first responders, police enforcement, ambulance, and, you know, they want to know where their assets are at all times. There's a lot of incidents, as you know, in the United States of violence against truckers and, you know, having the ability to know in real time where an actual vehicle is located and telling where drivers should reroute using our fleet tracking software to reroute around all these dispute areas.

Marc Moncion (25m 7s):

Chris, Safety Dawg (25m 8s):
Now is that dynamic? Yeah. Yeah. Not as cool. And again, just for our listeners, when I asked the word dynamic, what happens is in Mark, correct me. Cause this is my understanding of it. And as you know, I'm not in a truck, I don't work for an ELD provider, but to me dynamic means that the truck is on a certain route. And if a highway was to get closed, then the driver gets a notice and is told to reroute, according to the closure saving money.

Chris, Safety Dawg (25m 42s):
And a lot of time for the truck driver is that basically what dynamic means

Marc Moncion (25m 46s):
Essentially. Yeah. Real time, like real time live notices to say, you know, there's actually a dispute at this bridge here in San Francisco though. I think you'd best take the secondary routes or reroute yourself in that fashion

Chris, Safety Dawg (26m 1s):
And, and, and fleet complete knows the truck routes, right? Oh yes, absolutely. Absolutely. Well, you know, our experience in the insurance business, how many bridges we tried to deliver with?

Marc Moncion (26m 14s):
Yeah. I know. I still see the pictures of the bridges on Facebook and so on for truckers is the signs right there. It's not 13 feet six here. Don't go here.

Chris, Safety Dawg (26m 24s):
Yeah. Well, that's what, you know, with this. It just, it's more complexity when you're trying to do dynamic routing, obviously. I mean, it's obvious to me and I just wanted you to say it that fleet complete knows the truck route and wouldn't send the driver off on some inappropriate area. Exactly. Yep. Yeah, exactly. Talking about the Canadian rules or the LLDs any idea when they might come into effect, what have you heard?

Chris, Safety Dawg (26m 55s):
I know, you know, it was June, 2021 is the last date I actually heard.

Marc Moncion (27m 2s):
Yeah. June 13th, 2021. There's not going to be a grandfathering provision. The decision was made to not do that. Unlike what happened in the United States, where they had the phased in approach with automatic onboard recording devices, right. To then full ELD, for those that didn't have ELD while in Canada, it's just going to be full ELD. Now, the other thing that's really key and for your listeners is this is a federal law. This is transport Canada, federal law. So a lot of carriers that go North South will likely still have an ELD, which will then have to be compliant with the Canadian requirements.

Marc Moncion (27m 38s):
The same motor carriers that traveled East West would likely still deploy ELD. Now some fleets and you know this as well, some fleets have a mixed fleet. They say summer ELD, summer paper logs, like as a former safety director, that's very complicated to try and manage a mixed sleep. One day, the drivers on paper logs the next day, he's on electronic logs and he's got to account for his previous 14 days. So a lot of carriers have just said, let's just go fully LD.

Marc Moncion (28m 7s):
East-west where the challenge is going to be. Are the interprovincial carriers. So basically the carriers that stay within the domiciles of a province. So say Ontario, unless the government of Ontario elects not to adopt the rule, then these carriers will technically be exempt. Now I am, I'm anticipating provinces. Like Ontario has already made the statement to the minister that we will comply with the rules. Same thing with some province out in Western Canada, some have remained silent, but I'm anticipating hopefully full, full compliance, because it's going to be confusing for those carriers that are sometimes in ELD, sometimes not in ELD.

Marc Moncion (28m 50s):
So that'll be interesting to see.

Chris, Safety Dawg (28m 53s):
Well, just to be clear though, this is a federal law. So anybody that goes outside of their base province will have to comply. And that's June the 13th, you said 20, 21,

Marc Moncion (29m 3s):
June 13th, 2021. Now the other thing, and I haven't heard this yet and you know yourself, like some provinces have different requirements for hours of service than others. So a gain like you take in some provinces, the elapsed 16 hour rule applies and others, it does not in some provinces, the cycler rules don't apply in some provinces, the single and the team drivers are somewhat different. You know, you know, the emergency and adverse road conditions is North of 60.

Marc Moncion (29m 36s):
You have different requirements there. So it's, it should be fun. Yeah. That's the one word for it. It should be fun. Well, and the biggest thing is I wonder how, what carriers or what ELD providers who are currently servicing Canadian companies are not going to bother getting certified because I imagine to two points to that one, it costs money. And some of them may not have enough business structure here in Canada to justify the outlay.

Marc Moncion (30m 9s):
And the second part is because they have to comply and our rules are more flexible, which I think equals complexity. The programmers are going to go crazy, trying to make their device compliant. Yep. So there's be a lot of money in it. There's, there's a lot of development work. And the team at big road have been working diligently with me as well. I'm providing all of the rules, engine nuances to them. Like I'm not a developer, right?

Marc Moncion (30m 40s):
So when I talk to the team, I say, I don't know how to code this, but I'm telling you if you're going to go North of 60, the hours in a day are different. You know, the off duty times, the splits they're all different. So I provide them with all the regulatory nuances, but then they go ahead and develop the programs. And we have regular meetings, update meetings where they, they advise how they're coming along. But I fully anticipate a fleet complete to be a hundred percent compliant.

Marc Moncion (31m 11s):
We've actually even got an official letter. That's been written by our executive vice president, honoring the fact that, you know, at fleet complete big road, we are going to be fully compliant. Not only us side, but Canada side and provincially as well.

Chris, Safety Dawg (31m 26s):
Yeah, that's great because I'm not aware of many other Canadian ELD providers.

Marc Moncion (31m 36s):
There's, there's a couple of them. There's a couple of we're, we're one of the largest, if not the largest ELD vendor.

Chris, Safety Dawg (31m 43s):
Well, I mean, I, I did some work with, and I'll mention them fleet Rover. You won't, but I will, but I mean, I know that you have fleet complete, also has an association. I don't know what I haven't heard from fleet Rover in a long, long time. We don't even know if they're still operating at the moment, but they were Canadian as well out of the, the high tech area of Waterloo,

Marc Moncion (32m 7s):
Right? Yeah, you're correct. Yep. Yep, absolutely.

Chris, Safety Dawg (32m 10s):
Yeah. So anything else you want to say about the Canadian rules? And so we got the date we got, it's going to cost money. It's very complex. What else is happening here in Canada for ELD, or even, are there any hours of service changes coming there? Aren't,

Marc Moncion (32m 31s):
There aren't any contemplated, but I'm hoping, you know, the government of Canada takes this opportunity to perhaps revisit some of the requirements. You know, I sit on the committee, they haven't actually pushed that out to the stakeholder group, but if they do, I'm certainly going to make comment on areas where I think it would modernize the requirements. They certainly, our rules are much more flexible than the United States already. So I wouldn't want to make them even more flexible, but things such as, you know, in Canada, we have a specific definition of a day.

Marc Moncion (33m 5s):
Like that's very complicated, right? So, so for a fleet that has 50 drivers, they can all have different definitions of a day and they keep that definition throughout their cycle until it resets. And it makes it also very complicated for the enforcement community. I, as a former governor government auditor, I would go in and audit carriers. If I had a carrier that had like eight different definitions of a day, it made my job complicated. But you know, that's one thing I already alluded to the personal conveyance requirements.

Marc Moncion (33m 36s):
I find they're pretty restrictive. I think that would be an opportunity to, I wouldn't go full bore like the United States, because it's very difficult to enforce based on the language.

Chris, Safety Dawg (33m 48s):
Yeah. They've, they've opened that up to a lot of fraud, I think.

Marc Moncion (33m 52s):
Oh yeah. It's, it's very, very difficult to enforce that personal conveyance requirements. Now there's a whole detailed document. I'm sure you've looked at it where you can qualify for, for the personal conveyance. The other big difference between the two countries is in the United States, you have a number of, of lobby groups, stakeholder interest groups, and you can't please everybody. Like I think you've heard about the last hours of service reforms that are, that have been proclaimed. I'm not sure if it's going to happen by September 30th, 20, 20, that's the push.

Marc Moncion (34m 25s):
But you have, you know, the American trucking association, the truckload carriers association pushing in favor of the law. You've got the Teamsters against the law. You've got a, there's an organization that represents the rail industry. Yeah. Crash. They're pushing against it. You have truck drivers that are saying it hasn't gone far enough. You don't, you don't see that kind of like, you know, in Canada, we've got the Canadian trucking Alliance, we got OTA and all the provincial associations and they're all in favor of ELD, but you don't really hear a lot on the flip side of things.

Marc Moncion (34m 60s):

Chris, Safety Dawg (35m 1s):
No. And sorry about the U S law. And I was going to ask you what you thought of it, but I really don't believe we're going to see that change come this year.

Marc Moncion (35m 11s):
Yeah. I've heard a lot of rumblings because of that. There's a new regulation coming place with the USDA. It's through their fast act thousand 15 fast act. And I'm thinking it could delay it. So take a, take an ELD vendors such as ours, like big road. I've already, I put a whole detailed chart together, the, the current and the new and how it differentiates from one another. So we have to plan that it's going to happen. So the development we're cast to actually get done.

Marc Moncion (35m 43s):
Right. But it's just like, if they don't move with the regulation, it's wasted time and money for my company, right? Because the developers are working on certain things. They could be working on something else for the company. Now we've got to amend our rules engine to account for a reg change in the United States, which may or may not happen. So we got an air on the side of caution and I've, I've, I've directed them to, you know, update the rules engine to accommodate these changes under the hope that if it does get changed, at least we're going to have the work done and not have to do like a mad scramble at the 11th hour.

Chris, Safety Dawg (36m 20s):
Yeah, no, it's crazy. And then of course you've only got so many resources and right now I imagine you've got a lot of resources working to get everything compliant with the Canadian stuff. Then all of a sudden you've got all this little, not a little side job, but you've got another job to make a complaint with a possible new us rule that may or may not take effect on September. I think it was 28 is what I had heard. But, you know, because they tied it to a bill,

Marc Moncion (36m 51s):
They did tie it to a bill. Yep.

Chris, Safety Dawg (36m 53s):
That's gonna delay it. Yup. So, yup.

Marc Moncion (36m 55s):
So how did that group, the owner operator independent drivers association.

Chris, Safety Dawg (36m 59s):

Marc Moncion (37m 0s):
Yeah. They're, they're dead set against it as well. They think it hasn't gone far enough type thing, or just get rid of, let's not have any hours of service rules altogether. You know, each stakeholder group has legitimate concerns and you know, it's just trying to, trying to please everybody. It's just not going to happen really

Chris, Safety Dawg (37m 19s):
Well. I'm of the, the belief that if we just all drove, when we were wide awake and not fatigued or anything, we wouldn't have needed the hours of service. I know, but because we allow people to push us for many reasons, we sometimes choose to not do the right things as humans and

Marc Moncion (37m 40s):
Everyone gets painted with the same brush. And that's the unfortunate thing, you know, but it's a, that's how regulations work. It tends to be very reactionary. It's like the wheel off legislation, people are being hurt. So let's throw a $50,000 fine at you through absolute liability. And now let's how about, how about the enforcement side of it? Like you can have all the rules in the world, but if it's not going to be enforced, then that's another problem in itself, right?

Chris, Safety Dawg (38m 5s):
Yeah. Just before we wrap up Mark, what else do we want to cover?

Marc Moncion (38m 10s):
Well, I'm, I'm pretty good with what we talked about, unless you want to go into more detail about the U S rules, but there may be a little premature. Now we can perhaps follow up if we know there's a concrete

Chris, Safety Dawg (38m 23s):
When there's a date. Yeah.

Marc Moncion (38m 24s):
Yeah. Then, then if you wish to have me on, we can have a discussion just about the rules on that front. And that'd be my pleasure to join you for that.

Chris, Safety Dawg (38m 32s):
Yeah. I think that would be super actually cause yeah, because so many of our drivers do cross the border. They need to understand the rules and the last company I was working with intimately, I found out again how the drivers really don't understand the rules. The ELD says you're in violation and they go, why? Yup.

Marc Moncion (38m 53s):
Exactly. Well, I'm here to help. And again, I post a lot of material on ask the expert if ever you're looking or your audience is looking for anything. You go to big roads, homepage, sleep completes homepage. I have my own little button called last, the extra. You just click on that. And likely if you're curious about something I likely have written about it already.

Chris, Safety Dawg (39m 14s):
Well, we'll put a link in the show notes to the ask the expert I got to, I don't know why I'm tripping over that. Ask the expert. Shouldn't be that difficult. We'll put a link in the show notes, right? To it. Your contact info is in the show notes. Of course. Yep. And Mark, I want to thank you so much for coming on the show with gravy interview. Thank you. Okay.

Marc Moncion (39m 35s):
My pleasure. Always a pleasure chat with you, Chris, have a great day and congratulations on the podcast as well.

Chris, Safety Dawg (39m 40s):
Hey, thank you. Have a great day.

3 (39m 45s):
I hope you love the show. As much as I did. Please leave us a, like a thumbs up a review, a comment, a rating. If it is, thank you so much. And I do really appreciate your time and join us again next week for another exciting

2 (40m 3s):