The System in place currently has been broken for a long time, and solutions offered by Industry have yet to be
acted upon.

(the below is an exert of a communication that was sent by the PMTC to the CCMTA, Transport Canada & The
Council of Ministers Responsible for Transportation)

Currently Commercial Motor Carriers who wish to operate a trucking fleet in Canada must apply for a Safety
Fitness Certificate to the Provincial Authority in which they plan to licence their vehicles. If the Provincial Authority
of the base jurisdiction approves the application, a National Safety Code (NSC) will be issued to the Carrier. The
base jurisdiction is then responsible for monitoring the motor carrier for safety and compliance, based on National
Safety Code 14, which is a Memorandum of Understanding (MOU) all jurisdictions agreed to several years back.
https://www.ccmta.ca/en/national-safety-code

While in theory this process comes across as seamless and consistent, the reality of how carriers are monitored
from one Canadian provincial jurisdiction to the other vary significantly. For instance, if you were to run a Safety
Fitness Certificate from a carrier based in Ontario and then run one from a carrier in Alberta, it would be almost
impossible to compare the safety rating of the two fleets and decipher which one is the safest of the two.

The substantial differences in how one jurisdiction scores a carriers’ provincial safety rating compared to another,
also leads to chameleon carriers simply closing shop in one jurisdiction and opening in another, exploiting the lack
of communication between jurisdictions and simply open again in a different location. In addition, there are many
carriers in Canada, who exploit the lack of a central reporting system, and the lack of checks and balances in place
between jurisdictions. They start several fleets, register each of them in different jurisdictions with different
National Safety Code Numbers. When they face challenges in one jurisdiction, they simply continue to operate in
the others by transferring vehicles over to the fleet in different jurisdictions so they can continue to operate across
the country despite an undesirable safety profile.

The recent case with Chohan Freight Forwarders in British Columbia illustrates the current problem. The fleet had
its operating authority suspended in British Columbia but had another federally regulated fleet operating out of
Alberta. The absence of a coordinated and centralized system has basically allowed this fleet, deemed unsafe by
one jurisdiction, to continue to operate across the country, including into the province that just suspended their
operating authority. A fleet should only be allowed to have one National Safety Code Number. A central reporting
system would alleviate this type of unsafe practice and ensure a proper tracking system across the country.
https://www.trucknews.com/health-safety/b-c-asks-feds-to-reduce-safety-gaps-following-overpass-crashes/1003181013/

To further showcase how the lack of a centralized and uniformed regulated system may cause alarming road safety
issues, a simple internet search by one of our insurance company members demonstrates the seriousness of the
problem. Back in 2022, it was found that 34 Trucking Companies were listed as operating at the same address in
Dartmouth, Nova Scotia, while another 54 companies were found to be listed as operating at one address in
Halifax, Nova Scotia. Most of the emails associated with these companies were the same, from a consultant in
Brampton, Ontario. A quick check at the time showed no trucks were located in either of these locations, despite
records showing 88 trucking companies being registered at these locations. This is just one example of “jurisdiction
shopping” when trucking companies set up their business in a location to save on operating costs, insurance,
oversight, or can easily “relocate” as a result of being shut down in another jurisdiction.

To rectify this issue, we need a national recognized MOU that is more descriptive than what is currently in place
and has some teeth, to create a standardized Carrier Provincial Safety Rating. We must ensure that all the regions across the country monitor and audit carriers following the same consistent criteria with results easily accessible from a central reporting system/one stop shop. Hence, everyone will be able to see and compare a carriers’ safety rating score regardless of the region from which it has been completed and submitted. A seamless access to results
about the carrier’s compliance/non-compliance must be easily accessible to all, including the shippers who could
then verify the safety of the fleet they are hiring.

To achieve this goal, coordinated and harmonized jurisdictional regulations are needed. The current
inconsistencies in regulations and enforcement from one jurisdiction to another reduces efficiency and increase
burdens and cost to the industry. Sadly, it also leads to some carriers who do not have safety and compliance at
the top of their priorities to go jurisdiction shopping to find the one with the least stringent regulations to register
their fleet in.

The Private Motor Truck Council of Canada has been raising this issue at meetings with governments since 2015,
and the most recent case in British Columbia highlights the seriousness of this issue. It needs to be addressed
promptly by regulators, & the PMTC is ready and willing to work together with regulators on this process.

Questions regarding this article please contact :

Mike Millian President

Private Motor Truck Council of Canada

trucks@pmtc.ca