Electronic Logging Devices (ELD)

Who Will Need an ELD? | What type of ELD is required? | Enforcement Strategy | Important Links

An electronic logging device (ELD) tracks a driver’s hours of service (HOS). Compared to paper log books, ELDs can increase accuracy and decrease falsification in recording HOS. ELDs benefit both highway safety and reduce costs for businesses by increasing administrative efficiencies.

In 2019, Transport Canada revised the Commercial Vehicle Drivers Hours of Service Regulation for carriers that operate across provincial or territorial boundaries. The new regulation mandates all commercial/regulated vehicle carriers, including buses, to use ELDs by June 2021.

Manitoba’s Drivers Hours of Service Regulation adopts much of the federal regulation. The provincial regulation applies to drivers and carriers that operate strictly within Manitoba’s boundaries. As the provincial regulation adopts much of the federal regulation, the federal requirement to use ELDs will also apply to most Manitoba drivers and carriers. The new requirements pertain only to the method used to track drivers’ hours of service. The HOS regulatory requirements are not changing. All the rules related to driving time, on-duty time, rest time, and exemptions are not changing.

Currently, Canadian motor carriers travelling into the United States must use ELDs; this requirement has been in place since December 2017. For more information on the ELD requirements in the United States, visit the Federal Motor Carrier Safety Administration’s website.

The requirement for carriers operating across provincial and territorial boundaries comes into effect on June 12, 2021. The requirement for carriers operating strictly within Manitoba to use ELDs will not come into force until December 12, 2021.

Who will need an ELD?

Commercial/regulated vehicle operators, who are currently required to use a Record of Duty Status (RODS) or log book to record their hours of service will be required to use an ELD.

Commercial/regulated vehicles crossing provincial boundaries, including vehicles that would otherwise be exempt when travelling within Manitoba, will be required to use an ELD, unless exempted under the federal regulation.

The federal regulation outlines some exceptions to the ELD requirement for commercial/regulated vehicles crossing provincial boundaries. Via the adoption of the federal regulation, the following exemptions also apply to carriers and vehicles operating solely within Manitoba:

  • A motor carrier operating under a permit allowing for an exemption;
  • A motor carrier to which there is an existing exemption to hours of service requirements;
  • Vehicles that are subject to a lease/rental agreement that is no longer than 30 days; and,
  • A vehicle manufactured prior to the year 2000.

ELD exception for vehicles remaining within a 160 km radius of their home terminal

Both the federal and provincial regulations exempt drivers and vehicles that remain within a 160 km radius of their home terminal (the location where the driver normally starts and ends their work day) from utilizing ELDs; however, a driver’s daily hours must be tracked.

Manitoba recognizes that some carriers operate only occasionally beyond the 160 km radius exemption.  To support these operators, Manitoba is developing a permit to allow commercial/regulated vehicles to travel without an ELD when making an occasional trip that exceeds the 160 km radius exemption and occurs entirely within provincial borders.
In addition to the exceptions outlined in the federal regulation, Manitoba is exempting school buses that operate strictly in Manitoba from using ELDs. School bus drivers will still be required to maintain a Record of Duty Status.

Operators currently using an electronic log or recorder will need to replace or upgrade those devices to a certified ELD. Carriers with a vehicle that is currently equipped with an ELD should check to make sure that the device is on Transport Canada’s list of approved devices.

Hours of Service exemptions

Manitoba’s regulation currently exempts certain operators from hours of service requirements. All of the existing exemptions will continue, including: farm-plated trucks, emergency vehicles, and municipal transit buses. For a complete list of exemptions, please view Manitoba’s regulation.

What type of ELD is required?

To be compliant with both the federal and provincial regulations, operators must use an ELD that is certified by Transport Canada. The certification demonstrates that an ELD meets the prescribed technical specifications. As of April 2021, Transport Canada has not certified any ELDs; however, certification processes are underway.  Carriers should regularly check Transport Canada’s list of Certified Electronic Logging Devices on its website to find the ELDs that are certified.

Enforcement Strategy

Manitoba is aware that, as of April 2021, it is not possible for carriers to obtain and implement certified ELDs. Working with our partners in other provinces and territories, and Transport Canada, a staged enforcement plan has been developed, which will allow for drivers and carriers to acquire and learn more about the use of ELDs before full enforcement takes place. This enforcement plan may be extended depending on the availability of certified ELDs.

Stage one of the enforcement plan will start on June 12, 2021 and end in December 2021. This stage will focus primarily on education about the use of ELDs. Drivers and carriers will still be expected to be in compliance with hours of service requirements, however, drivers and carriers will not be penalized if they are not using ELDs.

Stage two of enforcement will start in December 2021 and last until June 2022. Enforcement officers will issue warnings to drivers and carriers who are required to use ELDs but are not in compliance. Much like stage one, all drivers and carriers are still expected to be in compliance with hours of service requirements.

Full enforcement of the ELD regulatory requirements is not expected prior to June 2022.

Drivers and carriers who utilize ELDs prior to the full enforcement stage are still required to follow the regulatory requirements with respect to their use.