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Agriculture committee  Initially, because we are talking about something we would like to put in place in the relatively short term, that clarification or guidance, particularly utilizing our existing regulations in subsections 76(1) and 76(2).... Ideally, as I mentioned, harmonization with the United States is preferable.

October 26th, 2023Committee meeting

Susan Fitzgerald

Agriculture committee  Yes. Thank you very much, Mr. Chair. That is an excellent suggestion. As was mentioned before, individual companies are not going to report to an association and so on the number of violations they've had, and not every company is a member of our association. Certainly the data and the true numbers of infractions should reside with those enforcement agencies.

October 26th, 2023Committee meeting

Susan Fitzgerald

Agriculture committee  Well, as you heard from Mr. Fehr this morning, they do schedule and plan loading and unloading spots, but when you get into those situations where you have limited alternative routes in terms of infrastructure, whether that be roads or bridges, etc., and one of those is closed or out—and we have the same sort of situation in northern Ontario as well with crossings coming across the top of the lake—it's a very difficult situation to then find alternative routes and to keep that load moving.

October 26th, 2023Committee meeting

Susan Fitzgerald

Agriculture committee  That's correct. We're talking about giving those drivers the assurance and the peace of mind that for doing what they know is best for the animals in their care, they're not going to be charged. You may hear from Transport Canada the concern about driver safety, and something they asked us was whether we could provide them with data or research on commercial truck crashes and any relevant research on ELDs.

October 26th, 2023Committee meeting

Susan Fitzgerald

Agriculture committee  Thank you very much for that question. I'm going to ask my colleague Mr. Shantz, who works at a transport company, to give an example of that.

October 26th, 2023Committee meeting

Susan Fitzgerald

Agriculture committee  Thank you for the question. What drivers are doing now when they're making that decision to go over their hours of service to benefit the animals in their care is recording the reason for that overage in their electronic logging device. That would be noted in case an inspection officer were to ask for their electronic logging device and noticed that they were over their hours of service.

October 26th, 2023Committee meeting

Susan Fitzgerald

Agriculture committee  Certainly. Thank you for the question. For sure. The situations we're talking about are not due to bad planning. The transporters have laid out their route and scheduled the times. What we're talking about are unforseen situations. These situations, as I mentioned, could be adverse weather, traffic accidents, bridge outages.

October 26th, 2023Committee meeting

Susan Fitzgerald

Agriculture committee  That's absolutely correct. My colleague, Mr. Shantz, who is joining me here this morning as well, perhaps has something to add to that, but, as was identified, both with the panellists here now and previously, loading and unloading animals is a stressful situation for them, so we want to get them to their planned destination as quickly and safely as possible.

October 26th, 2023Committee meeting

Susan Fitzgerald

Agriculture committee  That's correct. It's not like it's a frequent occurrence, but it does occur, and we want to ensure that the drivers feel comfortable. As I said, we don't want to put them in the difficult position of having to choose between complying with their hours of service by going off duty and safeguarding the care of the animals they're transporting.

October 26th, 2023Committee meeting

Susan Fitzgerald

Agriculture committee  Thank you very much, Mr. Chair. The Canadian Livestock Transporters' Alliance is pleased to have been invited by the standing committee to appear before you today in relation to electronic logging devices and animal transport. Our association represents commercial livestock transport companies.

October 26th, 2023Committee meeting

Susan Fitzgerald