Thank you for the opportunity to speak today.
My name is Scott Ross. I'm the executive director of the Canadian Federation of Agriculture. I should be joined shortly by our vice-president, Pierre Lampron, who is a dairy farmer from Quebec.
The CFA is Canada largest general farm organization. We represent over 190,000 farmers and farm families across Canada. They are the heart of the Canadian agri-food system, generating $135 billion of Canada's gross domestic product.
The concern farmers and ranchers have with electronic logging devices is not about hours of service but about recognizing the unique accommodations and flexibility required for the humane transport of animals. Our cargo, unlike freight, has unique temperaments that can lead to challenges and delays in getting the animals loaded or unloaded. Due to this, sometimes it takes longer to load a particular group than was planned. This can see the ELD beginning to calculate hours of service well before animals are loaded, putting unrealistic time constraints on farmers and drivers.
Drivers take their jobs very seriously, and animal care is a big part of transporting live cargo. Patience and attention to detail are crucial for animal transporters. Drivers hauling live animals cannot simply pull into a rest area and go off duty if they unexpectedly cannot get to their destination within their hours of service. Most of our livestock trailers are passively ventilated, which means the load cannot remain stationary for prolonged periods of time; it must be kept moving to attain optimum airflow and temperature control.
The issue at the heart of the matter is that unforeseen delays or events coupled with the functionality of the ELDs and hours of service can lead to animal welfare issues. These unforeseen situations can include adverse weather, traffic accidents, border crossing delays, road closures and breakdowns at processing plants that can hold up loading times.
We are not seeking a blanket exemption from ELDs or hours of service, but instead flexibility in enforcement of hours of service when unforeseen circumstances arise. We cannot leave drivers in difficult situations when doing what's best for animals would see them fall out of compliance with hours of service regulations.
As it stands, the commercial vehicle drivers hours of service regulations permit drivers to extend the driving time allowed during adverse driving conditions or emergency situations in order to reach their destination for the safety of the occupants and the security of the load. However, it's unclear whether this includes animal welfare considerations, leaving the matter open to interpretation by individual officers.
Ideally, Canada would align with U.S. transport regulations and provide an exemption for animal transporters from drivers' on-time duty within a 240 air-kilometre radius of their load's origin and destination. This would not only align regulations on both sides of the border but would also recognize the unique considerations needed when transporting live animals.
However, this regulatory alignment could take time. In the interim, we need immediate guidance for all enforcement officers that clearly states that animal welfare issues are defined as emergency situations in subsections 76(1) and 76(2) of the commercial vehicle drivers hours of service regulations.
There are precedents for such treatment, with the Canadian Food Inspection Agency accommodating infrequent unforeseen events in their enforcement of feed, water and rest intervals.
Both driver safety and animal welfare need to be considered. This requires an interdepartmental solution from Transport Canada, Agriculture and Agri-Food Canada, and the Canadian Food Inspection Agency.
Thank you for this opportunity to speak today. I would be happy to answer any questions you might have.