We appreciate the invitation to appear today.
For those of you who are unfamiliar with us, the Manitoba Trucking Association was founded in 1932. The Manitoba Trucking Association represents about 300 member companies. Our member companies represent over 25% of the for-hire trucking companies in Manitoba, whose fleets represent over three-quarters of the trucks licensed in Manitoba.
As Mr. Bradley mentioned, the MTA is a member of the Canadian Trucking Alliance.
I would suggest that it is generally accepted by those who have reviewed reporting on this subject that the trucking industry is safe and has seen consistent improvements in safety results.
Before I get into some TDG-specific considerations, I'll very briefly provide an overview of some of the Manitoba industry initiatives being driven by the MTA. I'm doing so to provide some context and insight regarding the safety culture of trucking in Manitoba. While I'm here today speaking from a Manitoba perspective, I can confirm that all other CTA member associations are engaging very similarly within their provinces.
The mandate of the MTA is to develop and maintain a safe and healthy business environment for its industry members. The inclusion of the word “safe” and its mention as a primary consideration by our member companies is not accidental. This statement highlights a core value of our membership and guides the work of MTA staff.
In June 2012 the MTA board of directors took a position in support of the creation of a trucking industry certificate of recognition program. The intention of this program was to create industry-specific tools and education that will assist trucking companies with their safety and prevention activities. Last month, SAFE Work Manitoba approved this initiative, and we are currently working with them on the implementation of this item.
I would like to note that the elements being sought under an industry-specific certificate of recognition program align very closely with the major components of an SMS, as indicated by Transport Canada, such as commitment by the organization's senior management to safety as evidenced by the endorsement of safety policies, measurable safety objectives, and clear organizational responsibilities and accountabilities for safety, as well as a variety of other items.
For years, the MTA has been an active participant in the creation and delivery of industry-specific education and training tools, such as partnering with Apprenticeship Manitoba on the creation of the designated trade of commercial truck driver. We partner with Manitoba Public Insurance on the entry level professional truck driver training program. We are currently partnering with the Province of Manitoba on an English-at-work program specific to the trucking industry, and we consistently deliver industry-specific regulatory training, including TDG training.
While not all of these have a specific safety focus, let alone a TDG focus, we mention them to highlight the culture of education and training supported by the trucking industry. While I can't provide any specific evidence that a culture of ongoing education and training has a direct positive impact on industry safety, it is our belief that there is an innate connection between increased education and training and improved safety results.
In direct response to some of the questions under consideration today, such as what additional measures could be taken to strengthen TDG safety across all modes of transportation, I'll provide some specific suggestions in conclusion, but prior to that, I would like to bring to the committee's attention Transport Canada's “Commercial Vehicle Safety in Canada” annual report for 2009, that being the most recent year available.
One of the items the report speaks to is Roadcheck, which is an annual safety inspection program undertaken across North America, including Canada, the United States, and Mexico. The report confirms that the 2009 Roadcheck out-of-service rate is slightly better than the previous year's figures and continues an overall national downward trend in the out-of-service rates over the last 12 years. In addition, the Canadian results were better than those reported in the U.S.
The report also indicates that commercial vehicle results in all categories, including inspections and incidents such as fatal personal injury and property damage, are all reporting lower; i.e., they are moving in a positive direction. This was also notwithstanding the fact that vehicle kilometres travelled are also increasing regularly. The report specifically states, “As can be seen...[from] the trend in collisions and casualties from 1990 to 2009, Canada's road safety record continues to improve.”
Specific to TDG incidents, a brief scan of CANUTEC's annual statistics shows an extremely low number of trucking incidents, especially relative to vehicle kilometres travelled. As Mr. Bradley mentioned, the specific number of TDG vehicle kilometres travelled isn't known, but it is believed to be substantial, as the majority of TDG shipments travel by road. The CANUTEC scan also shows that TDG incidents are decreasing over time. While the report doesn't speak to the scale of the incidents, the opportunities for large-scale events during road transport are extremely limited.
In answer to the question on whether the implementation of safety management systems should be adjusted to provide a greater focus on the transportation of dangerous goods, we believe the consistent annual improvements in road safety demonstrate the effect of the current regulatory regime.
While we aren’t suggesting enhancements in the current regulatory system or that industry’s current results shouldn’t be targeted, we are of the opinion that focusing on the system in place and discussing how to increase its effect would provide the greatest value to government and industry.
The previous comment being made, outside of anything contained in the Canada Labour Code and/or any provincial workplace safety and health legislation, the 2011 CCMTA report entitled “Addressing Human Factors in the Motor Carrier Industry in Canada” indicates that 71% of trucking companies already have some safety management system in place.
Has the implementation of safety management systems improved the safety of our transportation regime? Again, we can't comment on other modes, but Transport Canada’s information on road safety results shows that the trucking industry is continually improving in terms of road safety. While I wouldn't suggest that one can attribute these directly to safety management systems, it does suggest that current industry practices under current regulatory regimes are having positive impacts.
Safety isn’t just a regulatory function for the trucking industry. There are very well understood consequences of being unsafe, and we believe the results indicate the trucking industry understands this and is managing accordingly.
In regard to some additional measures to strengthen TDG safety for road transport, while I have spoken very briefly on the positive trends in road safety results, we would also suggest that the current system and industry’s results are not something that couldn’t benefit from continued efforts towards improvement. With this in mind, I put forth two items for consideration: greater involvement in road safety by all parties involved in the supply chain, and the strategic use of technology to enhance road safety.
Section 1.5 in part 1 of Canada’s TDG regulations states very clearly that dangerous goods “must be handled, offered for transport, or transported in accordance with these regulations”. This means that all parties involved in the supply chain, from those packaging and loading the product, to those hiring the transportation service provider, to the transportation company, bear responsibility for the safe movement of these goods.
We would suggest that improved means of limiting the ability of some in the supply chain to hand off liability and risk to others in the system would increase the overall quality of the system. Again, while this consideration is not predominant, especially when it comes to TDG activities, it is common enough that we believe it is worthy of mention and recognition as an opportunity for improvement.
As a member of the CTA, we also support the national positions maintained in relation to electronic logging devices and roll stability systems. Specifically, we would also suggest that a national mandate requiring all trucks where the driver is currently required to carry a paper logbook under hours-of-service regulations be equipped with an electronic logging device. Also, we would suggest a manufacturing standard in concert with the U.S. requiring all new heavy trucks to be equipped with roll stability systems. Both of these items would provide increases in regulatory compliance and road safety. While this isn’t specifically a TDG opportunity, the TDG road shipments moved under these initiatives would naturally benefit from the overall improvement in road safety.
Thank you for your time.