Transport Committee on Nov. 4th, 2014

[Grant Mitchell]

From a driving perspective, our drivers all have to complete a pre-trip of their unit prior to leaving one of our facilities or one of our yards or a rest area where they may have slept for the night. They have to do a complete pre-trip, which includes doing a mechanical check, checking all their paperwork, and updating their electronic device. All of our units have electronic logs. We don't carry the paper log book other than for a backup if there's a technology issue. There's a checklist in the morning or prior to the start of utilizing that vehicle that they have to complete and document. This checklist is subject to audit not only by our company but also by government regulations.

Once they complete that, then they're able to start with their day. We also ask that they stop a minimum of every four hours—

[Isabelle Morin, NDP, Notre-Dame-de-Grâce—Lachine, QC]

Are those documents Canadian? Do all companies have to complete such documents? Are they all the same, or do they vary from one company to another?

[Grant Mitchell]

All companies are obliged to do this. It's a regulation.

[Isabelle Morin, NDP, Notre-Dame-de-Grâce—Lachine, QC]

That's fine, thanks.

Last week, we talked about the loading and offloading of goods. It was mentioned that accidents often occurred on those occasions. We were told that 70% of accidents happened during those activities. Your website states that, whenever you are going to a new site, you inspect it before accepting the job. I would like to know how that works. How do you carry out the inspection? How does that help reduce the number of accidents?

[Grant Mitchell]

Prior to accepting a new delivery point, we do what we call a journey management plan. We have one of our safety professionals actually physically drive the route that one of our drivers would take, after they load the product, to the delivery site and they identify any hazards, railroad crossings, speed changes, you name it, anything that they see that would present a risk or a change in a driving habit, and they document that right to the site where we offload.

Once they're at the site, they do a complete inspection of the site, looking for accessibility for the size of our units, safety equipment, such as available water, hoses, fittings, you name it. They do a complete site inspection. They come back and they complete what we call a plot card and all the information is on that card, including contact information or any emergency information. All of that is completed before the first load is dispatched to that site. That is uploaded into our technology, our operating system, and until that's uploaded into the operating system, we physically cannot dispatch a unit to that location.

[Isabelle Morin, NDP, Notre-Dame-de-Grâce—Lachine, QC]

Are you often unable to make your way to a site? Is this something all companies do before accepting a new delivery point or did you decide to do that?

[Grant Mitchell]

Sorry, you broke up a little bit when you asked that question.

Could you repeat that, please?

[Isabelle Morin, NDP, Notre-Dame-de-Grâce—Lachine, QC]

First, I would like to know whether you often refuse to go to a site? Do you ask that certain changes be made before you go to a site?

Second, I would like to know whether that is a common practice. Do all companies do that, or are you the only one? Are there regulations on inspections to be carried out before a company goes to a new delivery point?

[Grant Mitchell]

First of all, it's not regulated as far as we are aware. This is a practice we follow and have for a number of years. We do, however, know of many companies similar to us that follow the same practice. Some of our customers do regulate it.

In terms of how many times we would refuse to work at a site, I don't have an exact number. Many times we would make recommendations to the management or leadership of the delivery site indicating some opportunities for improvement. I would say, very rarely, would we actually have to refuse to make a delivery there. We will track them to make sure our recommendations are either followed through or at least that we get a reason why they may or may not be followed. It would be less than 5% of the time that we refuse to make a delivery.

[Isabelle Morin, NDP, Notre-Dame-de-Grâce—Lachine, QC]

Okay.

Although this happens rarely, a number of recommendations are issued following your visits. Should the inspections be mandatory?

[Grant Mitchell]

It may be a bit of a challenge to make that mandatory. I think, from a private industry perspective, when it comes to site deliveries, we need as an industry to make sure we're doing our due diligence. I think it may be difficult to regulate something like this.

[Isabelle Morin, NDP, Notre-Dame-de-Grâce—Lachine, QC]

Thank you very much.

[The Chair, Conservative, Larry Miller]

Thank you very much.

We'll now move to Mr. Watson for five minutes.

[Jeff Watson, Conservative, Essex, ON]

Thank you, Mr. Chair.

Thank you to our witnesses for appearing today.

With respect to safety management systems, there is currently no federal requirement on trucking companies that engage in international or interprovincial trucking to have a safety management system. Is there any provincial or territorial requirement for a safety management system for operations within a given province or territory?

[Jean-Marc Picard]

As an industry, we all follow the national safety code, but it's up to the province to enforce it. Essentially, that's how the industry is set up today.

[Jeff Watson, Conservative, Essex, ON]

So you're not mandated to have a safety management system specifically, although the national safety code may have elements that would conceivably be in a safety management system.

[Jean-Marc Picard]

That's right.

[Jeff Watson, Conservative, Essex, ON]

But a strict safety management system, though, not the national safety code.... RTL, I think you said that you have a safety management system. It would therefore be voluntary. Is that correct?

[Grant Mitchell]

Yes, that is correct.

[Jeff Watson, Conservative, Essex, ON]

Who verifies your safety management system? Is there any external audit that's done on your safety management system?

[Grant Mitchell]

Yes, we in Alberta have what's called the core audit completed annually, and that's by a third party.

[Jeff Watson, Conservative, Essex, ON]

In your opinion, was the decision to have a safety management system made because of the scale of your operations? Is there a point at which safety management systems don't make sense given the size of a company or the fact that you might be an independent owner/operator, for example?

[Grant Mitchell]

As we were [Inaudible--Editor] to their organization, it definitely was a decision to make sure that we understood best practices and how to implement them into our operation to continue to allow us to grow in a safe manner.

[Jeff Watson, Conservative, Essex, ON]

Should they be mandatory for interprovincial or international trucking companies of a sufficient size then?

[Grant Mitchell]

I think they can be incorporated into the national safety code, and perhaps the current code could be something that is revisited on an annual basis based on what they see in the industry.