Thank you for the opportunity to participate in this important dialogue around motorcoach safety.
At the outset, I think it's important to remind ourselves that on the whole, motorcoaches are the safest mode of surface transportation, and second only to airlines in incidents per distance travelled.
That being said, no means of travel, in fact one could argue no human activity is ever perfectly safe. No matter how good your record, there is always more that can be done.
One thing I have learned about safety in over 20 years' experience in both government and industry is that there is no such thing as “safe”. There is no magic end point; you're never done and there is always something more that you can do next.
Briefly, these are the areas where industry and government can work together now to have the greatest impact on improving motorcoach safety: increasing seat belt use, finally moving forward on electronic logs, improving enforcement, and doing a better job of collecting and analyzing motorcoach safety data. I look forward to discussing these points further during your questions
There has been a lot of talk about seat belts lately. First, with regard to seat belts, let me be clear that the industry unequivocally supports them. We have been calling for a federal manufacturing standard and requirement for over a decade, lobbying which has, frankly, been largely ignored.
But despite the lack of interest by governments, around 2009, the industry and manufacturers moved to make seat belts standard equipment even without a regulatory mandate. And so, for almost the past decade, most new buses have come with three-point belts installed, although there are noticeable exceptions due to the lack of manufacturing requirement. We are moving forward as quickly as possible to ensure all coaches are equipped with belts, but because the lifespan of a motorcoach is 18 to 20 years—and I think that question came up earlier—it will still take a few more years before we get 100% adoption.
With respect to retrofitting, it's complicated and possibly dangerous if done incorrectly, and there was a bit of discussion with the previous panel about that. It's not as simple as just changing the seats, or worse, just adding belts on to existing seats. To be done properly, you need to anchor the seat to the body of the coach, which usually requires the coach to be ripped open and modified, potentially changing the structure of the coach, depending on how old the coach is and what it was originally manufactured with. And if the belts are improperly installed, they are a much greater safety risk than no belts at all because the belts themselves can become the safety hazard. It is frankly a difficult option for most coaches, unfortunately.
There is also an important issue regarding provincial laws creating driver liability for ensuring minors wear belts. Despite CCMTA agreeing many years ago that the provinces needed to remove the liability for bus drivers, only Quebec has done anything about it. The issue here is that the liability exists only if the coach has belts. If there are no belts, there is no liability. Thus it's been a very real disincentive for operators to install belts—a disincentive that most have ignored, but not all. This needs to be addressed.
But at the end of the day, the fact that a majority of coaches now have three-point belts means that given the very low usage rate, that's really where the problem lies. This is one area where we could all do a better job by getting people to wear their belts. We don't need a new law, as some have suggested. It's already the law in all provinces that you have to wear a belt if you're on a moving vehicle. It's just not enforced and it's not culturally done. So, we as an industry are looking at what we can do to increase usage.
Improving coach safety, however, goes beyond simply the issue of seat belt use.
We need the government to get on with mandating electronic logging devices, ELDs. Again, the industry has supported making these mandatory for some time. We accepted grudgingly that the Canadian government would not act until it saw what the U.S. government did for the sake of harmonization. But the U.S. law was announced years ago and has been in effect since 2017, yet we still don't have a clear path forward on Canadian regulations.
The existing “hours of service” regulations are adequate, and while some will pick at the details, liking this aspect and wanting to change that, remember that the current rules are the result of years of consultation, study and debate. They were not arrived at lightly, and there's no evidence that the rules themselves contribute to fatigue. But cheating does. And that's why we need ELDs now to make sure that drivers don't exceed the regulations.
And speaking of better enforcement of existing rules, little or nothing ever seems to happen to get unscrupulous operators off the road. For the most part, the safety regulatory regime is in fact sound. We have enough laws, but what we need is better targeted enforcement at the provincial level on those bad actors who ignore the good laws.
Finally, one of the frustrations that I think everyone trying to improve motor coach safety experiences is trying to find accurate motorcoach safety stats. In most road safety stats, we are categorized as commercial vehicles, lumping us in with trucks; or we are deemed buses, but that includes transit vehicles and school buses. Transport Canada and the provinces need to break out and make available the specific collision data for motorcoaches so that we can all do a better job of understanding the trends and the real causes of fatalities and injuries. Then we can all figure out what the next step forward is, because there should always be a next step forward.
Thank you. I look forward to your questions.
