COMPLIANCE CIRCULAR
NO. #03/17
March 24, 2017
SUBJECT:
Enforcement Policy re: Transition period between Paper Logs and Electronic
Recording Devices
Managers, Victoria
Regional CVSE Managers
Area Vehicle Inspectors
Deputy Director, CVSE
ADM, Highways Department
Passenger Transportation Branch
Trucking Industry
Carrier Safety Inspectors
Government Agents
Law Enforcement Agencies
Commercial Transport Insp.
(Inspection Stations)
ICBC
PURPOSE OF CIRCULAR
To advise that Commercial Vehicle Safety and Enforcement (CVSE) has a new policy directive
providing guidelines for the use of paper logs to record hours of service (HOS) while a carrier is
testing or a driver is being trained on an electronic recording device.
This policy does not allow a carrier or a driver to keep more than one daily log except in the
circumstances outlined below, and does not remove or reduce a carrier’s or driver’s responsibility to
maintain accurate information in a daily log as required under MVAR 37.18.06.
This policy will be amended as needed once a federal policy regarding this issue is determined.
BACKGROUND
Current legislation regulating daily logs does not address the need for a period to transition from
paper logs to electronic recording devices while still ensuring that carriers and drivers are able to
maintain accurate and complete daily logs.
In order to assist carriers in making the transition, the National Safety Code (NSC) program office
has been in the practice of issuing letters to carriers granting permission to run concurrent paper
logs while training drivers or testing new electronic systems.
In an effort to harmonize with the approach taken in neighbouring jurisdictions and to facilitate a
smooth transition for carriers as the use of Electronic Logging Devices (ELDs) becomes a
requirement in the US by December of 2017, CVSE has developed the following policy to advise
enforcement staff regarding when a driver is allowed to keep concurrent logs and not be considered
to be keeping duplicate log books.
Under the new policy, carriers will no longer need to request letters from the NSC program office or
have the letter carried in each of the vehicles, as per the conditional requirements below.
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APPLICATION
While a carrier is testing a new electronic recording or logging system or training drivers on the
system, the carrier may allow their drivers to use both a paper log and an electronic log for a short
period of time in order to ensure that they have accurate and complete time records during the
transition period.
It is anticipated that training a driver on a new electronic system would take no more than 14 days.
The driver should make every effort to ensure that the concurrent logs are identical. Any issues or
reasons for discrepancies should be noted in the comments section of both the paper and electronic
log.
In order to not be considered a violation under MVAR 37.18.06(1) “A carrier must not request,
require or allow a driver to keep and a driver must not keep more than one daily log in respect of
any day” when using both electronic and paper log, CVSE has set out the following criteria:


Driver must clearly note in the comments or remarks section of both the paper and electronic
log at the beginning of each day:
o Declare that the electronic log or device is being tested or being trained upon,
o Declare which log is the primary log that is to be considered as true and accurate (may
be either paper or electronic),
o Declare the secondary log that is being used as a testing document or device.
Driver must advise the officer that they are testing or training on an electronic device if
stopped and inspected and present the primary log or device as the true and accurate
document.
At roadside or during an NSC audit, if an officer has the supporting evidence that the logs are being
used in a false or non-compliant manner, the carrier or driver would be exposed to any applicable
enforcement action that would be deemed necessary, including fines and/or out-of-service
conditions.
All hours of service records must be retained in accordance with record-keeping requirements under
MVAR Part 3 – Hours of Service of Division 37 of the Motor Vehicle Act Regulations
For further information on the use of concurrent logs during the transition from paper logs to
electronic recording devices, please contact the NSC program office at 250-952-0576 or via email at
[email protected], or Karen Coverett, Manager, NSC, at [email protected] or Cole Delisle,
A/Deputy Director, CVSE at [email protected].
Steve Haywood
Director, Commercial Vehicle Safety and Enforcement Branch
Ministry of Transportation and Infrastructure
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