A Catalyst for Supply Chain Profitability

Fleet Size/Kilometres Travelled

If there is a change in fleet size or kilometres travelled, the operator must contact MTO Carrier Sanctions and Investigation Office to have a CVOR update application sent to them.

Note: Changes to fleet size and rate of travel are not automatically captured through the province's vehicle registration system (for example, licence-plate renewal, permit purchase or deletion).

– Source – MTO Commercial Vehicle Operators Safety Manual – as of 2021-02-19. Emphasis is mine.

When you work in compliance – whether it is oversight and management responsibilities for  your employer, or as in my case, as a consultant assisting others, guidance such as that above is fundamental to our activities. We guide our actions based on such policies. Participants in the industry are assessed, and at times sanctioned based on our degree of compliance with such regulatory mandates.  As such, perhaps the reader can share my confusion when one of my clients sent me the following message. It was in response to a request to update the Fleet Size and Kilometric distance travelled “…….   .  FYI we no longer need mileage updates, only fleet size so the form will look different just as a heads up.”

A call to the Carrier Sanctions and Investigations Office (a title obviously created with the intent of encouraging  the community it regulates to contact them) provided me  an auto-attendant speech of  great length and limited value. And as is the rule, the solution I sought was not a click away. The voice pre-emptively tells me that processing of certain applications, which has absolutely no relevance to my investigation, yet which I cannot avoid hearing,  is currently being done for those files received in October of 2020. After having taken a material amount of the customer’s (my) time, without consideration to my needs, I am connected with a voice immeasurably unsuited for such a role based on tone and eagerness expressed upon connection. I pose my question – When filing a fleet size adjustment, do we no longer need to report changes in mileage, as is the stated policy? - To which the succinct response was provided – No, we only do that on the annual renewals now. -

So I reach out to industry peers and pose the question – Hey were you aware????? And the response, from members including the paralegal community and other consultants was – an equal degree of confusion as my first reaction. Naturally, this prompts discussion: mileage is a key factor in carrier safety ratings?   Using mileage as a key determinant has been one of the bragging points of the MTO since their much ballyhooed  CVOR revision over a decade ago? And now, unannounced it is relevant only annually – regardless of what may happen to your fleet distance. So – a carrier sees the mileage basis of their fleet fundamentally change (for instance, a manufacturer for whom they supply transportation, moves from one jurisdiction to another) and this will not be accurately reflected for a period of time that could potentially extend to 12 months. Yet one’s exposure to activities with the enforcement community will change to reflect the new reality. Which, in turn, will reflect upon the carrier’s safety scores.

But I digress -  I move forward with my quest for an understanding, and am eventually rewarded -not from the Ministry, so caveat in place: The MTO wants to know when your fleet size increases by 20% or more prior to your renewal date. Once you report a fleet increase they will take the average Kilometric travel of the vehicles that were already listed and prorate the additional vehicles by that amount, which of course will also adjust your threshold. If at the time of your actual renewal you state their travel is more than the average that was used they will adjust your threshold number at that time to reflect the new number. Long story short you’re not going to be given KM over and above what your average has been until you can prove you actually are.

Now – do I have an issue with this as an approach to safety data? No. But I have a significant issue with how this change has happened in the complete absence of any communications to the industry, or even an update to the official policy as quoted in the opening of this commentary.

When your primary product is your knowledge of the policies, practices, procedures and requirements  of a given arena, lack of knowledge is detrimental to one’s reputation and deliverables

A carrier who acts in contravention to a written policy is held accountable to the written standard – one needs look no further than the Maintenance Statement component of a carrier compliance audit, as discussed in the same document quoted in the opening statement to this commentary. If the carrier had changed their practice but not their written policy  the assessment would still be based on the written standard.

I have voiced my concerns on the lack of vision on the behalf of this ministry before (see the article here Time for the MTO....) They insist on operating as if computers, databases, newsletters, and even LinkedIn do not exist. They decline to take advantage of the opportunities that exist to improve their product, service and communication. We need only compare the difficulty of accessing one’s safety information as provided via the level II CVOR versus that offered by the US counterparts in the form of SMS/BASICS & SAFER, or the ability to file a challenge using Data-Q as opposed to Ontario’s options, to validate this assessment. We still can’t get the CVOR points assessed against a driver on the personal CVOR abstract?

Why are we doing this arcane exercise in the first place? Why do we have the renewal form as a separate exercise?  This should be a matter of logging onto our password protected user profile, making the necessary adjustments and done.

Are there not methods of efficient industry communication to disseminate important and regulatory information?

Can we not keep our official reference pages current? Make the change to your policy at the same time you change the written policy.  Again – from the official Webpage as of today:

Commercial vehicle operators safety manual
The Carrier Safety and Enforcement Branch of the Ministry of Transportation of Ontario has prepared this guide to assist and ensure that truck and bus companies (commercial-vehicle operators) operate safely and are compliant with the regulations that govern highway use. (emphasis mine)

I understand we are in the midst of an epidemic of historic proportions – but surely we can do better than this? Indeed, this is exactly the type of work that can be undertaken effectively in our current environment (even if the underlying activity does not actually represent an improvement to the goal of the program).

There is a significant difference between a cost and an investment – and successful businesses recognise this. The MTO continues to be completely lacking in the ability to discern the difference and it is a travesty. We should not accept such conditions in silence, or else we shall not see a change we so sorely need.