A Catalyst for Supply Chain Profitability

Time for the Ontario Ministry of Transportation to move into the 20th Century

I realise everyone else is almost a 5th of the way into the 21st Century. But given that the wheels of bureaucracy turn slowly, the MTO appears to have got stuck at a stop light.

In an era when everything from banking to insurance to travel can be done online; in an era when you can access your credit scores from your phone and makes trades on the stock market from anywhere with an internet connection, it is near impossible to do even the most basic of transactions with the MTO through the internet. Why is this? Why do we have to go stand in a line-up (or rely on the mail with its incredibly poor turnaround time) to renew license plates or driver’s licenses? As a commercial operator, we have to rely on mail to deliver our abstracts, be they fleet CVOR or a driver's abstract to verify the qualifications. We can get a driver CVOR abstract immediately, why only this record?  And have pity on the driver whose time has come to renew their driver medical for their CDL: mail it or drop it in a box at the MTO office, depending on the circumstances.

               Where to submit Your Medical Report

If your physician/nurse practitioner has indicated "yes" or "no" to question 1 and "no" to all questions 2 through 9 on the front of the medical report, please take your completed form to your local DriveTest Centre for processing. Please note: You may want to keep a copy for your records. If your physician/nurse practitioner has indicated "yes" to any question 2-9 on the front of the medical report, please submit your form to the Medical Review Section at the address noted on the form. (http://www.mto.gov.on.ca/english/dandv/driver/medical-review/process.shtml)

Whoever thought of this has no idea what a commercial truck driver’s on the job hourly requirements are. Now a truck driver has to take a day off to get his medical completed, and possibly another day to deliver it? Can't we do better than this?

I became involved with the specifics of carrier safety and compliance in 2004. At that point the FMCSA was already posting carrier information online so carriers could ensure they were meeting their compliance requirements, were aware of and able to respond to current inspection trends,  and even had a method of appealing an unjust ticket or incorrect information. Other carrier's and shippers could use this information to assess the relative quality of a carrier's operations. At that time, Ontario at least provided a dedicated CVOR specialist who could be contacted to assist with appeals, questions and other issues. For instance, if you wanted to make the MTO aware that you were undertaking a concerted effort to address deficiencies that had come to light through inspections and your CVOR scores. Now, we have an email address. Not an improvement, folks.

 Once, not long ago, the level II CVOR abstract that I request the first week of the month, complete with personal information on the drivers in the report, was accidently sent to another carrier.  They were kind enough to let me know, and forward it to me. Not everyone would do that. I have been bounced from person to person within the MTO attempting to correct information on my CVOR that is incorrect. I can’t validate the status of a carrier who I am considering doing interliner business with, because other than one incredibly difficult to locate website, in which it is even more difficult to search, it is pretty well impossible to determine if a carrier is actually licensed. Relying on a carrier to fax or email an easily manipulated document is not the standard of care we should be presented with in this day and age. And if I wish to validate the quality of a carrier's over the road safety performance, and threshold scores? Well, don’t hold your breath. If the carrier chooses not to share that with you, well you can’t get it. Yes, a carrier declining to share this information is like the old saying that failing to make a decision is in itself deciding; it is unlikely that any arrangement would follow by those who exercise diligence in risk management under such a scenario. But it shouldn't come to this in the information age.

The US is introducing the Clearing House in 2020. (https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/CDL-D-A-Clearinghouse_FAQs-V05-1-508.pdf Once active, it will begin to compile data on drug and alcohol testing for people engaged in safety sensitive DOT regulated employment. It will allow a registered party to query a national database to see if a candidate has ever failed a drug and alcohol test, whether or not he or she actually worked for the employer where the failed test occurred. It will maintain records for a 5 year period to comply with the DOT regulations. Think about that for a second. How many individual records will this involve? Recent estimates indicate there are 3.5 million drivers in the US alone. Each one who undertakes interjurisdictional operations needs to do a pre employment at each carrier he or she applies to - and then there are the quarterly random tests - 25% for drug and 10% for alcohol. Given historical driver turnover rates at many US carriers approached, or even exceeded 100%, it's not unrealistic to think that this could result in the number of tests reaching, or exceeding, 7 million tests in a single year. And that is just US carriers - now we need to add in all Canadian drivers who are employed in cross border carrier operations. And we can access it online.  But I digress, sorry, back to the point at hand......

The FMCSA has been publishing carrier safety data for decades.  It’s not like the MTO has to invent something. And you want to talk about improving efficiency and driving down costs.  The sheer amount of human resources that could be re-allocated to responding to issues that need to be addressed (such as audits of carriers with poor CVOR scores) is mind boggling.

This isn’t modernisation folks. This is just how business is conducted in 2019.  The databases exist – they are accessed when we go into the licensing office, or when we submit a request online to mail us a document (average turnaround on this 2 - 4 weeks). It’s time for the MTO to take a good long look at their method of service delivery and consider how they can improve service, reduce processing time, and drive down costs.  No service provider who had to compete for business would possibly adopt this model. As customers, the residents and corporations of Ontario dependent on the MTO for the information and services they provide shouldn’t either.