The CTA has written, published, and posted to its website, a list of goals and objectives for whichever party wins the election in October this year. Will any of us live long enough for any of these goals and objectives actually become a reality.
TRUCK SAFETY: CTA and its provincial trucking association partners stand
by our commitment to work with all levels of government to enhance truck
safety on our nation’s roadways. And while the vast majority of carriers in
the Canadian trucking industry are already committed to operating at the
highest safety standards, there is also a small – but growing – number of
carriers that do not share this priority. These carriers do not make the same
level of investments in their operations, their equipment, their training
policies and corrective oversight mechanisms. Let’s take action and work together to improve road and truck safety.
LABOUR: There are a number of factors underpinning the driver shortage. However, chief among them is that the industry is facing a demographic crisis. Not only does the industry have one of the oldest and most rapidly aging workforces, it also simultaneously struggles to attract new drivers to the industry producing a demographic model that is unsustainable. Today, the average age of a truck driver is 46 years old (projected to reach 49 years old by 2024) compared to 41 for the total labour force. At the same time, the industry has very few young people choosing to enter the occupation despite the fact it pays higher than average wages.
Today, only 8.8% of the driver pool is under 30 years old, and that proportion
continues to decline. While this is a challenge for trucking companies now, it
will soon be a problem for the wider economy as shippers continue to struggle to secure truck transportation services.
Driver Inc.: A new and troubling business practice has emerged in the trucking industry, and as a result the government is leaking tax revenue by the truckload. Known as ‘Driver Inc’, a number of drivers and carriers are now entering into agreements whereby drivers will incorporate themselves and will then sell their driving services to the carrier. It is important to note that these are not traditional independent contractors (known as ‘owner-operators’ in trucking). What distinguishes these individuals from owner- operators is that these drivers do not own, lease or operate a vehicle. They drive the carrier’s vehicles and are virtually indistinguishable from an ‘employee’. CTA first raised this issue in late 2017 and since then have been working with the Canada Revenue Agency (CRA) and Employment and Social Development Canada (ESDC) to help educate authorities on the impact and spread of Driver Inc. This issue has only intensified since that time. Many of the companies and drivers involved in this scheme are knowingly avoiding many of their tax responsibilities, including paying the appropriate source deductions (CPP, EI, etc.) among other taxes. From the driver’s perspective, many are knowingly and unknowingly taking advantage of small business tax advantages not otherwise available to them. The government needs to better protect legitimate small businesses in our sector, who’s reputation and livelihood is being threatened by those who engage in the Driver Inc. model. CTA calls on the next federal government to better enforce the positions already taken by both CRA and ESDC on the use of the Driver Inc. model.
Don’t Leave Small Business Behind: When developing laws and new regulations, the federal government needs to remain mindful of the capacity of small business to understand and effectively implement these changes. This is not to say that small business does not want to adapt, but rather, the resources available to small business to implement change is much less than that of larger organizations. The trucking industry is dominated by small and medium sized businesses, which are often family owned. In this, there are tens of thousands of trucking companies in Canada with 100 employees or less. When the government enacts new laws or regulations, more attention needs to be paid to ensuring that small business has the guidance and support it needs. Too often we find small business is either unaware of new regulations or is incapable of implementing changes in a timely and cost-effective manner. This is particularly evident in the federally regulated employment sector, which tends to be dominated by mega-sized businesses in telecommunications, the banking sector, and other modes such as air travel. In each of these cases, the resources available to these businesses vastly outnumber those available to small businesses in sectors such as trucking. This is also true for other complex initiatives such as the implementation of the federal carbon tax. There are very few trucking companies with true ‘legal’ or ‘regulatory affairs’ departments which means they are forever playing catch-up to larger entities who have fully staffed departments dedicated to these areas. It is more important than ever that the next federal government be aware of the tremendous pressure businesses are under and to ensure small businesses are not left behind.
The Trucking Industry is Committed to Carbon Reduction: CTA has supported Environment Canada’s heavy truck regulations which have added billions in direct costs for the industry. The logic to adding a carbon charge on top of this is questionable. Carbon pricing has always been touted as intended to spur changes in behaviour, in the long-haul trucking industry, there is limited options for change. Currently, there are very few wholly-viable and widely available alternatives to the diesel engine. This fact is recognized in the Environment Canada regulations governing carbon emissions from trucking equipment. Consequently, the Canadian trucking industry finds it difficult to understand the policy intent behind adding carbon pricing to our diesel fuel as there is no true ‘alternative’ and the equipment on the market is already strictly regulated by Environment Canada from a carbon standpoint. Nonetheless, if a carbon tax is to be in place, CTA supports a policy that redistributes the revenue back to industry. In this, revenues should be used to support programs that incentivize the purchasing of newer and greener trucking equipment along with supporting the retrofitting existing equipment wherever viable. Contact CTA for a copy of our environmental plan.
Access to Immigration Channels: Unlike other industries, such as manufacturing, truck driving is an occupation that cannot be off-shored or shipped overseas. In turn, domestic demand for trucking remains strong, with the industry’s share of the total transportation sector only expected to grow. While the industry is taking steps on a number of fronts to help address its labour shortages – from increasing wages to better marketing the opportunities available in the industry – it will likely not be able to meet its labour needs over the coming years without increased access to labour through immigration. CTA would like to see the next government increase the industry’s access to immigration programs and to work with CTA to ensure the industry is supported in attempting to meet its labour needs.
Recognized Employer Status for the TFWP: In early 2018, CTA supported Trucking HR Canada (THRC) in hosting roundtable sessions across the country as part of their sector review of the Temporary Foreign Worker Program (TFWP). The overall goal of the process was to gather together relevant stakeholders – including employers, government officials, third-party consultants and other key individuals – from the trucking and logistics industry to discuss labour-market challenges within the sector. In particular, discussions regarding current recruitment and retention challenges directly fed into a larger conversation regarding the TFWP and ways in which the Program (inclusive of policy and service standards) could be amended/enhanced to improve the employer application experience and outcomes. In all, the review provided an analysis of key program areas including processing times, consistency of service, processing fees, work permit renewal times and application requirements. In addition, the review also provided a number of recommendations for program improvement. One of the chief recommendations was the need for a ‘trusted employer’ vetting process to expedite and streamline the Labour Market Impact Assessment (LMIA) process. CTA stands ready to help the next federal government administer a recognized employer program for the trucking industry and is willing to dedicate resources to such an initiative.
Provide Trucking and Logistics Employers Greater Access to Programs That Support Better Quality and Effective Training: While existing programs are being used in our industry, such as the Canada Job Grant, and the Apprenticeship Program in Ontario – more needs to be done to support employers. Mandatory-entry level training which will be in place in all provinces by 2020 will come with increased training costs. While this is needed to boost training quality, financial assistance from the government could help to manage this transition and support employers and new entrants. CTA is proposing that the next federal government undertake a pilot program to help assist new entrants in our industry. This could support enhanced training as it is envisioned that only select schools and employers with proven track records could participate. The end goal of this is to support and encourage more Canadians to consider truck driver as a career option and to better facilitate their entry into our sector. CTA requests that a conversation take place with the industry on how the government can support industry in raising the training bar in our sector.
Labour Code Exemptions: CTA supports modern labour standards; however, the Alliance has always held the position that any new standards that come into place must make sense for the industry and the customers we serve. Recently, a few provisions were introduced into the Labour Code without consultation which posed a serious threat to our industry (and other transportation modes). These primarily related to how scheduling in our industry works. Since that time, IPGs have been drafted to provide the trucking industry (and other transportation modes) some relief when it comes to these new provisions. This relief provided in these IPGs by ESDC now needs to be put into regulation. Only then can our industry be assured that they can continue to operate as they did before September 1, 2019. Having these exemptions made official will also help to assure all those in the economy that rely on trucking, that their supply chains are secure. This should be an early priority for any new government.
CTA’s 10 Point Action Plan on Truck Safety: Most trucking companies and truck drivers embrace a culture of safety by going well beyond minimum safety standards. However, events over the past few years have shown what can happen when carriers and drivers do not embrace a ‘safety first’ culture in their operations. This reminds us we can continue to raise the bar and should continue identifying and addressing companies that do not take their responsibilities seriously. CTA encourages the next government of Canada to ensure that Transport Canada continues to show leadership when it comes to truck safety and continues to address oversight and compliance shortcomings in the industry for both new and existing carriers. CTA has a 10 point action plan to help and you can view more about this plan at: http://cantruck.ca/wp-content/uploads/2019/09/CTA-Pre-Election-Discussion-Paper_public.pdf re.