Accidental Carrier Bulletin
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Background
An accidental carrier is a company, whose primary business is not the transportation of goods, equipment, materials, or people, but currently operates a commercial vehicle performing these functions. Examples of accidental carriers include, but are not limited to:
A construction company transporting a telehandler and/or materials such as rebar or concrete forms from their shop using a pickup truck and trailer.
A landscaping company moving equipment like a skid steer or hauling yard waste to the dump in a dump trailer behind their work truck.
An oilfield hot shot driver using a pickup truck and flatbed to hauling gear to site.
These scenarios illustrate how companies accidently take on the role of a "carrier". Consequently, they might not fully understand the responsibilities associated with operating a commercial vehicle weighing between 4,501-11,793kg or above.
What Rules Do I Need to Follow?
This bulletin addresses the most common situations faced by companies operating commercial vehicles weighing between 4,501-11,793kg. All the references mentioned can be found in the “2022 Commercial Vehicle Safety and Compliance in Alberta manual” and apply to all accidental carriers regardless of GVW. [1]
Safety Programs
A safety program is a formal written document that provides safety guidelines and expectations for all employees within a company. Anyone can prepare a carrier’s safety program so long as the final program contains at least the minimum requirements set out in regulations. The owner and employees of a company must be able to understand, implement and follow the safety program Pg (5-3).
In our industries a safety program consists of:
1.Occupational Health and Safety (OHS) program, which is how you ensure the safety and wellbeing of your workers; and
2.National Safety Code (NSC) Program, which is the transportation specific safety program aimed at maintaining public safety on the roads and elsewhere.
Every company and every worker is protected under Occupational Health and Safety legislation. No matter the size and maturity of the company, the employer has obligations to protect their workers. The company your work for should have Workers Compensation Insurance and likely has a safety association like the Alberta Motor Transport Association to help them develop their safety program. In fact, your company may also have a Certificate of Recognition or (COR) or SECOR. If not, you may want to consider pursuing a COR/SECOR to benefit from a standard OHS system layout and WCB rebates.
Safety Fitness Certificates and Operating Status
If your vehicles weigh between 4,501-11,793kg and you only operate within Alberta, you typically won't require a Safety Fitness Certificate. However, if you are operating vehicles in Alberta over 11,793kg you will need to have a provincial Safety Fitness Certificate. If your vehicles cross provincial or national borders and weigh over 4,500kg, you're considered a federal carrier and will require a federal Safety Fitness Certificate. This means you must comply with the National Safety Code and obtain a safety fitness certificate (see Pg 1-5).
Insurance
Carriers must ensure they have the appropriate insurance coverage for their vehicles and the nature of their operations. In addition to general liability and vehicle insurance, you might need Cargo Insurance and/or Liability Insurance, especially if you transport dangerous goods (see Pg 1-8).
Drivers License
Different vehicles require different classes of licenses for operation. Often, drivers with a Class 5 license are found operating vehicles with three axles, which requires a Class 3 license. Some drivers might also need an air brakes endorsement. Therefore, it's important to review your vehicles and verify that your drivers hold the correct class of license for them (see Pg 3-1).
Class of Plates [2]
There are three types of commercial plates. Class 1 plates are for commercial vehicles transporting their own or others goods cross border. For example, a traditional trucking company for hire. Class 2 are for transporting goods withing a 10 km radius of the registered address and does not cross a border. For example, a farm vehicle plates or other specialized permitted industry. Class 3 plates are for companies that transport their own goods. Ensure you have the correct plates for your business by consulting with your registry agent. (Pg 3-2)
Decals
Commercial vehicles that 4,500kg or more kilograms must have the following information displayed on the left and right sides of the vehicle:
• The name or registered logo of the vehicle’s owner;
• The vehicle’s TARE weight;
• The licensed maximum gross weight of the vehicle (GVW) (Pg.4-2)
The letters and numbers listed on the side of a vehicle must be at least 50 millimeters in height. They must also be a different color from their background so that the information is clearly visible. In addition , all information listed on the vehicle must be accurate.
Daily Trip Inspections
In Alberta, commercial vehicles like trucks and trailers over 4500kg must be checked every day to ensure they're safe to drive. This check is based on a list of defects and major defects found in Schedule 1 (Pg 6-12) [3] that need to be inspected to catch any minor or major problems. This list must be kept in the vehicle and shown to an officer if asked. Vehicles that don't meet these safety rules, including issues noted in Schedule 1 should not be on the road. If a major defect found during the daily check or at any other time, the vehicle must not be driven. It's the responsibility of both the vehicle's owner and the driver to follow these rules (Pg 6-4).
Cargo Securement
All commercial vehicles, must secure their cargo well enough to prevent any movement that could make the vehicle unsafe to drive and ensure that they use the correct number and means of securement. This includes making sure nothing can leak, spill, or get blown away. Additionally, all vehicles must be suitable for the cargo they carry, ensuring nothing shifts, falls, or escapes during transport. Special rules for farm vehicles that carry hay or straw short distances exist as well (Pg 5-1).
Our Services
AMTA can provide members with one-on-one guidance on the information provided in this bulletin. If you have any questions, please contact AMTA and our experienced staff will be happy to help. For your Safety, Compliance, and Human Resources questions, please email Workplace Support Services at wss@amta.ca or call 1-800-267-1003.
References
1] Commercial Vehicle Safety Compliance in Alberta. (2022, July). In Government of Alberta. Pg 5-15, Retrieved March 28, 2024, from https://open.alberta.ca/dataset/da0a07b9-4be8-48ab-807e-574a78d8a043/resource/ff267997-26e2-43fe-a68b-0da1f99e586c/download/trans-commercial-safety-in-alberta-2022-complete.pdf
[2] Commercial Vehicle Safety Compliance In Alberta. (2022, July). In Government of Alberta. Pg 3 1-2 Retrieved March 28, 2024, from https://open.alberta.ca/dataset/da0a07b9-4be8-48ab-807e-574a78d8a043/resource/ff267997-26e2-43fe-a68b-0da1f99e586c/download/trans-commercial-safety-in-alberta-2022-complete.pdf
[3] Commercial Vehicle Safety Compliance In Alberta. (2022, July). In Government of Alberta. Pg 6 12-14 Retrieved March 28, 2024, from https://open.alberta.ca/dataset/da0a07b9-4be8-48ab-807e-574a78d8a043/resource/ff267997-26e2-43fe-a68b-0da1f99e586c/download/trans-commercial-safety-in-alberta-2022-complete.pdf