Evaluation of Road Safety Programs

Report outlining the results of the Evaluation of Road Safety Programs at Transport Canada.

On this page

• Executive summary
• Introduction
• Evaluation purpose, scope, and methods
• Findings
  • Section A: Relevance, effectiveness, and efficiency
  • Section B: The Motor Vehicle Test Centre
  • Section C: Road Safety funding programs
• Conclusions and recommendation
• Annexes
  • Annex 1: Management Action Plan
  • Annex 2: Case study descriptions

List of figures

Figure 1. Road Safety organization chart

Figure 2. Number of fatalities and licensed drivers

Figure 3. Fatalities by transportation mode, 2017-22

Figure 4. Primary contributing factors to fatalities

Figure 5. New zero-emission vehicle registrations per year, 2017-23

Figure 6. Number of recalls per year (vehicles, tires, and child restraints)

Figure 7. Regulations and Oversight and Enforcement FTEs over the last five years

Figure 8. Timeline of MVTC operations

List of tables

Table 1. RSTPP and ERSTPP comparison

Table 2. ERSTPP applications and approved and completed projects by call

Table 3. Selected ERSTPP case studies

List of acronyms and abbreviations

ACTIVE: Analysis of Companies Technical Information for Vehicles and Equipment

ADAS: advanced driving assistance systems

ADS: automated driving system

AEB: automatic emergency braking

AMP: administrative monetary penalty

ATIP: Access to Information and Privacy

CAV: Connected and automated vehicle

CBC: Canadian Broadcasting Corporation

CBSA: Canada Border Services Agency

CCMTA: Canadian Council of Motor Transport Administrators

CMVSS: Canada Motor Vehicle Safety Standards

CVMA: Canadian Vehicle Manufacturers’ Association

ECCC: Environment and Climate Change Canada

EV: electric vehicle

ERSTPP: Enhanced Road Safety Transfer Payment Program

FQESR: Fondation québécoise d'éducation en sécurité routière

FTE: full time equivalent

GBA+: gender-based analysis plus

GOCO: government-owned, contractor-operated

HC: Health Canada

ISED: Innovation, Science and Economic Development Canada

MVSIL: Motor Vehicle Safety Investigation Laboratory

MVSA: Motor Vehicle Safety Act

MVTA: Motor Vehicle Transport Act

MVTC: Motor Vehicle Test Centre

NACTO: National Association of City Transportation Officials

NCDB: National Collision Database

NCR: National Capital Region

NHTSA: National Highway Traffic Safety Administration

NSC: National Safety Code

OAG: Office of the Auditor General

OTC: Ontario Traffic Council

PIPEDA: Personal Information Protection and Electronic Documents Act

PNR: Prairie and Northern Region

PSPC: Public Services and Procurement Canada

PTs: provinces/territories

RCMP: Royal Canadian Mounted Police

RSTPP: Road Safety Transfer Payment Program

SIS: Surface Infrastructure System

TC: Transport Canada

UBC: University of British Columbia

VIN: vehicle identification number

VRDB: Vehicle Recalls Database

Executive summary

About the program

Road safety in Canada is a responsibility shared by the federal government, provinces, territories, and municipalities. Transport Canada (TC) is responsible for developing and implementing regulations for motor vehicles, tires, child restraint systems and booster seats; auditing, inspecting, and testing vehicles, equipment, and companies to ensure compliance with regulations and standards; overseeing and auditing motor vehicle importations; investigating defects and influencing recalls; and supporting provinces and territories in implementing the National Safety Code (NSC). The Road Safety Program within Safety and Security consists of:

• Road Safety and Vehicle Regulations
• Motor Vehicle Regulation Enforcement
• Connected and Automated Vehicle Regulatory Policy

It also carries out its objectives in partnership with the Programs Group which is responsible for the administration of:

• The Road Safety Transfer Payment Program (RSTPP), which includes a Motor Carrier Safety component (administered as the RSTPP) and a Road Safety Outreach component (administered as the Enhanced Road Safety Transfer Payment Program; ERSTPP)
• The Motor Vehicle Test Centre (MVTC) and Motor Vehicle Safety Investigations Laboratory (MVSIL)

About the evaluation

The purpose of this evaluation was to examine the relevance, effectiveness, and efficiency/economy of TC's Road Safety programs. Specifically, this evaluation focused on highlighting the impacts of new technologies and changing patterns of transportation on the work of TC’s Road Safety programs, as well as examining the MVTC's operating model. The evaluation used several methods to gather information, including key informant interviews, document and literature review, case studies, and financial and data analysis.

Overall conclusions

The evaluation found that there is a clear need for Road Safety programming in Canada to help reduce road-related injuries and deaths but that new technologies, static staffing levels, and limitations with data collection are challenging TC’s ability to create and update regulations, conduct certain types of oversight, identify and respond to defects, and target funding through transfer payment programs. The current operating model of the MVTC provides good value and enables high quality work; however, given the complexity of the work conducted, costs are high with few opportunities to reduce/offset them. Lastly, Road Safety programs currently have difficulty with recruitment and retention, leading to capacity issues. It is recommended that TC’s Road Safety programs explore ways to collect more timely and complete data by collaborating with other Canadian road safety organizations to enhance TC’s ability to obtain insights from the National Collision Database (NCDB) and to support evidence-based decision making.

Key findings

Finding 1: There is an ongoing need for TC’s road safety programming to ensure the safety of Canadians while keeping pace with a quickly evolving motor vehicle industry.

Finding 2: While the National Collision Database (NCDB) is an essential tool for quantifying and qualifying trends in road safety outcomes over time, challenges with national data collection and timeliness limit its utility.

Finding 3: Road Safety’s Regulations function is struggling to keep pace with the rate of change and innovation in the motor vehicle industry (e.g., Connected and Automated Vehicles, Electric Vehicles, micromobility devices), leading to a backlog of unaddressed regulatory files.

Finding 4: The Enforcement function is also impacted by unaddressed regulatory files and increasingly complex vehicle technologies.

Finding 5: Capacity and resourcing issues are taking away from Road Safety’s ability to complete tasks expeditiously, given the regulatory backlog and the cascading workload impacts on the Oversight and Enforcement team.

Finding 6: The contractor for the MVTC provides a high quality of work at a fair rate but there are limited opportunities to reduce/recover the costs of running the Centre.

Finding 7: There is a continued need for RSTPP funding for provinces and territories to support a consistent approach to commercial vehicle safety.

Recommendations

Recommendation 1: Assess the potential for collaborating with other Canadian organizations that collect road safety data with a view to improving the NCDB.

Introduction

Road and motor vehicle safety in Canada

In Canada, road and motor vehicle safety is a shared responsibility among federal, provincial/territorial (PT), and municipal governments. The Motor Vehicle Safety Act (MVSA) ^{Footnote 1} defines different classes of vehicles and grants TC the authority to establish regulations for the safe manufacturing and importation of motor vehicles, tires, child restraint systems, and booster seats. Provinces, territories, and municipalities are responsible for other aspects of road safety such as licensing, vehicle registration, insurance, and the rules of the road.

Within its safety regulations, TC has established the Canada Motor Vehicle Safety Standards (CMVSS) which prescribe the minimum performance levels that different categories of motor vehicle products must meet to be sold, shipped interprovincially, or imported into Canada. Most of these standards prescribe performance-based requirements for manufacturers to test against. For example, Standard 101 applies to trucks, buses, and passenger cars, and specifies performance requirements for the location, identification, colour, and illumination of motor vehicle controls, tell-tales, and indicators (e.g., odometers). TC monitors new technology and road safety trends and updates these standards and regulations (or introduces new ones) as necessary. In general, TC strives to align its regulations and standards with the international community to reduce barriers to trade and innovation; because of the integrated nature of the North American motor vehicle market, harmonization with the U.S. is especially important.

Manufacturers, distributors, and importers operating in Canada are responsible for ensuring that their products meet all the relevant CMVSS and related technical standards through a process called self-certification. In a self-certification system, companies are responsible for demonstrating that they meet all applicable regulations and standards for their vehicle before introducing them for sale. Manufacturers must test and document all regulated aspects of the vehicles, tires, child restraint systems, or booster seats they produce, and keep records for at least five years. TC monitors the self-certification process through inspections, audits, compliance testing, and defect investigations and pursues enforcement options if a company is found to be in contravention of the MVSA. Both the U.S. and Canada employ self-certification for vehicle manufacturing; by contrast, most European countries require automakers to obtain approval from a governing body for each new model of vehicle or equipment they introduce by demonstrating compliance with regulations through witnessed testing. ^{Footnote 2}

Amendments to the MVSA

In 2018, Bill S-2 (the Strengthening Motor Vehicle Safety for Canadians Act) ^{Footnote 3} came into effect. This Bill made several significant amendments to the MVSA, mostly aimed at enhancing TC’s ability to oversee and enforce companies’ compliance with the Act. Key changes included:

• Giving the Minister of Transport the authority to compel companies to make defect and non-compliance information available; this led to 1) a requirement for manufacturers to maintain a Vehicle Information Number/VIN-based look-up tool on their websites where drivers can access recall information and 2) the development of the new Analysis of Companies Technical Information for Vehicles and Equipment (ACTIVE) program at Transport Canada, which, when implemented, will enable the department to request and monitor companies’ internal safety data (including foreign companies)
• Granting the Minister/TC new order powers, allowing them to order companies to:
  • Conduct tests, analyses, or studies of defects
  • Issue a recall
  • Correct defects or non-compliance issues at their own expense before sale
• Clarifying and strengthening TC’s inspector authorities and creating new Enforcement Officer positions with powers to investigate and issue penalties
• Introducing Administrative Monetary Penalties (AMPs) as an option for addressing non-compliance
• Creating a process for companies to apply for exemptions to existing safety standards (MVSA, s. 9) if doing so would promote the development of superior safety features or new technology (i.e., an Innovation Exemption)

Bringing these updated powers and processes to fruition required TC to make several changes to its regulatory framework, which is a lengthy process. At the time of writing, most of the changes stemming from Bill S-2 have been implemented except for the ACTIVE program, for which regulations are still under development.

Program profile

Road Safety programs are spread across multiple branches within TC and have undergone significant organizational changes in the past ten years, including merging Road and Motor Vehicle Safety with Multi-Modal Programs under a single Director General and the transfer of research testing activities from the Road and Motor Vehicle Safety to the Innovation Centre (at the MVTC). Figure 1 shows the current distribution of Road Safety programs within the department.

The activities managed by each group are discussed below.

The Connected and Automated Vehicle Regulatory Policy’s function:

• Develops guidance documents and tools for industry to support the safe and secure use of connected and automated vehicles (CAVs) and new vehicle technologies
• Acts as the regulatory policy lead for vehicle cyber security, including through research, stakeholder engagement and developing guidance and tools
• Provides regulatory policy support on emerging issues related to CAV safety and security (e.g., vehicle theft, micromobility, security)

The Road Safety and Vehicle Regulations function:

• Collects and publishes collision data through the National Collision Database
• Conducts collision investigations to assist in policy development and the modification of regulations
• Performs research to support the development of standards and regulations in key topic areas (e.g., road users, ergonomics and crash avoidance, CAVs)
• Engages and consults on legislative, policy, and regulatory issues with provincial, territorial, nongovernmental, international, and industry stakeholders
• Promotes motor carrier (truck and bus) safety
• Develops and updates evidence-based standards and regulations
• Promotes automated vehicle safety, including the development of guidance documents to support the safe testing and deployment of vehicle technologies in Canada
• Promotes public/consumer awareness of road safety issues
• Acts as the policy lead and subject matter expert for the ERSTPP

The Motor Vehicle Regulation Enforcement function:

• Monitors manufacturers’ and importers’ compliance with standards and regulations through inspections, audits, and testing of vehicles, tires, and child restraint systems and booster seats
• Works with the Canada Border Services Agency (CBSA) to administer the MVSA at the time of importation
• Authorizes manufacturers’ use of the National Safety Mark on Canadian vehicles and equipment
• Investigates defect complaints submitted by consumers (and will eventually conduct monitoring of internal manufacturer safety issues though the ACTIVE program)
• Oversees, tracks, and publishes information on recalls of vehicles and equipment
• Addresses non-compliance through enforcement actions, when necessary (e.g., AMPs, prosecution)
• Oversees the operations of the Motor Vehicle Safety Investigations Laboratory (MVSIL)

The RSTPP and ERSTPP teams:

• Deliver RSTPP funding, which promotes the safe operation of commercial vehicles by providing contribution funding to support provinces/territories in their implementation of the National Safety Code
• Deliver ERSTPP funding with the overall aim of reducing road-related collisions, injuries, and fatalities, and encourage harmonization with provincial and territorial road safety initiatives with projects that help create nationally consistent tools that address a variety of road safety challenges

Lastly, the Motor Vehicle Test Centre:

• Conducts destructive (i.e., crash) and non-destructive testing and research on vehicles, tires, and child restraint systems and booster seats
• Provides advice on motor vehicle standards, protocols, policies, codes, guidelines, and regulatory frameworks

These groups work collaboratively to accomplish common goals and deliver an integrated approach for federal road safety programming.

Evaluation purpose, scope, and methods

Purpose and scope

While key aspects of TC’s road safety programming have been reviewed over the past 10 years, including an update evaluation of the RSTPP in 2015, ^{Footnote 4}a review of the Motor Vehicle Test Centre in 2016, ^{Footnote 5}and a 2016 Auditor General report that examined the oversight of passenger vehicle safety, ^{Footnote 6} the department’s full complement of Road Safety programs has not been evaluated since 2011. Further, since the RSTPP and the ERSTPP are both transfer payment programs with combined average annual expenditures of more than $5 million, they had to be evaluated to address Treasury Board policy (i.e., Policy on Results) requirements. It should be noted that the RSTPP receives $4.4 million annually in A-base funding, while the ESRTPP received a separate $12 million of B-base funding (conditional to budget requests) between 2020 and 2026. The current evaluation was included in TC’s 2022-23 Risk-Based Audit and Evaluation Plan.

This evaluation examined the relevance, effectiveness, and efficiency/economy of TC’s Road Safety Programs and covered a period of five fiscal years, from 2018-19 to 2022-23; where available, data and documentation from 2023-24 were also utilized. The following Road Safety activities were included in the evaluation:

• Road Safety and Vehicle Regulations
• Motor Vehicle Regulation Enforcement
• The RSTPP, which includes a Motor Carrier Safety component and a Road Safety Outreach component (administered as the ERSTPP)
• The Motor Vehicle Test Centre (MVTC)

The activities and performance of the Connected and Automated Vehicles (CAV) Regulatory Policy group was not thoroughly examined in this evaluation given that this group is relatively new and not fully mature. However, the topic of connected and automated vehicles is discussed throughout this report. The activities related to commercial trucks and buses (i.e., commercial vehicles), undertaken by TC’s Road Safety and Vehicle Regulations group, were also scoped out of the evaluation because this aspect of road safety is governed by a separate regulatory framework (i.e., the Motor Vehicle Transport Act/MVTA).

Methods

The methods used to conduct this evaluation included: data analysis, key informant interviews, document and literature reviews, case studies, and an analysis of financial information.

Data analysis

The evaluation team analyzed data from key internal databases maintained by Road Safety Programs, including:

• The National Collision Database (NCDB)
• The Vehicle Recalls Database (VRDB)

The team also consulted external data sources where appropriate, including selected reports from Statistics Canada and the Transportation Data and Information Hub.

Key informant interviews

The evaluation team conducted 44 interviews with a total of 52 interviewees between June 2023 and February 2024. This included 36 interviews with staff and management working within Road Safety Programs and 8 interviews with external stakeholders, including industry representatives, non-profit road safety groups, and other levels of government.

Quotes from internal and external interviews are presented throughout this report without attribution. In some cases, the original wording has been amended to increase clarity or preserve the confidentiality of interviewees.

The evaluation team used the qualitative analysis software NVivo ^{Footnote 7} to code interview notes for thematic content.

Document and literature review

The evaluation team conducted a review of 60+ internal and external documents and reports. TC-authored documents included:

• Funding documents
• Terms and conditions and contribution agreements for funding programs
• Regulatory publications
• Organizational charts
• Logic models
• Team charters
• Guidance documents
• Data and statistical summary reports
• Previous audits and evaluations

External documents consisted of:

• Scientific articles
• Public opinion research
• Media items and news articles
• Reports and strategic documents from external road safety organizations
• Global/international road safety publications

Case studies

To assess the impacts of ERSTPP funding among Canadian road safety organizations, the evaluation team conducted six case studies of funded projects. To obtain a representative sample, case studies were selected based on the following criteria:

• Location: at least one nation-wide recipient and one recipient from each of TC’s five regions (Pacific, Prairie and Northern Region/PNR, Ontario, Quebec, and Atlantic ^{Footnote 8})
• Recipient type: a selection of recipients representing provinces and territories, industry associations, academic groups, not-for-profits, and private companies
• Project type: a selection of projects from various categories, like education and awareness campaigns, regulatory and standard development, research, technology and innovation, data and knowledge sharing
• Project cost: ranging from low to high-cost projects
  • Low: $1,000 to $99,999
  • Medium: $100,000 to $999,999
  • High: $1M to $5M
• Project year: at least one project from each of ERSTPP’s three calls for proposals (2019-20, 2020-21, and 2021-22)

The case studies included a review of available project documentation and interviews with key contacts from recipient organizations to elicit their perspectives on and experiences with various aspects of the ERSTPP (e.g., individual project results, application and reporting processes, interactions with TC staff).

Financial analysis

The evaluation team assessed internal financial records to examine the Programs’ resourcing levels over the evaluation period. For the RSTPP and ERSTPP, financial analyses included a breakdown of contribution funding amounts by recipient/project.

Considerations and limitations

The scope of the evaluation was expanded slightly during the conduct phase to accommodate a request to examine the operating model of the MVTC, which had undergone some changes following the contract renewal process in summer 2023. Delays in obtaining contact information for some external stakeholders meant the actual number of interviews was less than intended.

Findings

Section A: Relevance, effectiveness, and efficiency

1. Relevance

Finding 1: There is an ongoing need for TC’s road safety programming to ensure the safety of Canadians while keeping pace with a quickly evolving motor vehicle industry.

This section illustrates the need for federal programming in the area of road safety by demonstrating that: 1) travelling by road is the most dangerous mode of transportation in Canada, 2) the technology included in modern motor vehicles is advancing rapidly and will bring with it safety benefits and risks that will change the way motor vehicles function and are operated, and 3) harmonizing regulations with international regulatory frameworks should confer safety benefits to Canadian road users.

1.1 Risks of road travel

Travelling by car is one of the most common forms of intra and intercity travel in Canada. In fact, as of 2022, there were approximately 26 million road vehicles registered in Canada. ^{Footnote 9} For context, according to Statistics Canada, in 2022 the population of Canada was 39.3 million. Along the same lines, since 2013, the number of licensed drivers in Canada has been steadily increasing, with approximately 28 million as of 2022 (Figure 2). The number of registered vehicles, coupled with the increasing trend in licensed drivers, speaks to the volume of motor vehicle travel in Canada. Since 2013 the number of road fatalities has remained relatively stable. While there was a pronounced dip in 2019 and 2020 (Figure 2), likely due to the decrease in traffic volumes during the COVID-19 pandemic, the number of fatalities has since climbed back up.

Comparing the number of road fatalities to other modes of transportation helps to put these results into perspective. As seen in Figure 3, road crashes account for 90% of all transportation-related fatalities in Canada, making it by far the most dangerous mode of transportation in terms of cumulative fatalities.

It’s not only drivers and passengers that are represented in these statistics, but other road users too, including pedestrians, cyclists, and motorcyclists. Overall, road crashes remain a significant public health issue. Collision data suggests that while deaths among motor vehicle occupants (i.e., drivers and passengers) have reduced over the past 20 years (50% fewer fatalities), other road user groups have not seen the same safety gains. Specifically, motorcyclists have seen a 35% increase in fatalities during this time. ^{Footnote 10} Interviewees noted that the COVID-19 pandemic prompted a rise in the use of alternative modes of road transportation (like e-scooters and e-bikes), leading to a more dynamic and complex road system, especially in urban centres. Because of this, TC is paying close attention to interactions between cars and vulnerable road users.

“There are concerns about whether it’s safe, having more users on the roads. We’re looking at trends and impacts for vulnerable users.” – TC interviewee

Overall, TC’s Road Safety programming is intended to enhance the safety of Canadians by reducing the number of road crashes, injuries, and fatalities among road users. Understanding the causes of a collision can provide valuable information for TC to target their interventions and programming. TC categorizes the contributing factors of road fatalities into eight groups (Figure 4):

• Distraction
• Speed/driving too fast
• Impaired/under the influence
• Environmental factor
• Fatigue
• Other human factor (e.g., human-caused but does not clearly fit one of the other categories)
• Vehicular factor (e.g., defective brakes, broken light)
• No contributing factor (officer on scene could not determine an obvious cause)

When interpreting these data, pinpointing the cause of a fatal motor vehicle collision can be difficult since multiple factors like speed, fatigue, and distraction can all contribute to a given incident. As we discuss later in this report, these data come exclusively from provincial and territorial police reports and come with a variety of caveats.

For example, the “Other Human Factor” category is used as a catch-all when the primary contributing factor cannot be clearly identified. This category has been selected, on average, in approximately 75% of all fatalities captured in TC’s National Collision Database (NCDB) from 2017 to 2021, as seen in Figure 4.

There is a sizable and well-established body of research that indicates that two key risk factors for road crashes are gender and age, with males younger than 25 being much more likely than females to be involved in a road collision and representing approximately 75% of all road fatalities. ^{Footnote 11}These gender differences are stable across cultures and are largely attributed to a greater acceptance of risk by males versus females. ^{Footnote 12}

The complexity and imprecision in identifying the key contributing factors of a fatal motor vehicle collision are not within TC’s control. This ambiguity limits TC’s ability to extract information that could help target certain elements of its programming (e.g., education and awareness). The limitations of the NCDB are discussed in more detail in section 3 (Effectiveness: Data).

1.2 An evolving industry

Another factor contributing to the complexity of road safety in Canada is the rapidly advancing technology being used in motor vehicles. As the industry evolves, TC’s Road Safety programs need to adapt as well to keep their regulatory framework and oversight functions current. CAV technology is becoming more common, and the Government of Canada has committed that 100% of all new vehicle sales will be electric/zero-emission by 2035 (with 20% by 2026 and 60% by 2030). Automated Driving Systems (ADS) are not yet available for purchase in Canada, but with many manufacturers already testing this technology, their introduction is not far off.

Although CAVs will introduce certain safety benefits, there are also risks surrounding privacy and security. Some interviewees noted the possibility of being hacked. Moving forward, TC will play a key role in ensuring that this technology is safe and reliable through its established motor vehicle safety regulatory and oversight functions.

Advancing rapidly in parallel to motor vehicle technology are micromobility devices. Electric scooters and bikes are a novel form of transportation that has become much more popular in recent years, ^{Footnote 13} especially with the proliferation of sharing services in many urban centres. The key regulatory and safety concerns related to micromobility devices, CAVs, and electric vehicles are discussed in detail later in this report (see section 2, Effectiveness).

1.3 An international industry

Lastly, the motor vehicle industry is an international one, branching across various countries and jurisdictions. There is a continuing need for TC to actively participate in international fora like the World Forum for Harmonization of Vehicle Regulations (WP29) to ensure that, to the extent that is practical, foreign motor vehicle regulations that enhance safety are harmonized and to facilitate an efficient supply chain of vehicles. The Canadian Vehicle Manufacturers’ Association (CVMA) estimates that the auto industry: contributes approximately $14 billion to Canada’s annual GDP; directly employs approximately 125 000 people, with an additional 371 000 people having jobs in aftermarket services and dealership networks; accounted for 8% of Canada’s total goods exports (in 2022); and is responsible for $14.6 billion in investments in Canada. ^{Footnote 14}

2. Effectiveness: Data

Research and data play an important role in TC’s ability to draft evidence-based policies and regulations. Having access to accurate and timely statistics on collisions, fatalities, and injuries on Canadian roads is especially critical, as this information allows the department to detect emerging trends and risks that can help inform the development of relevant policies or programming, direct funding to high-priority areas, and prioritize competing regulatory issues. At TC, collision data are collected and disseminated through the National Collision Database (NCDB). Although valuable, this database has some key limitations that restrict its utility for predicting and detecting road safety trends, as mentioned briefly earlier in this report when discussing the contributing factors of fatalities due to road crashes (Figure 4).

2.1 National Collision Database (NCDB)

Finding 2: While the NCDB is an essential tool for quantifying and qualifying trends in road safety outcomes over time, challenges with national data collection and timeliness limit its utility.

The NCDB is maintained through voluntary partnerships between PTs and TC’s Evaluation and Data team. Collision details are recorded by roadside traffic officers (e.g., RCMP or provincial/municipal police) and aggregated by each province or territory, which then passes these data along to TC staff to clean, standardize, and enter into the NCDB, before being released publicly. Because capacity levels vary across PTs, there are often significant delays in receiving yearly statistics from all sources. The agreed deadline for TC to receive the data from the PTs is 9 months post calendar year-end (i.e., in the fall). TC generally waits much longer for all data to be submitted (especially if the outstanding PT is a large source like Ontario or BC) before the department is forced to derive an estimate. This results in a database that is typically two years out of date. There is also variation in how PTs collect and report data and the level of detail included, meaning that TC’s Evaluation and Data team needs to do the intensive work of cleaning, validating, and standardizing the data before releasing them, including producing estimates for jurisdictions who fail to provide data. Often, more detailed information collected by some PTs is left out of the NCDB to maintain a standardized dataset.

In addition to timeliness, the completeness and accuracy of collision data can sometimes be questionable due to the source. For example, police officers do not always have the time or ability to ascertain key details at the roadside, like the contributing factors of a collision or injury severity. Data within the NCDB are also limited to incidents that are reportable by law enforcement (i.e., involving injuries or causing damages above a certain amount); they do not include private road collisions or collisions with no road registered vehicle involved [i.e., bicycle with another bicycle]). This may result in an under-estimation of risks to some categories of vulnerable road users, like cyclists. ^{Footnote 15} Taken together, these issues with timeliness and completeness limit the insights that TC and other road safety stakeholders can glean from the NCDB:

“The NCDB is a record of history that we can use to track the quality of regulations that have been passed, and it does this well. The shortfalls are in timing, especially if something current has happened. The second part is flexibility to find the details that we need.” – TC interviewee

Although the Program is aware of these issues, TC does not provide any specific funding to support PTs in this work and there is no legislative requirement for them to participate, making it difficult to be overly prescriptive or demanding in how it monitors and requests collision data. Instead, the Program supplements its understanding of collision trends with other data sources, like the information collected by the Collision Investigation team.

Evidence from interviews with external groups suggests that there are multiple sources of data that TC could potentially access outside of the department as well; these include traditional data sources, like insurance information and coroner’s reports, as well as emerging sources linked to increased automation. Many CAVs are capable of capturing large amounts of detailed data on collision dynamics and safety performance, with minimal lag time. While negotiating agreements to share these data could be complex and costly, the potential benefit to TC’s evidence-based approach may merit exploring these options further.

Recommendation 1: Assess the potential for collaborating with other Canadian organizations that collect road safety data with a view to improving the NCDB.

3. Effectiveness: Regulations function

To address the need for a coordinated approach to road safety in Canada, TC’s role as a federal regulator begins with developing and updating evidence-based policies, regulations, and standards governing the safety of new motor vehicles, tires, and child restraint systems and booster seats. This work is completed by the Regulations function.

The regulatory development process starts with research and information gathering. This can include activities like: direct testing of vehicles, tires, and child restraint systems and booster seats; monitoring trends in fatality statistics; investigating collisions; assessing defect complaints; and staying current with the development and implementation of new vehicle technologies. The information gathered through these processes gives the Regulations function the evidence base needed to determine when a regulation or standard needs to be updated, amended, or added. While safety is TC’s first consideration, there is also a need to ensure that the regulatory environment does not place an undue burden on companies or stifle innovation/economic development in the motor vehicle industry. To this end, two other key aspects of regulatory development are consulting with industry and other road safety stakeholders as well as collaborating at the international level to ensure that Canada’s standards and regulations are in line with those of our closest trading partners, which allows manufacturers and importers to operate smoothly across borders.

The process of researching, developing, and publishing new or updated regulations and standards is often long and resource intensive. It is also critically important, because the resulting regulatory framework grants TC’s Enforcement function the authority to monitor and enforce safety requirements and serves as the basis for manufacturers to test and validate their products. While the Regulations function has been active in monitoring and developing new/updated standards and regulations over the evaluation period, evidence suggests that the current context of rapid change and technological advancement in the motor vehicle industry has begun to strain the Program’s ability to effectively keep its regulatory framework up to date.

Finding 3: Road Safety’s Regulations function is struggling to keep pace with the rate of change and innovation in the motor vehicle industry (e.g., Connected and Automated Vehicles, Electric Vehicles, micromobility devices), leading to a backlog of unaddressed regulatory files.

In the Relevance section, we established that the motor vehicle industry is undergoing important transformations, with significant implications for safety and demonstrating the relevance of TC’s road safety programs. Innovative motor vehicle technologies can introduce new risks that need to be managed, but they can equally present new opportunities to enhance safety outcomes. In this context, TC aims to keep its regulatory framework current and maintain its ability to monitor and respond to emerging trends. This issue was top of mind for many interviewees, with some program staff expressing concern about the department’s ability to keep pace:

“One of the challenges that [TC’s Road Safety Programs] will always have is that our ability to research and regulate is not nearly as fast as the advancement of tech.” – TC interviewee

Interviewees flagged three significant trends in today’s motor vehicle industry: increased automation and connectivity, electrification, and the micromobility boom. Each of these shifts represent new risks and potential benefits for the state of road safety in Canada, resulting in added pressures on TC’s Regulations function.

3.1 Connected and automated vehicles (CAVs)

The rise of automated driving technology in cars is one of the primary drivers of transformation in the automotive industry in Canada and globally. The possible safety benefits of these technologies are significant, with early data suggesting that fully automated driving systems have the potential to outperform human drivers. ^{Footnote 16} In ideal circumstances, they may also reduce traffic congestion, allow occupants to be more productive during travel time, and enhance the accessibility of road transportation, ^{Footnote 17} benefiting those with health conditions that currently prevent them from taking the wheel.

Fully automated vehicles (i.e., those that take over all aspects of the driving tasks from their human occupants) are not yet available in Canada, but many new cars on the market today are capable of partial or conditional automation and contain software that can assist with basic tasks like lane-keeping, acceleration and deceleration, and parking. Increased automation is often accompanied by increased connectivity, where a vehicle uses wireless technology to communicate with its occupants and surrounding environment (e.g., infrastructure, other vehicles).

From a regulatory perspective, there is a need to monitor the introduction of these technologies to identify risks as well as to gather evidence in preparation for crafting regulations to mandate the adoption of those that confer obvious safety benefits; one example of this is automatic emergency breaking (AEB), which monitors a vehicle’s surroundings and applies the brakes if it detects an imminent crash. This technology has been on the market for some time with strong evidence of improving safety, especially in rear-end collisions and crashes involving vulnerable road users. AEB is already mandated for passenger cars in many European countries, with the U.S. recently following suit. ^{Footnote 18}TC is currently testing this technology through the MVTC and continues to consult with industry and other stakeholders as part of its pre-regulatory process, which may eventually lead to AEB being required in new vehicles going forward. ^{Footnote 19} In general, Transport Canada must do its due diligence before adopting or incorporating regulations and standards by reference from the U.S. Canada has unique concerns, such as the need to consider how new regulations interact with Canada’s topography and climate, among other considerations.

Several interviewees also flagged the need for new regulations around data and cybersecurity. As mentioned in the Relevance section, vehicles are now increasingly computerized and capable of capturing large amounts of personal data about drivers and other occupants, creating concerns about privacy, especially as users are not always aware of what is being collected and for what purposes. ^{Footnote 20} The collection and storage of personal information through new vehicles technologies must comply with relevant privacy laws, including the federal privacy law for the private sector, the Personal Information Protection and Electronic Documents Act (PIPEDA), and similar provincial laws. TC works closely with Innovation, Science and Economic Development Canada (ISED) to provide insight on unique considerations relative to road safety. The wireless technology used in connected vehicles also creates potential vulnerabilities for hackers and other bad actors to exploit. ^{Footnote 21}Once accessed by an attacker, safety systems could be compromised, highlighting the importance of addressing cyber security concerns in an effort to maintain road safety.

Another possible gap to address lies in the use of over-the-air software updates by manufacturers. These updates can provide immediate fixes in the case of a malfunction or quickly confer new safety benefits to vehicles already on the road. However, some interviewees were concerned about their potential to fundamentally alter the functioning of a vehicle while bypassing TC’s oversight powers:

“We’re moving away from mechanical technology to software technology, and this is challenging because our regulatory system is designed for mechanical. Software means that vehicles can be updated throughout their lifecycle. We will have to grapple with this because our regulations are based on vehicles as they were at the point of assembly and sale.” – TC interviewee

TC recognizes the multiple emerging regulatory challenges presented by CAVs. The Connected and Automated Vehicle Regulatory Policy function strives to build departmental capacity to prepare for the increasing presence of automated vehicles on Canadian roads. So far, this group has focused on issuing and updating non-regulatory guidance and assessment tools – for example, creating a set of testing guidelines that companies can voluntarily follow when planning for the deployment of higher-level automated technology. ^{Footnote 22} This approach of providing guidance while monitoring technology as it develops is in line with Canada’s self-certification system and avoids the risk of regulating too soon, which could undermine public confidence or stifle innovation. However, some industry representatives have expressed frustration with the lack of more established rules and pathways for introducing fully automated technology in Canada:

“If you have a level 4 vehicle ^{Footnote 23} with no steering wheel, there’s really no way to bring that into the market. […] The reality is that this tech will be deployment ready before amendments are in place. There’s an urgency to get ‘regs and legs’ caught up to the state of play.” – External interviewee

Echoing this perspective, more than one TC representative noted that future standards and testing requirements will likely need to shift towards being more technology-neutral and outcome-based to account for unconventional vehicle designs, which will be a major regulatory undertaking. In the meantime, the Regulations function is expending considerable resources on monitoring, gathering evidence, and developing expertise in preparation for issuing new/updated regulations on issues linked to the increasing use of CAV technology.

3.2 Electric vehicles (EVs)

While modern electric vehicle technology has been on the market in North America since the 1990s, the presence of EVs on Canadian roads has increased considerably in recent years, buoyed by government initiatives to reduce emissions from the transport sector (see Figure 5).

The increasing electrification of motor vehicles was flagged as a key factor influencing road safety and the motor vehicle industry by both TC staff and external groups. As one interviewee pointed out, EV technology is comparatively less established and tested than traditional combustion engines and comes with a different set of safety concerns, some of which are challenging TC’s current regulatory framework. For example, EVs make less noise than traditional cars, making them potentially dangerous, especially for people who are blind or partially sighted; in response to lobbying from advocacy groups, TC recently amended its motor vehicle regulations to require EVs to emit sound when traveling at low speeds. ^{Footnote 24}

The significant weight of EV batteries also creates unique safety considerations. EVs can outweigh similarly sized gas-powered cars by hundreds of pounds, creating safety risks in a collision with a lighter vehicle. Their increased weight also means that some heavier models may fall outside of TC’s testing standards altogether:

“Electric vehicles are getting heavier, and our performance requirements are based on weight. It can get to a point where they’re not even subject to the requirements anymore because they are past the point.” – TC interviewee

Emerging gaps like these emphasize the importance of the Regulations function’s role in reviewing and updating established standards on an ongoing basis – and the challenges in doing so – as the motor vehicles used on Canadian roads evolve rapidly.

3.3 Micromobility

As mentioned in the Relevance section, the use of personal mobility devices like scooters and e-bikes has boomed in recent years with a proliferation of sharing services in many urban centres. Interviewees’ safety concerns around these devices largely centered on their interactions with larger vehicles and other road users, as well as their batteries which, in rare cases, can overheat and ignite. Micromobility devices meet the definition of “vehicle” under the MVSA, but are exempt from being a regulated class of vehicle if they travel less than 32 km/h. In addition, PTs and municipalities determine their own usage guidance for micromobility vehicles, resulting in a patchwork of non-standardized rules across the country; for example, some Ontario cities are participating in a five-year provincial pilot program for e-scooters, ^{Footnote 25}while others (like Toronto) have banned them entirely from city streets due to liability and safety concerns. Some interviewees suggested that TC could be doing more to guide PTs and ensure a more standardized approach:

“Provinces and territories are struggling with what to do with [micromobility devices]. These vehicles can skip from one type of infrastructure to the next (e.g., road to sidewalk) and because we don't regulate their use, we’re kind of at the mercy of what provinces and territories allow.” – TC interviewee

In terms of manufacturing, micromobility devices also fall into a regulatory grey zone between TC, which regulates vehicles, and Health Canada (HC), which regulates consumer items. TC’s Road Safety Programs is currently working with HC to clarify definitions and responsibilities and ensure that micromobility manufacturers are regulated so that they could be compelled to issue a recall if safety issues (like a defective battery that could combust) are detected. According to interviewees, resolving this issue may require TC to make changes to the way a vehicle is defined in the MVSA itself; this kind of legislative amendment would entail a significant amount of work for the Regulations function. Specifically, the Legislative Process to amend an Act requires a bill to be approved in identical form by both houses of Parliament – the Senate and the House of Commons. This process is lengthy and would require the Regulations function to prepare all material to support the bill through Parliament. Before introducing an amendment, Transport Canada would also need to develop a Memorandum to Cabinet (MC) to obtain policy cover for the amendment.

3.4 Capacity issues (Regulations team)

The rapid evolution of motor vehicle technology has left the Regulations team struggling to keep the regulatory framework up to date. The Regulations team operates with fewer Full Time Equivalent (FTE) staff members than they did in 2010, when the pace of motor vehicle technological advancements were more gradual and less disruptive. To determine staffing trends over time and to reflect significant staffing adjustments (e.g., during the Deficit Reduction Action Plan; DRAP), staffing data was obtained from the Program going back to 2010-11. Over the past several years, the Road Safety and Motor Vehicle Program has relied on B-base funding to fill staffing gaps, but given the nature of B-base funding, which is temporary, this is not a sustainable long-term strategy. The Efficiency chapter of this report will explore this issue in more detail.

According to program representatives, this situation has led to a significant backlog of regulatory files needing to be addressed:

“We currently have 8 regulatory files open at various stages of progression and over 60 potential others in our backlog at various stages of readiness.” – TC interviewee

In addition to regulatory complications linked to advances in the motor vehicle industry like those already discussed, this backlog also includes standards and testing requirements that have fallen out of date or require re-alignment to keep pace with changes enacted by international partners. For instance, the U.S. Department of Transportation National Highway Traffic Safety Administration (NHTSA), the U.S equivalent of TC’s Road Safety and Motor Vehicle Program, has a much larger contingent of regulatory staff than TC, making it possible for them to push through a high number of amendments each year and challenging TC’s Regulations team’s ability to keep its framework harmonized. For example, as of February 2025, the tracker maintained by the Regulations team shows approximately 340 backlogged files. Every year, approximately 10 regulatory update requests are added and approximately 5 items are completed.

The backlog is a list of items that are categorized into projects and their status (i.e., the stage of regulatory development such as consultation, Gazette publication, research phase, international standards development work, policy development, etc.). TC’s Regulations team has developed a prioritization scale and provides a weighted score for each item on the list. The four prioritization factors are:

• potential safety benefit/risk,
• public profile,
• governmental/departmental/administrative/stakeholder priority,
• regulatory alignment and oversight challenges/barriers.

The 10-year “lookahead” plan is reassessed and updated on a yearly basis, to account for shifts in priorities and staff capacity. To help with the yearly review, a project tracker was also created for the regulatory development team to keep track of all requests/items. The lookahead plan is based on a 10-year cycle due to the complexity and time it takes to advance regulatory proposals. Overall, from the identification of an issue to the research, the collection of data, stakeholder consultations, pre-publication in the Canada Gazette, Part I and final publication in the Canada Gazette, Part II, it may take between three to five years before amendments can be made to a regulation. Therefore, a plan that looks ahead many years is required.

A 2020 KPMG report shows that Canada is falling behind in preparing for autonomous vehicles. The report rated 30 countries on their readiness across four areas: policy and legislation, technology and innovation, infrastructure, and consumer acceptance. Since 2018, Canada has dropped out of the top 10 and was ranked 12th in 2020.

Non-regulatory work, like ministerial and media questions, Access to Information and Privacy (ATIP) requests, public inquiries, and maintaining Canada’s international representation also place demands on the team’s time and resources. In some cases, interviewees reported needing to pull funding and resources from other programs or offload work to other teams to meet operational requirements. As we will explore in later sections, this backlog also has a cascading impact on the ability of the Enforcement function to effectively perform its duties.

3.5 Regulatory timelines

In addition to the proliferation of new technology, some interviewees pointed to the slow pace of Canada’s traditional regulatory cycle as a factor limiting TC’s ability to keep its framework up to date:

“One of the big problems is the regulatory development process is very long. If I recommend a change today, in a perfect world, we won’t see any change for 5 years. [...] Technology is evolving so rapidly that trying to keep up is very difficult.” – TC interviewee

While not all files require a full regulatory update to resolve, requirements for developing and publishing regulations have expanded in recent years, adding new steps and processes that some program staff considered redundant or inefficient in some cases, for example, needing to assess in-depth gender-based analysis (GBA+) considerations or perform a cost-benefit analysis for a minor regulatory update. One interviewee suggested that industry stakeholders may even request extra research and review steps as a strategy to delay unpopular changes. While staff members have raised the question of whether some processes could be streamlined to help ease regulatory pressures, these issues are largely out of their control. Senior program representatives have mentioned that they are bound by certain legislative requirements and that the room to maneuver within that framework is limited.

4. Effectiveness: Oversight and Enforcement function

As discussed in the introduction, under Canada’s self-certification system companies are responsible for demonstrating that their vehicles meet all applicable regulations and standards before introducing them for sale. To ensure the safety and protection of the traveling public, TC plays an active role in monitoring this system through risk-based inspections, audits, testing, and defect investigations. When safety concerns or compliance issues are detected through these processes, the department can pursue graduated enforcement options against the company or compel them to undertake a recall. This process of overseeing and enforcing compliance with regulations and safety standards is managed by Road Safety’s Enforcement function.

Because TC's oversight and enforcement authorities flow directly from the MVSA and the regulations and standards maintained by the Regulations function, these processes are critically impacted when the regulatory framework falls out of date or is misaligned with international partners. Combined with the proliferation of new vehicle technologies, this has led to challenges for the Enforcement function.

4.1 Regulatory backlog and cascading impacts

Finding 4: The Enforcement function is also impacted by unaddressed regulatory files and increasingly complex vehicle technologies.

One key issue involves the CMVSS and related technical requirements that companies are required to test against. Although these standards are intended to be written as performance-based and technology-neutral, interviewees pointed to specific instances where they had fallen out of date with the realities of current vehicle technology (e.g., the case of EVs falling outside of existing vehicle classes based on weight, as discussed earlier). In other cases, standards may be lacking altogether. For example, current performance standards for windshield defrosting/defogging technology only apply to passenger cars and three-wheeled vehicles, even though CMVSS 103 requires more vehicle types to be equipped with this functionality (e.g., buses, multi-purpose vehicles). Trucks and other vehicle classes are not subject to the same performance requirements despite this being a critical safety feature in colder climates. Similar problems are caused when a given standard falls out of alignment with other countries. This can be especially challenging for the Audit and Importation team, which manages the importation of vehicles and related equipment into the country; lack of harmonization increases the likelihood that an imported vehicle will be non-compliant.

In addition to needing to update technical standards, some concerns raised by the Enforcement team, like the ability to oversee software updates, may require addressing ambiguities in the MVSA itself:

“Some of the text is open to different interpretations and it inadvertently makes some things unenforceable. We have a long list of things that need to be addressed in the legislation.” – TC interviewee

The slow pace of regulatory development and the number of backlogged regulatory files awaiting updates means that the Enforcement function (along with the industry itself) is often left without clarity while they wait for the Regulations function to catch up. For example, although Canada’s motor vehicle safety standards and requirements are largely harmonized with the United States, when standards in the U.S. are amended and Canada takes time to adopt the changes, it causes misalignment between the two markets, and vehicle manufacturers building to the newer standard may fail to meet the old one. Unless an interim order is pursued, TC cannot exempt or waive requirements relating to the misalignment, so TC's Oversight and Enforcement function must address the issues through administrative agreements or other informal mechanisms. This results in an administrative burden for the team.

For example, new testing requirements for child restraint systems, including revised frontal bench and side impact test requirements, were recently published in the U.S. This marks a significant change for the North American market. At the time of writing, Canada’s regulations and standards had not yet been harmonized. In situations like these, where there might be a defect complaint and subsequent investigation of a motor vehicle component or child restraint that doesn’t have a harmonized testing requirement, the Oversight and Enforcement function must conduct additional analysis to address safety issues that slip through TC’s lagging regulatory framework:

“Until there’s a standard in place, it’s on us to ensure that issues get addressed. It can be heavy at times. We’re looking forward to regulations catching up.” – TC interviewee

As discussed earlier, vehicle technology is increasing in complexity and often being integrated via software rather than physical components. This shift from traditional mechanical issues to software is not only challenging from the point of view of standards and regulations, but also in the sense that program staff must constantly update their understanding to effectively monitor new technology. As we will explore in the next section, the proliferation of novel technology may also create a higher likelihood for vehicles and their components to malfunction, a trend which has especially impacted TC’s work involving defects and recalls.

4.2 Defects and recalls

The Defects and Recalls function is responsible for detecting and investigating reports of malfunctioning/defective vehicles, tires, and child restraint systems and booster seats. They also work with companies through the process of issuing a recall and track their progress towards recall completion.

In the past 10 years, the team has recorded an increasing trend in the number of recalls issued in Canada (see Figure 6).

Defect complaints from the public, which the Defects and Recalls function tracks and follows up on through an internal database, have also increased over the same period as Canadian recall numbers. Taken together, these trends suggest that defects have become more common in vehicles and components in Canada in recent years. While the reasons are not completely clear, some program staff suggested that this increase is at least partially related to the increasing variety and complexity of technology in the motor vehicle industry. Similar trends have been observed in other markets, including the U.S. Some experts have pointed to CAVs specifically as a key factor in rising defect numbers, with advanced driver assistance systems (ADAS) and ADS technology forming a growing share of recall events. ^{Footnote 26}One recent high-profile example from December 2023 was prompted by a NHTSA investigation into Tesla’s Autopilot mode, which found that the manufacturer did not provide strong enough warnings to prevent driver misuse of the feature. ^{Footnote 27} In Canada, this issue may be exacerbated by the lack of updated safety standards in some areas, putting extra pressure on the Defects and Recalls team:

“ADAS, lane departure, lane keeping, warnings for backing up, side/back cameras – these are all opportunities for defects. And the standards aren’t able to keep up, so [the Defects and Recalls function] is the safety net until they have standards in place.” – TC interviewee

The function is currently managing the increased workload by taking a risk-based approach to investigating potential defects, prioritizing those with the highest severity/potential for harm. However, maintaining the same level of capacity and expertise in the future may be challenging if the number and complexity of motor vehicle defects continue to rise. This is explored further in the Efficiency section of this report.

4.3 New oversight and enforcement tools

As discussed in the introduction, most of the changes made to the MVSA through Bill S-2 in 2018 were aimed at enhancing TC's oversight and enforcement authorities. Due to the lengthy regulatory update process, some of these new functions are still under development or have only recently been incorporated into the regulations. While still in the early stages of their application, evidence suggests that these new tools will be helpful in strengthening TC’s approach to oversight and enforcement. Two significant developments brought about in the 2018 changes were the introduction of Administrative Monetary Penalties (AMPs) and the creation of the ACTIVE program.

AMPs

AMPs are a common tool used in other transportation modes within TC to address non-compliance with safety requirements. In line with a graduated approach to enforcement, they give the Enforcement function the flexibility to implement a response that fits the severity of the offense depending on factors like the degree of potential harm or risk, the company’s compliance history, and its level of cooperation with TC. Before the introduction of AMPs for motor vehicle offenses, enforcement options were more limited, with criminal prosecution being one of the only recourses for more serious situations of non-compliance. According to interviewees, this option has historically been extremely resource-heavy and time-consuming for the department while not always yielding useful results.

AMPs for contraventions of the MVSA officially came into force in October 2023. ^{Footnote 28}While AMPs had not been used yet by the Enforcement function at the time when interviews were taking place, TC interviewees had positive expectations about their potential to incentivize better behaviour from industry actors and some noted that they were actively preparing to use them to address specific instances of non-compliance.

ACTIVE

The impetus for the Analysis of Companies Technical Info for Vehicles and Equipment or ACTIVE program stemmed from a review of TC’s passenger vehicle safety oversight by the Office of the Auditor General (OAG) in 2016. ^{Footnote 29} The OAG’s report found that TC had limited knowledge of internal manufacturer investigations related to critical safety issues with their vehicles and recommended that the department make the legislative changes necessary to request this information on an ongoing basis.

“ACTIVE is us trying to be proactive. The idea is that industry has a responsibility to report certain pieces of information to us to address defects sooner rather than later. Fatalities, injuries, and fires are the big three pieces of information. Government should be aware of what keeps companies up at night, safety-wise." – TC interviewee

Pre-regulatory work on this file has been complex, with some resistance from industry along the way. Once established, the program will collect internal safety-related data from 460 companies that will allow the Enforcement function to detect early signals of emerging safety issues, which will be especially valuable in the context of rapidly evolving technology.

5. Efficiency

5.1 Resources

Finding 5: Capacity and resourcing issues are taking away from Road Safety’s ability to complete tasks expeditiously, given the regulatory backlog and the cascading workload impacts on the Oversight and Enforcement team.

As mentioned in the Effectiveness section, pressure to keep regulations and guidance up to date with new and evolving technology is straining TC’s regulatory and oversight capacity, leading to a heavy workload and backlogs. To determine staffing trends over time and to reflect significant staffing adjustments (e.g., during the Deficit Reduction Action Plan; DRAP), staffing data was obtained from the Program dating back to 2010-11. Staffing levels have varied since FY 2010-11 for both the Regulations and Oversight and Enforcement teams (see Figure 7). A decreasing trend in staffing numbers began in FY 2011-12, essentially reaching their lowest point in in FY 2013-14. Staffing numbers rebounded gradually with additional funding provided to the program in 2018, 2019, and 2021. These FTE increases are largely attributed to expansions of TC’s oversight programming associated with the passage of Bill S-2 in 2018. The additional FTEs provided to the Oversight and Enforcement team are funded with B-base (i.e., temporary) funding and have been since 2018; currently this team is funded with approximately 70% permanent (A-base) funding.

Although staffing levels for the Oversight and Enforcement team appear to be relatively stable over the past five years (2019-20 – 2023-24), there has been significant turnover with experienced inspectors, and staffing those vacancies has been prioritized over other operational tasks. Further, as demonstrated in Figure 7, these numbers have remained relatively static while the workload of the team (see Figure 6) has been increasing. Figure 7 shows that registrations of zero-emission vehicles, mostly battery-powered electric vehicles (BEVs), are increasing in Canada. This trend is a proxy for how quickly the motor vehicle industry is changing, as compared to TC's staffing numbers and its traditional road safety regulatory and oversight frameworks.

Overall, for all the aforementioned teams, these staffing levels do not reflect the increasing demands and workload (e.g., trends in defects and recalls, demand for updated regulations and standards) faced by TC’s Road Safety programs. Interviewees stated that they have “more issues than we can tackle.” For example, the Defects team noted difficulties keeping up with an increase in defects around novel technology, including ADAS, lithium-ion batteries, and automated software.

“When you compare us to the US, they have ten investigators just working on Tesla autopilot, self-driving cars. We have six total in TC.” – TC Interviewee

5.2 Classification levels

Staffing levels are influenced by a variety of factors, including employee retention. One challenge related to retention within Road Safety stems from how the Technical Services (TI) group is classified compared to other modal programs within the department. In general, Road Safety staff begin at the TI-03 level, whereas Marine and Aviation TIs begin at the TI-05 level. As described in the collective agreement for Technical Services, the rates of pay differ for the same levels across the different modes of transportation. In Marine Safety, for example, a TI-06 receives a higher wage (approximately $14,000/year) than an equivalent TI-06 working within Road Safety. ^{Footnote 30}Interviewees cited examples of staff transferring to other federal departments, like Environment and Climate Change Canada (ECCC), where there are opportunities for advancement and a higher pay scale.

“ECCC staff levels are not only higher for a narrower scope (at least as defined in the division of work Internationally) but their classification levels with additional leadership and management positions offers additional flexibility, succession planning, and retention potential.” – TC interviewee

Road Safety regulatory and enforcement engineers also reported being classified at a lower level than colleagues working in other modes within TC and in other departments (e.g., ECCC or Natural Resources Canada) even though their responsibilities were largely the same. When career advancement opportunities aren’t available, employees can search for them elsewhere, leaving programs like Road Safety with additional staffing pressures.

5.3 Succession planning

Road Safety is a specialized field that requires specific subject-matter expertise in an industry that is both competitive and constantly evolving. Interviewees from all Road Safety programs reported that key team members from their respective teams were nearing retirement and that it could take a protracted amount of time to hire someone new and train them adequately.

“Road Safety was an old place where people came in, spent their career there, and didn’t move around. The consequence is that now we have a very old shop and within a short amount of time there will be huge gaps in corporate memory.” – TC Interviewee

Interviewees also mentioned a reduction in the number of training opportunities for newer staff. Whether it’s encouraging TC staff to experience crash tests in person at the MVTC or sending junior staff to conferences, interviewees were concerned that without these opportunities and with staff attrition, the knowledge base and skills required to conduct their work would be diminished. Interviewees were not aware of concrete succession plans to backfill highly specialized and experienced Road Safety inspectors, engineers, researchers, and regulatory officers. A lack of expertise and corporate memory present a significant risk and would detract from Road Safety’s ability to fulfill their mandates.

6. Discussion of the corporate risks raised in Section A

The findings from this section of the evaluation have demonstrated that: 1) the motor vehicle industry is transforming rapidly due to the advances and implementation of new and innovative motor vehicle technologies, 2) the Road Safety’s Regulations function is struggling to keep pace with the rate of change in the industry, and 3) the Regulations’ team capacity has slightly decreased in recent years. Taken together, these factors have resulted in a growing regulatory backlog, with more files being added than can be cleared each year.

The trickle-down effects of this situation have adverse impacts on the Oversight and Enforcement function. For example, when safety standards are misaligned between the U.S. and Canada and new vehicles are built to align with a newer U.S. standard, TC’s Oversight and Enforcement function must address the misalignment/non-compliance through informal mechanisms and use of discretion, which results in an administrative burden for the implicated teams and exposes the department to legal risk. Generally, this situation also causes additional strain on an already busy Oversight and Enforcement function, where trends in defect complaints and recalls have been increasing over the past 10 years (see Figure 6).

The situation outlined above is not sustainable in the long-term. Vehicle technologies are continuing to advance rapidly. Without additional resources or a potential reduction in Road Safety’s scope of work, the regulatory backlog will continue to grow, which will put additional pressures on an already stretched Oversight and Enforcement function. As mentioned previously, the Program is bound by legislative requirements and there is minimal flexibility for them to adjust their scope of work. Most importantly, this situation outlined presents real risks for Transport Canada; program representatives have indicated that the longer this situation endures, the potential for negative safety impacts will increase, detracting from Transport Canada’s departmental core responsibility of fostering a safe and secure transportation system.

The Road Safety and Motor Vehicle Program recognizes the current challenges and continues to communicate and work with central agencies to secure stable, permanent A-base funding, given that there is minimal flexibility for them to adjust the scope of their work. Additionally, continuous efforts have been made by the Program to obtain supplementary funds to better address the emerging gaps and pressures resulting from the rapid advancements in the motor vehicle industry.

Section B: The Motor Vehicle Test Centre

7. Motor Vehicle Test Centre

7.1 MVTC contract

The Motor Vehicle Test Centre (MVTC) is a specialized motor vehicle research facility located in Blainville, QC that conducts:

• Compliance testing on vehicles and child car restraint systems
• Research testing to inform regulatory and policy development
• Ad-hoc testing to address suspected safety issues

The MVTC has operated under a government-owned, contractor-operated (GOCO) model for more than 15 years (see Figure 8 below for a timeline of the MVTC). Long-time contractor, PMG Technologies Inc., manages the day-to-day operations of the facility alongside a small number of TC employees. Testing programs are designed by members of the Regulations and Oversight and Enforcement functions in the National Capital Region (NCR), which are then coordinated and carried out by PMG at the Centre. PMG is encouraged to lease the facilities to external parties when not in use by TC.

In summer 2023, the MVTC went through a PSPC-managed contract renewal process. TC launched the process assuming that they would receive multiple, competitive bids, but due to the small size of Canada’s motor vehicle testing industry and the unique services, PMG was the only organization to submit a bid and re-signed a 15-year contract. This contract can be revisited every five years by mutual agreement between TC and PMG. The new contract modified the Centre’s operating model by 1) increasing oversight via a task authorization system, and 2) imposing new limits on commercial activities.

This evaluation reviews, at a high level, the strengths and weaknesses of the MVTC’s operating model only as a more thorough review of the MVTC’s operating model is being conducted by an external contractor. This evaluation focuses on the pros and cons of the current GOCO contract with PMG and does not address the relevance or performance of the MVTC.

7.2 Quality of work

Finding 6: The contractor for the MVTC provides a high quality of work at a fair rate but there are limited opportunities to reduce/recover the costs of running the Centre.

Overall, interviewees were satisfied with PMG’s performance. They praised the high caliber and professionalism of their testing services and the contributions that PMG has made to producing research that benefits both TC and the overall road safety community. Although the MVTC’s operating costs are high, they are reflective of PMG’s quality of work and the inherent expenses of operating a large and specialized research facility. There are no other firms in Canada that offer comparable services for motor vehicle testing.

Interviewees noted several positives of the GOCO contract. As the Centre is government-owned, it allows TC to maintain priority access to the Centre (whereas a private company may double book). Government ownership also incentivizes PMG to be a responsible steward of TC resources. Since PMG is a private contractor, it can also move faster than government and attract commercial activity to the MVTC to help with cost recuperation.

Concerns about new technology and the MVTC’s testing capacity were expressed. Although the structural facilities are out of scope for this evaluation, it was noted that the MVTC is falling behind in their ability to test new technologies. As a result, TC has had to look to U.S. facilities to conduct certain types of specialized testing, which generates additional administrative work around importing and exporting vehicles.

Finally, interviewees noted the benefits of the GOCO model and emphasized the importance of maintaining positive relations with PMG, particularly given the lack of other options for TC to maintain the critical safety work performed at the MVTC. There is a need for the department to strike a balance between ensuring that the contract reflects Canada's requirements while also being mindful of the impacts of any new restrictions or administrative requirements on the contractor.

7.3 Recovering costs

Given the complexity and high quality of work conducted at the MVTC, the operating costs are also high, with few opportunities to reduce/offset these costs. One opportunity would be to increase third-party use of the Centre, but as mentioned above, TC needs to maintain priority access for its own testing and research activities, which are subject to budget timelines and have an unpredictable schedule. There is also minimal demand for private testing since large vehicle manufacturers have their own testing facilities. In addition, the new contract in 2023 imposed restrictions that limit how third parties can use the facility (e.g., film and television productions are no longer allowed).

7.4 MVTC capacity

Capacity at the MVTC is an area of concern. TC currently relies on PMG staff to conduct tests, which has led to a lack of technical expertise among TC staff. Interviewees emphasized the importance of having expert engineering staff on site at the Centre to work with industry on improving products and produce international research.

“The capacity of technical people is limited at TC. People aren’t getting the experience and they’re becoming more removed from the daily technical work. We’re going to pay for that in the long run.” – TC interviewee

Overall, the MVTC’s GOCO model has both strengths and weaknesses. Despite the importance and the high quality of work being done at the MVTC and the professionalism of the contractor, there are limited opportunities to reduce or recover the high costs of operating the centre. Interviewees emphasized the need to continue working collaboratively with PMG to maintain critical research and testing capacity.

Section C: Road Safety funding programs

8. Funding programs

8.1 Funding programs background

TC’s Road Safety Transfer Payment Program (RSTPP) consists of two components: Motor Carrier Safety under the RSTPP, and Road Safety Outreach under the Enhanced RSTPP (ERSTPP). The former is a longstanding program that supports the provinces, territories, and the Canadian Council of Motor Transport Administrators (CCMTA) in their implementation of the National Safety Code (NSC), while the newer Outreach component through the ERSTPP supports diverse initiatives that help create nationally consistent tools to address road safety challenges. Table 1 highlights some basic differences between the two programs.

Table 1. RSTPP and ERSTPP comparison

Criteria	RSTPP (Motor Carrier Safety)	ERSTPP (Road Safety Outreach)
Launch date	RSTPP: 1987	ERSTPP: 2019
Funding type	RSTPP: A-base	ERSTPP: B-base
Amount	RSTPP: $4.4M per year	ERSTPP: $30M for 2019 to 2022; $27.1M for 2023 to 2026
Recipient type	RSTPP: PTs, CCMTA	ERSTPP: PTs, CCMTA, non-profits, academia, for-profit companies, municipalities
Purpose	RSTPP: Enforcement of NSC and delivery of training for commercial motor vehicle drivers/inspectors	ERSTPP: Development of tools that address road safety challenges (e.g., frameworks, standards, policies, programs, data, outreach)

TC’s Transportation Infrastructure Programs group administers both programs while the Regulations function provides policy support for the ERSTPP.

8.2 RSTPP

Finding 7: There is a continued need for RSTPP funding for provinces and territories to support a consistent approach to commercial vehicle safety.

The inter-provincial movement of trucks, busses, and other commercial vehicles creates a shared responsibility for motor carrier safety between the federal government and PT governments. The RSTPP, previously called the National Safety Code Contribution Program, was established in 1987 to support the implementation and administration of the NSC. This is a set of 16 performance standards that help to ensure a safe, standardized approach to the operation of commercial vehicles in Canada. Of these 16 standards, the RSTPP supports a subset of 4 known as the Safety Fitness Framework.

Since its inception, the RSTPP has received a consistent $4.4M per year in A-base (i.e., permanent) funding. TC distributes this amount among PTs each year using a population-based costing formula; all PTs have contribution agreements with the RSTPP except for Nunavut, which is currently unable to participate due to capacity constraints. PTs use this funding to support roadside enforcement activities, conduct training, and generally enforce federal regulations affecting cross-border commercial drivers.

The RSTPP also contributes an annual amount of $60,000 to the CCMTA, which acts as the custodian of the NSC. The CCMTA uses these funds to deliver training and education for commercial motor vehicle drivers and inspectors.

RSTPP funding to PT governments does not require an annual application; instead, PTs submit yearly reports to TC on work completed and invoice the program up to the pre-determined amount. These reports include the results of any investigations or inspections of driver and motor carrier companies that took place during the year.

Road transportation is the primary mode of shipping in Canada, with approximately 77% of goods (by volume) being moved by truck. ^{Footnote 31}In this context, there is a clear, ongoing need for RSTPP funding. In fact, several internal interviewees felt that the program has been long underfunded, pointing out that although costs for enforcement and reporting have increased with the addition of new federal rules governing commercial drivers (such as requirements around electronic logging devices ^{Footnote 32}), the RSTPP’s yearly funding has remained unchanged for over 30 years.

“With the amount of trucks we have and the fact that there are more goods being transported by trucks, our funding is a drop in the ocean. [$4.4M] is absolutely nothing and provinces and territories have said so repeatedly – if they want to be effective in compliance and oversight and enforcement, the money is not enough.” – TC interviewee

Given the stable nature of the funding involved, previous evaluations explored the option of changing the RSTPP from a contribution program to a grant, which would simplify its administration and reduce the reporting burden on recipients. However, interviewees indicated that the administrative effort associated with the RSTPP is minimal and the annual reporting by PTs allows the government to maintain close oversight on how the funding is being spent.

8.3 ERSTPP

TC introduced the Enhanced Road Safety Transfer Payment Program (ERSTPP), the outreach component of RSTPP, in 2019. It provides short-term project funding to a variety of road safety stakeholders including PTs, municipalities, not-for-profit groups, for-profit enterprises, and academia. Unlike the RSTPP, recipients must apply for ERSTPP funding, which covers up to 75% of projects costs. There have been four calls for proposals since the program’s launch, with the most recent call closing in February 2024. ^{Footnote 33}As seen in Table 2, over the program’s four completed calls, TC has approved 89 projects for funding and 80 have been completed (118 applications were received during Call 4. The number of approved completed projects for Call 4 were not available at the time of writing).

Table 2. ERSTPP applications and approved and completed projects by call

Source: Transport Canada

Call	Number of Applications	Number of Approved Projects	Number of Completed Projects
Call 1 (2019)	22 applications	22 approved projects	20 completed projects
Call 2 (2020)	46 applications	38 approved projects	33 completed projects
Call 3 (2021)	60 applications	29 approved projects	27 completed projects
Call 4 (2024)	118 applications	35 approved projects	N/A
Total	246 applications	89 approved projects	80 completed projects

The ERSTPP’s open, non-prescriptive approach to funding has attracted a diverse set of project applications, including:

• Research projects (31.5%)
• Technology and innovation projects (23.6%)
• Public awareness campaigns (20.2%)
• Updates to standards and regulations (13.5%)
• Data and knowledge-sharing initiatives (11.2%)

8.4 Case studies

To better understand the types of projects that TC selects for the ERSTPP and their impacts, six case studies were conducted. As discussed in the Methods section, to obtain a representative sample, the case studies were selected based on the following criteria: location, recipient type, project type, project cost, and project year (to cover each of the calls for proposals; see Table 3). The selected projects were chosen based on their diverse approaches to enhancing road safety in Canada through outreach, policy, research, and innovation.

Table 3. Selected ERSTPP case studies ^{Footnote 34}

#	Project cost (TC funding amount)	Call #	Location	Project Type	Recipient Type	Project name	Outputs
1	High cost: $1,991,770	Call 3	Pacific	Project type: Research	Recipient type: Academic	Monitoring Impaired Driving in Canada	A national dataset on drug use among drivers has been shared with academics, policy makers and expert groups.
2	Medium cost: $760,636	Call 2	Ontario	Project type: Public campaign	Recipient type: Private company	Raising Awareness and Knowledge of Advanced Driver Assistance Technologies Amongst Motor Vehicles Drivers through Virtual Reality Technology	Ontario driving students familiarized themselves with new technology on a simulator and before driving on public roads.
3	Low cost: $71,250	Call 3	PNR	Project type: Research	Recipient type: Public insurance group	Observation Study on the Use of Seatbelts and Handheld Electronic Devices Across Manitoba	Key findings on distracted driving and seatbelt use will be used to plan future awareness and enforcement campaigns in Manitoba.
4	Medium cost: $130,500	Call 2	Ontario	Project type: Data/ knowledge sharing	Recipient type: Industry association	Ontario’s Vision Zero Guide	Canada’s first Vision Zero guide, including steps on how to implement Vision Zero.
5	Medium cost: $440,000	Call 3	Quebec	Project type: Public campaign	Recipient type: Not-for-profit organization	Safety Awareness Campaign for Beginner and Novice Motorcyclists	Awareness videos were incorporated into QC driving programs and were received positively by students.
6	Low cost: $28,648	Call 1	National	Project type: Standards and regulations	Recipient type: CCMTA	Strengthening and Enhancing the National Safety Code (NSC)	Strengthening NSC Standard 6 on cardiovascular conditions. Now in use by CCMTA’s membership and other stakeholders.

These case studies provided insight into some of the key benefits and limitations of the ERSTPP.

8.5 Benefits of ERSTPP

The ERSTPP is a unique program in that it offers funding for diverse projects, in terms of their subject matter and interventions. Internal interviewees pointed out that while similar programs exist in the U.S. and Europe, they tend to be focused on a specific issue; by contrast, the ERSTPP funds a variety of topics, from motorcycle safety awareness to observational studies on seatbelt use.

All four calls for applications have been oversubscribed, indicating a strong appetite for ERSTPP funding among road safety organizations. The funding addresses a public demand to conduct road safety initiatives that benefit not just large organizations but also smaller, grassroots groups:

“It’s mom and pop, volunteer organizations that apply. They're not looking for a lot of money, but they’re doing important work and creating meaningful projects in the community.” – TC interviewee

Interviewees also emphasized the importance of the program’s role in advancing research, especially as technology and trends on Canadian roads evolve. Other Road Safety programs like the Regulations and CAV Policy functions can benefit from the results of this research when drafting related regulations and guidelines.

Case study participants echoed the value of ERSTPP funding, which allowed them to develop new and innovative projects or expand the scope of ongoing activities. Several recipients re-applied to the program in subsequent calls for proposals or were planning to in the future. One interviewee observed that some road safety topics (such as accessibility in transportation) are often difficult to match with available funding sources; the ERSTPP’s more generalized approach to project eligibility helps to bridge that gap. It also allows smaller organizations to tailor projects to the trends and topics that are most important in their region.

“ERSTPP allowed many organizations to access support for their road safety initiatives that they wouldn’t have been able to do. It has contributed to our understanding of road safety in Canada and helped us work toward safer roads.” – External interviewee

In terms of administrative processes, recipients appreciated how the program’s flexibility allowed them to combine the ERSTPP with other funding sources or modify their budgets to carry funding forward to the following year in case of unforeseen delays (for example, in response to pandemic-related complications which were common for projects in the program’s first two calls for proposals). Some felt the application package was too long, but most agreed that it was generally straightforward and in line with similar largescale funding programs. Recipients found that the frequency of reporting to TC was manageable and not overly burdensome.

Recipients also indicated that TC communicated well throughout the lifespan of their projects and found that the online program information was useful. More than one recipient praised the performance of ERSTPP staff, who were responsive to questions and quick to help them navigate any challenges along the way.

8.6 Limitations of ERSTPP

Road safety outcomes are the result of several interacting factors, some of which have been explored in this report, like familiarity with new technology, testing and certification, and defect completion, to name a few. Positive change in road safety outcomes may not be obvious for several years, and even then, lower collision and fatality rates are difficult to link back to specific initiatives. Because of this, assessing the effects of a specific program or initiative can be difficult, and the diversity in the scope, scale, and intended results of ERSTPP projects adds another layer of complication. In general, the topics addressed by recipients’ projects seemed timely and were often aligned with important themes raised by TC staff (such as understanding ADAS technology and measuring impaired driving). Based on this, the evaluation determined that these projects are cumulatively contributing to the advancement of road safety in Canada.

However, some internal interviewees felt it was too early to comment on the tangible impacts of ERSTPP projects (which are generally short-term) and tracking the performance of specific ERSTPP initiatives was not systematic. Others felt that the broadness of the funding may have diluted its effectiveness and suggested that it may be more valuable to select projects that focus on higher risk areas based on an analysis of road safety data.

“We need to appreciate the road safety landscape from a data perspective more maturely to select more impactful interventions.” – TC interviewee

The ERSTPP’s fourth call for proposals was more targeted than previous calls, aiming to prioritize projects that:

• Address the leading causes of road collisions and fatalities (i.e., impairment, distraction, aggressive driving, and excessive speed)
• Promote innovative design, testing, and integration of CAVs
• Contribute to the education, training, testing, and enhancement of ADAS technologies

Secondary focus areas included vulnerable road users, commercial motor vehicles, enforcement activities, and emerging road safety technology. ^{Footnote 35}

8.7 ERSTPP administration

Case study participants highlighted a few areas where the ERSTPP’s administrative processes could be improved. Several recipients reported long delays between their project application being approved in principle and having a signed contribution agreement in hand, leaving recipients in a state of limbo in the interim. All recipients are responsible for funding their projects upfront and receive a reimbursement from the ERSTPP after the work is completed, but some (especially smaller, more risk-averse, or less financially flexible organizations) preferred to wait for a signed contribution agreement before proceeding, which ultimately compressed their project timelines.

Internally, these delays were related to seeking approval of projects from the Minister, which can take three months or longer. Combined with the time TC’s Infrastructure Programs need to negotiate the details of each contribution agreement with recipients, this could create a gap of six or more months between initial approval and project launch.

Ministerial approval is required at two stages of the ERSTPP’s internal process: the first is to launch a new call for proposal, where the ERSTPP needs to secure policy and funding authorities; and the second is to approve recommended projects. As such, it is difficult to predict the exact timeline of a call for proposal as the launch may depend on various factors such as budget or funding decisions, a Treasury Board decision, or a ministerial approval. The duration of the call (i.e., the time given applicants to submit a project proposal) has added an extra week for each call based on the growth of demand for the program, beginning with 5 weeks for the first call, 6 weeks for the second, 7 weeks for the third, and 8 weeks for the fourth call.

The project reimbursement process operates through an online claim system called SIS (Surface Infrastructure System), a program that TC is adopting to standardize the delivery of grants and contributions. A recent evaluation of TC’s Airport Capital Assistance Program highlighted challenges with SIS, noting that it takes more time and there are more steps to processing claims compared to the old method through Microsoft Outlook and the Oracle Financial System. ^{Footnote 36}ERSTPP interviewees felt that submitting project expenses through SIS could be clunky and time-consuming, requiring recipients to balance their budgets exactly in order to proceed with a claim; one recipient speculated that the system was likely designed for expensive, large-scale infrastructure projects and therefore ill-suited for smaller projects like those funded through the ERSTPP.

Despite these issues, recipients who had applied to more than one ERSTPP call for proposals observed that processes seemed to improve as the program matured, with staff learning from the experience of previous calls and making improvements where possible.

Lastly, in the early days of the ERSTPP, recipients could not receive more than $10M in cumulative funding over five consecutive years across both the RSTPP and the ERSTPP, meaning that larger PTs were limited in how many projects they could submit. In September 2023, the ERSTPP was modified so that funding is now capped at $10M per project instead of per recipient and references to the five-year consecutive period were removed.

Conclusions and recommendation

Overall, the objective of this evaluation was to assess the relevance, effectiveness, and efficiency of TC’s Road Safety programs. Based on the evidence collected, it is clear that there is an ongoing need for road safety programming in Canada given that, when compared to other modes of transportation, travelling by road is the most dangerous (as indicated by the total number of road-related fatalities), and the motor vehicle industry is advancing rapidly, fundamentally altering the way in which motor vehicles function and are operated (e.g., CAVs). Canada’s federal road safety regulatory framework and oversight functions are two key interventions that are intended to address these factors, in partnership with PTs and municipalities. TC’s Road Safety programs have succeeded in bolstering some of their key program activities, like amending the MVSA to strengthen their oversight and enforcement tools, and conducting valuable testing and research at the MVTC, under a renewed operating contract.

However, the rapid evolution of the motor vehicle industry, including the constant changes in vehicle technologies, is causing issues and impacting TC’s ability to keep its road safety regulatory framework current. This issue is exacerbated by static staffing levels and a lengthy regulatory development process. Furthermore, a lagging regulatory framework has a cascading impact on the oversight and enforcement function, reducing the efficiency of the program overall.

For these reasons, there are key challenges that the department must address in the future. A key challenge will be to identify ways to reduce the regulatory backlog and keep the regulatory framework, and its associated safety standards, harmonized with international partners and reasonably up to date with current motor vehicle technologies. Although this will be a complex and resource intensive task, it will lead to improvements for the downstream work of the Oversight and Enforcement function.

Annexes

Annex 1: Management Action Plan

This Management Action Plan addresses the recommendations of the evaluation with proposed actions, forecasted completion dates and the Office of Primary Responsibility.

Recommendation	Proposed Actions	Forecast Completion Date	OPI
1. TC’s Road Safety Programs should: Assess the potential for collaborating with other Canadian organizations that collect road safety data, with a view to improve the NCDB.	1.1 Conduct an environmental scan of alternative data sources that could inform regulatory research and development.	1.1: End of fiscal 2025-2026	ADM, Safety and Security
	1.2 Conduct feasibility/proof of concept projects to assess viability of data resources for different regulatory needs.	1.2: End of fiscal 2027-2028	ADM, Safety and Security
	1.3 Explore partnerships (e.g. MOUs) and/or procurement contracts to support longer term regulatory needs within available resources.	1.3: End of fiscal 2028-2029	ADM, Safety and Security

Annex 2: Case study descriptions

Case Study 1

Project Name: Monitoring Impaired Driving in Canada

Recipient: University of British Columbia (UBC) - Road Safety and Public Health Research Lab

ERSTPP Funding Call: 3

TC Funding: $1,991,770

Completion Date: March 2023

Description: This project aimed to produce the first objective national data set on drug use in drivers, a phenomenon which had previously been poorly studied in Canada. The research team monitored alcohol and drug use by testing leftover blood from injured drivers treated in 16 participating trauma centres across Canada. Among other findings, it was observed that younger and male drivers were more likely to test positive for substances than other demographics.

Results: The research team has shared their work in multiple venues, including academic presentations and publications in scientific journals. Aggregate reports and findings are being made available for use by policy makers and expert groups, hopefully leading to more effective interventions and an eventual decrease in drug-related incidents on Canadian roads.

Case Study 2

Project Name: Raising Awareness and Knowledge of Advanced Driver Assistance Technologies Amongst Motor Vehicle Drivers through Virtual Reality Technology

Recipient: Innovations in Business Solutions Inc. (IBS)

ERSTPP Funding Call: 2

TC Funding: $760,636

Completion Date: March 2023

Description: In a survey of Ontario drivers, IBS found that car dealerships would often list new safety features without demonstrating how they worked, leaving drivers to contend with beeping, vibrating, or automatic controls that could potentially cause confusion/distraction and reduce safety. To address this gap, IBS developed a simulator that would allow drivers to experience features like lane departure warnings, crash avoidance, and backup sensors before getting on the road. The machine was equipped with a steering wheel and a screen that allowed participants to safely experience different virtual driving scenarios.

Results: IBS worked with driving schools in Ontario so that student drivers could benefit from use of the simulator, which was well received.

Case Study 3

Project Name: Observation Study on the Use of Seatbelts and Handheld Electronic Devices Across Manitoba

Recipient: Manitoba Public Insurance

ERSTPP Funding Call: 3

TC Funding: $71,250

Completion Date: March 2022

Description: This project studied risky driving behaviour in Manitoba. Approximately 29,000 vehicles were observed in 46 towns and cities across the province in September 2021. Some key findings:

• Younger drivers were more likely to use handheld devices
• Handheld device use was higher in Winnipeg than in rural areas
• Non-seatbelt use was higher in rural Manitoba
• Those driving trucks were more likely to not wear seatbelts compared to cars or vans/SUVs

Results: This research will be used to plan future distracted driving awareness and enforcement campaigns in Manitoba.

Case Study 4

Project Name: Ontario’s Vision Zero Guide

Recipient: Ontario Traffic Council (OTC)

ERSTPP Funding Call: 2

TC Funding: $130,500

Completion Date: March 2023

Description: The OTC created Canada's first comprehensive Vision Zero guide, with the goal of assisting Ontario municipalities to develop or expand their own Vision Zero programs. The OTC gathered knowledge and perspectives from municipalities (in Canada and abroad), academic experts, and the Vision Zero Academy in Sweden.

The Guide contains background information on Vision Zero's philosophy and describes the detailed steps required to develop and implement Vision Zero.

Results: Although targeted mainly at Ontario municipalities, the Guide has been made available for use by professionals involved in transportation infrastructure and road safety across Canada. It has garnered positive feedback from municipalities and other road safety stakeholders.

Case Study 5

Project Name: Safety Awareness Campaign for Beginner and Novice Motorcyclists

Recipient: Fondation québécoise d'éducation en sécurité routière (FQESR)

ERSTPP Funding Call: 3

TC Funding: $440,000

Completion Date: January 2023

Description: This awareness-raising campaign focused on discouraging impaired and distracted driving/riding, particularly among younger drivers/riders. The project produced four short videos with a humorous bent, where winning a “What a Champ” trophy isn’t something to be proud of.

Results: FQESR partnered with QC driving schools to integrate these videos into their curriculums, where they were positively received by young/novice drivers and riders. The videos were also posted on YouTube and featured on Harley Davidson’s website.

Case Study 6

Project Name: Strengthening and Enhancing the NSC

Recipient: CCMTA

ERSTPP Funding Call: 1

TC Funding: $28,648

Completion Date: January 2021

Description: This project provided funding to the CCMTA to update NSC Standard 6, which establishes the criteria that determines whether someone is medically fit to drive. Based on a comprehensive review of new medical evidence, members, stakeholders, and consultants came together to propose changes that would strengthen Standard 6, particularly the chapter on cardiovascular conditions.

Results: The updated NSC standard document has been published on CCMTA’s website for use by CCMTA's membership and other stakeholders.