Enserva Delivers – Advocacy Win!

Modernized Alberta Oil Well Service Vehicle Cycle Exemption Permit

Enserva is pleased to announce that, as a result of our advocacy efforts, the Government of Alberta has released an updated modernized Oil Well Service Vehicle Cycle Exemption Permit and made complimentary amendments to the Exemption Policy as well. A copy of the Exemption Permit can be found here, and a copy of the Exemption Policy can be found here. As part of their roll-out, Alberta Transportation has notified all enforcement agencies of the updated permit conditions and procedures and will make website updates. Alberta Transportation will also be emailing all permit holders to inform them of these changes and permits will be updated and sent out over the next weeks.

The Oil Well Service Vehicle Cycle Exemption permit support an exemption provided in the Federal Hours of Service Regulation for oil well service vehicles. The changes made to the Alberta permit clarify the language of the permit conditions and expand language on services allowed under the permit to create efficiencies for the industry while maintaining a focus on public interest and safety.

The energy services industry has changed significantly since the Oil Well Service Vehicle Cycle Exemption Permit was developed and there was a need to modernize the permit to reflect current operating practices. In summer 2022, Enserva brought together a subcommittee of members to provide input on suggested changes to the permit. For Enserva members using the permit, the biggest roadblocks encountered are the limitations in the allowed conditions. Following a formal submission to Alberta Transportation and a series of advocacy meetings over the last year, we have landed on an updated permit that better reflects current operating practices and the realities of today’s energy services sector.

Work is also underway to harmonize the updated permit conditions across Western provinces. Enserva has been working with representatives from Saskatchewan over the last year and it is anticipated that Saskatchewan’s updated permit conditions will be rolled out in the coming weeks. Enserva has also engaged with representatives in British Columbia, Manitoba, Northwest Territories, and Yukon.

Changes to the exemption conditions:

  • Change #1: We requested the removal of the clause that states: “The primary intent of this Permit is to only allow a transportation service to be provided directly to or from a well head. Unless specifically stated, the Permit does not apply when travelling between any two locations that do not include a well head site”. The clause was not removed but was adjusted to expand the scope of when the permit applies to include the staging location as a third location, where the driver can pick up equipment and materials before directly travelling to an active well site. This will help permit users significantly as it will allow equipment to be picked up on the way to a well site or approved location.
  • Change #2: Amended the clause that states “Travelling ‘directly’ may include making rest stops (each no longer than 24 hours) such as at a motel, branch office, etc. before getting to the final destination (e.g., well site or home terminal” to include “staging” and to add flexibility on the 24hrs period for unforeseen on-site delays. In essence, the 24-hours period for a rest stop can now be extended for unforeseen delays provided the driver documents the reason for the delay and stays within operational requirements.
  • Change #3: Amended the clause that states “Directly servicing or drilling of the well head or of equipment directly associated with the drilling of the oil/gas well site such as testing, mud filling, cementing, hydraulic fracturing, data logging, servicing done with a water truck or vacuum truck, etc.” as we requested to reflect the increased scope of activity that occurs on a well pad site in present day. The new clause reads “Directly servicing or drilling of the well head or of equipment directly associated with the drilling of the oil/gas well site for services done by and in relation to coil tubing, well testing, wireline, cementing, water or vacuum trucks, well head maintenance and hydraulic fracturing.”
  • Change #5: Amended the clause that states “Conducting driver evaluations/re-certifications in a vehicle as long as the duration does not exceed 3 hours. A copy of the evaluation is to be retained in the driver’s file and the time must be noted in both the driver’s and the examiner’s daily logs” to include our requested changes of removing the “3-hour time limit” on driver evaluation and recertification. This will help a lot of members with driver training
  • Additional changes include:
    • The permit holder is now required to provide the Registrar quarterly updates to the list of drivers who are authorized to operate under the terms and conditions of the exemption permit.
    • Expanded language on collision reporting to align with compliance requirements.
    • Removal of the requirement for employee signature on training records.

Background – What is the Oil Well Vehicle Cycle Exemption permit?

The Oil Well Vehicle Cycle Exemption Permit is an exemption permit exempts oil well service vehicle carriers/drivers from some of the mandatory off-duty requirements under the federal Commercial Vehicle Drivers Hours of Service Regulation (“the Regulation”), if the motor carrier meets the regulatory definition of an oil well service vehicle and provide at least one of the eligible services outlined in the permit. The reason for hours of service exemption is that the Oil Well service vehicle drivers typically need to work for longer periods than the cycle limits imposed by the Regulations. The exemption permit applies to carriers that travel extra-provincially and their drivers of oil well service vehicles who are engaged in specialized services to the oil and gas industry between and through the provinces of British Columbia, Alberta, Saskatchewan, and Manitoba.

“Hours of service” refers to the maximum amount of time drivers can be on duty within a given period of time. These rules include driving times and specify the number and length of rest periods drivers must take between shifts. Knowing the hours-of-service rules is essential for many fleet managers and drivers. Hours of service—or HOS—rules govern the maximum allowable working hours for drivers of commercial motor vehicles. These rules help truck drivers stay safe and alert while on duty and keep the public interest and safety at the forefront.

Transport Canada’s Motor Carrier Division is the federal department responsible for transportation policies and programs in Canada. While Transport Canada oversees federal governance, most of the daily regulatory enforcement is handled by the individual provinces and territories.