I am someone who has spent…

I am someone who has spent the last few years as a light and heavy duty (both diesel and gas engine) inspector at a facility that is also certified to perform drive clean repairs. I have seen a bunch of pros and cons of the program at my level and would like to make some comments about my observations as an inspector. This is very long and goes into some detail, but I have a summary at the end.

First of all, the testing needed to become an inspector is absurd. The skill required to perform the emission test itself is very low, but it can be difficult to find people who are capable of passing the test required to become an inspector. The inspection process is very simple, as all of the steps are spelled out one-by-one while performing the test, and calibrating the machine prior to testing is not difficult. The testing to become an inspector asks some complex and useless questions that do not relate to the process of performing an emission inspection. At least, that was my experience when I went for my test to become an inspector years ago.

As a drive clean facility, we are responsible for keeping the testing machine in good repair. The skill required to perform basic diagnostic and repairs on the machine is still very low, and if there is any issue that cannot be fixed easily the drive clean program can be contacted to assist in the diagnostic. If there are any problems that cannot be figured out through remote diagnostics, there are mobile technicians that can be dispatched to assist with diagnosing issues and repairing the testing machine.

The machines use some old technology, so when parts do need to be replaced, they can be absurdly expensive as they are now vintage parts. The cost of these repairs is prohibitive to the drive clean facilities. The drive clean program at a facility level is also a complex process, and we deal with audits on a regular basis that can take up a considerable amount of time to assist with. In addition, ever since the tests became free to the customer it has become even more complex on the accounting side.

Generally businesses use lower skilled and therefore lower paid employees to perform these tests as they are very simple, so with the recent minimum wage hike and no increase in payment of these tests, it should be pretty clear that there is no money to be made from the drive clean program as a facility. I have seen a number of places shut their testing program down and refer their customers to us because of these factors. We continue to do this as a loss-leader to keep customers coming back for other work instead, and we basically strive to break even from our participation in this program. From a business perspective, this program does not make much sense. If you think it is bad for the government and the taxpayer, it is also bad for the business as well.

The pre-test check for vehicles asks us to check for exhaust leaks pre-catalytic converter, or to check if any emission components are missing. On most vehicles, this is not possible without putting the vehicle on a hoist. We can make a guess based on the sound of the exhaust, but there is no definitive way to know with how the test is setup. Because of this, on something like a diesel test, we cannot know if they have removed their catalytic converter, performed an EGR bypass and delete, and flashed their PCM to stop the check engine light from showing up, for instance, yet when testing the vehicle it would still pass. This is just one example of many. It’s entirely possible to swap the engine to a different engine, and the inspection tech would have no way of knowing it had been done. I have declined dozens of vehicles from tests due to audible exhaust leaks, but I don't know how many other places do the same as it does take some knowledge to be able to know what you are hearing, and a lot of places that perform these tests do not have licensed mechanics that can double-check things like this. I personally believe this program should be limited to places that have licensed mechanics around to ensure it is being done properly, even though the test itself is not complicated enough to justify requiring a licensed mechanic to perform the test.

The testing process itself is also terrible and if the program is ever to be kept in the long run or revived in the future, it should be radically redesigned. As an example, for a light duty OBD test, the first step is to input vehicle information into the testing machine. From there, it confirms that the vehicle needs an OBD test, and asks me to attach the OBD connector. At this point, if there is an issue with the connection to the vehicle, it will abort the test. This can happen from something as simple as just accidentally hitting the connector when going in or out of the vehicle. From there, it asks me to take photos of the vehicle and upload them. After I finish uploading the photos, it starts the heart of the OBD test, which takes approximately 1-2 minutes. From there, the test is over. The time it takes to perform the entire test could be reduced if it had started to perform the OBD test before taking photos, and then while the OBD test is running, the inspector could be taking the photos as required, then upload the photos and have the test finish the entire test one or two minutes quicker. While this does not seem like a big deal, one to two minutes per test can be a big deal in the long run, as this would allow a busier shop to get a few more tests completed per day or leave more time for other productive work, which would make it a more viable program. Other changes could be made for all other types of tests to streamline the process. I suspect the reason these types of changes have not been implemented is due to either the costs to implement them, or that the older technology is not capable of doing these separate actions simultaneously. I’m sure I can’t be the only person who has thought of this along the way.

Another frustrating thing for the inspectors and the customers is when situations where the inspector gets partway through the test and some error occurs, such as finding out the camera is no longer paired to the OTU. This is one example, but there are many other types of errors that occur during tests and force them to be restarted and wastes time.

Any good business would want to do whatever they can to streamline processes like these tests to increase productivity and therefore revenue, but as these tests seem to have been designed by people that do not perform them, I do not think streamlining them were as high of a priority as I believe it should have been. When there are hundreds of thousands of vehicles being tested each year, it adds up to a large amount of hours wasted.

I have had to charge several customers for their light duty tests because they had it performed too early. For some people, their convertible gets parked in the winter, and because of that they need to have the test performed before they put it away for the winter so they can get a valid sticker in the spring when their car comes out of hibernation. It can also be difficult to explain this to the customer, as the drive clean program has been advertised as “free” and that is now the expectation.

When a light duty test fails, it can often be difficult to explain the conditional pass process to customers. This can be even more difficult if there is a language barrier. We are a country with numerous nationalities represented, and it is not uncommon to have a customer come in who does not speak the same language as their primary language. If the test fails due to a “not ready” status, it can also be difficult to explain to the customer how to proceed. The guidelines say that the customer needs to drive 40km and spend 48h between tests, but from experience I know that certain makes typically need more than 40km to get out of “not ready” status. Additionally, a lot of people wait until their sticker is very nearly due to have the emission test performed on their vehicle, which causes issues for them when they get a fail or not ready result. A lot of people do not understand that the process takes some time, and sometimes their stickers run out before they get a pass.

I have seen many vehicles receive a conditional pass and come back 2 years later without getting repairs performed. These customers usually have us diagnose their vehicle again and supply them with another conditional pass. Some of these vehicles will be very heavily polluting, and because of that loophole it makes the program pretty ineffective at ensuring these vehicles get fixed or removed from our roads. I completely understand and appreciate the reasoning behind the conditional pass program. I understand that people may not have the money to fix the problem at that moment, but some people have no intent to ever repair their vehicles. These vehicles are some of the worst polluting vehicles on our roads, and the ones that I believe the drive clean program was designed to try to fix or remove from our roads.

A number of my customers paid for repairs in excess of the conditional pass amount because of the changes to the conditional pass program. As no more consecutive conditional passes would be awarded, these customers chose to repair their vehicles and receive pass results, so that if something else happened in the future which is expensive, they could obtain a conditional pass at that time. I believe we will be able to see fewer failures in the future due to this change, and in my opinion, this was one of the most important changes I have seen as a drive clean inspector in the years I have been performing these tests. In my opinion, it should have been like this from the start. Also, in my opinion, I believe that the light duty program was highly ineffective until this and other changes were made that started on April 1, 2017. There were a number of ways that the system could be cheated and the changes helped eliminate some of the biggest offenders. At least, it would, if the program were to continue.

I support winding down the drive clean program. It was never intended to last forever, and the number of failures has drastically decreased. I have watched that happen as an inspector, and I have seen we have fewer repairs performed as well. I also believe the program should continue for another two years (ending April 1, 2021), as this would force some of the biggest offending vehicles that have abused a loophole in the system to either fix their cars, or retire it. I am sure there would be some stubborn individuals who would keep their car parked until the program is cancelled instead of repairing or retiring their cars, but I suspect keeping the program running for an additional two years would remove a lot of polluting vehicles from the road or have them get fixed.

As an emission inspector, I have also witnessed some vehicles in terrible mechanical shape come in for an emission test, also knowing that the owner has no intention of repairing the vehicle. I have performed emission tests on many vehicles I would not feel comfortable driving on the road, yet pass the emission test. If the drive clean program is to be discontinued on April 1, 2019, as an emission inspector and as a taxpaying citizen, I hope that a mandatory safety inspection is implemented on all vehicles every two years instead of a drive clean test as a prerequisite to obtain new license plate stickers. I believe this should include checking for diagnostic trouble codes in the vehicle’s computer if applicable, checking to see that a drive cycle has been run (to stop people from just disconnecting and reconnecting the battery to clear diagnostic trouble codes) if applicable, and ensuring that no lights such as the check engine light, ABS, traction control, emergency/parking brake, wrench light, and any other warning lights are illuminated in the instrument cluster as these signal that there is an issue with the vehicle. I also believe these inspections should also check to ensure that the factory emission control systems have not been tampered with or removed.

When it comes to heavy duty vehicles, I support keeping the program, but I do believe some modifications could be made. Similar to how diesel vehicles that have less than 20% opacity can skip a year I believe we should extend the ability to skip a year to heavy duty gas vehicles as well. I would also strongly suggest reducing the opacity limits as even 20% opacity is a lot and most vehicles should be well below that amount. Heavy duty vehicles are also usually more expensive than passenger vehicles and often used for business purposes, and from a business perspective it is usually cheaper to repair and keep an older heavy duty vehicle than buy a new one so these vehicles often have a longer lifespan than passenger vehicles. As heavy duty vehicles are usually the type of vehicles that put more mileage on them, or spend time idling, and are older, these vehicles will produce more pollution than a light duty vehicle would and I believe testing should continue on these vehicles.

In summary, I believe the program for light duty emission inspections should last for an additional 2 years past when it is scheduled to be retired in 2019. Our province and the people in it have spent a lot of money running this program for years with a giant loophole. The loophole was closed in 2017, and retiring the program earlier than 2021 stops that change from being effective. While all previous expenses on this program are sunk costs, I believe it is still worth continuing to get some of the worst polluting offenders off the road or fixed as that is the intent of the drive clean program. If the program is to be cancelled in 2019, I believe that we should institute mandatory safety checks and expand the requirements of the safety check to check for emission concerns as part of the safety inspection in its stead, as this would accomplish the same goal. I support making changes to the heavy duty test process as I believe gas vehicles should also be able to skip a year if they are in good working order, and I also would hope that the opacity limit for diesel tests is lowered as the current amount allowed is very high.