The public comment period closes March 8, 2019 for a joint petition requesting a temporary modification of hours of service (HOS) requirements for livestock, fish, and bee haulers. The petition was filed on Oct. 15 by the Livestock Marketing Association (LMA), National Cattlemen’s Beef Association (NCBA), American Farm Bureau Federation (AFBF), American Beekeeping Federation, American Honey Producers Association, and the National Aquaculture Association.
“As of Wednesday, March 6, 198 comments have been posted on the Federal Register,” said Jara Settles, LMA General Counsel. “LMA encourages interested parties to comment to tell their story and speak about how important safety is to the livestock industry as the Federal Motor Carrier Safety Administration (FMCSA) will take public comments into consideration when deciding whether to allow livestock haulers more drive time.”
Under the current hours of service (HOS) rules, drivers are only allowed to drive for 11 hours out of a 14-hour work day after which they are required to rest for 10 consecutive hours. Many livestock hauls are farther than 11 hours and it is inappropriate from an animal welfare perspective to leave livestock on a trailer while the driver takes the required rest. Unloading the livestock is also not practical as there are not facilities available along the majority of roadways to house livestock in-transit.
Joe Goggins, LMA transportation subcommittee member said, “We need a large volume of thoughtful comments to tell the story of why this flexibility is so important. It is only common sense that every producer should comment for extra drive time for {livestock} haulers.”
Comments can be submitted by visiting the regulations.gov website and searching for docket ID number FMCSA-2018-0334-0002.
According to the LMA, the best comments are those that are professional, concise, and personal to the submitter. Begin by identifying yourself and your role in the livestock industry and how live animal transportation impacts you and your business. Then, clearly explain your support of the request for more drive time.
The number of total comments, as well as the quality of those comments matter. Hearing the impact of the currently too-short drive times allowed for livestock haulers and the impact it has on livestock marketing businesses and producers directly from the source will increase the weight with which views are heard.
Settles expressed, “LMA asks every single market owner, dealer, order buyer, and livestock producer to post a comment in support of this request for modified hours of service rules for livestock haulers. Members of the livestock and trucking industries should see this as their opportunity to have their voice heard.”
The entire petition can be viewed at LMAWeb.com/Policy. The 27 page document includes seven bullet points concerning the following: Scope of Proposed Exemption, FMCSA Authority to Grant This Exemption, FMCSA’s Prior Findings on Regulatory Relief for Livestock Hauling, Estimate of the Drivers, CMVs, and Trips Under the Exemption, Assessment of Safety Impacts of the Exemption, Ensuring an Equivalent or Greater Level of Safety under the Exemption, and Negative Impacts if the Exemption is Not Granted.
Source: Livestock Marketing Association