To better address livestock haulers’ unique needs, the American Farm Bureau Federation and several state Farm Bureaus are urging the Department of Transportation’s Federal Motor Carrier Safety Administration to be flexible in implementing a split sleeper berth program. The groups are also asking the agency to put in place rules that encourage drivers to avoid fatigue by allowing short rests that do not count toward a driver’s end-of-day rest period.
Current rules require livestock haulers to rest for 10 consecutive hours once they reach the maximum on-duty drive time of 11 hours.
In comments to DOT and FMCSA, the Farm Bureaus explained in detail why the current hours of service framework is incompatible with livestock hauling. For one, the trailer environment has the greatest effect on animal welfare during transport. Animals that don’t get adequate airflow, a common problem when the trailer is stopped, can suffer weight loss, lameness and even death, either in transit or upon arrival at the feed yard.
“The key to safely hauling live animals, especially in times of great heat and humidity, is to stop as infrequently as possible and to keep the trailer moving to provide ventilation,” the groups wrote.
Haulers also can’t simply unload their animals for 10 consecutive hours. Even if there was a place to put the livestock, doing so would raise a whole host of biosecurity concerns. In addition, the acts of loading and unloading are reportedly more stressful than transport itself.
“Animals that are unloaded, ‘rested,’ and then re-loaded will not have rested at all,” the groups warned.
To meet the needs of both drivers and animals, the Farm Bureaus support allowing livestock haulers to break up their rest period via a split sleeper berth program. However, such a program won’t work for livestock haulers if it is too rigid in practice and if the rest periods are too long.
“Weather, type and age of livestock, and other environmental factors all play a role in determining when and how haulers move their livestock, which is why flexibility is so important,” the organizations said.
Rather than a mandatory 10-hour stop, or a requirement that drivers split their 10-hour break into two five-hour periods or a six-hour period and a four-hour period, the groups recommended that drivers be permitted to stop for multiple periods of two or three hours. This way they would be able to evaluate humidity and temperature and determine if a stop is tolerable for the animals they are hauling, which will allow them to rest to avoid traffic or other roadway hazards.
In conjunction with a split sleeper berth program, the groups are encouraging FMCSA to consider incentivizing shorter “nap breaks” for drivers, as short naps of 20-30 minutes can help improve mood, alertness and performance, according to the National Sleep Foundation. These naps should not count toward a driver’s rest time.
“The current regulatory structure encourages drivers to push through tired moments or spells of fatigue because, if they stop to rest, even for a short and refreshing nap, their on-duty clocks are still running,” the organizations said. Drivers would be incentivized to take these rests if they were allowed to go off-duty during the time they are resting, they further explained.
AFBF submitted these comments in response to FMCSA’s advanced notice of proposed rulemaking concerning hours of service for drivers of commercial motor vehicles. More recently, AFBF and organizations representing livestock, bee and fish haulers across the country submitted a petition to the Department of Transportation requesting additional flexibility on hours of service requirements.