Walking On Volume 5, Issue 1, January 2018 | Page 16

Industry Info
American Horse Council Efforts
to Address ELD Mandate
Over the past months the Amer-
ican Horse Council (AHC) has
reached out to the equine com-
munity to determine the potential
impact of the upcoming Electronic
Logging Device mandate. Based on
the information received, the AHC,
in collaboration with the rest of the
animal agriculture community, has
requested that the Department of
Transportation (DOT) grant a one-
year enforcement delay followed by
a waiver and limited exemptions
from compliance with the Decem-
ber 18, 2017 implementation date
for the Final Rule on Electronic
Logging Devices (ELDs) and Hours
of Service (HOS). Additionally, we
requested that the DOT address the
significant problems with the man-
date that will occur if the compli-
ance deadline is not extended. The
welfare, safety, and health of the
animals in transit, together with the
safety of other drivers on the road,
16 • Walking On
are top priorities for the equine
industry and its enthusiasts.
The livestock sector has con-
sistently been one of the safest of
the commercial hauling sectors.
The Large Truck Crash Causation
Study, conducted by the Federal
Motor Carrier Safety Administra-
tion (FMCSA) and the National
Highway Traffic Safety Institute,
showed that of 1,123 accidents
involving trucks hauling cargo, only
five involved the transportation of
livestock. Similarly, the report titled
Trucks Involved in Fatal Accidents
Fact-book 2005, conducted by the
Transportation Research Institute,
shows that livestock transporters
accounted for just 0.7 percent of
fatal accidents. The ELD mandate
itself, which is the subject of this
petition, does nothing to improve
that record of safety over paper
logs.
While this figure is not irrele-
vant, and any safety improvements
should be considered, the trajectory
of this rule’s implementation has
left much to be desired.  Despite
its being issued nearly two years
ago, awareness of this rule among
livestock haulers and the equine
industry is nearly non-existent. For
instance, FMCSA’s recent change to
include livestock in its interpreta-
tion of the 150-air mile exemption
for agricultural commodities, a
change that the industry strongly
supports and appreciates, has raised
many additional questions from
livestock haulers who are unsure
about the mechanics of the new ex-
emption and even if it means they
are exempt from the ELD mandate
altogether. More time is needed to
reach out to the horse industry, and
ensure that industry outreach can
address ELD compliance and ELD
impact.
Many horse operations and
competitions are in rural areas,
routinely requiring long, and re-
peated, trips. These animals, when
loaded onto trailers, are vulnerable
to changes in temperature, humidi-
ty, and precipitation. Horse haulers
are accustomed to managing these
changing conditions through plan-
ning, log books and notations in
those books. These planning tech-
niques have adapted and evolved
over decades as technology has
improved. Unfortunately, the quick
transition to ELDs does not allow
for the natural trial and error pro-
cess to adequately meet the needs
of the horse industry. 
The equine industry and the
millions of horse fans who attend
equine events rely on safe and
effective methods of transportation
from every corner of the United
States. Domestic transit of our
competition and breeding animals
is critical to the business continuity
of our industry and largely relies on
the use of large commercial haulers.
These individuals have expressed
their concern with the implications
of this rule in regards to the nega-
tive impacts to standards in welfare,
biosecurity and cost.
We are disappointed that the
FMCSA did not feel the need to