October 22, 2019
For fiscal year (FY) 2019 NASS, received an appropriation of $ 174 .5 million of which $129.2 million was available for the Agricultural Estimates program. NASS did not collect information for the Cost of Pollination survey, or data for those operations with less than five honey bee colonies in the Honey survey during FY 2019. USDA will continue to collect and publish data for the annual Honey Bee Colonies, report which records number of colonies producing honey, yield per colony, honey production, average price, price by color class and value; and honey stocks by State and the U.S. The repo rt also notes trends and changes in the honey producing sector, such as percent change in honey prices or quantity of production. It is a way to monitor bees as it captures general trends in colony numbers over time.
At the close of the second quarter in fiscal year 2019, NASS had obligated approximately 73 percent of the appropriated funds. NASS also had unplanned acreage re-interview costs related to weather in major crop production States. The decision to suspend data collection was not made lightly but was necessary given available resources. NASS reviewed our Federal agricultural statistical programs using the criteria below to ensure timely, accurate, and useful statistics.
Principal Economic Indicator Data;
Data which directly impacts the market;
Data necessary to implement USDA programs which provide payments to farmers and are used to administer the farm safety net for producers; and
Data for which there are no other publically available sources of information.
Savings from suspending data collection were utilized for the expenses related to the acreage re interview costs. On September 13, 2019, NASS issued an Agricultural Statistics Board (ASB) notice, informing the public of the decision to resume the Colony Loss Survey with the October 1 reference date after a one quarter suspension. The survey results, which include quarterly data on honey bee colony numbers and death loss, will be released in the August 2020 Honey Bee Colonies report.
Bees Declared To Be The Most Important Living Being On Earth
The bees have been declared the most important living beings on this planet, the Earthwatch Institute concluded in the last meeting of the Royal Geographical Society of London. However, according to wildlife experts and scientists, the bees have joined the endangered species long list.
The recent studies show a dramatic decline of the bees' number as almost 90 percent of the bee population has disappeared in the last few years. The uncontrolled use of pesticides, deforestation or lack of flowers are the main reasons for their extinction.
However, why would such a little being be named the most important creature on Earth? Well, the answer is actually more simple than you ever thought. Seventy percent of the world's agriculture depends exclusively on bees. Needless to mention the pollination is the bees' job, although the plants would not be able to reproduce, therefore the fauna would have been gone in a very short time. More than that, a study conducted by the Apiculture Entrepreneurship Center of the Universidad Mayor (CeapiMayor) and the Apiculture Corporation of Chile (Cach) with the support of the Foundation for Agrarian Innovation (FIA) concluded that the bees are the only living being who does not carry any type of pathogen.
After all, Albert Einstein's say about bees has never been truer. "If the bees disappear, humans would have 4 years to live," the famous physicist said.
Since the bees' importance is crucial in our planet's ecosystems and they've also been declared an endangered species, we really need to be as careful as possible on the matter. And we need to act quickly as we still have some solutions.
Therefore, in order to protect these hard-working creatures, some activists believe that we should immediately prohibit the use of pesticides, promote completely natural agricultural alternatives and we should carefully monitor their health and welfare.
Lately, people started to realize the importance of the bees and many animal rights groups are trying their best for the conservation of the species. Many celebrities have also joined the cause. And maybe the most wonderful example is Morgan Freeman. Recently the Hollywood star transformed his huge 124-acres land in Mississippi, into a bee sanctuary, in order to protect the species.
"There is a concerted effort for bringing bees back onto the planet... We do not realize that they are the foundation, I think, of the growth of the planet, the vegetation," Morgan Freeman said in an interview.
Studying Bees at Penn State
The oft-memed slogan “save the bees” has been all the buzz for several years now, but who is actually making an effort to save one of the planet’s most important insects?
Penn State’s prominence in the world of agriculture is well-known. The farms around University Park draw crowds for multiple farms shows each year, while the university’s agricultural and forestry programs rank within the top 10 worldwide. Gameday tailgates and Creamery ice cream pasteurized at our convenience are sure signs of Penn State’s agricultural prowess in the everyday lives of students.
What would happen, though, if the agricultural world and therefore the entire planet lost one of its most import resources due to declining populations?
ENT 222: Honey Bees & Humans, a course focused on the life and prominence of the Western Honey Bee, addresses the possible solutions to this problem. This popular gen ed explains not only why humanity should make an effort to save these crucial members of Earth’s ecosystems, but also how to go about it.
ENT 222 students observe the insect world in the Arboretum and take frequent field trips to the apiaries (where the bees are kept, off Orchard Road) on the Blue Bus. Through these experiences, they become their own researchers, formulating their own questions on what would happen if a single major entity in the circle of life were to go extinct.
The idea for the class originated when Dr. Harland Patch, assistant research professor, and his wife Dr. Christina Grozinger, distinguished professor of entomology and director at the Center for Pollination Research, decided to share their love of bees with fellow Penn State alum Maryann Frazier.
Frazier, a 1980 graduate who majored in bee husbandry and later earned her Master’s of Agriculture in 1983, knows how to raise honeybees.
Bringing a practical side to the couple’s already in-depth bee research, she allowed Patch and Grozinger to take their lab-based insight into the field.
The first half of Grozinger and Patch’s class covers the physiology of the honey bee. Understanding bees and their entomology are critical in understanding why pesticides kill them and therefore harm agricultural production. Patch Challenges his students with questions such as: How do we use pesticides in a way that doesn’t harm species?
The second half of the course dives into how humans have relied on honey since the beginning of time, utilizing bees’ work to bolster their micro-nutrition.
“People all over the world have thought of bees as being associated with the good life,” said Patch. “Israel is known as the land of milk and honey.”
Students also learn how evolution has influenced agriculture over time, as well as the effect of cultural influences like the success of large pesticide companies.
The triad also asks students to channel their majors. They know not everyone will be as originally enthralled in entomology as they are, but everyone brings something to the table. Bee politics, as explained by Patch, confirms that the solution is in thinking that anyone can help solve the problem, not just scientists.
“A business person, whatever you do in life, anyone can be conscious and find solutions, because they’re collective solutions,” Patch said. “We ask students to channel their majors. For example, econ majors can observe the tomato plants of the Arboretum, then write about how bumblebees contribute to the pollination of tomato plants, how tomatoes can be used for a lot of things, and how important this is for the economy.”
Though the class addresses an alarming concept, his students’ progress helps him to remain hopeful about the world’s bee crisis.
“This takes us to why we teach the class. My optimism is in what Penn State students do. The hope is that they will raise awareness to how people make decisions in the world,” he said. “I’m optimistic in that the students will do something when they’re my age, or they’ll be aware of it.”
Through the lenses of his glasses Patch’s eyes widen as he discusses his favorite topic over his desk. A giant honey bee poster hangs in his office.
“They look for a story here. The purpose is to slow down, try not to multi-task, and try to observe the world for yourself; the natural world, unmediated, and come out with your own experience of the thousands of questions nature has to offer,” he said.
“The question of honeybees and their challenges is what we do — if we just think these thoughts and do nothing, nothing happens in the world.”
There’s a reason the waiting list for this gen ed seems to always overflow: Students want to solve real-world problems in a way that expands their mindset outside the classroom. Plus, there’s nothing like a tailgate-saving cause.
“If we didn’t have bees, we wouldn’t have tomatoes,” Patch said. “And hot dogs would be a lot less fun.”
Don’t Poop Where You Eat: Bee Defecation on Flowers May Explain Disease Transmission
By Melissa Mayer
For most people, flowers call to mind many things—romance, appreciation, well wishes—but probably not … bee poop. Insect pollinators are crucial to maintaining biodiversity and crop yields but face global declines. Clues that may help save these important insects might come from an unexpected place: apian fecal matter.
It turns out that bees defecate while foraging pollen or nectar, and sick bees may defecate more than usual, possibly transmitting infection through their fecal matter. In a recent paper in the Journal of Insect Science, researchers set out to determine how important flower shape is to bee defecation patterns, with the hope that this data might help unravel the mysteries of disease transmission among bees.
“While it is common knowledge amongst bee biologists that bees frequently defecate, the fact
that they will sometimes defecate on the flowers upon which they are feeding seems counterintuitive and deserves further study,” says Jenny Hazlehurst, PhD, assistant professor of biology at California State University East Bay and one of the authors of the study. “I am most excited about the potential applications of this research for understanding how to best protect pollinators from pathogens that are spread from the fecal to oral route.”
So Many Flowers, So Little Time
To figure out the importance of flower shape to the likelihood of bee defecation during foraging, the team performed 31 separate 4-hour foraging trials in a flight cage. For 12 hours before each flight, they fed the common eastern bumble bees (Bombus impatiens) a 30 percent sucrose solution mixed with fluorescent dye to make it easier to visualize their fecal matter.
It’s a strategy that Hazlehurst thought up while working on an earlier project, looking at another type of pollinator. “Sometimes the birds we captured as part of the [University of California Riverside] macrosystems project had been visiting hummingbird feeders in residential areas where people had put red dye in the nectar solution. The fecal samples we collected would come out as colorful red splashes as a result,” says Hazlehurst. “That gave me the idea to track where pollinators were defecating using fluorescent dye, which I had previously used as an analog for pollen to track the movement of pollen grains between flowers.”
During each flight trial, the bees had access to 12 individual flowers or inflorescences arranged in a random grid. These included four flower shapes: cup, tube, small composite flower (diameter of the disk is smaller than petal length), and large composite flower (diameter of the disk is larger than the petal length).
To standardize the foraging experience, the team emptied the flowers of naturally occurring nectar and deposited a sucrose solution in each flower prior to the trials. They also set up paper disks below each flower to simulate the way flowers pack together in natural foraging circumstances.
A Bouquet of Results
After each flight trial, the researchers examined the flowers and paper disks under ultraviolet light to detect bee poop. They reported 28 total fecal events with 46 percent of those taking place on flower parts and 54 percent occurring on the paper disks below the flowers.
The results confirmed that flower shape matters. Bees were significantly more likely to defecate on the seaside daisies (Erigeron glaucus), which served as the large composite flowers in the study. Statistical analysis revealed significant differences between large composite flowers and each of the other three flower shapes (cup-shaped, tube-shaped, and small composite flowers).
The researchers think floral morphology might explain these findings. The longer it takes a bee to forage on a flower, the more likely it is that that forager will defecate. Some factors that influence how long a bee spends at an individual flower include corolla depth, nectar concentration and viscosity, and whether the bee is gathering nectar or pollen. Composite flowers comprise many small florets, so foragers must move from floret to floret, which takes more time, increasing the likelihood that they will defecate and/or face exposure to fecal material left by a previous forager.
The Big Picture
That exposure is particularly important to researchers since fecal matter may pass infection from bee to bee—and, crucially, from groups of managed bees to wild bee populations (or vice versa). “Emerging work is looking at the potential for the spillover of bee pathogens from managed bees that are used in agriculture such as the European honey bee and the eastern bumble bee into wild bee populations,” says Hazlehurst.
“Pathogen transmission at shared floral resources through defecation on the floral surface and subsequent consumption by the next pollinator to visit is one potential mechanism for how diseases could move between managed and wild bee populations, or even in the reverse direction. It is important that we know about this possibility so that we can come up with good management strategies to prevent this from happening.”
Hazlehurst hopes this study leads to more research into the factors, like infection, that play a role in bee defecation patterns and pathogen transmission on flowers. Future studies should also look at other large composite flowers to confirm the findings.
There’s no doubt that insect pollinators are vital links in the food chain. In fact, one out of every four bites of food needs bee participation to get to the fork—and bee pollination helps the agricultural industry to the tune of $15 billion in increased crop value every year. Which means bee poop might be a hot commodity, at least for researchers hoping to protect pollinators.
With so many varieties of honey to choose from, just how do you know each should taste?
This introductory course uses sensory evaluation tools and methods to educate participants in the nuances of varietal honey. Students will learn about methods of evaluation, stands and quality in this certificate program.
This evaluation course is for anyone interested in learning how to critically taste and assess honey. Using standard sensory techniques, packers, chefs, beekeepers, writers, food manufacturers, honey aficionados will learn about the nuances of varietal honey. Attendees will receive a UC Davis Honey Flavor Wheel and our newly published Honey Journal in addition to access to all presentations.
The program features an introduction to the world of sensory science with specific applications to honey. We use both the well-known Italian method taught at the registry of Experts in Bologna, alongside our own research creating both protocols and tasting techniques. Instructors in the course include Orietta Gianjorio, professional taster of honey, wine, olive oil, chocolate and more; Suzanne Teuber, MD, a UC professor in the Department of Medicine, whose focus is allergies; Amy Myrdal Miller a national consulting nutritionist; Joyce Schlacter, a QC specialist at Crockett Honey with a direct interest in adulteration; Mani Niall a professional chef and occasional beekeeper who has authored “Covered in Honey”. In addition to these presenters, members of our research team and I will also be offering sessions. Attendees will taste and analyze about 40 different honeys from throughout the world. The buzz after Apimondia is that honey customers are beginning to develop more flavor specifications and that more education is needed to help them achieve their goals.
Amina Harris will also teach an abbreviated class on this subject at our North American Honey and Pollination Summit and Trade Show on January 8th, 2020 in Sacramento, California.
October 7, 2019
AHPA Executive Board Report
American Honey Producers Association would like to introduce a new series of articles for our Latest News emails. An AHPA Executive Board member will write an article once a month as a way of getting to know them and communicating important issues to our members. We hope you enjoy this new addition to our Latest News.
We also welcome guest commentary articles. If you would like to submit an article for review, please email to: email@example.com
*Please do send send advertisements, they will not be published*
AHPA Executive Board Report
Hello all! It sounds like the new guy gets to submit the first article to the mail-out, so here goes a bit about myself… I’m a second generation beekeeper, my brother and I operate about 3,000 hives in Saskatchewan, our operation is approximately 4 hours north of the Montana-North Dakota border. We don’t move for pollination, honey crops, or wintering, and have some beeyards that have had beehives in the same spot every day for over 30 years. We produce lots of honey, but that’s our only income from our bees. No packages. No queens. No pollination cheque.
I’ve been lucky to be working with the AHPA Board since January, and it is interesting to see that Canadian and American beekeepers have many of the same issues. Foremost is honey pricing and imports of cheap honey causing lower honey prices on the domestic market. Many Canadian beekeepers have been selling their honey at or below the cost of production for the last 4 years. This needs to change if our industry is expected to survive, and it needs to change in the near future, not the distant future.
A close second is varroa levels and the ability to keep mites under threshold numbers from season to season. Our regulations have most beekeepers treating with Apivar as the first treatment (often in spring), and then significant monitoring during spring-summer-fall and follow-up treatments from late August to late October with formic acid or oxalic acid. There is limited use of Thymovar. Hopguard is expected to be approved for use by spring 2020. Apistan is used very sparingly, most beekeepers see some-to-full resistance.
Labour and the ability to ensure a crew will be in place for the season is also a concern, although that situation has been improving in the last number of years. Our federal government has held numerous consultations in recent years, most of which were very well attended by beekeepers resulting in many significant changes, often for the better. The creation of a labour task force called the Canadian Agriculture Human Resource Council CAHRC) has been instrumental in helping the agriculture sector push for change within our industry. While still a work in progress, labour is no longer our top priority.
Nosema levels seem to have been increasing of late, and Nosema does not seem to be as well understood as varroa, especially what should be considered ‘threshold’ or treatment levels. Having Fumagilin-B back on the market as-of mid-September was important to many beekeepers, and there seem to be many who seem to think that prebiotics or probiotics are also an important part of the solution. A number of beekeepers have their own microscopes so testing can be done quickly, instead of waiting on lab results.
Apimondia 2019 was held in Montreal in early September with over 5,000 attendees and 100+ speakers - by far the biggest beekeeping show I have attended. One of the biggest topics of discussion was that 100% of the entries to the honey competition were analysed, and 46% were rejected for a variety of reasons. This shows both degree to which honey may not meet expected requirements (adulteration, chemical contamination, antibiotic contamination, or other reasons), as well as the current limitations of honey analysis (eg. NMR testing of a monofloral honey not in the NMR database).
I was really impressed by the level of professionalism laid out in the display booths, the poster boards, and the speaker presentations. From honey markets and honey analysis, to bee health and environmental concerns, to current and upcoming disease pressures and treatments, it was easy to find a wealth of information. It was a wonderful trip to meet people I had only spoken to over the phone or email, and many, many new friends were made during the show.
Please feel free to reach out to me with any questions. While our style of beekeeping in Canada is somewhat different than the US, the basics are the same. We all seem to be fighting for the same thing… one more year in business with healthy bees…
Canadian Relations Advisor,
American Honey Producers Association
USDA Economic Data Faces Lag as Employees Balk at Agency Move
Internal memo blames staffing losses that could slow releases
Union says 16 of 280 Economic Research Service workers moved
By Teaganne Finn | September 26, 2019 12:25PM ET | Bloomberg Government
Some regular releases and reports produced by the Agriculture Department’s Economic Research Service are expected to be cut or delayed as a result of the agency’s relocation to Kansas City, according to an internal memo.
“Due to decreased staffing levels, ERS will for considerable time be unable to provide the same level of breadth and depth in its economic research and outlook analysis as it did in the past,” according to the four-page, undated memo listing products potentially affected.
Items on the calendar of planned research releases wouldn’t be discontinued but could see delays “due to potential shortages in staff, including web posting staff,” according to the memo, obtained by Bloomberg Government. Other non-calendar reports could be delayed or discontinued altogether, the memo said.
The monthly food price outlook could be delayed in October, November and December, while reports on organics production and marketing, the distribution of farm income and wealth and honeybee pollination could also be delayed. The production and marketing data helps farmers price their products, and lawmakers rely on historical USDA data to make policy.
The USDA didn’t return a request for comment on the memo.
The first 100 employees from ERS and the National Institute of Food and Agriculture were slated to be relocated by Aug. 1 and the last 247 staffers affected are projected to be relocated by Sept. 30. Overall, the USDA planned to move almost 600 employees from ERS and the NIFA out of Washington.
However, the most recent numbers from the ERS employee labor union show only 16 out of 280 ERS staff chose to move to the Kansas City region. Ninety-three left the department and 52 retired, while others have opted to stay in Washington through exemptions or telework accommodations.
The Senate Agriculture-FDA fiscal 2020 spending bill (S. 2522) includes $25 million to fund the relocation, likely teeing up a fight with House appropriators whose measure (H.R. 3164) would block money for the move. The Senate Appropriations Committee advanced its measure last week.
“USDA’s misguided push to relocate key agencies and uproot employees impacts the Department’s ability to provide support to farmers, consumers, and rural communities,” Rep. Marcia Fudge (D-Ohio) and Del. Stacey Plaskett, a Democrat representing the U.S. Virgin Islands, said in a statement Wednesday.
Fudge leads the House Agriculture Subcommittee on Nutrition, Oversight, and Departmental Operations and Plaskett heads the Biotechnology, Horticulture, and Research Subcommittee.
Employees who have agreed to move are temporarily working in the Beacon Complex, a USDA location in Kansas City, and the USDA hopes to find permanent office space soon.
To contact the reporter on this story: Teaganne Finn in Washington at firstname.lastname@example.org
Worker bees forgo sleep to care for young
By Brooks Hays
Oct. 3 (UPI) -- Most parents know that sacrificing sleep is part of raising a young child. The same goes for bees.
New research suggests brood-tending bumble bee workers sleep much less than other bees, even forgoing sleep to care for offspring that is not their own. But unlike other animals, bees seem to do just fine without the normal amount of sleep.
Most studies of sleep behavior have focused on humans and other model organisms in the lab, but the latest research -- published this week in the journal Current Biology -- suggests their is value in studying sleep in diverse species.
"Our findings show that sleep is more plastic and less rigid than is commonly accepted," study co-
author Guy Bloch of Hebrew University said in a news release.
Tests show that when humans, rodents and flies are sleep deprived, their health and performance suffers. But while bee sleep looks a lot like the sleep of other animals, the latest research suggests there are ways to avoid the physiological costs of sleep deprivation.
Scientists determined chemical compounds released by the pupae trigger changes in the sleep patterns of worker bees. The affected bees, dubbed "nurse" bees, tend to the needs of pupae around the clock, forgoing sleep even when the offspring don't need to be fed.
Using video footage and detailed behavioral analysis, scientists tested the impacts of sleep loss on bee response times. When researchers removed the pheromone-like substances released by the pupae, the nurse bees didn't show the same sleep rebound patterns observed in other sleep-deprived animals.
Their response times were unaffected, and the bees continued to sleep less than usual. The surprise discovery suggests bees aren't affected by a lack of sleep in the same way.
"The fact that the nursing bees sleep so little, even when caring for pupae that do not need to be fed was the most surprising," first author Moshe Nagari said. "Before this study, we assumed that the main functions of activity around the clock without circadian rhythms in nurse bees is to provide improved feeding to the developing larvae, enabling them to grow rapidly."
Previous studies have shown birds sleep less during seasonal migrations. Male birds and fruit flies have also forgone sleep during mating season. The latest study suggests sleep patterns are similarly flexible for bees, and that some species can sacrifice sleep without suffering a decline in performance.
"If there is no cost for sleep loss, it means that the brood-tending bees have mechanisms allowing them to significantly reduce sleep without a cost to the brain and other tissue," said Bloch. "This of courses raises the question about what exactly are these mechanisms and what is the basic function of sleep."
Bahamas Beekeepers Hurricane Relief Fund
Hurricane Dorian’s wrath has devasted the Bahamas including the lives of beekeepers, their apiaries and the bees. Very few hives have survived in Grand Bahama. Those on Abaco are a total loss. And many beekeepers are unaccounted for at this time.
Last year, 2018, Bees Beyond Borders worked with 30 young adults in a 6-week training course in the biology and business of beekeeping. After the completion of the course, these young entrepreneurs formed the Grand Bahama Beekeeping Association, even renting a building for meetings and for production of products from the hive. The Bahamian Development Bank then set up a specific fund for loans that these individuals could borrow from to purchase equipment. New equipment was purchased this past spring and things were looking positive. Until Dorian. The dreams of these young adults becoming beekeepers with thriving businesses has been temporarily lost.
With your help we can raise funds that will go directly to these 30 individuals through the bank to repay their loans and ultimately assist in rebuilding their lives.
Let’s keep their dreams alive! Please donate to the Bahamas Beekeepers Hurricane Relief Fund.
September 27, 2019
The Honorable Raymond Martinez Administrator
Federal Motor Carrier Safety Administration 1200 New Jersey Avenue, S.E., Suite 600 Washington, D.C. 20590
Re: Docket No. FMCSA-2018-0348, Hours of Service of Drivers; Definition of Agricultural Commodity
Dear Administrator Martinez,
I write on behalf of the Agricultural and Food Transporters Conference (AFTC) of the American Trucking Associations (ATA), and other interested agricultural organizations, to express sincere appreciation for the opportunity to comment on the advanced notice of proposed rulemaking (ANPRM) focused on the current definition of an agricultural commodity as it relates to the hours of service (HOS) rules.
The current definition of an agricultural commodity, albeit vague, has worked well for the majority of the industry for many years. The vagueness has allowed the industry, the Agency and enforcement officials to interpret the definition broadly. As agriculture, and its supply chain, continue to evolve we have begun to realize that certain interpretations are not sufficient for inclusion of those ever evolving products and processes.
Agricultural practices that took place 30, 40, 50 years ago have drastically changed and practices 30, 40, 50 years from now will undoubtedly follow a similar evolution.
Moreover, the recent mandate of electronic logging devices (ELD) and the subsequent discussion around HOS flexibility provides us a great opportunity to address the agricultural commodity definition and ensure we not only have today's products and processes covered, but we write the definition in a way that the evolving industry will be covered 50 years from now. Our goal is to address the definition in such a way that it will not have to be addressed every 10 years, but rather be something that encompasses the broad spectrum of agriculture for many years to come.
The idea of listing specific commodities would be a drastic mistake. The evolution of the industry mentioned above would deem the list outdated the moment it was printed. This task was undertaken by the now abolished Interstate Commerce Commission (ICC) in 1958.1 This commodity composite list of exempt and non-exempt commodities provides 31 pages of products, some of which no longer exist. Our industry is changing so rapidly that we believe the listing of specific products would only cause additional confusion among all parties involved, especially within the enforcement community. Unfortunately the aforementioned list is referenced in several other sections under FMCSA's regulating authority. It is our request that the list of outdated commodities, from a commission which no longer exists, be replaced by the newly proposed definition.
As FMCSA is acutely aware, components of the agriculture industry work very closely with one another on a wide range of issues with transportation being one of those. We know and understand transportation's importance to agriculture and its significance to the entire supply chain. That being said, our respective industries have worked diligently over the past 60 days on a definition that would fully encompass the products and processes that span agriculture in its entirety. We are confident that the following definition would accomplish that goal:
Agricultural commodity and livestock are defined as:
Any products planted or harvested for food, feed, fuel or fiber;
Any non-human living animals (including fish, insects, and livestock as defined in Sec. 602 of the Emergency Livestock Feed Assistance Act of 1988 [7 U.S.C. 1471)) and the products thereof, to include, but not limited to milk, eggs, honey, etc.;
Agricultural, raw forestry, aquacultural, horticultural and floricultural commodities; fruits, vegetables; and other agricultural products that are sensitive to temperature and climate and at the risk of perishing in transit;
Animal feed (including ingredients);
Products of preservation - products used during harvest or packing in final preparation for processing, including but not limited to bin, boxes, jars, cans, etc.;
We believe this definition sufficiently covers agricultural commodities, animals and products along those supply chains that support the movement of the products to ensure they are efficiently and safely transported. Below are further comments to questions posed in the ANPRM.
Question 2. Should FMCSA define or otherwise clarify the term "non-processed," as applied in the definition of "agricultural commodity?" If so, given the context of harvesting and planting seasons referenced in the applicable statute, how should that term be defined? Please provide examples of "non-processed" agricultural commodities that should be included and discuss the distinction between "processed" and "non processed."
Current changes in the interpretation of what constitutes the "source" of a commodity under the current HOS agricultural exemption show us the positive direction the Agency is moving in interpreting a non-processed agricultural commodity.2 It is important to note that products "prepped" for further transport should be classified as non-processed or raw commodities. For example, melons harvested from a field and transported to a chilled warehouse to be cooled prior to further transportation are, and should continue to be, defined as non-processed. Dairy milk that is harvested and then moved to a terminal site prior to further transfer to a processing facility is, and should be, considered non-processed. These examples simply highlight the fact that raw commodities should be considered non-processed even if they have been handled, as long as their composition has not been altered.
Regarding the planting and harvesting season designation, there are only 17 states3 that don't have a year round (Jan 1 - Dec 31) designation. We believe, for uniformity and to limit confusion, the planting and harvesting dates be made year round for all 50 states. In many northern US states, the designation has been set to omit the harshest of the winter months, a period of time when the strong majority of products covered under the exemption are not impacted. However, products such as live animals, and products from those animals (milk, eggs, etc.) continue to be moved as they are year round industries and become unnecessarily captured under "planting or harvesting".
There is current legislation4 that would fix this issue, but we believe FMCSA has the authority to make such a change and would be fully supported by industry.
Question 3. Would clarification or definition of other terms used in the definition of "agricultural commodity," such as "food," "feed," or "fiber," be helpful? Please provide recommendations and data to support your suggested definition.
We believe the terms listed would be helpful in crafting a more complete definition. These terms encompass a great deal of general and special commodities that are grown and harvested. However, there are other products that should be included but won't fall within these terms. Our proposed definition would consist of these terms in addition to the inclusion of additional products and processes that should be included.
Question 4. Should the definition of "livestock" be revised to include aquatic animals in addition to live fish and crawfish? Please provide data to support your answer, such as how far aquatic animals are typically transported and why you believe the HOS exemption would be appropriate for the transportation of specific aquatic animals.
Live fish for human consumption were appropriately included in the initial livestock definition5, and the inclusion of all live fish is an appropriate addition. Live animals, including fish, are subject to the elements regardless of whether they are immediately destined for human consumption or are en route for another purpose. We believe it is important, and clearly stated in our definition, that all live animals are covered under the definition, and any subsequent definitions.
We are confident that questions 5, 6 and 7 were covered in the above answers. The definition of livestock should be modified to accommodate all live animals, and the listing of specific commodities/animals/products have been down a road that does not need to be traveled again. The inability to accurately list, track and enforce each commodity as it evolves over time is not only impossible, but terribly inefficient.6
Another inefficiency is the lack of uniformity between not only certain regulations, but their regulating agencies. We believe, that unless special circumstances warrant it, a definition of an agricultural product should be the same across industry, the federal government and the enforcement community. As referenced above, our respective groups work very closely together to ensure harmony in many rulemakings. We also work closely with our main regulating body, the US Department of Agriculture (USDA). Understanding that there are certain circumstances that specific products need be defined, we think it is important that our collective groups have a general definition to coalesce around. We are confident that we have put forward this definition, encompassing agriculture and minimizing confusion for all interest parties.
Question 11. Do you believe ambiguities in the current definition of the terms "agricultural commodity" or livestock," as applied to the HOS exemption in§ 395.1(k)(1), impact highway safety? If so, how?
The HOS agricultural exemption was adopted in 1995. Since its adoption, there have been several modifications made to accommodate the evolution of the industry. We have included farm supplies as an important part of the supply chain movement of product, understanding that there is more that goes into planting a seed than just putting it into the ground. We made alterations after the adoption of the Chemical Facility Anti-Terrorism Standards (CFATS)7 following the attacks on September 11, 2001. As agriculture continues to grow, machinery gets larger and the need for product increases. It was important that we had flexibility within the supply chain to allow certain fertilizers a path to the retail facility, and ultimately the farm for its intended application. Most recently we were successful in extending the exempted air mileage radius from 100 to 150 air miles8 to ensure that the industry continues to enjoy the needed flexibility necessary to survive as it grows and consolidates.
We are nearing our 25th year under the exemption, and even with our continued evolution and growth, we are able to provide a safety record that we are very proud of. The clarification of the definition for agricultural commodities will not only sustain our exemplary safety record, but it will provide additional clarity for the industry, the Agency and the enforcement officials on the applicability of the exemption.
On behalf of the undersigned organizations, we would like to thank FMCSA for providing the opportunity to comment on the agricultural commodity definition. Over the last decade, FMCSA has done a great job of reaching out to and consulting with our respective industries, and for that we are thankful. As a sector we transport the most sensitive, perishable and diverse products in the world, and being able to have the understanding and first hand dialogue of the overseeing agency is essential. This is a very important topic and we believe it revolves around the definition itself. We are confident that our proposal is reasonable and accurate. Again, thank you for taking into account our comments and we look forward to working with you as this process continues forward.
Executive Director, AFTC
On Behalf of:
Agricultural Retailers Association
Agriculture Transportation Coalition
Agribusiness Association of Iowa
Alabama Cattlemen's Association
American Beekeeping Federation
American Farm Bureau Federation
American Honey Producers Association
American Soybean Association
California Cattlemen's Association
California Trucking Association
Chicken and Egg Association of Minnesota
Colorado Cattlemen's Association
Corn Refiners Association
Exotic Wildlife Association
Florida Cattlemen's Association
Florida Trucking Association
Forest Resources Association
Georgia Cattlemen's Association
Georgia Poultry Federation
Grain and Feed Association of Illinois
Hawaii Cattlemen's Council
Illinois Beef Association
Illinois Trucking Association
Indiana Motor Truck Association
Institute of Shortening and Edible Oils
International Milk Haulers Association
Iowa Poultry Association
Kansas Agribusiness Retailers Association
Kansas Grain and Feed Association
Kansas Motor Carriers Association
Kentucky Cattlemen's Association
Livestock Marketing Association
Maine Motor Transport Association
Maryland Cattlemen's Association
Michigan Agri-Businesses Association
Michigan Bean Shippers
Minnesota Turkey Growers Association
Mississippi Cattlemen's Association
Mississippi Poultry Association
National Barley Growers Association
National Cattlemen's Beef Association
National Chicken Council
National Council of Farmer Cooperatives
National Farmers Union
National Grain and Feed Association
National Milk Producers Federation
National Oilseed Processors Association
National Pork Producers Council
National Sunflower Association
National Turkey Federation
Nebraska Cattlemen's Association
Nebraska Grain and Feed Association
Nebraska Trucking Association
Nevada Trucking Association
New Mexico Cattle Growers' Association
New Mexico Wool Growers Inc.
Northeast Agribusiness and Feed Alliance
North American Meat Institute
North American Millers' Association
North American Renderers Association
North Carolina Cattlemen's Association
North Carolina Egg Association
North Dakota Grain Dealers Association
Ohio Agribusiness Association
Ohio Cattlemen's Association
Oklahoma Cattlemen's Association
Pennsylvania Cattlemen's Association
Plant California Alliance
Renew Kansas Biofuels Association
Rocky Mountain Agribusiness Association
South Carolina Trucking Association
South Dakota Agri-Business Association
South Dakota Association of Cooperatives
South Dakota Grain & Feed Association
South Texas Cotton & Grain Association
Texas Agricultural Cooperative Council
Texas Allied Poultry Association
Texas Broiler Council
Texas Cattle Feeders Association
Texas Cotton Association
1 Composite Commodity List. Federal Motor Carrier Safety Administration. Source: https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov /files/docs/Administrative Ruling 119.pdf
2 Agriculture Exemption Diagrams. (2019). Federal Motor Carrier Safety Administration. Source: https:Ilwww.fmcsa .dot.gov/hours -service/ eIds/agriculture-exemption-diagrams
3 Manager's Guide to Safe Trucking During Agricultural Planting and Harvest Season. (2009). American Trucking Associations. Source: https://www.trucking.org/ATA%20Docs/About/Organization/AFTC/Safe%20Trucking%20Guide .pdf
5 Emergency Livestock Feed Assistance Act of 1988, Pub. L. No. 115 -334, 132 Stat. 4942 (2018). .house.gov/view .xhtml?path=/prelim@title7/chapter35A/subchapter5&ed ition=preIim
6 Composite Commodity List. Federal Motor Carrier Safety Administration . Source: https://www.fmcsa.dot.gov/s ites/fmcsa.dot.gov/files/docs/Administrative Ru ling 119.pdff
7 Chemical Facility Anti-Terrorism Standards. (2019). Department of Homeland Security. Source: https://www.dhs.gov/cisa/chemical-faciliyt- anti-terrorism-standards
8 How can the MAP-21 "Transportation of Agricultural Commodities " exemptions be summarized?. (2014) .
Federal Motor Carrier Safety Administration. Source : https://www.fmcsa .dot.gov/faq/how-can-map-21-%E2%80%9Ctransportation-agricultural-commodities%E2%80%9D-exemptions-be-summarized