I'd love to jump in on that suggestion, because we absolutely don't want to impair the human health side of this. It is a “one health” approach in agriculture. The safety of drivers is very important.
We talk about delays at the beginning and end of trips. That time counts towards drive time, but it is not really drive time. Often, the drive time is the fatiguing part of the voyage for the driver. I grew up in an auction barn setting, so I've been in multiple-deck pot-belly trucks far too often.
The difference and challenge with ELDs versus paper-based is that when it was paper-based, when your truck was loaded, you marked and moved. The ELDs kick in at five miles an hour. The truck, in an auction barnyard or on a feedlot, may make multiple stops at multiple pens, and each of those stops kicks off their time. It starts their time and counts towards it. However, that whole loading event could be hours long.
We're teaching our truck drivers and handlers to respectfully load animals into those trailers. If you've seen them, you know they have to go up a ramp, down a ramp, up the ramp on the back side and back up this way. You can't do that quickly and ensure that animals are safe while they're getting on and off those trailers. You're slowly and cautiously loading animals and moving them from one loading ramp to the next to fill up your truck. For sheep, it's 400 animals on a trailer, and they may not all come from the same place. Now all of that time spent getting loaded is part of your drive time, whereas it wasn't with paper. Your drive time was this: “I'm loaded and heading out of the driveway.” That was the drive time.
I think that's where the difference comes in—it's where that ELD kicks off. We're not changing, I don't think, the total suggested drive time for trucks. Maybe we are. I could be mistaken there. I should have researched that better. However, the point is that there is a delay now, which gets captured. That's how long they've driven, and that's where we start to spark an issue.