Logistics

Could A Railroad Merger Be Building Steam?

Mon, 21 Jul 2025 21:05:22 GMT

Late last week, the Wall Street Journal cited exclusive yet unnamed reports Union Pacific was pursuing an acquisition of Norfolk Southern.

This would mean two of the six largest class 1 railroads would be combined to form the first-ever rail service network stretching from coast to coast.

“The question was always, when are we going to get to the time where there’s a lot of energy to pursue a merger from with one of the Western railroads, with one of the Eastern railroads to provide that coast to coast service,” says Mike Steenhoek, executive director for the Soy Transportation Coalition. “And there’s always been kind of a reticence to that, just because there’s has been a lot of mergers and acquisitions within the railroad industry, consolidation, et cetera.”

The current geographic service areas for freight railroads in the U.S. can be broadly described at Union Pacific and BNSF Railway in the western half and Norfolk Southern and CSX in the southern half.

The Surface Transportation Board with its five-member panel would have to approve any acquisition.

Steenhoek also highlights the Department of Justice and Congress/other elected officials would also be involved in any such business transaction and its approval.

“It does show within Union Pacific they think this is a more favorable climate. They’re doing this in year one of a four year administration,” he says. “And so I think there’s some optimism they might get some traction on this. But either way, even if the climate’s favorable, it’s going to take multiple years for this to go through.”

No official comments have been made by either Union Pacific or Norfolk Southern, and it’s worth noting Union Pacific Corporation will release its second quarter 2025 financial and operating results on Thursday, July 24. Northfolk Southern’s next investor report is next Tuesday, July 29.

What could this mean for agriculture?

If this speculation materializes into confirmed news, Steenhoek says shippers will be focused on how any such merger would effect service.

“You’re going to hear a lot of opposition among agricultural shippers because there has been a track record–this is undeniable–that in especially in certain areas, when you see more consolidation within the rail industry, all of a sudden, a shipper, a grain handler, maybe had multiple railroads competing for their business. Now, all of a sudden, there’ll be one,” he says.

Steenhoek says with railroad mergers over time, the agricultural industry has faced upward pressure on rate as well as diminished service.

“Tor someone who advocates for efficient movement of agricultural products, we want transportation providers, including railroads, aggressively competing for our business. That’s good for us,” he says. “And so that’s one of the things that we are going to hear a lot of concern being expressed among grain shippers and handlers about, you’re going to decrease competition and we’ve been down this road before. It’s going to probably result in increased rates, decrease in service.”

The most recent approved railroad merger was in 2023 when Canadian Pacific Railway and Kansas City Southern merged. The transaction formed the first cross border network connecting Canada, U.S. and Mexico.

Citing 2024 annual reports of Class 1 Railroads (which are defined to have operation revenues of $490 million or more by the Federal Railroad Administration), here’s the ranking:

Union Pacific: $24.3 billion
BNSF Railway: $23.4 billion
CSX Transportation: $14.54 billion
Canadian National Railway: $12.4 billion
Norfolk Southern Railway: $12.1 billion
Canadian Pacific Kansas City (CPKC) Railway: $10.4 billion

Second U.S. Port Strike Averted as Union, Employers Reach Deal

Thu, 09 Jan 2025 14:55:03 GMT

The union representing 45,000 dock workers on the U.S. East and Gulf Coasts and their employers on Wednesday said they reached a tentative deal on a new six-year contract, averting a strike that could have snarled supply chains and taken a toll on the U.S. economy.

The United States Maritime Alliance employer group and the International Longshoremen’s Association, in a joint statement, called the agreement a “win-win.” The deal includes a resolution in automation, which had been the thorniest issue on the table.

“This agreement protects current ILA jobs and establishes a framework for implementing technologies that will create more jobs while modernizing East and Gulf coast ports — making them safer and more efficient, and creating the capacity they need to keep our supply chains strong,” the groups said.

Terms of the deal were not disclosed.

The talks had been extended until Jan. 15 to hammer a deal on automation. Shipping industry executives had been concerned that the parties would not be able to overcome their impasse, leading to a second ILA strike just days before President-elect Donald Trump’s Jan. 20 inauguration.

A three-day ILA strike in October triggered a surge in shipping prices and cargo backlogs at the 36 affected ports. Longshoremen returned to work after employers agreed to a 62% wage increase over the next six years.

ILA and USMX have agreed to continue operating under the current contract until the union can meet with its full Wage Scale Committee and schedule a ratification vote, and USMX members can ratify the terms of the final contract.

(Reporting by Gnaneshwar Rajan in Bengaluru; Editing by Alan Barona and Leslie Adler)

Trump waives hours of service rules for emergency transport of food

Tue, 15 Nov 2022 07:38:55 GMT

President Donald Trump has declared a national emergency because the coronavirus COVID-19 and waived the hours of service rules for truck drivers transporting emergency supplies of food.

It’s the first time since the rules were enacted in 1930 that they’ve been suspended.

The March 13 emergency declaration covers “food for emergency restocking of stores,” as well as medical equipment, hand sanitizer, masks, and other items. The waiver remains in effect until midnight April 12 or when President Trump terminates it, if sooner.

The waiver grants emergency relief form the hours of service rules. Those rules still apply for routine deliveries and mixed loads that include “essential supplies” that are not being transported in support of emergency relief efforts, according to the declaration. Drivers must start the clock when they’re dispatched to “begin operations in commerce.”

The declaration does not define what are emergency relief efforts versus a return to “interstate commerce” not supporting relief efforts for drivers supplying retailers. It does not specific if the waiver covers fresh produce and other foods being transported to processing facilities.

President Trump, Vice President Mike Pence, Agriculture Secretary Sonny Perdue and other White House officials participated in a call with retailers and industry groups on March 15.

According to published reports, executives of Walmart, Aldi, Whole Foods, Wegmans, Publix and other retailers participated.

Greg Ferrara, CEO of the National Grocers Association, welcomed the opportunity to speak to White House officials.

“While local, independent grocers are currently experiencing an unprecedented demand in store traffic and for product and goods, we continue to work closely with the president and our federal, state and local officials nationwide to ensure the resilience of both the food supply chain and our local economies,” according to a statement from Ferrara.

“Our industry has faced emergencies before from hurricanes to earthquakes, and fires to floods,” he said in the statement. “Grocers are experienced and prepared to continue serving their communities and employees as our members do each and every day.”

The Food Industry Association (FMI) also released a statement, ensuring the “viability of the supply chain and the availability of safe, affordable food.”

“We are resilient; our industry is working 24 hours a day to replenish and restock while ensuring the cleanliness of our stores and facilities,” FMI president and CEO Leslie Sarasin said in the statement. “We are seeking to be sensitive to the needs of all our customers and partners, including our WIC and SNAP shoppers and the food banks our stores support.”

Many grocery stores are expanding the hours they are closed to clean the store and restock shelves.

“As we continue to see an increase in customers, this temporary reduction in hours will allow us time to focus solely on store cleanliness and product availability,” according to a news release from St. Louis-based Schnucks. “Our supply partners and warehouse teams continue to work around the clock to ensure that product is available to our customers as quickly as possible.”

For more coronavirus coverage, check out our landing page on the topic here. To contribute to a survey on how the pandemic is affecting the produce industry, click here .

Related stories:

How the coronavirus is affecting the produce industry

Foodservice sector bearing brunt of outbreak

Sonora Grape Summit postponed, but crop report offered online

Freight Rates Skyrocket

Tue, 15 Nov 2022 07:27:49 GMT

Transportation woes continue to haunt Northeast shippers as trucks remain hard to come by and freight rates skyrocket because of rising fuel costs and a scarcity of drivers.

“Trucks are at a premium right now,” said Tracie Levin, controller at M. Levin and Co. , in Philadelphia.

“It’s a major hindrance for our industry and anyone else that uses trucking, which is basically every industry out there,” she said.

Shippers can’t even buy trucks.

“We’ve been on wait lists to get more trucks, trailer and tractors,” she said. “You just cannot get those things these days.”

But Levin is optimistic that things will turn around. She said some relief is already in evidence.

“We’re slowly able to get things again in a semi timely manner,” she said.

East Coast shippers have been dealing with transportation issues, but there are trucks available, said Tom Beaver, director of sales and marketing for Sunny Valley International Inc. , in Glassboro, N.J.

“Obviously, the cost of brokering a truck, especially for our (less-than-load) business, has increased considerably, but the same is true for all of our competitors,” he said. “We’re adjusting to this ‘new normal,’ but the important thing is that we can get fruit loaded and out to our customers on time and in full.”

Transportation challenges are more prevalent during the winter than they are during the spring and summer for Vineland, N.J.-based The Freshwave Fruit & Produce and its growing operation, Consalo Family Farms , said Chelsea Consalo, executive vice president.

That’s because the company has more local deals during the warmer months.

During the winter, the firm must bring in products from outside growing areas, such as Mexico, and transport fruits and vegetables imported from offshore growing regions, such as Chile, from U.S. ports.

“We have more trucks on the road (in winter),” she said.

Transportation costs are a major concern.

“We’re managing to get the trucks,” Consalo said. “It is just more expensive.”

The Freshwave has added Nick Crisafulli, who recently completed an internship at Americold Logistics LLC, to its logistics staff to help arrange transportation.

Vineland-based Flaim Farms Inc . has its own fleet of trucks for local deliveries, said president Ryan Flaim.

But trying to find trucks for destinations that are farther out is challenging.

The company has good relationships with trucking firms, but rates are much higher than they have been in the past, Flaim said.

Finding transportation isn’t a problem, as long as you’re willing to pay exorbitant fees, said Joel Fierman, president of New York-based Joseph Fierman and Sons Inc .

“It’s really a pity when your cost for transportation pretty much is as high as your cost for goods,” he said.

He blamed the price spike on high fuel costs and a scarcity of drivers.

“It’s a terrible, terrible thing that this country is experiencing right now,” he said.

An added problem during the Christmas season was that many trucks were sidetracked delivering Christmas trees.

“It’s fast, easy money,” he said.

Filindo Colace, vice president of operations for Philadelphia-based Ryeco LLC , attributes the skyrocketing inflation rate the industry has experienced to high freight costs.

“Freight has been a premium for quite some time,” he said.

While seed prices and other costs have also gone up, he said high freight rates are 90% of the cause of inflation.

“Nothing in the industry has gone up at the same rate as freight has,” Colace said.

But he remains optimistic.

“We think the country is moving on,” he said. “We’re going to be as back-to-business as usual as possible in the first quarter of next year.”

He expected buying patterns to return to where they were in 2019.

“We hope the workforce returns to those levels, as well,” he said.

“If that’s the case, it will be our expectation that freight rates will start to lower because there are more truck drivers coming back into the workforce.”

Related articles:

Rising freight rates pose challenge

Distributors cope with rising freight costs

Final compliance deadline nears for ELD mandate

Fri, 23 Sep 2022 20:00:28 GMT

The final compliance deadline for mandated electronic logging devices in U.S. trucks will arrive Dec. 17.

Beginning on that date, all motor carriers and drivers subject to the U.S. Department of Transportation’s Federal Motor Carrier Safety Administration (FMCSA) electronic logging devices final rule must use an ELD.

The deadline also applies to “grandfathered” automatic onboard recording devices, which after Dec. 17 will no longer be allowed under the Federal Motor Carrier Safety Regulations to provide records of duty status as a substitute to a required ELD. Motor carriers utilizing an automatic onboard recording device must have a fully operational ELD installed by Dec. 17.

The Commercial Vehicle Safety Alliance — a nonprofit association comprised of local, state, provincial, territorial and federal commercial motor vehicle safety officials — said in a news release that inspectors will begin fully enforcing the ELD rule on Dec. 17; there will be no “soft enforcement” grace period.

In addition, the release said the FMCSA has said there will be no extensions or exceptions made to the Dec. 17 ELD rule deadline. According to enforcement guidelines in the North American Standard Out-of-Service Criteria, the release said a property-carrying driver who does not have a record of duty status in his or her possession when one is required will be declared out of service for 10 hours and a passenger-carrying driver without a record of duty status when one is required will be placed out of service for eight hours.

An electronic logging device automatically records a driver’s driving time and other hours-of-service data as a way to minimize driver fatigue and improve safety, according to the release.

The device monitors a vehicle’s engine data and can detect when the vehicle is moving.

The FMCSA has published an online list of frequently-asked-questions about the ELD mandate.

Related articles

Produce shipments, truck rates down so far in 2019

Year in Produce No. 5 — Trucking industry and ELDs

More flexibility coming for hours of service regulations?

Truck rates soar and no immediate relief expected

Fri, 23 Sep 2022 19:59:32 GMT

Produce truck rates are up 70% or more compared with a year ago, and industry sources don’t think relief is coming anytime soon.

In the U.S. Department of Agriculture’s Fruit and Vegetable Truck Rate Report for May 4, truck shortages were noted in Nogales, Ariz.; all districts in California, Colorado, Florida, Michigan, North Carolina and central Washington.

Slight shortages were noted in Georgia, Oregon, Idaho, south Texas and the Columbia Basin of Washington.

USDA-reported May 4 refrigerated produce truck rates compared with 2020 were:

Nogales, Ariz., to Boston: $9,200 to $10,600, compared with $5,300 to $6,700 a year ago;
Salinas-Watsonville, Calif., to New York: $10,000 to $10,800, compared with $5,800 to $6,200 a year ago;
Southern California to Chicago: $7,500 to $8,600, compared with $3,800 to $4,700 a year ago;
Yakima Valley and Wenatchee District, Wash., to Philadelphia: $8,600 to $10,000, compared with $5,600 to $6,500 a year ago; and
Vidalia, Ga., to New York: $4,300 to $5,200, compared with $2,600 to $3,200 a year ago.

Already elevated truck rates were pushed higher with the convergence of floral imports into South Florida for Mother’s Day demand, accelerating volume of Southeast U.S. produce shipments and an early Department of Transportation Road Check Week, said Noah Hoffman, vice president of North American surface transportation for C.H. Robinson, Eden Prairie, Minn.

The delayed produce season in the Southeast is accelerating, which also diverts trucks from the rest of the country down to Florida.

Beyond those factors in Florida, the U.S. Department of Transportation held its annual DOT Road Check Week May 4-6.

This time period, Hoffman said, brings about a drop in truckload capacity as some drivers remain off the road to avoid checks or are forced off the road due to violations discovered during checks.

Beyond May, demand for refrigerated trucking will increase in the summer season, owing to higher domestic output during the summer and a gradually strengthening economy, he said.

Hoffman said comparisons with year-ago truck rates are complicated by the big swings in freight demand during the early weeks of the pandemic in 2020.
Hoffman said the structural constraints of adding more truck capacity could translate into upward pressure on transportation rates for the next year or so.

The supply of truck drivers has not kept up with demand, especially considering that competing industries have taken some drivers off the road, he said.

Hoffman said the volatility of truck rates is causing some shippers and receivers to look at shorter duration contracts for transportation or incorporating some variable pricing strategy into contracts.

Short supply in freight and trucking has skyrocketed rates, said Walt Dasher, chief operating officer of Glennville, Ga.-based G&R Farms, a year-round grower, packer and shipper of sweet onions.

Dasher said he thinks this challenge stems from several COVID-19 pandemic effects: government economic stimulus programs influencing employees to stay home, struggling owner-operators retiring or taking buyouts, and higher retail demand overall.

“It’s really bad right out there at the moment. It’s extremely challenging,” Dasher said. “I think a lot of it has to do with economics. You just have to ride it as it is and manage as best you can.”

John Pandol, director of special projects for Delano, Calif.-based Pandol Bros., said truck rates are usually cyclical, with each year bringing stories of “truck shortages.”

“In the food waste discussion, I’ve never heard about lack of transport being an issue,” he said. “I’ve seen fields abandoned for overproduction, lack of market, low grade, no workers to harvest, and maybe this year lack of packaging, but not because of lack of trucks or ocean containers.”

On the other hand, Pandol said both ocean containers and trucks seem to have shortages, and in both cases, it seems to be more of a “driver shortage” than equipment shortage.

Pandol said the most freight-sensitive items are watermelons and mixed melons. For those items, the freight can be more than the f.o.b. price.

Pandol said a challenge for the artificial intelligence community would be to build a prediction model to have the capacity and drivers in the right place at the right time, essentially predicting volume and its distribution.

The industry’s driver shortage, Pandol speculated, could be related to a number of factors, including:

Government stimulus money;
Driver fears of COVID-19;
Competing driving jobs closer to home;
Failed drug tests by drivers/operators;
Job opportunities in construction; and
Competition with non-refrigerated loads because of frustration with loading and unloading delays for produce.

Vidalia growers gearing up for promotional efforts

Fri, 23 Sep 2022 18:49:38 GMT

The Vidalia onion industry is planning for an aggressive promotional season, said Bob Stafford, interim director of the Vidalia Onion Committee in Vidalia, Ga.

He said the committee has signed public-relations agency Porter Novelli’s Atlanta office to help promote the crop.

The committee also is working with the Georgia Department of Agriculture’s Georgia Grown program for some cross-promotions, Stafford said.

“We’re going to try to extend our promotions,” he said.

The committee also is redesigning its website, vidaliaonion.org, with Porter Novelli’s help, Stafford said.

The committee is reaching out to chefs as well as retailers, he said.
There’s also a concerted effort to reach out to younger consumers, Stafford said.

“We’ve been chasing millennials, getting them used to using our onions,” he said.

Individual suppliers have their own plans, as well.

Glennville, Ga.-based Bland Farms is working on a couple of promotions this year, said Delbert Bland, president.

“We’ve always crossed with our condiment side of the business, but we’ve got a new promotion we’re doing with a sandwich company — mayonnaise, lunch meat and onions and you buy all three and get a pretty big discount,” he said.

It’s important to work with promotional partners, said Walt Dasher, co-owner of G&R Farms in Glennville.

“We have a multitude of items which help customers succeed in promotions,” he said.

G&R’s Growing America’s Farmers scholarship-based program, designed to bring a new generation of growers into the business, is “the driving force” behind many retail promotions, Dasher said.

“The partnership we have with the National FFA Organization has truly changed the lives of so many kids wanting to enter production agriculture and given the younger generation a sense of hope in knowing that so many retailers/customers truly care about the American farmer and the future of this industry,” Dasher said.

Vidalia season creates a promotional “excitement” all its own, said Lauren Dees, sales and marketing manager with Lake Park, Ga.-based grower-shipper Generation Farms.

“Easter is late this year. You always see a big push around Easter and sales look good, and near Memorial Day there’s another big push as people start grilling outside.”

Greencastle, Pa.-based Keystone Fruit Marketing, a division of Progressive Produce LLC, has numerous “customer-specific” promotions planned, said Mike Blume, sales and marketing director.

Promotions heavily target the consumer, displaying tips on how to use onions to include recipes when possible, Blume said.

Keystone also has in-store demos with its chef, Dave Munson, in which “shoppers are selected to participate, introducing new recipes — emphasizing quality, flavor, and nutrition,” he said.

Related articles:

Retail tools to sell Vidalias onions abound

Vidalia onion acreage down

Official Vidalia onion pack date set as April 22

A helpful Q and A on the hours of service regs and ag commodities

Fri, 23 Sep 2022 20:02:26 GMT

Putting a finer point on government regulations or providing clarity on bureaucratic language is not easy to do.

However, there are ways it can be done. The simple process of question and answer is perhaps the best approach.

Chad DeWitt, with Benton Harbor, Mich.-based Lenk Transportation Inc., recently shared with me a series of email exchanges he had in June with the Federal Motor Carrier Safety Administration related to hours of service regulations and the agricultural commodity exemption provision.

With Chad’s permission to reprint, here are some excerpts:

From Chad to the FMCSA:

Good afternoon,

I am reaching out in hopes of some clarity on the new laws & regulations for driving time.

We are a small firm that handles produce shipments from packing houses to retail markets.

Would the exemptions apply to these shipments? Or is it more a case of field to packing sheds?

Also, another question that keeps coming up is when the “service” actually starts? An exampleon what we run into, is we deal with LTL (less than truckload) orders, so it is common for our loads to have multiple pickups and multiple drops. I would like to present a scenario, and you tell me at what point the drivers hours start.

Pick up 1. In Sparta, MI – driver leaves Grand Rapids, MI at10:30 am, arrives at packing shed in Sparta at 11:30 am. Upon arrival, shed notifies driver that product will not be ready until 2 pm. Driver waits for product. Finally is ready to leave pick up #1 at 3pm, heads over to pick up #2 in Hudsonville, MI.

Arrives at pick up # 2 @ 4pm, loaded by 5:30pm @ pick up #2. Ready to head to pick up # 3 in Benton Harbor, MI.

Arrives at shed #3 at 7:30pm, and is loaded with the product, doors close at 9pm.

Drivers 1st delivery is in Indianapolis, IN at 4am. Can he legally make this shipment?

Or is he technically out of hours before getting loaded? I do apologize for the long email, and drawn out scenario, but it seems that there is quite a bit of “propaganda” being thrown out there by drivers as well as shippers and packing houses. So I thought I would just go directly to the source and find out what the protocol actually is.

Is there an explanation to the rules and exemptions that we can direct them to, so everybody can get a clear understanding? The more simple the explanation, the better not only for our customers, but for myself as well.
I really appreciate your time, and look forward to hearing your input!

The following was the response from the FMCSA official:

Let see if I can help here, if not it much be good to talk with me or one of my specialists on the phone. A few key points for your scenario.

• The points where you load can be considered a “source” if the product still meets the definition of agricultural commodity, meaning it is not processed in any way. Packaging is not processing. Also, I am assuming you don’t load any other products that are not agricultural commodities on the vehicle. If you do you lose the exception.

• I also am assuming your driver is coming off a 10-hour break.

• Sparta is your source in the scenario, so all transportation-related activities that occur within the 150 air-mile radius (172 or so road miles) are excepted from the hours of service. That means Grand Rapids to Sparta, the waiting and loading time in Sparta and any other work within that radius does not count toward the hours of service.

• Multiple pickups do not change the fact that Sparta is the source where the radius is drawn.

• Whether you can make trip to Indianapolis at 4 AM depends on what time your driver leaves that 150-air mile radius. Upon leaving, he has 11 hours of driving available.

• If it can be done, that is a very long day, so he and you both still have the responsibility to make sure he has adequate rest and is not too fatigued to drive safely.

I hope this is helpful. There is a summary and other information on our website, and additional materials will be added over the course of the next several days. www.fmcsa.dot.gov/ag

Here was the follow-up question from Chad:

I do apologize for my lack of understanding. But using the same scenario that I listed below. If a driver is not coming off of fresh hours, say he unloaded in Grand Rapids, and we send him on the shipment in which he has 6 hours left. Can he go make the pick ups that I have listed, and still have 6 hours left after leaving the 150-mile radius of Sparta, MI?

The FMCSA response:

If you aren’t coming off a 10-hour break you have to watch the 14-hour clock, which will start the when you leave the initial 150 air mile radius. I don’t know the distances of all of those places, but just be aware of that when thinking about your delivery in Indianapolis.

Another question from Chad to the FMCSA:

I have been spreading the information that you shared with me in regards to the rules. And a few questions that have come up have been what is considered the “Source”? A number of them have been told that their home base is the source.

Also there seems to be confusion on how to log this on the electronic logs. If they are picking up the load, and has 3 pick ups……..do they turn their ELD’s off? There are only 4 or 5 modes to choose from.

1. Sleeper berth

2. Off Duty

3. On Duty

4. Personal use

5. Yard Move

Which one would my driver use in my case that I presented to avoid a status of “Violated”? This issue seems to be widespread amongst drivers? They understand the essence of the rule, but they don’t seem to know how to apply it to their instruments. Trust me, I have looked at the website rules that you referred me to , and I have not come up with anything. Please help,

FMCSA response to the “source” question:

There are three options for operating with an ELD and the Ag HOS exemption. They are described on our webpage .

The options are:

1. Don’t log it. Then when they do they will have to reject the unassigned miles and annotate them as Ag excepted miles

2. Log in and annotate the excepted miles accordingly

3. Use the personal use function ad annotate as ag excepted

Noting a violation is not a requirement of the ELD spec and doesn’t necessarily mean anything. In reviewing the ELD information the officer will look at all of the information available to determine compliance, including annotations.

Chad’s response to the FMCSA clarification:

Thanks again!

So, is the “source” that you speak of, another word for “home base”?

FMCSA response

The “source” is not necessarily home base, it is the location that the agricultural commodity is loaded, such as a grain elevator, sale barn or some intermediate loading location. From the guidance:

Determining the “source” of the agricultural commodities under § 395.1(k)(1)

Although an agricultural commodity may have several “sources”, the “source” excludes the point at which the commodity is processed to such an extent that it is no longer in its original form or does not otherwise meet the definition of an agricultural commodity in 49 CFR 395.2.

Question: How is the “source” of the agricultural commodities in § 395.1(k)(1) determined?

Guidance: The “source” of an agricultural commodity, as the term is used in § 395.1(k)(1), is the point at which an agricultural commodity is loaded onto an unladen commercial motor vehicle. The location may be any intermediate storage or handling location away from the original source at the farm or field, provided the commodity retains its original form and is not significantly changed by any processing or packing

TK: Thanks to Chad for sharing this exchange and giving a little more clarity to federal government guidance on hours of service and the ELD mandate relating to agricultural commodities.