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USPOULTRY: Why EPA and the States Inspect Farms video
why EPA and the states inspect farms
because clean water is a priority for
everyone we all have a role to play in
making sure we protect it for you the
farmer that means managing your
operation in a way that recognizes the
significance your actions can have on
water quality for EPA and States it
means they must track water quality
analyze and identify the potential
causes of poor water quality and monitor
compliance with regulations designed to
protect water quality the overall
objective of this video is to explain
what you should expect during an epa or
state inspection of your farm this video
will help you better understand the
roles we all play in running
well-managed farms provide insights into
what EPA and state inspectors look for
when analyzing and addressing issues
related to local water quality and
provide information on assistance
available to producers to address water
quality issues
the EPA's and the state's roles in
protecting water quality mean they may
need to inspect your poultry operation
to make sure you are managing your
operation in a way that protects nearby
rivers lakes and streams including the
public health of those who use those
water bodies for drinking water or
recreation inspections help EPA and
States collect information to evaluate
whether a facility is complying with an
existing NPDES or state permit or is in
need of an NPDES permit to comply with
the Clean Water Act inspections may also
occur in response to a citizen complaint
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section 308 of the Clean Water Act
provides EPA with the authority to enter
any premises in which an effluent source
is located under the Clean Water Act a
concentrated animal feeding operation or
CAFO is defined as a point source of
pollution the Clean Water Act provides
broad authority to allow EPA to inspect
operations where discharges from point
sources are located before the
inspection EPA and the states may often
call you the farm owner prior to an
inspection to provide advance notice to
confirm a date and time for the
inspection and to allow time for you to
arrange for the correct personnel to be
present during the inspection if
possible it is best that you accompany
the inspector during the visit you are
encouraged to go with the inspector take
notes and ask questions individuals that
are beneficial to invite to join you on
the inspection may include the
operations manager nutrient management
advisor and integrator representative
while planned inspections allow you time
to prepare EPA and the states also may
conduct unannounced inspections review
records
if you are notified of an inspection
prior to the actual inspection date it
is best to organize your records prior
to EPA's visit to be prepared for an
unannounced inspection it is best to
keep your files up-to-date at all times
the inspector may ask to see records
pertaining to farm operations for
instance the amount of litter removed
from the poultry houses between Fox and
the amount of litter that was
transferred off-site or land applied
during an inspection the producer should
be ready to share nutrient management
planning information such as soil tests
nutrient applications or a nutrient
management plan if you have an NPDES or
state permit the inspector likely will
ask to see any other specific records
required under your permit such as your
weekly self inspection logs and your
annual reports initial interview upon
arrival at the facility an EPA inspector
or inspectors should present inspector
credentials if an inspector does not
present these credentials you should ask
to see them if you have any doubt at all
about the legitimacy of the inspector
you may ask for the phone number of the
inspectors supervisor so you can call
and verify the information and confirm
the visit is authorized before beginning
any inspection you can ask the inspector
why the inspection is occurring is the
inspection occurring on the basis of a
complaint such as a strong odor to
investigate a potential environmental
problem or as a routine inspection to
ensure that your farm is complying with
regulations you have the right to deny
the inspector entry onto the farm if you
feel this is necessary however EPA or
the state has the option of obtaining a
search warrant and returning to the
facility to conduct the inspection the
inspector will discuss the purpose of
the inspection where the inspector plans
to go on your property and whether there
will be a need to review records or
collect samples the inspector may also
ask basic questions about your farm such
as how many birds are raised on the farm
how each flock is raised how litter is
handled between
flocks and how litter is stored good
communication during the initial
interview and throughout the inspection
can help the inspector better understand
your operation and can help you better
understand regulatory requirements
biosecurity
EPA has their own national biosecurity
procedures which they will follow
however you may request that they follow
additional steps that are implemented on
your farm biosecurity procedures may
include wearing personal protective
equipment such as boot covers and
coveralls prior to the inspection EPA
will reach out to USDA Animal and Plant
Health Inspection Service a ffice or the
state veterinarian to identify any
high-risk areas with existing emergency
animal disease events where inspections
may need to be delayed during the
inspection the inspector will likely
conduct a visual inspection of your farm
during the visual inspection the
inspector will ask questions about the
area's being visited and will take notes
and photographs to document what was
observed the goal of the visual
inspection is to gather information to
determine if your facility is complying
with your NPDES or state permit
requirements such as properly operating
and maintaining your litter storage
facilities if you do not have a permit
the goal of the visual inspection may be
to help determine if your facility is
discharging pollutants to US waters in
violation of the Clean Water Act and is
therefore in need of an NPDES permit the
inspector may view the poultry houses
the litter storage facilities feed
storage areas and the mortality storage
and disposal areas such as composting
bins the inspector may also view the
land application areas where litter is
land applied the inspector will usually
take pictures during the visual
inspection to document what was observed
it is wise to also take identical
pictures as documentation and pictures
of the surrounding subjects to provide
context sampling
while on your farm the inspector will
often take litter samples soil samples
or water samples from nearby streams the
inspector should explain the reasons for
taking the samples such as identifying
the presence of pollutants like
nutrients or bacteria be sure to ask for
an take note of what lab will be
analyzing the samples it is your right
and in your best interest to ask EPA to
split the samples and give half of them
to you so that you can have them
analyzed at your own cost and compare
the results to EPA's analyses exit
interview
at the completion of the inspection the
inspector should conduct an exit
interview with you if the inspection is
drawing to an end and you feel as if
there will be no exit interview request
one during this exit interview the
inspector may identify issues or
concerns that were observed during the
inspection at this time you should ask
any questions that you may have about
regulations and the inspection if the
inspector has not already given you
their contact information you should ask
for it at this time and keep it for your
records the information provided to you
by the inspector at the exit interview
will be preliminary the inspectors focus
is to gather information not to make the
determination of compliance or
non-compliance at the time of the
inspection to ensure accuracy and
consistency the compliance determination
will be made later at the office at the
exit interview the inspector may also
ask you to mail copies of your nutrient
management plan or records if the
inspector needs to review them further
after the inspection
immediately after the inspection you
should complete a written set of notes
these notes should include a detailed
account of the inspection including the
name and title of the inspector what
initiated the inspection where the
inspector went on the farm what pictures
and samples were taken and any other
distinguishing parts of the inspection
also remember to promptly send to the
lab any split samples that you requested
from the inspector after the inspection
the inspectors next steps vary among EPA
and the states after the inspection and
determinations of compliance are made
EPA or the state may send you a copy of
the inspection report for your records
the inspection report is the factual
record of what the inspector observed
and was told during the inspection after
the inspection once EPA or the state has
made a compliance determination and
identified any violations EPA will
contact you again if no violations were
found EPA or the state may informally
notify you that no follow up actions
will be necessary for minor violations
that can be quickly addressed EPA or the
state may send you a warning letter or a
Notice of Violation Nov this letter will
explain the violation and instruct you
to correct the violation and achieve
compliance EPA or the state may conduct
a follow-up inspection to confirm that
the violations have been addressed
alternatively you may be asked to
provide documentation such as
photographs to show that the violations
have been corrected for repeat
violations or violations that are more
serious or may take longer to fix EPA or
the state may issue an administrative
order or may meet with you to negotiate
and jointly sign a consent order or
consent agreement this order or
agreement will require you to take
certain actions to fix the violations
and will set a schedule or deadline when
those actions must be completed EPA or
the state may also issue a penalty order
that requires you to pay a fine for the
violations serious violations or
situations in which a facility
repeatedly fails to correct
violations may result in EPA or the
state pursuing a civil judicial action
in court these actions may impose a
court-ordered schedule requiring you to
take the necessary actions to achieve
compliance and to pay a civil penalty if
the inspection identifies areas of
concern or a violation it is important
for you to address the issue as soon as
possible assistance addressing the issue
may be available from a number of
sources including the Natural Resource
Conservation Service a local County
Extension agent the land-grant
University for your state or the State
Department of Agriculture
although the prospect of being inspected
can be intimidating the process can
inform and assist farmers with
protecting and enhancing the core
element that insures the livelihood of
their vocation productive land and clean
water it also helps with meeting a
shared interest of having viable farms
that can meet the demand for the
production of more food to meet a
growing population hi I'm Kelley shank
I'm with the Environmental Protection
Agency and a favorite part about my job
is coming to the farm and talking with
the growers and the family and learning
about their operation and also just what
their vision is for their family farm we
know when we come on to a farm that were
not just coming to a business we're
coming to their home and it's a
wonderful opportunity to talk about both
the successes and the challenges of
growing food for the community and
having clean rivers and streams for all
of us to enjoy we think that having
these interactions and talking with one
another really helps us to understand
the connection between agriculture and
water quality so that we can come up
with winning solutions on how to have
profitable thriving AG and also clean
rivers and streams for the long haul
I know we can do that together this
message was brought to you by the US
poultry and egg Association funding for
this video was provided by the
International poultry Expo please
support our exhibitors and we invite you
to attend
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