Preparing for a Regulatory Inspection Melony Wilson University of Georgia Bio & Ag Eng and Animal Dairy Science
Farm Inspections in GA Historically have been complaint driven New CAFO Rule: all NPDES farms will be inspected by a regulatory agency Inspections of smaller farms will be situational and may be the result of a complaint or pollution reports in the area.
Farm Inspections in GA Goal of the state government for inspections to be fair and consistent. EPD has memorandum of understanding with GDA to conduct inspections on AFO/CAFOs Inspectors comfortable and familiar in an agricultural setting They understand operational realities of a livestock operation Inspectors are well trained in the on-farm issues they are assessing
Farm Inspections in GA Defined GDA protocol and inspection form (www.agp2.org) Efforts are made to place a courtesy call and appointment Visits resulting from pollution threats or reported spills may not follow this routine Once on site, inspectors are to follow the form described above
Farm Inspections in GA GDA may suggest that a farmer seek assistance in correcting problems or addressing management issues with an independent non-regulatory agency: Extension NRCS SWCC Consultants
Inspections Preparation Make sure all relevant paperwork is in order and available: Permit NMP Records Other Farmer and Planner should be able to explain any components of the NMP
Inspections Preparation Consider a self or independent non-regulatory inspection Use GDA inspection form Inspection form is also a useful tool to help determine what records should be kept on operation
Inspections Preparation Management and employee responsibilities Everyone should be aware of environmental issues and on-farm rules Good to have a point person to manage environmental issues A farm’s environmental “team” may include: owner/certified operator, managers, and non-employee representative, such as the certified planner.
Inspection Day Farmers rights: Farm work cannot be stopped at the spur of the moment; prepare for the visit at the appointed time. OK to ask inspectors to briefly wait until any loose ends can be wrapped up Inspectors should follow bio-security rules of the operation Assemble all necessary farm personnel before beginning inspection
Inspection Day Greet the inspector in a courteous and professional manner All parties should keep a non-confrontational tone OK for the farmer to request an explanation of the visit Let the inspector know the farm takes their suggestions seriously
Inspection Day Discuss disagreements in a non-confrontational manner Additional opportunities will exist to explain the farms position Working with an independent agricultural/environmental professional for this step may be very helpful (Extension, NRCS, Planner…) Take your own notes for follow-up and reporting
Inspection Day Ask for contact information and a business card from the inspector. Request a copy of the inspection report as soon as it is available
Follow Up Farm management should review report with appropriate employees and additional assistance providers A follow-up letter may be required and is in the least, advisable Address any issues identified in the inspection Identify corrective measures
Follow Up Seek help, do not go this process alone Additional inspections may occur Failure to address issues may result in report being forwarded to regulatory agencies who may impose fines and penalties!
Summary Preparation is priceless! Ask for assistance NRCS GASWCC Extension Service