Maryland poultry growers get advice for inspections

By NANCY L. SMITH
AFP Correspondent

SALISBURY, Md. — Maryland poultry growers got advice on how to survive an inspection by the U.S. Environmental Protection Agency or the Maryland Department of the Environment under the Concentrated Animal Feeding Operation program at a workshop sponsored by University of Maryland Extension on July 7.  
MDE operates EPA’s programs under the Clean Water Act, including CAFOs within the state, according to Gary Kelman, director of MDE’s Office of Special Programs.
CAFO applicants were required to submit a Notice of Intent and a comprehensive nutrient management plan by February 2009.  
Because assistance to prepare CNMPs is scarce, few farmers have filed one.  Instead, MDE allows producers to file a status update form to show they are in the process of having a CNMP prepared.  
Once the application is complete, Kelman said, MDE does a site visit to confirm the information on the NOI and CNMP and update it if necessary.  
After a permit is issued, “if you have a permit, you are going to be inspected” by MDE, said David Mister, Eastern Shore regional coordinator for the Maryland Department of Agriculture’s Office of Resource Conservation.  
In addition to MDE inspections, EPA can inspect the farm.
Mister, who has accompanied EPA on the nine CAFO inspections it has performed in Maryland, told the group what to expect during inspections.  
Kelman said the advice applies to MDE inspections as well.
Mister said MDA is not a compliance enforcement agency, but is “there to help the farmer” have a successful inspection. He advised they “shouldn’t wait until they get their CNMP to be a better manager.”
During an inspection, he said, producers must provide facility information, including size, age and number of houses as well as number of birds.  
They also must document their live-haul and clean-out schedules as well as records of manure handling and field application.  
Copies of their NOI and current NMP or CNMP must be provided. He stressed the importance of up-to-date paperwork.  “Good recordkeeping is essential.  All plans have expiration dates.  Keep your nutrient management plans updated,” he advised.
Mister recounted one instance in which inspectors thought a producer had not filed an NOI.  The producer showed them a copy, as well as a mail receipt.  
“For your own protection, make a copy of everything you send MDE and get a mail receipt,” Mister advised.
He urged producers to obtain a copy of the NRCS checklist for inspection.
He offered detailed tips for successful inspections and emphasized, “Your best effort is required.  If the inspectors see you are making your best effort, you’re in good shape.  You don’t even have to be the best manager; just use your best effort.”
He recommended special attention be paid to manure storage facilities.  “Maintenance is important,” he said, even if the shed is beyond the 15-year MDA cost-sharing agreement period. “MDE will make you repair the manure shed to keep your permit.
“MDA can help fix a manure shed” with cost-share assistance, Mister said, “but you have to enter into a new 15-year new agreement.”
Mister said inspectors will look at the storage facility to determine if there’s surface water conveyance at the ends that are discharging into a ditch or swale, if there are non-mobile items stored in the shed, and if the structure of the facility is sound.  
He reminded the group manure can be stockpiled outside the storage shed for no more than 14 days.
The composter can be inspected, Mister said, to verify the right recipe and look for odor, leakage, and whether dead birds are visible.
“Be vigilant in your management,” Mister advised. “Maintain your waste storage facility and your composter.  Practice good housekeeping.”
Another area of concern is Heavy Use Pads, Mister said. “Your HUA must be broom-clean, even if you have a (vegetative) filter around it.  
“I know farmers don’t like this, but it is what it is,” he added.
Inspectors also will look for vegetative cover between houses and the overall farm appearance.
EPA gives about 24 hours notice of an inspection, said Mister.  Farmers who have been inspected report EPA inspectors have been courteous, prompt and informative, he said.
“We encourage producers to accompany the inspectors,” he said.  “You need to understand the process, you need to show sincerity and you need to treat the inspection professionally.”
Mister concluded, “Perception dictates the inspection.  When I drive up the driveway (accompanying EPA inspectors), I know what kind of day we’re going to have.”
If EPA inspectors find a problem, “they will do to great lengths to make their case,” Mister said.  “Farmers need to take this seriously.  It can cost a lot of money, a lot of heartache.”
Mister showed a picture of a farm where a feed delivery truck had created deep ruts near a chicken house, causing a potential runoff channel and advised producers who have similar problems to “call the company.  Tell them it’s not acceptable.  Talk to the company about helping you comply.
“We’ve all got a role in this, even feed truck drivers.  It needs the cooperation of everybody.  The bottom line is – it’s about the Bay.  Everybody plays a part whether they think they do or not.”