Transcript Preparing for a Regulatory Inspection

Preparing for a
Regulatory Inspection
Melony Wilson
University of Georgia
Bio & Ag Eng and Animal Dairy Science
Farm Inspections in GA
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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
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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
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Farm Inspections in GA
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Defined GDA protocol and inspection form
(www.agp2.org)
Efforts are made to place a courtesy call and
appointment
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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
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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
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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
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Consider a self or independent non-regulatory
inspection
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Use GDA inspection form
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Inspection form is also a useful tool to help
determine what records should be kept on
operation
Inspections Preparation
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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 nonemployee representative, such as the certified
planner.
Inspection Day
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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
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Inspection Day
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Greet the inspector in a courteous
and professional manner
All parties should keep a nonconfrontational tone
OK for the farmer to request an
explanation of the visit
Let the inspector know the
farm takes their suggestions
seriously
Inspection Day
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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
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Inspection Day
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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
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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
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Follow Up
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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
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Preparation is priceless!
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Ask for assistance
NRCS
 GASWCC
 Extension Service
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