Preparing for a Regulatory Inspection

1
Preparing for a Regulatory Inspection

• December 14, 2004SE GA Dairymens Meeting
  BlackshearTommy Bass UGA/CES

2
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.

3
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

4
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

5
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

6
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

7
Inspections Preparation

• Consider a self or independent non-regulatory
  inspection
• UGA CES Mock Inspection Program
• Prepares you for the real thing
• UGA FarmASyst
• OFAER
• NRCS
• GDA Inspection Form

8
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 farms environmental team may include
  owner/certified operator, managers, and
  non-employee representative, such as the
  certified planner.

9
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

10
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

11
Inspection Day

• Discuss disagreements in a non-confrontational
  manner
• Additional opportunities will exist to explain
  the farms position
• Working with an independent agricultural/environme
  ntal professional for this step may be very
  helpful (Extension, NRCS, Planner)
• Take your own notes for follow-up and reporting

12
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

13
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

14
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!

15
Summary

• Preparation is priceless!
• Dont let this happen in Georgia!
• Thanks to Dairy Herd Management Magazine, for
  contributions to this presentation.