EMS in Agriculture and Agribusiness - United Egg Producers XL Project

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EMS in Agriculture and Agribusiness - United Egg
Producers XL Project
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Clean Water Regs are Changing

• New EPA rules will require states to issue NPDES
  permits for poultry egg production (as well as
  dairy, beef, hogs)
• Rules authorize states to issue general permits
  to majority of CAFOs
• But rules expect states to issue individual
  permits for exceptionally large CAFOs, or those
  with significant public concern

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XL Option for Egg Producers

• Egg industry dominated by 318 companies, mostly
  family owned, but large CAFOs
• Produce 75 billion eggs/year at a total of about
  500 farms in 25 states
• New CAFO regs would require negotiating
  individual permits for each farm, each state
• Teamwork produced a regulatory option that is
  effective years before new CAFO regs

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XL Workgroup

• EPA (Headquarters, Regions V, VI, X)
• USDA (NRCS)
• State DNRs (IL, MN, CO, OH)
• UEP egg producers (NC, WI, IN, IL)
• NGOs (ELI, IEI)
• Capitolink consultants
• Endorsed by ASIWPCA, NRCS, lawmakers
• FPA signed by EPA October 25, 2000

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CAFO Egg Producers
On-Farm Assessment
XL Adds
EMS
Planning, BMPs, Records, Public Notice
3rd Party Audit of EMS
Risk Reduction, Public Acceptance
Permit
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What the XL is All About

• States may choose to participate
• Few costs for states to participate
• Detailed guidance EMS, audit, general permit
• Auditor certification and protocol EPA approved
• Audits funded by congressional authorizations
• Egg producers implement an approved EMS
• Annual audits verify EMS is implemented
• Alternative is more costly individual permits

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Benefits of an EMS

• Reduce accidents
• Improve cost control
• Reduce possible liability
• Lower insurance rates
• Satisfy lenders/investors
• Improve public relations
• Improve regulatory status
• Qualify for general permit

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XL is a Progressive Option
EMS is a cookbook for avoiding
dealing with problems
3rd-party audit public notification reduces
issues
General permits save state resources producer
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An Egg Producers EMS

• Pledge to follow a code of good practices
• Develop environmental objectives and plans
• Share these with neighbors and public
• Establish management systems for anticipating
  problems avoiding mistakes
• Delegate authority but retain responsibility
• Implement all critical management programs
• Review progress regularly adjust as needed
• Keep proper records and document efforts

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Critical Management Programs

• All animal water must be in closed systems
• Maintain fly, rodent control programs
• Maintain dead bird disposal program
• Maintain odor management program
• Maintain preventative maintenance program
• Maintain emergency response program
• Use CNMP to land apply manure/compost
• Maintain communications with public

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Third-Party Audits

• Necessary to qualify
• Annual thereafter
• Comprehensive
• Becomes public when audit is successful
• Failed audits remain confidential
• Currently are free

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Linking the EMS Permit

• Producers interact with the public for EMS
• Once 3rd-party audit is done, producers will
  publish notice in local newspaper and give notice
  to key local stakeholders
• Information on audit results is then sent to
  state and posted on website along with NOI
• Information about the EMS, audit and general
  permit are public documents

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Whats in the General Permit??

• Developed by EPA Office of Water
• Requires continual implementation of EMS
• Consistent with new CAFO regulations
• Requires CNMPs for all land application
• Requires recordkeeping, manure testing
• Prohibits abandonment of lagoons, houses
• Includes statutory enforcement authorities

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Role of UEP Capitolink

• Urge states to adopt XL
• Publish educational materials for members
• Conduct workshops
• Help producers upgrade facilities and practices
• Help off-site manure users
• Monitor XL effectiveness
• Produce XL reports