It’s Inspection Time
By: Terri Queck-Matzie
It’s the phone call nobody wants. Trevor Urban, senior CAFO inspector for the Environmental Protection agency, calls about mid-afternoon and says he will be on site the next day for a feedlot inspection.
What should you do? What can you expect?
“We always have a goal to do a fair and thorough inspection,” Urban says. He is one of three inspectors working out of the Kansas City office covering Region 7 of the EPA. “We always try to do the same inspection from the same checklist.”
And they try to temper their dutiful attention to detail with common sense that comes from experience. “We’ve all been around cattle and hogs and turkeys and chickens,” says Urban. “We understand the difference between a spreader and a slinger and at some point we’ve all probably eaten or fallen down in manure ourselves.”
The process starts with that ominous phone call.
“When we get called out to do an inspection. We’re going to try and give you a little bit of notice so we get the right people there,” Urban explains. “We try to work with the producer. We know it’s an inconvenience and we’re taking time out of your busy schedule. But we want to see the facility as it’s operated on a day-to-day routine basis.” If the facility operator is not available, he will be expected to delegate inspection responsibilities. Inspections are rescheduled only under extreme circumstances such as a death in the family.
Urban says producers can be assured he and other inspectors have done their bio-security homework by calling the state veterinarian to check on any possible disease outbreaks, and when he calls he will inquire as to the facility’s bio-security protocol. “If they don’t have one, Region 7 does,” says Urban. Trucks and boots are washed and disinfected between facilities. “We don’t want to track anything on or anything off.”
Upon arrival, the inspector will show credentials and provide opportunity for the operator to call the EPA and check them. “If someone doesn’t do that, you should be suspicious,” says Urban.
The visit will then begin with an entry briefing. “We want to know how the facility operates, what’s going on,” he explains. How many animals are on site? What do you do with manure and waste? The inspector will likely have maps of the feedlot layout and potentially harmed waterways.
That, says Urban, is the reason for the visit: “Our goal on every inspection is, quite frankly, environmental protection. Our job is to prevent discharge to creeks and streams.”
He stresses the importance of detailed, accurate records. “Good records can really expedite the process.”
Urban says he and his cohorts will want to see virtually everything during the course of the inspection – animal census records, permits, manure management plans. “We will take a look at the MMP records and see what you’re doing. Are you taking soil samples, comparing them correctly? We’ll make sure you’re doing the right calculation.” He says operators should look at the experience as an opportunity. “I’ll take the time if you want to sit there and go through it and explain things you might not understand.”
The physical site inspection is just as thorough, and includes feedlots, holding basins, drainage ditches, feed stockpiles, winter feeding areas. “We ask all the questions, look at the whole facility,” he explains. “We don’t want to come back because we failed to snap a photo, or ask the right questions.”
He says he bases his inspection on three criteria: permit violations, maintenance issues, and housekeeping issues. “Housekeeping issues and maintenance issues can turn into a permit violation if you don’t do what you need to do,” says Urban. For instance, loose hay or distiller’s grains scooped up with snow can leave a pile of rotting vegetation in a ditch at spring thaw.
The inspector will likely offer suggestions while the inspection is in progress. “We can’t tell you how to run things,” says Urban, “but we see a lot of facilities and we can share ideas for how things can be done feasibly and economically.”
As they tour the facility, the inspector will take photos and collect discharge samples.
Issues unrelated to feedlot runoff, like chemical and fuel use and storage, are not under the CAFO inspector’s jurisdiction, but will be noted on a multi-media survey and forwarded to the correct agency. “If they feel the issue is worthy of follow-up, they will,” says Urban. “And we’ll offer suggestions as we find things.”
Urban says the inspections act as a deterrent as well as a mechanism for bringing feedlot operations into compliance. And they help level the playing field. “It’s an issue of fairness. A lot of people have invested a lot of time and effort and funds into improving their systems so they’re not polluting the Waters of the U.S. and it’s hard to compete with someone down the street who maybe hasn’t invested that effort.”
It’s a strategy that appears to be working. “We don’t see purposeful pollution a lot anymore, like we did 20 or 30 years ago. I think everybody’s trying their best.”
If the inspector finds any violations, the EPA will follow-up with appropriate action, and you will likely know by the time Urban leaves the premises. An exit briefing provides an opportunity for questions and clarification – from both sides.
“We want the report to be accurate,” he says. “The last thing we want to do is write something that is wrong. You’re going to know what we know when we leave. The purpose of identifying issues is to bring you back into compliance. We’re here to help. If we can’t answer your questions, we’ll connect you to someone who can.”