EMS in Agriculture and Agribusiness - United Egg Producers XL Project

1. EMS in Agriculture and Agribusiness - United Egg Producers XL Project

2. 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

3. 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

4. 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

5. CAFO Egg Producers On-Farm Assessment XL Adds: EMS Planning, BMPs, Records, Public Notice 3rd Party Audit of EMS Risk Reduction, Public Acceptance Permit

6. 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

7. 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

8. 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 $

9. An Egg Producer’s 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

10. 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

11. Third-Party Audits • Necessary to qualify • Annual thereafter • Comprehensive • Becomes public when audit is successful • Failed audits remain confidential • Currently are free

12. 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

13. What’s 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

14. 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