Preparing for a Regulatory Inspection

1. Preparing for a Regulatory Inspection Melony Wilson University of Georgia Bio & Ag Eng and Animal Dairy Science

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 • Use GDA inspection form • Inspection form is also a useful tool to help determine what records should be kept on operation

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 farm’s 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/environmental 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! • Ask for assistance • NRCS • GASWCC • Extension Service