U.S. EPA regularly conducts compliance or enforcement inspections of large concentrated animal feeding operations (CAFOs), including egg layer farms and ranches. Just as “by the time you need friends, it is too late to make them” one should remember that “by the time you get a visit from your regulatory inspector, it is too late to get ready.”  There are several practical and effective steps you can take before that call or surprise visit.  Below is a brief review of some resources to help prepare.

Inspections can happen even if your operation does not have a federal Clean Water Act National Pollution Discharge Elimination System (NPDES) permit. EPA will come to farms for any number of reasons. They may be acting on a report of a discharge of manure, a local fish kill, or complaints from a neighbor about possible violations of the law.  They also perform inspections as a normal course of business or if there are possible paperwork discrepancies in documents.

In most instances, the inspectors make advance contact with the farm, by letter, fax or phone call, and attempt to schedule the visit at a day and time when the operator or their representative can be present.  But surprise visits do occur.

The key to being ready for an inspection is to have an operation that is designed, operated, and maintained to prevent animals and their manure from coming into contact with rainfall and stormwater; or if that occurs that this “process wastewater” is impounded and properly handled.  Fortunately, today’s layer operations are explicitly designed to meet these standards as a normal course of operation.  Doing so is the best preparation.  But besides this core consideration, it is wise for an egg producer and those responsible for the environmental matters in egg production to:

1. Have an up-to-date, working familiarity with how EPA conducts inspections.
2. Learn about the “standard operating procedures” (SOPs) that inspectors expect to see on a “well-run, responsible operation” and then ensure those SOPs are in place.
3. Know EPA’s obligations (including biosecurity protections, and in turn what are the producer’s obligations and rights.)

Below are resources with which to start.  UEP will provide a comprehensive review of these resources next month.

1. Watch the video “Why EPA and the States Inspect Farms” – an educational video created by the US Poultry and Egg Association, in partnership with EPA
2. Review EPA’s “NPDES Compliance Inspection Manual Chapter 15 (CAFOs)”
3. Review EPA’s “Sample Permitted CAFO Inspection Checklist,” page 738, (page 61 in PDF)
4. Review EPA’s “Standard Operating Procedure (SOP): Biosecurity Procedures for Visits to Livestock and Poultry Facilities,” page 719

As always, contact the UEP staff with questions or requests for assistance.