Partnerships for Livestock Environmental Management Systems:
National Stakeholders Roundtable

May 30-31, 2001

Allan Stokes, Chief Operations Officer
America's Clean Water Foundation

Mr. Stokes was asked to address the following questions in his presentation:

  • Why has your organization developed an EMS?
  • What do you see as the benefits?
  • Please describe your materials and how producers have put them to use. What factors make them most useful to producers?
  • What lessons have you learned related to making this approach acceptable to producers?
  • What lessons have you learned related to making this approach credible to environmental agencies and organizations?
  • What have you learned regarding approaches to documenting outcomes?

First of all, what is America's Clean Water Foundation? It's a private, non-profit organization that's based here in Washington D.C. It's been in existence since 1989, and it's dedicated to helping build and maintain support for clean water through education, demonstration, and research programs. We don't advocate for or against passage of any particular state law, or federal law or regulation. We deal in education, technology transfer, information-sharing types of activities.

How did we get into developing Environmental Management Systems, or working with Environmental Management Systems in the agricultural sector? The Clean Water Foundation was asked in 1997 by the US EPA, the USDA, and the National Pork Producers Council to chair and convene as an impartial moderator what was then called the National Environmental Dialogue on Pork Production. This Dialogue brought together people from the federal, state, and local governments, environmental interests, academics, and various other groups to talk about the issues that were emerging and are still ongoing today, relative to pork production in the United States. One of the results of that effort was the recommendation that there needed to be some form of voluntary, no cost, or low cost, non-regulatory type of program available in the pork production industry, to help those people understand what they need to do to operate an efficient, effective production facility and do so in an environmentally sound and safe way. That had some resonance, and as a result, there were some appropriations passed by the United States Congress along with a mandate to America's Clean Water Foundation to develop such a program. And so we did develop a program that we call the On-Farm Assessment and Environmental Review Project (OFAER).

The goals of our own farm assessment program are very similar to the goals that Gary Jackson outlined for you this morning relative to what this group is trying to pursue. The first and foremost goal is to enhance the stewardship of poultry and livestock operations to protect the surface and ground waters of the United States through better environmental management. But we also have as a goal improving operational efficiency and helping a producer with the bottom line. The data that we are gathering indicate that we are having some success.

The key to our program is the on-farm assessment itself. The on-farm assessment mechanism that we employ was developed using private funds initially. It was a baseline product developed by the National Pork Producers Council using about $1.5 million of their check off funds. It reflected about two years of development effort by a multi-disciplinary team of people including those from NRCS and Land Grant Colleges, Quality Consultants, producers themselves, and producer organizations. Rather than take some of our precious funds and duplicate the effort, we decided to use that product as a launching pad from which we would build. The initial program was known as the OFOEAP, the On-Farm Odor Environmental Assistance Program. It focused primarily on odor issues. We have strengthened the tool in terms of its water quality aspects.

We have continued to build on that tool, and we have since expanded its focus to serve all animal sectors. We have worked with all the other animal production units: National Turkey Federation, US Poultry and Egg, United Egg Producers, various state associations, Iowa Cattlemen's Association, Virginia Dairymen's Association. Various groups have been working with us to expand the focus of the environmental assessment tool so it is in fact useable and useful in all of the areas of swine, beef cattle, dairy cattle, poultry, and egg-laying operations. In fact, we are conducting on-farm assessments in all of those animal sectors.

What we focus on are big picture issues: general site management, building and lot management, manure storage and handling, mortality management, and nutrient management. If you don't get management in those systems right, you're going to have environmental problems somewhere down the road, which is probably going to put you in some sort of a regulatory violation.

We have continued to improve the On-Farm Assessment Tool through more than 1400 assessments that have been conducted across the nation in the first two years of our project. The assessments themselves are voluntary. No one forces the producer to enter into one of these. The producer has to willingly sign up, and has to complete a ten-page questionnaire that we give them, where they provide some basic information to us about their facility, not the least of which is, what are their bio-security protocols? It's important to us to adhere strictly to the bio-security protocols of the producer. Bio-security measures are those management steps that a producer has put in place to protect herd or flock health from diseases that could be introduced from outside the facility. These could include showering in a nd out of the production area, wearing specific clothing (hair nets, coveralls, boots) provided by the producer, delay times in number of days between visiting facilities. The assessments are confidential. We do not divulge any farm-specific information, or name and address of producers who participate. This is confidential business information.

We do maintain a database of aggregated data, however, and that database captures over 500 separate data attributes and can be sorted in any combination of those attributes. And we are willingly making that information available, and will be using it to develop educational tools. It can be a very powerful tool to know the common environmental strengths and challenges of a two million bird egg-laying operation. You can use that kind of information to develop education at Land-Grant Universities, or to producer organizations or governmental entities. If there are going to be regulations, perhaps the thought that goes into the regulatory development at the state and federal level can be better focused and better directed. The data can be used for a wide variety of purposes. So while the farm-specific information is confidential, we are sharing broad-based information of a non-regulatory nature.

There are 50 state regulatory programs, probably more than that, depending on which state you're in. In some areas local governments have their own regulatory schemes. Regulations can change moment by moment. Trying to keep track of the current interpretation, status and fine nuance of all those state and local regulations would be extremely difficult to do from a central location. Certainly it's a job that needs to be done, but that is something that is probably better done at a state level, perhaps from a state check list. For example, I think John Lawrence, who is here representing one of the Partner pilot states, has developed some things that will be useful to Iowa cattlemen. Those kinds of programs will be something that will be better developed at the local level.

When we say that our assessments are non-regulatory in nature, what that really means is we don't certify that if you have one of these assessments, that you're going to be bullet-proof if the state inspector shows up the next day, the next week, or the next month. We may not be fully aware of all of the state regulations and we don't focus on the regulatory issues. Our program is really designed to be a pollution prevention and education program. We actually look at cause-effect relationships. We don't just look at the outside of the building to see if there's an insult going on, which at that point in time is kind of like trying to close the barn door after your cattle are half out. We deal with the issues inside the building and the root causes of what can be some significant problems down the road. We help the producer understand those cause-effect relationships and what they can do to help alleviate those problems from happening in the future. Our assessments are objective. The tool is specifically designed to be a third party assessment. It is not a self-assessment tool. I want to be very clear about this; there's been some misinformation out there that we're trying to take over the world. That is not the case. We have a niche we are trying to fill. We are firm believers in self-assessment mechanisms, and we always tell producers, nothing replaces a producer knowing what goes on at their facility on a day-to-day basis. And nothing in our program obviates or eliminates the need for a self-assessment program conducted by producers. Conversely, we also tend to think that it's a good idea to have an objective third party assessment. "Third parties" are not familiar and are not day-to-day involved in a facility, so you get a fresh set of eyes. It's kind of like my apartment here in D.C. I think I keep it pretty clean, but when my family comes to visit they are always asking, don't I ever dust, or don't I ever straighten up? I just live in it every day, so it becomes a routine. Another analogy that I draw, it's like a yearly physical exam. We all check our health every day. Nothing replaces the need to do that. But periodically we all go to have a physical exam from our doctor to have a trained objective third party give us an opinion: yes, you are healthy, or no, you may need to do some things, or you may need to go see a further specialist for some more in-depth opinion and assistance. The role we play is like the general practitioner. And our assessments are provided at no charge to the producer currently. The funding that we receive through the Congressional Appropriation is what we use to pay the costs of the assessments.

The folks that we use to do the assessments are either current or retired NRCS or Extension service staff. The bulk of them are probably private consultants, people who already have a background in agriculture and who have been specifically trained and certified in the use of our on-farm assessment tool and our on-farm assessment techniques. Our systems do identify risks and challenges. We also identify strengths, the good things that are going on out there on a facility because it's important to provide that positive reinforcement. We provide information and education. It's a one-on-one teachable moment. The producer, or the farm manager, goes along during the assessment. It's important to have that interchange. Each facility has its own unique character, and it's important that we know why that facility is set up and operated the way it is. One size does not fit all. You have to look at things in context. It's particularly important during that assessment that if we see something that looks like a risk or a challenge that we can point it out and talk it through with the producer. It has a lot more meaning in it, rather than just reading a sterile assessment report that is provided at the end. We also provide a source for additional assistance and information whether it's to go see your extension service office, your NRCS, or a private consultant of your choosing.

What we don't do is mess with telling producers what kinds of animals they ought to be raising. We don't tell what kinds of feed ration mixes they ought to be using, we don't delve into their veterinary medicine regimens and we don't sell goods and services.

Assessments are available to all livestock producers. While we originally started out with a main focus on the pork industry, we are now doing assessments in all of the other animal sectors. If you take a look at the assessment requests that are coming in, we're running 12% in poultry, 9% in cattle, and about 79% in the swine area. We have seen a major increase in the number of assessments being requested. We have conducted assessments or have assessments scheduled in 39 states. We expect to be in all 50 states by the end of this calendar year.

These assessments benefit any size or type of facility. We've been on facilities that have had as few as 70 animals in open lot facilities, to facilities that have had millions of animals in total confinement. In fact, over 75% of the assessments we've conducted have been on facilities with fewer than 1000 animal units in size, and 42% have been on facilities with fewer than 300 animal-units.

So that in a nutshell is our on-farm assessment program. I want to stress that it is an environmental management system in a way. Is it a full EMS? No, it was not designed to be that. It was designed to be an assessment program, and compatible with other types of programs. In a Dairy or Ag Quality Assurance program, one component may be an assessment of environmental risks; that may be a niche where our program can fit in, but it's not designed, nor do we have the intention of taking over quality assurance programs. In a full environmental management system, perhaps this assessment program can serve a use, but it's not designed to be a full-fledged environmental management system for all facilities. In fact, my opinion is that it's better developed at the producer level, the producer organization level. I think the work United Egg Producers and EPA have done on the EMS under the Project XL is to be commended. There you have buy-in by a producer organization and producers that are working with the regulatory community on what is an acceptable environmental management system. So our program is designed to fill a niche and what we have is a voluntary, confidential, no charge, third party assessment program, designed specifically to be that. And designed specifically to be complimentary to self-assessment processes and other industry quality assurance programs. It is not designed to replace those. Thank you.

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