Program Overview: Policies/Procedures, ES Facts
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Policies & Procedures
CDQA Environmental Stewardship Certification
Background
The Dairy Waste Management: an Integrated Approach to Education and Compliance Partnership Agreement was signed September, 9, 1999 at the University of California, Davis. Herein it will be referred to as the Partnership Agreement.
The Partnership Agreement establishes a voluntary, cooperative government and industry environmental stewardship educational program. These Policies and Procedures establish minimum standards for certification. Unanimous consent of all designated representatives of the Partners is necessary prior to their implementation or for subsequent revisions. Continuity of the program is enhanced through participation of the designated Partners’ representative. Other interested parties such as the Regional Water Quality Control Boards (RWQCB) and the County Department of Health Services (DHS) will be invited to participate in future revisions of the certification process.
The ultimate goal of the California Dairy Quality Assurance Program Environmental Stewardship (CDQAP ES) program is to help ensure a healthful environment for the people and wildlife of the State of California. The key objective is to assist California dairy producers to meet all federal, state, regional, and local regulations relating to manure and nutrient management.
The Partnership Agreement establishes the responsibilities of each agency and acknowledges that the completion of environmental certification does not certify or guarantee that a facility is in compliance with environmental laws and regulations.
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Requirements for Certification
There are three core components of the certification process:
- Complete the Environmental Stewardship Short Course (ESSC 1) (all three classes) offered by University of California Cooperative Extension (UCCE);
- Develop an Environmental Stewardship Farm Management Plan and locate necessary regulatory documents;
- Successfully complete on-site evaluation by third party evaluator.
Education
Producer Education
The curriculum for ESSC 1 is well established. It will be reviewed by Partners twice annually to determine additions and modifications necessary to deliver a current, consistent, and credible program throughout the state.
As long as grant funding is procured, ESSC 1 will be delivered to dairy producers at no cost. Partners will assist as necessary to procure grants to allow continued producer participation at no additional cost. When a producer commits to the program he/she is providing in-kind contributions in labor, physical improvements to their facility, and more intensive management.
It is anticipated that additional short courses will be developed for Statewide delivery. Partner representatives will identify issues for incorporation into future short courses. Curriculum outlines will be presented to Partners. As with the ESSC 1, Partner staff will assist in document development and review prior to program delivery.
Partner representative education
Partner representatives who will be providing non-regulatory technical assistance to producers and who may assist producers prepare for the evaluation process will need to be trained and successfully complete a written test. Two core courses are necessary. The first is the allied industry ESSC 1 (equivalent to producer ESSC 1). There is no charge to any Partner representative staff person taking the ESSC 1 for allied industry. The second course provides specific detail for the CDQAP-ES producer evaluation and certification process. Additionally, it reviews the storage capacity software and the uniform checklist. This course will be available to Partner staff at a reduced rate.
The initial curriculum for the second course was established through the pilot program and will be reviewed once Partner members have been trained and at six month intervals thereafter. An annual refresher/update course will be necessary to maintain certification. Consultants who are retained by Partners and who can gain financially by the information gained during the training process should attend the consultant training program. Proficiency is defined as correctly answering all questions related to regulations and correctly answering 80% of the questions related to the CDQAP ES certification process. Training is valid (current) for one (1) year from the date of completion. Courses will be offered at least twice annually to provide updates.
The initial curriculum for training is:
- Overview of CDQA--status of each component
- Environmental Certification
What does it take?
ESSC, Environmental Stewardship Farm Management Plan, Evaluation - How do you put together an Environmental Stewardship Farm Management Plan?
Prioritize risk assessment high risk categories and identify timeline to reduce risk; pond calculations--review items needed and go over examples of freestall and corral situations to be sure people understand how to properly make calculations; review software use; storm water pollution prevention plan; emergency plan; other appropriate management tools.
- preparing for the third party evaluation
- review regulations (Federal, State, Regional, County)
- review third party evaluation checklist
- review manure problems identified by regulatory staff
- review biosecurity issues
- pass post session test on CDQAP ES component
- attend refresher course (updates) annually
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Training of consultants and others
Consultants should receive similar training to Partner staff. This training may require more detailed information to convey regulatory requirements or details related to CDQAP-ES component. All non CDAQP members and employees will be charged for the information and the training. The income will be used to offset costs associated with development and maintenance of the non-funded components of the ES program. Proficiency is defined as correctly answering all questions related to regulations and correctly answering 80% of the questions related to the CDQAP ES certification process. Training is valid (current) for one (1) year from the date of completion. Courses will be offered at least twice annually to provide updates.
Educational review process
Partner representatives receive program updates at quarterly meetings. They will review curriculum and evaluation summaries for ESSC 1 annually. Curriculum for training of Partner staffs and other professionals will occur after Partner staff have been trained and at six month intervals.
Participation on third party evaluation
Producers who have completed components 1 and 2 will contact the California Department of Food and Agriculture CDFA (Bob Donnalley/headquarters for the Milk and Dairy Foods Branch) to arrange for the third party evaluation. CDFA will contact UCCE to determine producer eligibility (attended all three classes of ESSC 1). The producer is responsible for identifying the individual on the facility who has completed the ESSC 1. If any unresolved discrepancies exist in the records, those of UCCE will prevail.
A packet of information will then be forwarded to the producer. This packet will contain a cover letter, a document "What do I need to do to certify", the first half of the third party evaluator checklist, and a list of individuals trained to assist producers in preparation of the evaluation process. Additional information related to CDQAP will be made available, including question and answer sheets, program highlights, and program updates. The producers will also be asked if he/she would like to have a field representative (trade association or creamery) or University of California Cooperative Extension Dairy Advisor notified that he/she has requested information for the ES certification component. CDQAP may establish a web site to allow producers to request program information electronically. The verbal request through CDFA shall remain a component of the CDQAP and not a part of the CDFA record.
Producers will receive the first part of the checklist ahead of time. It will be labeled "to be completed prior to the evaluation". He/she should complete this part before the evaluator arrives. Assistance is available through non-regulatory Partner staff trained in the CDQAP ES component (a list will be maintained and published on the CDQAP web site and in Partner newsletters). Producers may attend a pre-evaluation class prior to the evaluation. This is highly encouraged for producers who attended ESSC 1 during 1998 and 1999. Producers may choose to not participate in a pre-evaluation class prior to the evaluation. Regardless of participation, producers are responsible for completing the initial component of the checklist prior to the arrival of the evaluator.
Producers should schedule their evaluation as soon as possible. He/she should arrange a date that is convenient with the evaluator and the individual who completed the ESSC 1. Also, the date should allow for completion of the initial half of the checklist. Evaluators will need to schedule appointments ahead of time. Producers should not expect same week evaluations.
Storage calculations
A printout with appropriate storage calculations is necessary to answer part of the initial questions on the checklist. Producers can obtain these values through numerous routes. Producers are encouraged to have a trained individual use the UCCE software and provide a printout created to complement the CDQAP checklist .
Other software or hand calculations can be used. Sufficient definition of assumptions and detail of inputs will be necessary to enable the evaluator to interpret the report. A listing of all input items necessary for calculations can be worked through with the evaluator (completed forms 1-10 for input for estimating storage) and appropriate information to determine existing pond capacity. The evaluation process will take more time if alternative software is used.
The UCCE software is not effective for non-rectangular ponds. Hand calculations will be necessary. All calculations must be provided on the output to allow appropriate interpretation.
All data forwarded and accrued during the establishment of the program are the property of CDQAP and is subject to confidentiality and disclosure of records governed by applicable federal law.
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Uniform evaluation tool development and distribution
The uniform evaluation tool (checklist) is used by the evaluator to determine if the facility and its management meet regulatory requirements (federal, state, and local) related to manure management.
The checklist content was developed to allow yes/no answers when possible. This established a more objective rather than subjective list for producers. The questions will be used to evaluate facilities to determine if legal requirements are met. More detailed information pertaining to the criteria used to determine if a Y/ N answer is appropriate for each question will be included in evaluator training documentation.
In addition to signatory Partners input from agencies will be requested during regular updates of the checklist. Staff from Regional Water Quality Control Boards and California Department of Fish and Game will be requested to provide input. Other interested parties (DHS, County planning agencies, mosquito abatement districts) will be contacted to determine their level of interest in development of future questions and future certification criteria.
A parallel descriptive document will be developed. This document may be given to producers at the completion of an evaluation (used as an educational tool) or the material in the document will be gleaned and made into an exit document for producers. This document will provide criteria for each question and can be used by producers to make needed improvements. Once developed, the parallel descriptive document will be left with producers after the initial evaluation. The concern is that the document will contain more information than applies at a given facility and that the "extra" information may be cumbersome to wade through. Exit materials will be developed based on comments and input from those evaluated and those doing evaluations, as well as Partner representatives and field representatives assisting producers in the evaluation process.
The checklist is the property of the CDQAP. It is subject to disclosure governed by applicable federal law. The informal distribution of the checklist is based on guidelines established by CDQAP. They are as follows: distribution to sister organizations of Partners is acceptable if the checklist is going to be used for educational purposes or in the development of a similar list for a different species or state. Individuals and organizations that may profit through the use of the uniform checklist and individuals and organizations that are not assisting producers in the certification process are encouraged to receive similar training as Partners to obtain a copy and working understanding of the checklist.
The checklist will be reviewed annually. Changes in questions will be reviewed by the Partner representatives prior to implementation. Questions on the checklist may have one of four types of notation. Notation "*" is a regulatory requirement. Questions with "**" represent programmatic responsibilities as spelled out in the Partnership Agreement. Questions with "***" may be identified by the Partners as critical to the certification process. All "*" and "**" questions must be answered appropriately. All other questions have no notation and provide background and supplemental information for the evaluator to use to determine certification outcome.
Addendums to the checklist will be made to address Regional and County specific requirements or policies. These will be developed by UCCE based on information received from RWQCB through their basin plans and on information received from County DHS or Planning Departments when it is provided. It is acknowledged that, initially, some counties may lack appropriate addendums due to lack of information. As these are created the Partners can review addendums for use. Any changes in addendums will be provided to those producers who are already certified. Draft addendums will be sent to RWQCB, County DHS, Planning Dept, and Mosquito Abatement, Fish and Game for review and identification of omissions.
Alterations to the checklist resulting from new policy or regulations (AFO Strategy and changes in effluent limitation guidelines) will be prepared in a timely fashion. It is anticipated that greater emphasis will be placed on land application of nutrients once these are finalized. Currently, there is no uniform policy of land application of manure and wastewater that specifies specific reasonable rates.
Modifications of the checklist will be distributed to producers who are certified, are in the evaluation process, and to individuals who are certified to assist producers.
The producer retains ownership of the checklist once the evaluation process begins. The checklist is to remain on the dairy. The only component of the checklist that leaves the dairy is the front page. This is removed from the dairy and forwarded for CDQAP ES certification when complete. Any information contained in the checklist is already available to regulatory agency staff upon request during an inspection. There is no new information captured during this process that is not already accessible to regulatory staff. Furthermore, the information incorporated into Environmental Stewardship Farm Management Plan is already available to regulatory agency staff upon request. None of this information is deemed business confidential.
The individual who completed the ESSC must be the individual to accompany the evaluator during the evaluation. Additional key facility personnel (facility owner if leased, manager, and persons responsible for day to day management of manure) may be included during the evaluation process to assist in information exchange.
Producers will have access to the evaluation process regardless of milk processor or trade association affiliation. During the availability of grant funds from the Toxic Substance Control Act (TSCA), producers will be eligible to receive up to 2 evaluations prior to certification. Once the producer is certified he/she is not eligible for TSCA funded evaluations. Additional evaluations beyond 2 will be billed at cost to the producer. Cost will be determined by CDFA.
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Partner responsibilities
The Partnership Agreement establishes the primary responsibility of all Partners to be the development of training materials designed to assist producers in determining if their facilities are in compliance with all federal, state, regional and local environmental laws and regulations related to dairy manure and nutrient management. Individuals should consult the Partnership Agreement for specific details and responsibilities.
Communication
Communication at all levels will ensure efficient and effective delivery of a quality ES program. Producers must be aware of the contents and requirements of the CDQAP, specifically the ES component. All Partners must understand their role in the CDQAP. Accurate and efficient distribution of information is best accomplished through a central clearinghouse that accepts questions, obtains appropriate answers, and disseminates the answers to ALL trained persons, certified dairy producers, Partners, and the Dairy Issues Forum.
Partner representatives shall meet quarterly during the first three (3) years of ES certification. More frequent meetings can be convened as needed. The three-year term coincides with the implementation of the TSCA grant. This will allow all Partners to receive timely information pertaining to the progress of the TSCA grant objectives and also allow agencies and organizations to redirect resources if necessary. All Partners are committed to the success of activities funded by the TSCA grant.
Progress reports will be prepared quarterly. All Partners will receive copies and have the opportunity to comment. Press releases or articles suitable for industry publications will be prepared and distributed to Partners and through media contacts.
At a minimum, quarterly media items shall be prepared and distributed to Partners and through media contacts [first quarterly report will contain a list of media contacts]. The CDQAP will establish a web page with links to Partners. Program information related to Environmental Stewardship will be posted quarterly or more frequently when possible.
Each Partner shall provide an overview of written and oral public communications regarding the CDQAP-ES . The news releases established through the CDQAP-ES will be sent to all Partners. Newsletters and items will be sent to Partners or be made available at quarterly meetings. This includes but is not limited to: copies of weekly news items to clientele, a list of media contacts (dates and persons involved), popular press articles, etc.
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Acknowledgment of certification
Individuals who have attended all three classes of the ESSC 1 will receive a certificate of participation. Individuals who have attended the classes and have had a successful third party evaluation will be certified in environmental stewardship. The CDQAP will develop methods of recognition (e.g., certificate for environmental stewardship, optional road signs, bumper stickers, clothing, etc.). It is important to differentiate between the recognition of participation in the ESSC 1 and certification in environmental stewardship.
Re-certification process
The certification is valid for a period of 5 years or until an illegal discharge or a material change in manure production occurs. Producers who have an illegal discharge from their property must report the discharge to the appropriate regulatory agencies (RWQCB, DHS, CF&G). Regulatory enforcement actions will result in de-certification. Re-certification will be necessary when there is a change of ownership or a change in management that removes the ESSC 1 attendee. This will be determined through an annual obligation/reminder document that must be signed and returned to maintain certification. A material change is defined as an increase in cow numbers, amount of manure collected, or amount of farmland available to receive manure. A baseline value to reflect a 20% change will be used unless extenuating circumstances exist that require more or less stringent threshold levels necessary to protect groundwater and surface water. A material change will impact the volume of manure handled on the facility and/or the management and amount of receiving farmland.
Evaluator Training
Minimum training necessary for the third party evaluator is the equivalent of the US EPA training, a minimum of a day with a RWQCB enforcement staff from each region 1, 2, 5, and 8 and others as needed. Additionally, they shall complete the allied industry ESSC 1 and the second course offered for certification of those trained to assist producers in the evaluation process. Quarterly debriefings and updates will be utilized to identify problems and assure uniformity in evaluations. Each new evaluator will participate in 4 evaluations before beginning independent evaluations. Input from evaluators will be used to further meet necessary training needs.
Environmental Stewardship Checklist committee
Chuck Ahlem, Dairyman
Dr. Richard Breitmeyer, California Department of Food and Agriculture
Ria de Grassi, California Farm Bureau Federation
Jay Goold, Western United Dairymen
Jack Hamm, Dairyman
Jack Hodges, State Water Resources Control Board
Dan Johnson, National Resources Conservation Services
Phil LaRussa, United States Department of Agriculture- Animal and Plant Health Inspection Service
Lynn Kuo, United States Environmental Protection Agency
Steve McGinnis, California Department of Food and Agriculture
Dr. Deanne Meyer, University of California, Cooperative Extension
Denise Mullinax, Hilmar Cheese Company
Dr. Mike Payne, University of California Davis
Rod Simon, California Fish and Game
Case van Steyn, Dairyman
Gary Veserat, University of California, Cooperative Extension
Dr. Dennis Wilson, California Department of Food and Agriculture
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Environmental Stewardship Facts - Milestones
In the wake of severe dairy farm flooding in 1998, the CDQAP steering committee directed that the environmental stewardship module receive the highest attention. In this module, producers attend a short course at the University of California at Davis (UCD), develop a pollution prevention plan, and have their facilities certified as meeting all regulations by a third party evaluator. The following progress has been made in meeting those goals.The California Dairy Quality Assurance (CDQA) program’s success is tied to its support from all parties - dairyman, academia and governmental agencies. Since its inception in 1997, the program has made significant progress in providing dairymen with the tools they need to proactively address dairy confidence concerns and navigate the many rules and regulations that govern the industry.To date, more than 1,300 producers have completed the six-hour environmental stewardship water course. More than 215 dairies have been certified by completing a third-party facility evaluation and 25 dairies are in the process of being certified. This means they will be able to display the new "Environmentally Certified" CDQA roadside sign that made its debut this year.CDQAP involvement is paying off for producers in many ways. For the first time, certified producers saw a reduction in Storm Water Permit fees by the State Water Board. These fee reductions ranged from $200-2,000 per year depending on the dairy size. The CDQAP also is negotiating with the Central Valley Regional Water Board by providing written comments and presentations with a goal of having CDQAP environmental certification serve as a method to document compliance with a yet-to-be-adopted water permit.Air quality, a major concern for dairymen and consumers, also is being addressed. The CDQAP delivered a new air quality curriculum to more than 800 producers in workshops throughout the state. The program leveraged university, state, federal and processor resources to do so, including a $50,000 grant from the US Environmental Protection Agency.Processors are heavily invested in the CDQAP program - especially through the Community Alliance for Responsible Environmental Stewardship or CARES. Made up of propriety creamery, cooperative and service organization leadership, CARES spends its annual budget of $300,000 on advocating industry views on environmental matters as well as assisting CDQAP efforts. CARES funding allowed for the production of 200 roadside signs, an informational CDQAP newsletter and brochure, and helped to finance air workshops. CDRF support of CARES assists in outreach efforts for environmental stewardship.Biosecurity and the safety of our food supply are important to the continued survival of the dairy industry. By leveraging more than $332,000 in government and philanthropic foundation grants, the CDQAP has developed a Food Safety/Emergency Preparedness Module that is near completion. The Module includes three videos on BSE Prevention, Biosecurity and Emergency Response and will be rolled out throughout this year by various dairy organizations. A collaboration between the CDFA, USDA and UC Davis, the program is the most useful training tool on the subject available to dairy producers in the country.Another successful collaboration has produced an education, evaluation and certification package for Johne’s Disease prevention. More than 180 veterinarians have received special training and are available for on-farm evaluations to develop Johne’s mitigation plans. Through the CDQAP, this service is free to California producers as is cow blood testing and confirmatory fecal testing for cows positive or suspect in blood testing. In addition to minimizing the spread of Johne’s on a dairy, this program can also help reduce common GI disease transmission on the farm and will save dairies money.Michael Payne, DVM, Ph.D.
Program Director
California Dairy Quality Assurance Program
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