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.
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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.
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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.
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.
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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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