November 14, 2008

Weekly Update is a publication of Western United Environmental Services (WUES), designed to bring you valuable information and helpful tips for compliance with the Waste Discharge Requirements of the Central Valley Regional Water Quality Control Board. Each week you will find features on compliance issues, regulatory changes or common questions, as well as workshop notices and introductions to the WUES technicians. If you have missed any of our past issues, they can be found on our website at www.wuenvironmental.com.

The Devil is in the details: why good records are critical to success

For a small sub-set of the population, collecting and maintaining records is an enjoyable activity. For the rest of us, it varies from a necessary evil to something worse than a root canal without anesthesia. As a consequence, most of us only collect and maintain the minimum amount of data required, and that grudgingly. However, in this time of increasing regulatory oversight, good records are more than just a good idea; they might be the key to survival.

Dairymen are no strangers to record keeping. They have been tracking breeding stock and milk production for years. Neither are they strangers to technology. No commercial dairy milks by hand today, and many milking barns are automated to a very high degree. So it isn’t that keeping records or using technology are foreign, but rather that the new record keeping requirements are being imposed from the outside. It is much easier to keep track of things that are interesting or important to you, but hard to keep up with things that are only of use to someone else.

So why are good records critical to success? In the case of breeding or production records, it’s easy to see why they are important because the payoff is fairly clear. With these types of data, there is generally a reward for good records and a consequence for bad ones. Regulatory compliance offers little in the way of rewards, and the consequences are often delayed. However, since the consequences can range from a simple notice of non-compliance to fines worth thousands of dollars daily, they can be quite severe. A hefty fine could even be significant enough to force a producer out of business! The ultimate consequence of poor record keeping is a revision of the General Order to require that all records be submitted to the Regional Board, rather than allowing many of the records to remain on the farm.

WUD pushed hard to win the right for producers to maintain most of the records on the farm, submitting only compiled reports and certifications of compliance to the Regional Board at the reporting deadlines. In order to preserve this right, it is critical that producers maintain the required records and make them available to the Regional Board during inspections. Records should be kept in a single location, and organized by type for ease of inspection. WUES technicians are available to assist you with organizing your records, and will join you for any inspection.

What records are required? The CDQAP binder lists all the records that are required, but here is a quick recap for easy reference.

• date & amount of all solid manure applied
• date & amount of all liquid manure applied (every application, every gallon, every field)
• date & amount of all irrigation water (amount of every application, every field, every water source)
• date & amount of waste water and solid manure exported (manifests of amount and destination)
• date & amount of all harvested crops (amount harvested and from which field)
• lab results for each of the above (manure, lagoon, water and plant tissue samples)

These records are also necessary during the preparation of Annual and Interim Reports, whether you will be preparing them yourself or with assistance, so having all your records gathered together in one place makes this task easier as well. Ultimately, the payoff for good record keeping is the ability to do business with a minimum of intrusion.

CDQAP Workshop Reminder

l  Merced County Thursday, November 20, 9-12 at Merced County Cooperative Extension Office, 2145 W. Wardrobe Ave, Merced (please park in lot B – the gravel lot to the east of the building)

l  Stanislaus County Tuesday, November 18, 9-12 at Stanislaus County Ag Center, 3800 Cornucopia Way, ABC Room

l  Tulare County Wednesday, November 19, 9-12 at Tulare County Cooperative Extension Office, 4437 S. Laspina Street, Tulare

CALENDAR OF MONTHLY MONITORING ACTIVITIES

NOVEMBER

To receive more information on WUES, please contact your WUES Environmental Technician or WUES Office:

• Phone (209) 238-3818
• Fax (209) 238-3808
• Email: info@wuenvironmental.com
• www.wuenvironmental.com