Although it wouldn’t be most farmers’ first choice of essential farm duties, most become adept at keeping records. And if there’s one area that requires extra vigilance, it’s manure records.
If you have a permitted manure storage or use farm manure under a written plan, some degree of record keeping is required. Christine Blanton, North Carolina Department of Environment and Natural Resources, Division of Water Quality, says that record keeping is always a requirement for permitted operations.
“There’s also a benefit to you the producer to keep good records,” said Blanton. “If you’re ever questioned about your facility, good records and complete records protect you, and demonstrate your level of compliance. Documentation is your best defense against any complaint.”
Because nutrient levels in waste analysis can vary throughout the year, good records can help the producer identify trends. “If you’re accustomed to seeing your nitrogen levels at around 2 pounds of nitrogen per thousand gallons and you get one back that’s 4.2 pounds, you know that you need to take another sample immediately,” said Blanton. “Perhaps you got a bad sample or there’s an error in the lab. You don’t want to be stuck using a sample with a higher nutrient value just because you weren’t paying attention, and perhaps run out of available waste application opportunities.”
Records also help identify problems. If you normally track of rainfall levels and lagoon levels and find that a one-inch rainfall shows a three-inch rise in your lagoon, there might be a problem. “Perhaps you have a leak,” said Blanton, “or there’s a diversion that needs to be worked on.”
Blanton says records will wave warning flags to you long before an inspector arrives. Good records also help you track which practices are working well on your farm. “The type of records you have determine for you how you will organize – what works best for you. Most importantly, be organized,” said Blanton. “If you can’t find your waste plan to show it to the inspector, there’s no way you can be following it.”
There are various methods to keep records, and whether it’s with a complex computer program or a clipboard, the most current information should be easily accessible. “Know how to get to it easily,” said Blanton. “The older information should be filed so you can get to it easily.”
Retention time for records is an important aspect of record keeping. Federal permitting requires that records are maintained for five years, but it doesn’t hurt to keep them longer. Records maintained on paper should be kept in a file cabinet in a safe room that is not prone to flooding. Many records, including the original permit, design information, irrigation design and waste plans should be kept indefinitely — anything that’s critical to prove the date you established operations in the event new rules are passed. Be sure you are familiar with the requirements in your state and any other states in which you haul and/or apply manure.
“If your state requires a certified operator, you’re going to want the certified operator’s name and license number,” said Blanton. “You want to be able to show that they’re up to date on all of their fees and they have all their current educational credits.”
Annual records should show calibration, and not just the calibrated number for the flow volumes, but the method you use and your data. “For the soil sample analysis,” said Blanton, “make sure whatever lab you use for soil sampling, that all parameters required in your permit are included in that analysis, and that the values are reported, not just a range.”
Blanton added that for metals, some labs’ reports include low, medium, high or very high. As levels approach ‘very high’, it’s important for the inspector to know what the actual value is. The farm’s emergency plan and mortality plan should also be part of records.
Crop yield records should be included, and remember that application rates are based on realistic yield expectations. If yields are down, crops may not be utilizing nutrients efficiently and an agronomic consultation might be in order.
Daily record keeping requirements may vary by state, but could include rainfall, waste level, waterline inspection, waste analysis, irrigation records (weather conditions, nitrogen loading, phosphorus loading) stocking and mortality. Blanton says some states require a walk-around inspection of the entire waste system following a one-inch or more rainfall to make sure there are no problems.
Some states have developed downloadable forms that make it easier to keep required records. Some of these forms can help the farm owner discover and track trends and result in making better management decisions.
“For stocking and mortality, you need to do more than just keep up with door cards and how many animals are in that particular barn,” said Blanton. “If you keep track of that on a weekly basis, you can see definite trends in mortality, and maybe identify a certain time of year when you have higher mortality.” Good record keeping on mortalities can help monitor and identify disease issues and ages of animals or particular groups that might be at risk.
Other records related to manure management include previous inspection reports. “Some states have duplicate forms, so they’ll hand you the form before they leave,” said Blanton. “Others will mail you a report. Keep these — they show areas of improvement since your last inspection. If you have a new inspector coming in who hasn’t been there before and there’s a problem area you’ve worked on, this is a good way to show the inspector ‘here’s what I’ve had before, here’s what I’ve been doing and here’s my improvement.’”
If you have received a violation letter, Blanton advises keeping it along with any correspondence you’ve had on the issue. “You may need to show the limit of the issues you had, and all the steps you’ve taken to correct that,” she said. “This is something you’ll want to hang onto for a long time.”
Any records of a plan of action (POA) for an activity such as sludge clean out or other actions that are outside of typical waste production should be maintained. Blanton says it’s important to make sure that the plan of action does not conflict with the farm’s regular waste plan and that fields included in the regular plan don’t end up being overloaded.
Keep current records on waste transfers off-site to a different facility, and transfers that involve third-party haulers. Be sure to document spills, and know exactly what must be documented in the event of a spill according to your state’s laws. “Document what surface waters were reached, if any,” said Blanton. “If you reported it, when did you report it to the appropriate agency? What samples did you take? Take any pictures as necessary.”
A combination of accurate, up-to-date records, specific personnel assigned to keeping certain records, timely checks of records to ensure they’re complete and attention to ever-changing details in regulations can go a long way in making sure your manure records are always squeaky clean.