Pew Commission Questions EPA On CAFO Air Release Exemption

Feb 29: A release from the Pew Commission on Industrial Farm Animal Production (PCIFAP) indicates that as the U.S. EPA considers lifting a requirement that industrial farming facilities report their toxic gas emissions, the Commission's panel of experts told Congress that the vast amounts of animal waste and byproducts from such facilities pose significant risks to human health and the environment, requiring greater -- not lesser -- scrutiny. Members of the PCIFAP said the traditional methods used to dispose of animal waste are often insufficient to deal with the amount of waste generated by the high-volume industrial facilities that today produce food products for much of the nation. The waste run-off from these facilities can contaminate groundwater and drinking water supplies, and the toxic gas emissions can be harmful -- and even fatal -- to farm workers and surrounding communities.

PCIFAP says that as the production of meat, poultry, milk and eggs has become more concentrated, so too have the by-products of that production. Industrial food animal production (IFAP) facilities [a.k.a. Concentrated Animal Feeding Operations, CAFOs] often house thousands to tens of thousands of animals in confined areas, producing large quantities of concentrated fecal matter and other wastes. The hundreds of thousands of gallons of manure from dairy cows and pigs are often stored in liquid form and held in large tanks or outdoor lagoons, until it can be sprayed or spread onto nearby fields, or pumped into the ground. PCIFAP said, "If left to the age-old methods of disposal, these extremely concentrated wastes can quickly overwhelm the ecosystem’s ability to deal with them, resulting in severe environmental degradation."

Conditions and waste management methods common to IFAP facilities can also produce emissions of harmful gases such as ammonia and hydrogen sulfide. PCIFAP indicated that, "Many of these compounds are known to be toxic to the nervous system in sufficient concentration, and can cause respiratory symptoms, disease and impaired function. . ." Moreover, the Commissioners explained, animal wastes are known to be a primary source of “zoonotic” pathogens -- disease-carrying microbes that pass between humans and animals -- that can lead to disease outbreaks. They said monitoring is a basic component of strategies to protect the public from harmful effects resulting from contamination or disease, yet "monitoring systems in IFAP are inadequate -- a situation that makes mandatory reporting of toxic emissions even more important."

On February 26, 2008, in a letter to EPA Administrator Stephen Johnson, the Pew Commission expressed their concerns about the Agency's proposal to lift reporting requirements on industrial farms. Commission Chairman John Carlin said, “Clearly we must balance the imperative of human and environmental health with an ever-growing consumer demand for safe, abundant animal-based food products. Through improved practices we can achieve both ends, but this means at a minimum not weakening the existing means of monitoring harmful emissions from IFAP operations.”

In its letter, the PCIFAP wrote, "The Pew Commission was under the impression that the recently formed Farm, Ranch, and Rural Communities Advisory Committee was going to be investigating issues such air pollution from agriculture and then make recommendations to the EPA about how to approach these important issues that directly affect public health. . . Given the opposition that the publication of this rule has generated, it seems there should have been, and should be, consultation with stakeholders and the Advisory Committee before decisions like this are made. A preemptive proposed rule on exempting large animal feeding operations from reporting ammonia or hydrogen sulfide releases without consulting your own advisory commission questions EPA’s commitment to making that advisory commission more than 'window dressing'."

On Feb 20, 2008, the EPA Administrator announced the appointment of 30 citizens to serve on a newly-formed Farm, Ranch, and Rural Communities Advisory Committee (FRRCC) [See WIMS 2/20/08]. EPA said it EPA would ask the committee to focus on three issues: (1) How EPA's policies and regulations on climate change and renewable energy will affect the agriculture community. (2) An environmental strategy for managing waste from livestock operations that considers regulatory and voluntary approaches, and provides tools for producers to attain superior environmental performance. (3) Development of a constructive approach to advancing sustainable agriculture, protecting the environment, and addressing communication between environmental and agricultural interests. The first meeting of the committee is scheduled for March 13 and 14, 2008 at The Madison Hotel in Washington, DC.

The Pew Commission was convened in 2005 to study the impacts of dramatic changes in animal agriculture in America over the past 40 years. It is funded by a grant from The Pew Charitable Trusts to Johns Hopkins Bloomberg School of Public Health. The decline of the family farm and the concentration of the industry into a relative few large corporations has meant greater efficiency and lowered costs for producers. But this shift has also brought environmental, public health, and socioeconomic problems, such as the threats posed by poorly managed farm waste.

PCIFAP has scheduled an April 29, 2008, release of a set of recommendations to address the risks and challenges of managing IFAP facilities. The PCIFAP’s two-year study encompassed site visits to production facilities across the country, consultation with industry stakeholders, public health, medical, and agriculture experts, public meetings, and peer-reviewed technical reports.

On December 28, 2007, EPA proposed a CERCLA/EPCRA Administrative Reporting Exemption for Air Releases of Hazardous Substances From Animal Waste in the Federal Register [72 FR 73700-73708]. Specifically, the proposed administrative reporting exemption applies to releases of hazardous substances to the air where the source of those hazardous substances is animal waste at farms. EPA said, "This administrative reporting exemption is protective of human health and the environment and consistent with the Agency's goal to reduce reporting burden where there would likely be no Federal, state or local emergency response to such release reports. Eliminating such reporting will allow emergency response officials to better focus on releases where the Agency is more likely to take a response action." The comment deadline on the EPA proposed rule is March 27, 2008.

Access a release and the letter from the PCIFAP (click here). Access the PCIFAP website for extensive information (click here). Access the docket for the EPA rulemaking which includes the proposed rule, background information, comments received to date, and commenting instructions (click here). Access the FRRCC website for additional information (click here). Access the WIMS-EcoBizPort CAFO links for additional information (click here). [*Air, *Agriculture]