Auditing and Assessing Air Quality in Concentrated Feeding Operations1,2,3

Professional Animal Scientist, Feb 2008 by Cole, N A, Todd, R, Auvermann, B, Parker, D

Environmental audits may be as simple as a tour of facilities and review of records or as complicated as intensive air sampling and monitoring. Audit criteria may be management practices that benefit the environment or may be compliance requirements such as regulations. For example, if the goal is to test for compliance with regulations, the audit may provide information on whether compliance has been achieved or not, and if not, what specific measures are needed to comply with regulations. Environmental audits should be performed by persons that possess a working knowledge of the regulations and have a familiarity with the operations and practices of the facility being audited. These 2 basic skills are a prerequisite for adequately identifying areas at the facility subject to environmental regulations and potential regulatory violations (EPA, 2001).

The US EPA (EPA, 1996b, 1997; 2000, 2001), several states (IWRC, 2000), and the International Organization for Standardization (ISO, 1999, 2001, 2002) have developed resources to assist small businesses in designing audit programs, including audit checklists, protocols, and software. A number of businesses and agencies also provide training courses and certification for environmental auditing (BEAC, 1999; EPA, 2000), most designed around the ISO 14000 standards (ISO, 1999; EPA, 2004a). In 1993 the ISO began work on the "ISO 14001 - Standards for Environmental Management Systems" which was subsequently supplemented with "ISO 19011 - Guidance for Quality and/ or Environmental Management Systems Auditing" (ISO, 2002). These ISO standards are the basic framework around which an auditing program may be developed.

To encourage environmental audits, the EPA and several states have developed incentive programs that encourage regulated entities to voluntarily "police" themselves. Facilities that voluntarily discover, promptly disclose, and expeditiously correct violations of federal environmental regulations can obtain elimination of, or substantial reduction of civil penalties, criminal prosecution, or both (CFR, 2000). The policy was designed to encourage greater compliance with federal laws and regulations by promoting a higher standard of self-policing. The potential cost savings associated with waste and emission management and liability risks are factors in motivating industries to establish proactive environmental programs that encourage auditing and pollution prevention.

Pollution prevention opportunity assessments (PPOA) can be used by environmental managers to identify opportunities to change facility operations in order to save money, increase worker safety and morale, and decrease regulatory liability (EPA, 1992). The PPOA can be used as a tool for identifying and eliminating the underlying causes of compliance problems. Compliance problems can be resolved via a combination of best management practices (EPA, 2007d), management changes, or technical modifications.

Accurately defining the objectives and scope of an environmental audit is critical to ensure that the audit achieves the desired results. The scope of an audit usually defines a specific procedure or area of investigation and can be influenced by factors such as facility conditions, cost, staff availability, or other resource constraints. An initial air quality audit at an AFO might include a listing of air emissions of concern, their source(s), estimates of emissions or concentrations within and downwind of the facility, and potential effects of management practices on the emissions. It should also identify potential environmental or human health problems and develop schedules for remedial actions. The audit should include management audits, PPOA, and auditing standards (EPA, 1997). Other factors that should be evaluated include organizational structure, environmental commitment, formality of environmental programs, internal and external communication programs, staff training and development, program evaluation, reporting and corrective action, environmental planning and risk management, and the environmental protection program (EPA, 1996b).