Alternative Approach to On-Site Status Reviews

Posted: February 5, 2025

Due to the current heightened concern with Highly Pathogenic Avian Influenza (HPAI) the State Conservation Commission (SCC) has developed the following guidance for performing Act 38 Nutrient Management On-Site Status Reviews, as an alternative, without going on the actual farm where the animals are housed. This alternative approach is only for use during periods of heightened biosecurity concern identified by The Pennsylvania Department of Agriculture (PDA). The SCC, in consultation with PDA’s Bureau of Animal Health will determine the biosecurity risk and the timeframe this alternative approach may be offered.

Alternative Approach to On-Site Status Reviews
Performing Nutrient Management On-Site Status Reviews Without On-Site Farm Visit

Issued January 27, 2025

Conservation Districts (CDs) shall limit this alternative approach to only those operations that qualify according to the specific PDA identified biosecurity risk, and the guidelines listed below. If after applying the below guidelines, CDs still have questions concerning who qualifies, or procedures to take, they should contact their SCC regional coordinator.

Guidelines for Using the Alternative Approach Status Review:

  1. Identified potential biosecurity risk of concern at this time:
  2. Highly Pathogenic Avian Influenza (HPAI) for all poultry operations and increased risk to dairy operations.
  3. This Alternative Approach will be in effect until:__Further Notice_____________________
  4. The Alternate Approach is only being offered for poultry operations that have poultry listed in their Act-38 nutrient management plan (NMP) as a separate animal group (i.e. greater than 5 AEUs). This alternative approach does not include poultry in small animal groups.
  5. Use of the Alternative Status Review is determined on a case-by-case basis between the CD and operator.
  6. A face-to-face meeting between the operator and CD shall be required to review the operator's records and answer the appropriate questions listed in the status review form. The face-to-face meeting may take place off-site at a variety of locations, including the CD office, a local restaurant, township building, or on property owned by the operator other than where the animals are housed. CDs need to be mindful of the operator’s added challenges to meet off site and try to accommodate a suitable and appropriate meeting location.
  7. The current On-Site Status Review form will be used for the alternative approach. Questions requiring the on-site inspection will be noted as "alternative status review performed," and include operators responses (if applicable).
  8. In cases where an operation's approved NMP calls for Best Management Practices (BMPs) to be implemented (as listed in the plan's BMP Implementation Summary) or cases where the operation has implemented additional BMPs since the CD's last on-site inspection (annual status review or post construction of the BMP) these farms do not qualify for the Alternative Approach. In these cases an on-site farm visit will be required to verify installation of practice, as well as, operation and maintenance of practices.
  9. Where applicable, drive-by inspections of BMPs on a public road may be utilized.
  10. CDs are not required to perform an Alternative Approach Status Review with all qualifying farms, but it is strongly encouraged that they do offer this approach to eligible operations.
  11. If the CD suspects a pollution situation or a violation of Act 38, an on-site visit is required.

Biosecurity for all on-site visits:

  1. Maintain recommended time interval between visits to operations of the same species. Current recommendations are (48 to 72) hours between visits of the same species.
    1. Any visit to a non-qualifying species (i.e.: swine) that includes a small animal group on an operation is considered a visit to a farm with the qualifying species, whether or not the animals are included in the NMP as an animal group. For example, any visit to a swine farm that includes even a few poultry (a small animal group of less than 5 AEUs) needs to be considered a visit to a poultry farm.
    2. With the increased risk of dairy operations contracting HPAI, visits to dairy operations would be considered a qualifying species if followed by a visit to a poultry operation. The recommended downtime of 48-72 hours should be followed.
  2. Call ahead to confirm with owner/operator all farm specific biosecurity procedures. CD staff should not show up to operation without prior notice to the owner/operator.
  3. Use disinfectant, footbath, boots and clean clothes.
  4. Do not go inside any animal housing facilities.
  5. Avoid walking or driving through any manure or fan exhaust.
  6. CD Staff with poultry on their own farm, or who live or work on farms that keep these animals, are highly discouraged from visiting animal operations with the same species. If that CD does not have enough NM certified staff to make this possible, they should contact their SCC regional coordinator to discuss options or further precautions.