AAMP Statement on EPA Questionnaire
We share our members' concern that the questionnaire asks for sensitive financial data that could potentially be released to the public or used to levy additional taxes or fees upon the industry.The American Association of Meat Processors (AAMP) has been in contact with many of its processor members about a questionnaire sent out by the Environmental Protection Agency (EPA). While we respect the right of the federal government and its agencies to gather information about the meat industry, we share our members' concern that the questionnaire asks for sensitive financial data that could potentially be released to the public or used to levy additional taxes or fees upon the industry.
The “Meat and Poultry Products Questionnaires” issued by EPA is, according to the agency, part of its efforts to renew and revise, as appropriate, effluent limitations guidelines and standards for the meat and poultry products industry. It asks for information about wastewater generation and treatment information, pollution prevention practices, and environmental assessment information. It also asks for a detailed annual income statement and annual revenue for 2017, 2019 and 2021.
AAMP made an inquiry about the reason for the financial information, and the response received was, “EPA requires industry financial data to determine if effluent guidelines based on BAT [Best Available Technology Economically Achievable] will be economically achievable for the industry.” The Association is concerned that the financial data will be used to see how much processors can be taxed regarding future rules on water usage, wastewater discharge, and emissions.
“The federal government has stressed the importance of diversifying the meat supply chain, and it has offered numerous grants to help small processors expand their operations or buy needed pieces of equipment. These efforts have been appreciated by the small processor community, and many of our members have been able to expand and modernize years ahead of schedule,” said Chris Young, AAMP Executive Director. “However, using this questionnaire to determine how much in additional taxes or fees processors can afford to pay would be contrary to those supply chain diversification efforts. It is our hope that the EPA will not use this information to determine just how much our small processor community can bend but not break.”
Many of the questions have an option to mark the supplied information as “CBI,” or Confidential Business Information. AAMP is urging its members to check the CBI box at every possible opportunity. This action should help protect much of the supplied information from being released to the public. AAMP also recommends that processors pay close attention to the date that they received the questionnaire. The deadline to submit the form is 60 days after receiving the notification letter from EPA, and failure to submit or late submissions may result in fines or other penalties. Please take all the time you need to fill out the questionnaire, but do not miss the deadline.
Additionally, AAMP recommends that its processor members contact their state and federal representatives to express their concerns about how this data may be used in the future. AAMP already is in contact with members of Congress. For further information and recommendations, visit www.aamp.com or follow AAMP on Facebook or Twitter.
Jeannine Schweihofer, Ph.D., of Michigan State University Extension, has put together a few bullet points about the questionnaire. Thank you to consultant Robert Culler and the Indiana Meat Packers & Processors Association for getting us this information:?
- This survey is for meat and poultry processors but also renderers. Do not get confused when answering questions that are meant for renderers.
- You can work on the survey online and save and continue. When you go back to the survey, the information you previously entered should still be there. This does not have to be completed at one time.
- For USDA-inspected plants, quarterly pounds data that is submitted to the PBIS system may be of help to you.
- A GIS map with property boundary is needed as an attachment for the survey. Options such as https://beacon.schneidercorp.com/ allow you to create one for your location, save a screenshot and create a PDF.
- The survey requests a flow diagram of all waste streams, including pens.
- It appears this is for slaughter plants or those making greater than 6,000 pounds of finished product daily. If you receive it and are not in these categories, you can select that at the beginning of the survey and then submit it.