Confined Feeding Operations

Inspection Programs

Environmental Risk Screening Tool

The environmental risk screening tool (ERST) was developed in 2009 to provide a consistent, science-based way of determining whether a manure storage facility at a CFO could cause a risk to groundwater or surface water. NRCB staff worked with experts in Environment and Parks, Agriculture and Forestry, and the agricultural industry to design and test the tool. The ERST was initially used for the NRCB’s leak detection program, which focused on groundwater, and was then applied to the risk based compliance program for both groundwater and surface water. Approval officers now use the tool for all AOPA permit applications. NRCB inspectors use the tool to help respond to complaints and other compliance issues.


The tool records information about the soil characteristics and depth to aquifers, and the construction of existing and proposed facilities and water wells. This information is scored to determine whether the facility poses a low, moderate, or high risk to groundwater and surface water.


Based on the results of the risk screening (low, moderate, or high), the NRCB can determine whether risks to groundwater or surface water are being appropriately managed. In many cases, minor operational changes or enhancements to operating requirements may be the appropriate response. If a risk to the environment is identified, the inspector works with the operator to ensure that appropriate corrective action is taken.    

Risk Based Compliance Program

The risk based compliance program was introduced in 2010 and completed in 2016-17. The program was a one-time project to identify confined feeding operations that could pose a risk to groundwater. (Any surface water issues that required attention were also identified.) The environmental risk screening tool was used to identify potential risks or confirm their absence. In some cases, appropriate monitoring or modifications to a site were required, and existing monitoring requirements were adjusted as necessary.

Confined feeding operations were identified for the program if they met all three of the following criteria: 1) the facility was constructed before 2002 (before AOPA came into effect); 2) the facility was an earthen liquid manure storage; and 3) the facility was located in a region identified as having an aquifer with a high potential of vulnerability.

From the start of the program to its end, 170 CFOs with a total of 213 facilities between them were evaluated. Of those, 176 were identified as low risk to groundwater, 29 as moderate risk to groundwater, and eight as high risk to groundwater. Any surface water risks that were identified during the inspections were addressed.

Follow up includes an annual inspection and review of the risk scoring of all high-risk sites. Inspectors each review two moderate risk sites per year. Each low risk will be reviewed every four years.

Risk Based Compliance Program 2010-17

CFOs screened since 
start of program
 Facilities* ranked low
 risk to groundwater
Facilities ranked moderate
 risk to groundwater
Facilities ranked high
risk to groundwater 
170 176 29 8

* A confined feeding operation often has more than one facility.

Surface Water Data Collection Program

The surface water inspection program began in 2013. Inspectors collect information about surface water quality every time they conduct a site inspection of a CFO. An annual report compiles the number of sites and inspections, the issues identified, and livestock types. The information is used to inform the NRCB’s compliance policy and how it prioritizes its resources to respond to severe weather events. 

Water Well Exemption Screening Tool

To protect groundwater, AOPA requires manure storage facilities to be a minimum of 100 metres from a water well. Some sites, however, have geologic, topographical, or other characteristics that may prevent contamination of a well that is closer than 100 metres. The water well exemption screening tool provides approval officers with a consistent means of assessing the risk to a water well. If the assessment demonstrates that the water well won’t be affected by the manure storage facility, the approval officer may consider exempting the 100 metre distance requirement. The reasons for the exemption must be clearly explained in the decision summary issued with the permit. 

Leak Detection Program    

The leak detection program was a one-time project from 2008 to 2011 to evaluate the risk to groundwater at operations that were required by their permits to conduct regular groundwater monitoring. The project ensured that appropriate monitoring was in place to reflect the actual risk at each site, as measured by an environmental risk screening. Follow up with operators was undertaken where issues were identified. The majority of operations were found to pose a low risk to groundwater.

The environmental risk screening tool developed for the program is now used for the risk based compliance program and to evaluate applications for new or expanding operations.

The program was recognized in August 2011 with a Gold Premier’s Award of Excellence and in September 2011 with an Excellence Canada Award of Merit.

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