Executive Summary

Report

Feedlot Dust
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Koch
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Pilgrims Pride
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Smith Farms
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Sustainable Livestock
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Antibiotic Resistance
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Vertical Integration
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Natural Meat
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Organic Meat
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Recommendations

Waste Generation

Each year livestock facilities create a staggering amount of animal waste which is stored in earthen lagoons, piled up in the open air, or sprayed over agricultural land. Due to the concentration of facilities and dense stocking of animals, the waste produced may exceed the surrounding environment's capacity to safely reintegrate the nutrients and waste products.

Texas ranks as the #1 state in the country for total animal waste production, creating twice as much manure as the # 2 ranked state (see Table 1). (18) Overall, the state's animal production facilities are creating an estimated 280 billion pounds of manure each year. (19) If improperly managed, this waste output threatens the integrity of the state's air and water resources and endangers the health and quality of life of Texas residents.

Texas ranks first in the nation for cattle production, with as many as 14.3 million head of cattle on site in Texas at a given time, (20) and cattle account for 88% of the state's total animal waste production. Each animal may produce up to 47.3 pounds of feces and urine per day. (21) Therefore, on a given day, Texas' 14.3 million head of cattle produce approximately 676 million pounds of fresh manure. This translates into an estimated 247 billion pounds of waste per year that must be handled by Texas cattle facilities.

Waste generation by the state's hogs and chickens adds to the disposal burden. Texas is home to approximately 755,000 hogs, (22) each of which produces approximately 11.3 pounds of manure per day. (23) In one year these animals generate an estimated 3.11 billion pounds of waste in Texas.

Finally, the Texas egg and broiler chicken industries-concentrated primarily in East Texas-further enhance the waste problem. Texas poultry facilities produced an average of 480 million broilers in 1998 as well as housed approximately 17.4 million laying hens. With each broiler and layer producing approximately 62 pounds and 95 pounds of fresh manure per year, respectively, (24) the Texas poultry industry generates almost 31.4 billion pounds of chicken waste each year. Most of these facilities use a dry waste system, which exempts them from permitting under Texas law. Therefore, East Texans may find their farmlands, air, and waterways at risk from the unregulated disposal of billions of pounds of poultry waste each year.

Air
Cattle in feedlots stand on piles of manure. In the hot, dry West Texas summer evenings, as the cattle rise and move in their pens, plumes of manure dust lift from under their hooves and travel miles in the wind. (25) Thousands of tons of manure dust fill the air in the Panhandle each year. One recent study estimated that Texas cattle feedyards with capacity over 1000 head produced 7,300 tons of inhalable small particulates (PM10 regulated under the National Ambient Air Quality Standards) in 1998, largely in the Panhandle. This is a low estimate because the study excluded all late afternoon and evening particulate test data. Using EPA standard assumptions, actual 1998 particulate emissions may have been four times this amount. Studies around individual feedlots have found particulate levels significantly above state and federal (US EPA) standards. (26)

Dust from CAFOs may affect the health of nearby residents. When Koch Beef proposed to expand its Hale Center, Texas feedlot to 80,000 head, a number of neighbors opposed the expansion because the existing feedlot dust already caused health problems. "We live about…one mile north of the office of the Hale Center feedlot," Elizabeth Jimenez told the Texas Natural Resource and Conservation Commission (TNRCC). "When my children and myself move here (sic) …the cattle were quite far away. And we still had a lot of trouble adjusting to the smell and our allergies…the watery burning eyes, the nose drainage and the burning of the throat…(T)here's the cloud that picks up, you can see it coming because of the size of the cloud and the thickness of the cloud." (27) Other residents note that the evening is the worst. "I live two miles north of the feedlot and at times in the afternoon the dust and the smell is so bad we have to leave the house for a while," said John L. Ray, also of Hale Center. (29) At another feedlot, members of a nearby family developed such serious sinus and respiratory problems that their young son was hospitalized for respiratory distress before the family was finally forced to move from its homestead of 100 years (see sidebar, next page).

People who live nearby or work in animal confinement buildings have reported health problems such as respiratory irritation, chest tightness, headaches, sore throat, diarrhea, and more related to the dust and gas, especially from swine operations. (30) These symptoms could affect residents as well as nearly 17,000 people who are occupationally exposed in animal confinement buildings in Texas. (31) And because the dust from feedlots and animal housing units contains biologically active organisms such as bacteria, mold, and fungi from the feces and feed, this dust poses a greater health hazard than does general "nuisance" dust. (32) For example, about 20 percent of swine confinement workers suffer from organic dust toxic syndrome (ODTS), "an acute influenza-like illness that follows four to six hours of intense exposure to agricultural dusts." (33) Acute ODTS may last from twelve hours to 3 days and is characterized by flu-like symptoms such as fatigue, muscle aches, headaches, fever, dizziness, and shortness of breath. (34)

In addition to dust, the odors from cattle, poultry and swine operations can be overwhelming. Animal manure odor is composed of, among other things, ammonia and sulfides (including hydrogen sulfide) (35) -and swine manure odor is a combination of at least 121 different compounds. (36) Swine odors emanate from barns, waste lagoons, dead animal disposal areas, and wastewater during field applications. (37)

Odors create health problems in both the animals and humans. For example, bacterial action in manure pits underneath confinement buildings releases ammonia, hydrogen sulfide, carbon dioxide, and methane, among other gases. Every year animal confinement workers report illnesses caused by exposure to these gases. (38) In swine production facilities air contaminants such as ammonia, carbon dioxide, dust, and microbes have been associated with animal disease, low productivity, and even death. Pneumonia, arthritis, and abscesses are not uncommon in swine raised in CAFOs and these diseases may be attributable in part to the presence of gas and dust contaminants in the air.39 Furthermore, airborne ammonia can be detected downwind of swine facilities and may lead to psychological and physical distress in nearby communities. (40)

Neighbors particularly notice the smell from barns. Pig barns and chicken houses have a large fan at one end which draws out the ammonia and sulfide soaked air. The heavy odor spreads on the wind. "When they put the fans on the pigs [in the barns], there's nothing like it," said Elmer Schoenhals of Perryton, Texas. (41)

"Chicken houses have fans, the same as swine. Fans blowing out," said Dr. John Sweeten of Texas A&M, the state's leading expert on animal feedlot odor. "One thing you can do is erect a barrier, even plant some trees. But better, you set up a wet or dry scrubber. It can be water, or chemical, or packed beds. Like you have for a rendering plant. If you are located on a big tract of land with neighbors a long way off, there's no problem." (42)

However, operators do not always voluntarily agree to use the best available technology-like aerobic rather than anaerobic lagoons, composting, or lagoon covers-to reduce the smell and ammonia emissions. (43)

"In many ways, the industry has designed facilities to meet minimum regulatory standards. They have not adopted the best technology appropriate for a given site," said Sweeten. On the other hand, Sweeten argues that improved regulations drive consolidation and force out smaller operators. "The ones who are in jeopardy are the family farmers. If you have one set of standards that apply to a 1000 head feedlot and a 100,000 head feedlot, it's not realistic." (44)

Some neighbors finally sell out, often to the animal operation itself, rather than live in the constant smell. "This is our place, right here," said Bill Pletcher of Perryton, standing in front of his abandoned homestead. "My daughter sold it to Texas Farms...I was raised in this place. All we sold was the house. I'm still out here every day. Some days [the smell] is worse than others." Mildred Pletcher added, "They just got started. Wait 'til it's been out here a few years." (45)

The Amarillo regional office of the TNRCC conducted ambient air monitoring near hog farms, feedlots, and slaughterhouses in 1998 and 1999. Sampling teams measured hydrogen sulfide and ammonia emissions downwind from the facilities. One ammonia sample was collected downwind from a Texas Farm, Inc. swine operation at the border between the hog farm and the neighboring property. The investigators found that the ammonia concentration in the air was almost nine times higher than TNRCC's "health-based effects screening level" or ESL. Sampling teams also measured ammonia concentrations over ESL guidelines downwind of a cattle feedlot and a broiler farm. (46)

The agency uses an ESL as a benchmark for possible health effects rather than as a strictly enforced standard. In the case of Texas Farms, the TNRCC concluded that "(e)xposure to the measured ammonia concentration may cause respiratory irritation...in sensitive individuals." (47)

For hydrogen sulfide, state law does limit emissions, and existing tests did not find H2S levels in excess of the legal limit at CAFOs. (48) TNRCC also assesses hydrogen sulfide based on a lower "odor threshold" range-a level which does not exceed the state emission standard but at which "the majority of exposed individuals can discern an odor." (49) TNRCC personnel reported offensive odors downwind from anaerobic lagoons ranging from the rotten egg odors characteristic of H2S to "strong fecal odor" and "strong dead animal odor." (50) The investigators found that another Texas Farms facility and a Dean Paul Farms swine facility both exceeded the odor threshold range for hydrogen sulfide. The survey team found that the strength of septic odors from the waste lagoons correlated with increased hydrogen sulfide levels. The investigators also noted in their report that "the CAFOs may not have been operating at maximum permitted capacity during the collection of these monitoring data," thus implying that the odor effects might have been even stronger if the facilities were stocked to capacity. (51)

In August 1999, investigators found strong hydrogen sulfide emissions downwind of rendering plants and slaughterhouses owned by IBP, Inc., Excel Corp., and Caviness Packing Co. that significantly exceeded the state's emission standard. (52) Ammonia emissions were also high downwind of feedlots. Ammonia emissions at Stratford Feedyard, Circle C Cattle (cattle CAFOs), Top of Texas, (a relatively small-2500 head- swine CAFO), as well as IBP, Excel, Caviness, and Hereford Bi-Products, all exceeded the health-based ESL. (53) Despite these findings, TNRCC has no mechanism in place to penalize the offending facilities because the health-based ESL is merely a benchmark for monitoring possible health impacts.

Slaughtering/rendering facilities are subject to compliance with the state hydrogen sulfide emission standard, however TNRCC does not regularly monitor CAFOs for emissions. While some rendering plants have been cited for exceedances, no CAFO has ever been subject to an enforcement action for violating the state emission standard for hydrogen sulfide. (54)

NOTES:

18 Environmental Defense, "Environmental Defense Scorecard" (2000). Internet source: http://www.scorecard.org/env-releases/aw/rank-states.tcl?drop_down_name= Total+animal+waste.

19 Based on most recent (1998-1999) animal inventory data from the Texas Agricultural Statistics Service and manure production estimates in 2000 North Carolina Agricultural Chemicals Manual. To obtain the total pounds produced, the total number of animals in Texas in each livestock category was multiplied by the amount of manure produced by each class of livestock and summed over all classes of animals (see text for figures used). The total presented in Table 1 is slightly lower than the text calculation because Environmental Defense used older (1997) animal inventory data in its calculations.

20 Texas Agricultural Statistics Service, "Texas Cattle and Calves: Inventory, Calf Crop and Disposition, 1994-99," in: 1998 Texas Agricultural Statistics, p. 32 (Compiled by Texas Agricultural Statistics Service).

21 Barker, J.C., S. C. Hodges, and C.R. Campbell, "Livestock Manure Production Rates and Nutrient Content," in: 2000 North Carolina Agricultural Chemicals Manual, Chapter 10 (North Carolina State University, 2000), p. 1. (Based on output by an average weight-800 pound-beef animal.)

22 Texas Agricultural Statistics Service, "Hogs and Pigs: Inventory of All Hogs Breeding and Market, December 1, 1998-99." Internet source: http://www.io.com/~tass/thoginv.htm. (Average of January 1998 and January 1999 inventories.)

23 Barker, J.C., Hodges, S.C., and Campbell, C.R. 2000. "Livestock Manure Production Rates and Nutrient Content," in: 2000 North Carolina Agricultural Chemicals Manual, Chapter 10, North Carolina State University, p. 1.

24 Barker, J.C., Hodges, S.C., and Campbell, C.R. 2000. "Livestock Manure Production Rates and Nutrient Content," in: 2000 North Carolina Agricultural Chemicals Manual, Chapter 10, North Carolina State University, p. 1.

25 Letter to Gerald Hudson, Regional Director, Texas Air Control Board from David L. Bergin (July 14, 1991); Citizen petition to TNRCC (March 6, 1997), re: Expansion of Koch Beef Company; TNRCC Complaint Investigation Report, Complaint No. 029000020 (February 7, 1990); TNRCC, Complaint Investigation Report, Complaint No. 029100031 (March 11, 1991); TNRCC, Complaint Investigation Report, Complaint No. 029100036 (March 19, 1991).

26 Parnell, Charles, Bryan Shaw and Brent Auvermann, Agricultural Air Quality Fine Particle Project, Task 1 Final Report, December, 1999. Phone conversation with Brent Auvermann, May 4, 2000 confirming that estimate is low due to exclusion of evening data. Sweeten, John M., Calvin B. Parnell, Robert S. Etheredge, and Dana Osborne, "Dust Emissions in Cattle Feedlots," Veterinary Clinics of North America: Food Animal Practice, Vol.4, No. 3 (November 1988), pp. 558, 577.

27 Letter to TRNCC from Elizabeth Jimenez, May 28, 1997, re: Koch Beef.

29 Letter to TNRCC from John L. Ray, May 27, 1997, re: Koch Beef expansion.

30 Wing, Steve and Susanne Wolf, "Intensive Livestock Operations, Health and Quality of Life Among Eastern North Carolina Residents," Environmental Health Perspectives, Vol. 108, No. 3 (March 2000), p. 233; Donham, Kelley J., "Potential Health Hazards to Agricultural Workers in Swine Confinement Buildings," Journal of Occupational Medicine, Vol. 19 (1977), pp. 385-386; Donham, Kelley J. and Kim E. Gustafson, "Human Occupational Hazards from Swine Confinement," Annals of the American Conference of Governmental Industrial Hygienists, Vol. 2 (1982), p. 139.

31 Texas Workforce Commission, "Covered Employment and Wages by Industry: 1994-1999, 1st Quarter Selected Texas Private Animal Agriculture," (Compiled by Texas Workforce Commission, Labor Market Information Department, March 1, 2000).

32 Donham, Kelley J., "Association of Environmental Air Contaminants with Disease and Productivity in Swine," American Journal of Veterinary Research, Vol. 52, No. 10 (1991), p. 1723.

33 Donham, Kelley J., "The Impact of Industrial Swine Production on Human Health," in: Pigs, Profits, and Rural Communities, ed. Kendall M. Thu and E. Paul Durrenberger (State University of New York Press: New York, 1998), p. 80.

34 Ibid., Donham, Kelly J. (1998), p. 80.

35 Sweeten, J.M., "Odor Control from Poultry Manure Composting Plant Using a Soil Filter," American Society of Agricultural Engineers, Vol. 7, No. 4 (July 1991), p. 439.

36 Sweeten, John M., "Odor Abatement: Progress and Concerns," National Poultry Waste Management Symposium (Harrisburg, Pennsylvania, October 21-23, 1996).

37 Miner, Ronald, "A Review of the Literature on the Nature and Control of Odors from Pork Production Facilities," Paper for the Odor Subcommittee of the Environmental Committee of the National Pork Producers Council (September 1, 1995), p. 4.

38 Donham, Kelley J., et al. "Acute Toxic Exposure to Gases from Liquid Manure," Journal of Occupational Medicine, Vol. 24, No. 2 (February 1982), p. 142; Lorimor, Jeff, Charles V. Schwab, and Laura Miller, "Manure Storage Poses Invisible Risks," ISU Extension Publication # Pm-1518k (February 1994); Chapin, Amy, Charlotte Boulind, and Amanda Moore, Controlling Odor and Gaseous Emission Problems from Industrial Swine Facilities: A Handbook for All Interested Parties (Yale Environmental Protection Clinic, Spring 1998), Section 2.3.1.

39 Donham, Kelley J., "Association of environmental air contaminants with disease and productivity in swine," American Journal of Veterinary Research, Vol. 52, No. 10 (October 1991), p. 1727.

40 Reynolds, Stephen J., et al, "Air quality assessments in the vicinity of swine production facilities," Journal of Agromedicine, Vol. 4, No. 1/2 (1997), pp. 41-42.

41 Interview with Elmer Schoenhals, Perryton, Texas, August 18, 1998.

42 Interview with John M. Sweeten, Amarillo, Texas, August 19, 1998.

43 Ledbetter, Kay, "Swine raisers employ numerous odor eaters, with varying degrees of success," Amarillo Globe-News, May 28, 1998. Internet source: http://www.amarillonet.com.

44 Interview with John M. Sweeten, Amarillo, Texas, August 19, 1998.

45 Interview with Bill and Mildred Pletcher, Perryton, Texas, August 18, 1999.

46 TNRCC Interoffice Memorandum from Laurel Carlisle, Toxicology & Risk Assessment Section, Chief Engineer's Office to Brad Jones, Director, TNRCC Region 1, Amarillo, re: "Toxicological Evaluation of Air Monitoring Results, Hydrogen Sulfide and Ammonia, Concentrated Feeding Operations, Ochiltree County, August 13-18, 1998," November 19, 1998, p. 1; TNRCC Interoffice Memorandum from Janet Pichette, Toxicology & Risk Assessment Section, to Brad Jones, Director, TNRCC Region 1, Amarillo, re: "Toxicological Evaluation of Mobile Air Monitoring Results, Hydrogen Sulfide and Ammonia, Amarillo and Lubbock Regions, August 9-17, 1999," December 2, 1999, p. 2; TNRCC Interoffice Memorandum to JoAnn Wiersema, Toxicology and Risk Assessment Section, from David Carmichael, Laboratory and Mobile Monitoring Section, Re: Correction to Reported Ammonia Sampling Results, February 1, 2000. TNRCC Interoffice Memorandum to Zoe Rascoe, Director TNRCC Region 9, from Vincent Leopold, "Toxicological Evaluation of Results of Air Monitoring...Sanderson Farms, Leon County, September 15,-16, 1999," November 16, 1999, p. 3.

47 TNRCC Interoffice Memorandum from Laurel Carlisle, Toxicology & Risk Assessment Section, Chief Engineer's Office to Brad Jones, Director, TNRCC Region 1, Amarillo, re: "Toxicological Evaluation of Air Monitoring Results, Hydrogen Sulfide and Ammonia, Concentrated Feeding Operations, Ochiltree County, August 13-18, 1998," November 19, 1998, p. 1.

48 30 T.A.C. §112.31 (effective January 1, 1976). The law states that hydrogen sulfide emissions may not exceed 0.08 parts per million averaged over any 30-minute period near property used for residential, business, or commercial purposes. For other property, the standard is slightly higher at 0.12 parts per million (30 TAC §112.32).

49 TNRCC Interoffice Memorandum from Laurel Carlisle, Toxicology & Risk Assessment Section, Chief Engineer's Office to Brad Jones, Director, TNRCC Region 1, Amarillo, re: "Toxicological Evaluation of Air Monitoring Results, Hydrogen Sulfide and Ammonia, Concentrated Feeding Operations, Ochiltree County, August 13-18, 1998," November 19, 1998, p. 1.

50 TNRCC Memo to JoAnn Wiersema, Toxicology and Risk Assessment Section, from David Carmichael & Edward Ragsdale, Laboratory and Mobile Monitoring Section, Re: Hydrogen Sulfide sampling, August 13-18, 1998, dated October 14, 1998.

51 TNRCC Interoffice Memorandum from Laurel Carlisle, Toxicology & Risk Assessment Section, Chief Engineer's Office to Brad Jones, Director, TNRCC Region 1, Amarillo, re: "Toxicological Evaluation of Air Monitoring Results, Hydrogen Sulfide and Ammonia, Concentrated Feeding Operations, Ochiltree County, August 13-18, 1998," November 19, 1998, p. 2.

52 TNRCC Interoffice Memorandum to Brad Jones, Director, Region 1, Amarillo, and Jim Estes, Director, Region 2, Lubbock, from Janet Pichette, Toxicology and Risk Section, Re: "Toxicological Evaluation of Mobile Air Monitoring Results, Hydrogen Sulfide and Ammonia Sampling and Analysis Project, Amarillo and Lubbuck Regions, August 9-17, 1999," December 2, 1999.

53 Ibid.

54 Phone conversation with David Henrichs, TNRCC, Air Enforcement Division Team Leader, March 29, 2000.