Implementing. Once the overall environmental policy (Code) and objectives are in place, the egg producer should then systematically implement needed critical management programs and related Best Management Practices (BMPs) and carry out planned tasks/activities to make the plan work. The producer should also ensure that responsibilities for implementing the EMS are clearly defined and that employees are provided with the necessary training to ensure that can carry out these responsibilities. As part of the XL project, UEP and the other stakeholders have identified a series of critical management programs that need to be addressed by each facility. These critical management programs include such things as odor control, fly and rodent control, dead bird proposal, etc. A list of these programs is included as Appendix B. Facilities should also ensure that they are using the appropriate Best Management Practices (BMPs) to ensure the effectiveness of each critical management program. These BMPs could be based on the Model General Permit for this XL Project, state permits, or separate BMP Guidance developed by UEP. Checking As the EMS is implemented, the facility needs to monitor and periodically audit the EMS to ensure that critical management programs and BMPs are properly implemented, and ensure that the facility is meeting or making acceptable progress toward meeting its objectives and targets, including compliance with regulatory requirements. Egg producers should keep records to document how critical management programs and BMPs were being implemented, changes to any of these programs, and completion of planned tasks and activities necessary to implement the EMS. The facility should also carry out periodic internal audits to ensure that compliance with regulatory requirements was being maintained and performance of the EMS based on objectives and targets is satisfactory. Internal auditing could be done with facility personnel or with the assistance of outside groups. Each year the facility should compare the status and results of the EMS to the objectives desired, take necessary steps, as necessary, to enhance its effectiveness, and communicate with external parties about the performance of the EMS and their ideas on possible improvements This review function should be lead by facility management and should make use of all available information from things like internal audits, critical management program and BMP implementation, changes to regulatory requirements, and any issues raised by external stakeholders since the last review. As a result of the review, the facility should make information available on the performance of the EMS against objectives and targets, any changes to the EMS agreed to, and steps the facility will take to address any significant issues identified by external stakeholders.
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