Preparing for a Manure Application Equipment Inspection
February 19, 2021
- There we go. I'm gonna talk a little bit about the application equipment, loading equipment and also traveling on the road. One of the significant issues that we need to understand is really what the definition of a spill is. And that's one of the significant problems that we have out there, where you look at this inspection process. What we're looking at doing is to reduce or eliminate the potential for a manure spill. So when you look at the spill, in its broadest form, it is any unintended release of manure, or for that matter, any other chemical product or actually farm product. All of these could be considered a spill. Generally, we look at leaking equipment. That's where we get the neighbor riding behind you and seeing your equipment leaking. Overfilling, and I'll explain a little bit of that in terms of your fill location, and application equipment residue. Residue coming off of your vehicle is considered a spill and can be considered a blocking of the roadway as well. And ultimately, it can and does include a misapplication. So we'll take a look at each one of these in a little bit broader sense. Now, as you heard, the spill plan is part of what we're looking at. I'm not gonna go into the details in an inspection of that spill plan directly. What I'm gonna look at in terms of equipment is do you have what you would need for the types of activities that you're looking at? That could be anything from shovels to end loaders, from hose raps to system shut-off systems. Those are the types of things that we would take a look at to make sure that they are really able to deal with the type of application structures that you actually have. Equipment maintenance is probably one of the areas that you'll get the most questions on. We would like to start some of the folks that are involved with the maintenance activities. They may or may not be there, but we'll also take a look at the overall equipment to determine whether or not it may pose a potential risk structure. In many cases, we're asked, "Well, you know, this equipment fails. We build something that's better, works better." We're not there to say you have to have store-bought equipment on each one of the pieces of equipment. Again, what we look for is the potential risk that is there. So your farm fixes, in many cases, will do almost a better job than some of the situations that you see from the manufacturer. And we may also discuss some of the pertinent regulatory structures that would apply to either that particular piece of equipment or the operation of that piece of equipment and ultimately, there's calibration. So we have equipment involved in calibration as well. So we likely would take a little bit of a look. Now, we have all kinds of different equipment that is used in terms of manure application structures. Here, we have essentially, a commercial vehicle that is used as an application piece of equipment. This structure is one of the areas that we would recommend for you to expand your process to be able to put together, for example, a checklist, and what your individual pieces of equipment might look like. So when we have a commercial motor vehicle, we potentially have annual inspections, scale inspections and even trip inspections. So this gives you kind of an opportunity of what I would do when I would go around and look at not only your commercial equipment, but also your farm implements. We are gonna take a look very similarly to what you would do in a DOT checklist type of structure to make sure that the equipment typically is in reasonably good shape and repair. When I mentioned commercial motor vehicles, we have two structures that we need to talk about. First, we have the farm structure. In many cases, farm vehicles are not required to go through the full annual inspection or even the trip inspection. However, and this is very critical in terms of minimizing risk. The farms need to be aware that their equipment that meets the definition of commercial motor vehicle must be in compliance with Part 396 at all times. What this means is that even that taillight that's out, puts you in non-compliance in terms of what you're looking at at a traffic stop. And in many cases where we have traffic stops, the operation may not get a penalty for the actual spill. In other words, there's material on the road and that's why the call was there, but you can get a significant amount of tickets in terms of not having equipment that meets the requirements of Part 396. So we'll use that as a base where we have the commercial vehicles. Now, on the custom hauler side, these are operations that do not have farming operations in and of themselves. And they're operating as a commercial hauler. In that situation, they will have an annual inspection and the driver post-trip inspections. And these post-trip inspections are required to be maintained for at least three months. Those are the types of things that can assist in minimizing risk in terms of your overall operation, particularly, if you wind up getting stopped, or if you do have an incident that requires place in this case, more carrier activities, and they do happen. In many cases, we are applying where conditions are not as good as they could be. And as I've talked in the regular transportation training programs, it always happens with a school bus with elementary kids at a stream bed. And it overturns inaccurate, which has protected endangered species. Unfortunately, sometimes that's the case where we have minority challenges. So in this case, of course, they had 4,500 gallons that went over into the banks of this particular creek. These are the types of situations that we really wanna minimize in terms of spill within the program. These are very visible out there, and they really begin to cause a problem in terms of what we do in our industry. So if you were using this type of situation, would this be incorporated within your spill and an emergency response plan? What did you say that you would do in case of a situation that you would have? And when you took a look at your equipment, is that equipment structured to minimize in this situation, the amount of material that might be spilled? In many cases, we use open tap. In many cases, we see the tank covers wide-open, driving down the road. So did we have a training process? Do we have properly-seated covers that would minimize the leakage in the situation of an overturn? So when we look at that commercial motor vehicle inspection, it's really kinda grouped into these areas. And this is what I would intend on using, when we look at your farm equipment, which we'll cover in a moment. I'm gonna take a look at the frame and the running gear. What I'm looking for is any cracking, and that is stress cracking or full cracking, taking a look at hubs, bearings, et cetera, that would be engaged with it. Any pivot points to determine whether there's any significant wear there. And then also, on the tanks themselves, any bending, crumbling of the surface leads to a potential risk point. And then, of course, any cracks in any of the welds that are actually associated with the tank. I'll take a look at air, hydraulic, and electrical lines as well. Recognize, I'm not gonna go in there and do a pressure check on these systems, I'm not gonna do an electrical check, but I'm gonna check the general condition of those different systems that are in there. We use an awful lot of hydraulics, and as we all know, sometimes they don't seal as well as they could be. But what I look at is where we have risk points, where we have hoses lines that are crimped, where they're under a stress. Those are the types of areas that we could have a catastrophic failure leading to a significant spill. Control systems also are used. We go from very minimal mechanical systems through very complicated electrical systems and computer systems. So I'll take a look at whether or not we have electrical supply capabilities, whether those lines are in good repair and whether they're protected. Steering gear probably, is the area where a motor carrier indicates. We have the greatest number of overturns and incidents with manure haulers across the Midwest. So I will take a brief look, if you do have a commercial vehicle that will take a look for example, at the steering box, make sure that you have reasonably good and sound ball joints, et cetera, within your steering structure. Brakes, no, I'm not gonna go out and say, "We're going to do the roll test." But what I'm gonna look at, are your stack adjusters in good shape? Do you have a plan in which you have inspected the brakes on a regular basis? And of course, are there any brakes that are actually disconnected, which I can assure you I've found in many cases and some of the older farm equipment. And then on the trailer, recognize, in the photo that I showed, we have application equipment. So we do have a maximum length of a commercial vehicle, even though it applies, of 50 feet. So I will point that out, because that can become a fairly significant problem. It means that you need a wide load permit, and you'll be put on different roads, many cases than what you wanna do. Calibration, am I gonna come out with a whole bunch of barrels? No, but I am gonna ask how you do the calibration, just to make sure that there's someone there that has gone through the process of determining which calculation method. And I may ask, do you have any information as to how to do that? And so here, if you take a look at the MSUE publication 2825, I might ask the folks that are involved with the calibration, "Are you aware of this? Do you have a copy of it on hand?" Just to give me an idea of whether or not that the people that are doing this have in fact, looked at the types of equipment to make sure that they are doing it. So moving into loading, one of the challenges that we have is that many cases, this is very large equipment, and we're operating in slick, muddy surfaces. So is there some type of protection around the loading devices? These are the types of things. And in many cases, you say, "Well, it's closer. It's on our containment area." Well, that's part of the questioning that I will take a look at. So we're also looking at some of the process that's there. It's pretty easy to see operations that have a fair amount of spillage. And in other words, less fill out all the way up until it overflows, and we know we're full. That can be a potential spill that you're looking at. So the other area is the worker's safety. We do have a lot of pits, we do have a lot of areas in which we have the employees' safety issues that we wanna pay attention to. And in many significant spills around the country, it is where a person has become injured or disabled and unable to respond to flowing manure. So we are going to take a look too at whether or not you have reasonable protections for your worker. And that could be fairly broad. And so in this situation, clearly, we're attaching and detaching the hose in many cases, and we have a missing PTO shaft shield. Now, the shaft shield doesn't directly causes (indistinct), but if we didn't have the hydraulic hoses held with the chain there, we could have significant problems that will lead to a spill. Also, we'll take a look at the connection system here. You'll notice that the hose has a significant kink in there, likely to fail in a relatively short period of time. Those are the types of questions that we will ask. What is your replacement repair structure for this type of equipment? Now, let's say we do have a leak there coming out of the hose. So now, is that within our containment structure? So is that in the membrane or clay liner? If it is outside, it potentially can also be deemed to be a spill, because it would have the potential access directly into the water table. So these are some of the areas that we've take a look around the mixed load areas. Now, in many cases, you folks have put together a variety of different type of pad and protection structures that are out there. And that too is something we would look at. You notice on the tripod there, for the elevator support, there is marking on there. And I ask why? Well, we've run into that two or three times. So if you look at the potential damage and the problem that it could cause, these are situations too that we would take a look at. And again, here, you also have your power supply right there as well. So do pay attention in terms of setting up to minimize the risk of having an unintended release. Take a look at where you're loading as well. We do wanna pay attention again, to the employee safety. And in many cases, situations like this is where we wind up having a problem. And this is just normal use. And we wind up leading to the holes where we get a significant amount of water. And that turns into mud, and then when we put the equipment through areas like that, we wind up tracking it on the road. And from the standpoint of that passerby, they're saying you're dropping manure on the road. So if there's any way to minimize the amount of attraction to your tire and equipment in your loading process, that benefits you and the community, and minimizes the risk for complaints. So moving into transportation equipment. One of the first things that I would recommend on the Farm Bureau website, Michigan State Police website, is the "Farmer's Transportation Guidebook". I'm gonna mention a few of the key things when we're operating equipment on the road and some of the equipment issues, but I'm not gonna go through all of the requirements for operating implements on the road as we go through. But this is very important as well to minimize the risk that is out there. Having a vehicle contact, having a rear-end collisions, operating at a slower speed than those around you, all can lead to contact with other vehicles leading to a manure spill. So when we take a look, and I'm not gonna walk all the way around in this photo, but just quickly pointing out, and I think you can see my cursor. So we have essentially similar pieces of equipment. We do have the light cord here. The cord is back here, but it has been cut off. So one of the issues that you need to be aware of, if the units were manufactured after 2002, in some, 2004, that if it has a light package, that light package is required to work at all times. So it needs to be connected to a vehicle that is capable of operating that light package. We also take a look at some of the seals. And so we do have the openings there. We will take a look at a little bit of the seals, making sure that we don't have significant damage, dents that would lead to seepage or leakage out there. And yes, when you take a look, duct tape is used in an awful lot of places. Sometimes it works very good. Sometimes we really need something else. I'm beginning to see a fair amount of the flashing tape out there, it's relatively cheap, but there are commercial-grade raps out there, that give you not only leak protection, but also can give you some pressure protection as well. And those are the types of areas that I would ask for. If in fact, you do have a small leak, what's your practice? What's the process in which you would minimize the leakage as you would go forth? And hopefully, you'll say, "I will repair." Cracking is a situation out there. And one of the things that I would look at, I'm kind of a spatter guy, my welding skills are pretty good, as long as you're not gonna put a whole lot of weight on it. So I will take a look at repairs or lack of repairs and point those out too. But we do have the opportunity to do a fair amount of fixing, but in many cases, you really need to have a proper understanding of both metal and the rod usage and what type of heat that you would be placing on these types of, in this case, the trailer frame. But more importantly, if you do have a crack or need to weld on the tanks, make sure that you communicate with the supplier of the tanks. That is very essential in terms of understanding what type of repair is available for and capable on that tank, because you can actually cause a significant increase in stress, leading to failure, if you are a welding or fixing the tanks. On the commercial side, where we're hauling hazardous materials in particular, we have to go to a certified tank repair shop to be able to do any repair on tanks. So on the farm, we don't have that requirement, but understand there is a reason why you need to know what that is. So I would ask if I do see a fair amount of welding on the tanks, I would ask, "Is there someone who is engaged in it? Could you reasonably explain to me what is the process that you'd be looking at doing there?" Now, again, I'm going through kinda the full-scale. I'm going a little bit beyond some of the bronze level, but this gives you an idea as you move forth, and then, prove your program what to look for as you move forward. Tires, yes, tires. Deflation, overinflation, and the quality that tires have led to overturn to in a number of states around the country. So the first thing I'm gonna look at is for weather checking. In many cases, these are stored outside. They haven't seen the inside of a facility in quite a long time. So when we look at weather checking, clearly, that the tractor tire there has a fair amount of weather checking. But what I'm gonna look at is utilizing how on the commercial tire side, where we have to take a look. So if we have a two-millimeter or deeper, essentially, a 10-tire, that's the type of thing that I would be looking at to question whether or not we're getting to the point where that tire should be looked at. Coupling is probably an area that we need to understand a little bit more. Our traditional drop-pin structure can cause problems. And in this situation too, we have some reasonable support for our control lines, but we have them close to, and if we make a sharp turn, they're gonna be at or on that damaged PTO shaft. So am I gonna say, you need to buy a brand-new PTO shaft for all the equipment? No, but it must be protected under my OSHA. That is a part-700 violation. And in this situation, you were actually subject to a potential penalty of up to 70... It's now 72,100 and some odd dollars that you could be penalized under my OSHA of violation of the PTO shaft shield guard and... So I'll mention that in terms of situations that we might find. And when we talked about loading, that overfill situation is where we wind up losing a fair amount of material on the road. So this operation did put on, they built up a spill box for their application equipment. So spill box is something we're gonna recommend. A lot of manufacturers didn't have mine there, but this gives a little bit of an opportunity for overslope. When you do shut off, it minimizes the opportunity for the leakage down and around the sides. So I'm gonna take a look at that recommended. It's not specifically required, but this is a practice that we really need to do a little bit better job of. So most of us that have been out there, this is what it looks like when we get down. So one of the challenges that we need to understand when we're operating on the road, we can't lose our product. That's violation of basic law on the road. So if you look here in all likelihood, we've lost chunks. Meantime, you have a chunk, that's where the motor carrier officer is more interested, and it can in fact, be a violation, and it can be a DEQ issue as well, where we're dropping our actual load, manure, onto the road surface. Now, when you get done, you're tired, but what don't you see on this? And that's one of the areas that we wind up getting into trouble with. "Well, I have lights, so I'm okay." We do need to pay a little bit of attention to cleaning. I'm not recommending that this is the proper way to clean, but keeping your equipment as clean as possible can significantly minimize. And here, you can very clearly see that we had over-fill situations, and that's what we're wanna pay attention to. And when we're operating down the road, are the markings visible that is out there? So when we get down the road, markings. So the primary unit here is not operated on the road. That's just run around the farm. And while there are lights in the bottom, there is no SMV, and it doesn't require an SMV, if you don't operate it down the road. Conversely, the traditional manure spreader over there does have an SMV on. And that is very important. It is the cheapest insurance policy that you can put out. We also have to replace damage to faded SMVs. Please be aware that if you were struck from behind and an implement of husbandry is not properly marked, you were automatically at fault. In other words, you're subject to full liability in this situation. So that SMV is a very, very cheap protection. If the person hits you from behind and you are properly marked with an implement of husbandry, they're automatically at fault. So it is critical that we take a look at the process that we're out there. I was over in Montcalm County a few years ago, and there was a hauler going down the road and I looked up and wow, here's nice, beautiful SMV, nice and clean. And the back of the unit was full of manure. And I go, "How in the world did they do that?" So there was a few cars there. I was in a hurry to get to the meeting, but I stopped. He went out and luckily started immediately spreading. And the moment that he hit the spread button, that SMV closed up on itself. So you folks are very ingenious. You can come up with solutions for virtually everything. So take a look at how you're gonna maintain the visibility. Now, for those units that were manufactured after that, early in 2000 level, we do have extremity marking requirements, marketing requirements. For these older vehicles, we do have red reflective material on the outboard edges. Typically, this can be in the light, but these lens are just the circular lenses, they're not the hatch lenses. So they are not reflective material. And we don't have a bumper requirement on these. So do take a look at where the placement is. If we have equipment extending significantly beyond that unit, we really should consider sharing that that SMV is as close as it can be in other forms of application equipment. So when we're operating down the road, in all likelihood, we could say that, "Yes, I can see the SMV." You know, we probably would be in compliance here, but please pay attention. Also, that we're operating over the center. Many cases, we do applications throughout the course of the day. During the day, we have the opportunity with an implement of husbandry to go across the centerline. At night, we don't have that opportunity. So understand at night, even though it might be safer, law enforcement can pull us over for operating over the center. During the day, we have the opportunity to do that, where we have an obstruction or a reason why we can't operate on our side of the road. So many cases we have limited or no shoulders. These are the types of situations where we can have a vehicle that's over 102 inches and utilize the road right away for our use. So going back to the coupling devices, mentioned that grapped him, all drawn vehicles. So an implement of husbandry is a vehicle. Likewise, a tractor is. All drawn vehicles must be secured with a safety chain or two safe to change depending on the structure. For most agricultural pieces of equipment, this is the standard that we're looking at. And please notice that you do have the weight tag on here. So we're also looking to make sure that the chain devices are in fact, rated for the load that you're looking at. Also here, you have a captured pin. These are the types of things that we wanna see when we're out there looking. In many cases, and I asked the manufacturer, "Why didn't you use the safety chain?" Well, it didn't fit in the drawbar opening. So the fact that you have a safety chain on there isn't gonna save you. You really need to have it properly attached. So do take a look at how you're gonna do that and instruct the operators to make sure that you have it on there. Decoupling is a fact of life. In many cases, most of us cannot honestly say, "We've never lost a wagon on the farm." Well, when we lose grain hauling unit, we can have very significant and difficult situations. So this uncoupled came in, dropped into the ditch and overturn. These are the types of situations. Did we properly secure the fuel door to minimize the leakage? They didn't have a significant amount of linkage apparently in this situation, but you can see the damage that was caused to the road right away. And this in all likelihood, is gonna be somewhere in a 10 to $50,000 repair. And you look at that, and you look at cold patch, and you go, "Well, how can that be?" Well, the way in which incidental road damage is calculated really puts the burden on the person who is damaging the road. So please be a little cautious, and do make sure that you have proper hitching devices. (indistinct) This operation gave me a call, and their operator was pulled over. Now, they were operating with one of the tractors that has a fast speed opportunity. And the officer said, local law enforcement officer said, "You cannot have an SMV on that, because you're operating over 25 miles an hour." No, that is false. All implements of husbandry must have a slow-moving vehicle, (indistinct) low visible when operated on the road. And that's very important again, because you can have a problem if you have an accident. Talked about operating in your side of the road. Now, this is something to pay attention to. Can you adjust some of your transport directions to assure that you have the best opportunity to maintain your side of the road as well? Going back, looking at the running gear, I do pay attention. Of course, this is a new one, but I do pay attention. And what the hubs look like, what the condition of the lug nuts. Do I have any bent rims? Or do I have any significant cuts in the tire that we would put it beyond that two-millimeter structure as well? Now, when we operate, I just told you about the fact that they had the tractor operating above 25 miles an hour. This is the area that you have to pay attention to as well. Our implements for husbandry are covered by weight. - [Facilitator] Craig, I don't mean to interrupt, but if you could speak a little bit louder, your voice is fading in and out on occasion. But speak up a little bit too, please. - Okay, I normally don't have that problem. I normally speak up, so I must have some equipment problem here. One of the things to take a look at is the maximum load structure. The law enforcement can't. So it looks as though I did have a cordish. Law enforcement is not gonna give us a standard weight ticket. In other words, we don't have maximum loads, but they can give us a ticket for overloading the equipment that we have. So many cases, the people will purchase the vehicle, and it will have a particular load rating, in this case, 7,600 pounds. And then they will replace the tire with something that has a significantly lower load rating, that you can get a weight ticket for that. Also, we have speed ratings. So here we have a 15, 180 pound maximum, but at 40 miles an hour. So we also have speed-rated tires. So for operating over that speed limit, we also can have a problem. So I will take a little bit of a look and point out where we have, for example, tires that are only rated for 10 miles an hour, let's say. Many cases, operations move to the commercial tire, for example, tens, that gives you in full-speed rating, and this isn't an implement of husbandry, but there's one other place that you really need to look in terms of knowing what you're doing. Here, the manufacturers put this designation on there. It's an implement of husbandry, and when loaded, should not exceed 10 miles an hour. So if we're doing let's say 40 miles an hour with this, that's 30 miles over the rated speed of the equipment, and that's a reckless driving ticket, and it also can lead... Many cases, they have this on there because of the top-heavy nature of the equipment that you're using. So where we go at speeds faster, it may not be properly baffled for that speed, or it may be so top-heavy that any movement could lead to an overturn. And I'll finish up with the application. We do need to understand modified application or modified agricultural vehicles. These are back in the commercial vehicle side. You'll notice here that it does not have a license plate. These now do have to have a license plate. There are no longer an implement of husbandry by design, even though they're making application. A change in the requirements said that the vehicle needs to be so modified that it would not be able to be used in its original purpose. Hence this three-quarter 10 Chevy pickup that is down here. I'll take a look at the general maintenance of the application equipment, particularly, the hoses, distribution structures, connections, hydraulics, pump facings, those are the types of things that I'm gonna take a look at to look for loose, insecure, cuts, damages, et cetera, in that type of distribution. And also, I'm gonna ask about, particularly, in the dragline situation or in buried or fixed line, what type of structures do we have in terms of preventing or being able to shut off flow remotely? So many cases, these lines are quite long. We may or may not have visual access to that length of line. So if we do have those situations, what type of practice is going to be there. I'm also gonna talk a little bit about additional equipment. So if we're doing tanker activities, we may have a significant amount of different styles and types of equipment that is used; everything from pumping equipment through the oil field tanks. And in this case, if you look at the lower-left, we have that hopper. Recognize that we have a limited opportunity to load, actually load on the road right of way. We're trying to get a determination from the state police in terms of how far our qualification goes. But we have had loading situations. We had a fatality this past year, where we're loading grain on the road or waiting for grain to be loaded. And we had a rear-end incident, and they may go after the operation for loading on the road. At least in that situation, there was no actual loading. The truck was there waiting for a truck in front of them to be loaded. So these are some of the types of things that we're looking at. It's a quick overview, and I'll open it up to questions. - [Facilitator] Thanks, Craig, I always learn something from you whenever you present, so great presentation. And I would definitely recommend to anyone who has further transportation questions, check out the transportation guidebook on Michigan Farm Bureau's website. So folks, raise your hand, if you would like to ask a question, pop it in the chat, that will start with the question from Jody in the chat, and it says, "Craig, have you seen any tongues completely break in the middle of the tongue on fairly new to your older laughs, 10,000-gallon (indistinct)?" - The answer is yes, we do have a stress point. Many cases, we will have the large tractors, have to make a tight turn. And we put a stress point on these drawbars. Most are now a twin or a triangle, which makes them much straighter, but that's part of the stress cracking that I would take a look at out there. The other thing is we do have pivot points and many of the times nowadays. Do take a look at those pivot points. In many cases, they do require lubrication. And so that lubrication point is one of the areas that might get missed, and that could lead to the pin fracture and the loss of the drawbar. - [Facilitator] All right, are there any other questions? - And folks, feel free as the inspection process goes forward, the inspectors who are out there, many of them have had a lot of opportunity to see an awful lot of equipment, tens of thousands of pieces of equipment during their career. But we learn something every single day. And you folks are probably the most capable of making and modifying and solving issues. So an awful lot of the equipment out there is not something that's off the rack. And so bear with us, we will ask some questions that may seem maybe a little bit, "Do you really know what you're talking about?" No, those questions are by design, to give us a better understanding to make sure that we make the proper communication in this program. - [Facilitator] Thanks, Craig, so we have another question. Do all trailers or farm equipment require the safety chain? - Yes, all drawn equipment requires either a safety chain, and that's why I put up the agricultural standard or twin chains. So in some cases with the weight that we're looking at, the single chain, it's gonna be a very, very large chain to meet the load requirements. And again, that applies to all drawn vehicles, regardless of whether it's an implement, whether it's a licensed trailer, if it's drawn by a vehicle, it does need to have the safety chains. - [Facilitator] Awesome, thanks, Craig. And then we did, another question says, this is more I think about the program in general, but will you need to inspect all of our custom hire applicator's equipment as well? And so I don't know if that would be a question for Charles, if you wanna jump in or you have a thought on that. - [Charles] Tyler, could you unmute yourself and just maybe explain a little bit more about what the intent of your question is? - [Tyler] Yeah, so you were saying when you come on to doing your inspection, is that you might have to check all that stuff, but so in our case, 99% of our stuff is all custom hire. So are you gonna just have to see like maybe our main customer hires equipment to be able to get the certifications or are you just wanna look at a couple of art pieces or how does that work? - I'm not in the lead on this, but what I would look at is that again, from an equipment standpoint, we're looking at the spill side of the equation. So you have your own equipment. And do you have the potential for protections, where you bring in a third-party equipment process? Do you have those protections in place coming out of your systems to minimize the spill at that load point? - [Charles] So Tyler, the way that I understand your question is you have a for-hire manure applicator that comes in and applies manure for your operation. So that inspection process would be independent of your operation. We would hope that whoever that you're using would go through the certification process and become certified, so that, you know, they're equipped to apply manure before they get to your operation. - [Tyler] Okay. - [Facilitator] Thanks, Charles, and any other questions? I don't think I've seen any come through the chat. Any other folks that have questions for Craig? - There is one question about the licensing. I think I covered that, but if it is a modified agricultural vehicle, that's why I brought up the side slinger on there. If it started as a registered vehicle and it isn't so significantly modified, then yes, a modified agriculture vehicle does require a license plate. And from the standpoint of tread depth, generally, we don't get to a tread depth issue in terms of the trailers. Now there what we're looking at is the cracking. And that's why I brought it up. - [Facilitator] All right, thanks for all the questions. We still have time, so any other questions, feel free to put them in the chat. Give another second for any other questions to come through. - So typically, we get a lot of the transportation questions. So I left a little bit of time to do that. (both laughing) An area that I dropped out due to time was the load securement. I did mention the ability to put on the boxes. However, understand that when we haul manure, manure is our product, and load securement requirements, while we don't have, for example, tarping requirements in this situation, we are covered by the load securement rules. So if we have a spill, including coming off the edges of that unit, it is an unsecured load for DOT purposes. So recognize that it is not only the spill itself, but in most cases, you're gonna wind up to get an unsecured load ticket on top of that. And that can be fairly significant. If you're hauling with your commercial vehicle, that is a high-point issue in terms of your CSA standing and any insurance company if you will, or any other party can check your CSA data and determine if you had any significant problems, including the loss of manure. So be a little cautious in load securement side as well. - [Facilitator] And it looks like Craig, we got a question from Chase in the chat. Does a modified vehicle that has a license plate also need a slow-moving vehicle sign? - This is one where I get to say possibly. The modifying agricultural vehicle in and of itself would not need to have it. However, if you are doing application with that vehicle, then it does also become an implement of husbandry. So yes, and the answer to the second question is yes, you can have a license plate, and have a slow-moving vehicle sign. Now, some of the local law enforcement officers question that, but we're able to straighten out fairly quickly if need be. We go to a lieutenant and the state police, and they provide the documentation directly to that local law enforcement officer. - [Facilitator] Awesome, well, thank you so much, Craig. We really appreciate your presentation, all the great information you have. We're gonna take a early five-minute break. So feel free to go... Oh, we got another question. We'll do that since we're running early. If it is determined that a spill is caused by a driver who was hit on the road by another driver, is the driver of the manure tanker at fault still? - I'm gonna interpret this at fault for the spill. So there are two sides of what you're looking at. The first thing is that they're gonna determine is there cause for the other driver? In other words, is that driver at fault for the collision on the road right of way? And that the manure hauler would not directly become liable for the spill. And the second part of that is that if we're operating in terms of the commercial vehicle side, so if it is either an actual commercial vehicle, a semi and tanker trailer or modified agriculture vehicle, then that officer is gonna go through and determine whether or not that piece of equipment met the Part 396 requirements. And if the spill was deemed to be because of the failure to follow the 396 requirements, that driver could be held at fault for the spill. - [Facilitator] Question from Dan. Are you going to cover manure application calibration in the program as part of equipment inspection or nutrient management? - As I understand it, We're gonna look at that initial inspection as are you doing it? And nutrient management is going to cover the methods and what needs to be done to assure that you're applying in the correct amount. Is that correct, Tess? - [Facilitator] Charles, go ahead. - [Charles] Yeah, that's correct. As part of the inspection process, we wanna know that your spreader is calibrated, and the technique that you used, but that's as far as that goes. Actual manure spreader calibration. We have meet technicians and extension educators that can help applicators to, you know, calibrate their spreaders if they need some assistance. - [Facilitator] And I do believe that online training trials, you can correct me if I'm wrong, that also does cover the importance of calibration as well. Correct? - Yep, yep. That level-one video that you watched covers that. Thank you, Tess, yep. - [Facilitator] Yep, all right- - And then the extension bulletin does a good job in outlining in a very easily readable format, the primary methods that are out there. The flow meter's side of the structure. Flow meters are significantly different between the various manufacturers. So I'm not gonna have the ability to go in there and check the computer structure to determine whether or not you're following or it's actually functioning. What we're looking at is what you were doing in terms of that, and ultimately at the end, you need to have some opportunity to know how much you put out in the field, and what the nutrient characteristics of that material was. That is essentially your check on the calibration side. - Awesome, well, it looks like, I don't know, Craig, if you've got any other direct questions, but it looks like we're done with the questions that are coming into the chat. So thank you again, we greatly appreciate your time and expertise for this presentation.