In the early 1990s, the Idaho State Department of Agriculture (ISDA) administered a comprehensive inspection program focusing on milk sanitation within the state's dairy industry. In 1995, it was found that approximately a quarter of Idaho's dairy farms had been discharging untreated sanitation process wastes into groundwater sources. This indicated that traditional models of voluntary regulation within the dairy sector had begun to fail. As dairy operations had become an industry, industry models for regulation of pollutants were a better fit. The EPA and Idaho Department of Environmental Quality (IDEQ) found themselves unable to ensure the regulation of the dairy industry using the antiquated regulation model.
Concerned with the ability of state and federal agencies to handle the new pollution problem, the ISDA led the formation of the Idaho Dairy Pollution Prevention Initiative. The Dairy Initiative first fostered cooperation between ISDA, EPA, IDEQ, a number of industry groups, such as the Idaho Dairyman's Association, and environmental conservation groups in order to compose a memorandum of understanding (MOU). The MOU defined the roles of the three government agencies to reduce the amount of bureaucracy and to efficiently bring Idaho's dairy industry into compliance with the Clean Water Act.
The ISDA spearheaded the new approach outlined in the MOU, which increased the frequency and severity of inspections. The Dairy Initiative would accomplish this with minimal financial impact to the state by retraining ISDA sanitation inspectors to include pollution control in their site visits. To embolden inspections, the Dairy Initiative would also give inspectors the authority for milk license revocation and suspension as a penalty for non-compliance. Once this penalty was enforced, all proceeds from the given dairy operation would go into the correlating county's coffers. Inspections would occur at a minimum of once annually, although in 2000, inspections averaged 2.5 times a year. This was a drastic departure from the former system in which the EPA inspected approximately 5 percent of Idaho's farms annually.
The Dairy Initiative emerged from a spirit of cooperation in which the EPA and IDEQ handed authority over to ISDA, and the Dairyman's Association accommodated heightened enforcement. This public-private cooperation resulted in the effective management of dairy sanitation pollutants. Since 1995, ISDA has conducted over 14,000 inspections. Under the former system, IDEQ and EPA would have conducted approximately 200 inspections of lesser intensity. As of 2001, all but one of Idaho's dairy operations is in compliance with the Clean Water Act.