Approval of biogas and composting plants


 

by Veterynary Inspection

 

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HACCP FOR BIOGAS PLANT

Each biogas operator who intend to use animal byproducts (hereinafter ABP)  in his biogas facility like: manure, slurry, whey or slaughterhouse wastes etc.is obligated 30 days before start operation submit an application about approval activity to the relevant territorial supervised the District Veterinary Officer.

By start of operation should be understood introduction (put?) to biogas installation ABP`s eg. slurry or frequently used for technological start fermentation residues from another biogas plant (which use or used in past to production ABP). These formalities must be respected when you planning technological start-up to avoid unpleasant consequences like administrative penalties of up to several tens of thousand złotych.

After  submit application for approval, District Veterinary Officer carry out initial inspection in order to determine whether the installation complies with all formal and technical requirements (described in UE regulations 1069/2009 and 142/2011) enable to approval activity and  imparting a veterinary number. Properly designed biogas plant generally has appropriate technical equipment, but hasn`t elaborated and implemented HACCP procedures and validation of the fermentation process based on alternative transformation method of ABP.

In Art. 44 UE regulation No 1069/2009. are provisions under which the District Veterinary Officer may give conditional decision for a period of three months (up to six months) during which the operator of biogas plant (entity?) has time for complete adaptation of the  installation, work out and implement appropriate procedures.

Why mandatory is to have and implementation HACCP in biogas plant which transform animal byproducts?

Without elaborated and implemented HACCP biogas plant doesn`t receive approval of the activity  by District Veterinary Officer, because it does not fulfill the requirement of Art. 29 |of UE regulation No 1069 of 2009.

What are the consequences associated with it?

  • If you exceed the maximum period (up to 6 months) on adjust/adopt the biogas plant to the requirements laying  in UE regulations 1069/2009 and 142/2011 District Veterinary Officer has the right to issue a decision ordering the prohibition of activities in range of transformation ABP with order of immediate enforceability.
  • For infringement of veterinary law i.e. operating without approval, the lack of implemented HACCP procedures, improper actions on ABP etc. District Veterinary Officer has the right to impose administrative penalties of up to several tens of thousand złotych.
    (legal basis: rozporządzenie Ministra Rolnictwa I Rozwoju Wsi  z dnia 2 maja 2014 r. w sprawie wysokości kar pieniężnych za naruszenia określone w przepisach o ochronie zdrowia zwierząt oraz zwalczaniu chorób zakaźnych zwierząt dotyczące postępowania z produktami ubocznymi pochodzenia zwierzęcego i produktami pochodnymi).
  • In addition, in cases where it is found that this type of activity causes a threat to human and animal health, the District Veterinary Officer must report on suspicion of committing the crime to law enforcement (police / prosecutor's office).

    At this stage, arises the question – what I should to do???

Best to rely on professionals and practitioners who have already elaborated  many such documentations for biogas plants! What is important, to properly prepare for all procedures can do a person who has extensive practical knowledge about operation biogas plants. Entrusting such a task the company, which has in principle knows the structure of the HACCP but "not feel" issues in biogas sector, will end up with serious problems to fulfill the requirements imposed by the company that develops this type of documentation! Having in mind that biogas  facility isn`t  food production plant, the guiding principle should be "the simpler, the better" with maintaining all of the requirements of the law.