Any entity that intends to use animal by-products (hereinafter ABPs), such as manure, slurry, whey, or waste from meat plants, for the biogas production process is obliged to submit an application for approval of supervised activity to the territorially competent District Veterinary Officer 30 days prior to the commencement of the activity.
The commencement of the activity should be understood as the introduction of e.g., slurry or often fermentation residues from another biogas plant (using ABPs for production) into the ABPs biogas plant. These formalities should be fulfilled when planning the technological start-up to avoid unpleasant consequences, e.g., in the form of administrative penalties amounting to tens of thousands of zlotys.
Once an application for the approval has been submitted to the District Veterinary Officer, a preliminary inspection is carried out to determine whether the installation in question meets all the formal and technical requirements (as described in Regulations 1069/2009 and 142/2011) to enable a veterinary number to be assigned and the activity to be approved.
A properly designed biogas plant generally has the appropriate technical equipment but does not have a developed and implemented HACCP system.
However, Article 44 of Regulation 1069/2009 provides that the District Veterinary Officer may issue a conditional decision for a period of three months (up to a maximum of six months), during which the operator has time to fully adapt the installation as well as develop and implement appropriate procedures.
Why is it a prerequisite to have and implement HACCP procedures for a biogas plant processing animal substrates?
Without a developed and implemented HACCP system, the biogas plant will not receive full approval of the operation by the District Veterinary Officer, as the requirement of Article 29 of Regulation 1069 of 2009 will not be fulfilled.
What are the implications of this?
- When the maximum time limit (up to 6 months) for adapting a biogas installation to the requirements of Regulations 1069/2009 and 142/2011 is exceeded, the District Veterinary Officer is entitled to issue a decision ordering a ban on biogas production from animal substrates with immediate enforceability.
- For breaches of veterinary regulations (e.g., operating without approval, lack of implemented HACCP procedures, inappropriate activities on the ABPs), the District Veterinary Officer is entitled to impose administrative penalties amounting to tens of thousands of zlotys.
(Legal basis: Decree of the Minister of Agriculture and Rural Development of 2 May 2014 on the amount of fines for infringements specified in the regulations on animal health protection and the eradication of infectious animal diseases concerning the handling of animal by-products and derived products).
- In addition, in the event that this type of activity is found to pose a threat to human and animal health, the District Veterinary Officer is obliged to report the suspected offence to the law enforcement authorities (Police/Prosecutor’s Office)
At this stage, the question arises – what is the right thing to do?
It is best to entrust the task of carrying out the approval procedure to a company specialised in providing such services.
BIO-INDUSTRY is a leader in Poland in the approval of biogas plants processing animal by-products by the Veterinary Inspection. Our company has aided in the implementation of an HACCP system for dozens of installations using the anaerobic digestion process. We guarantee an efficient and professional service and full customer support at every stage of obtaining the approval for supervised activities.
Depending on the client’s needs, we offer:
- technology verification – identifying a list of ABPs that can be processed,
- development and implementation of an HACCP system and initial GMP and GHP programmes
- development of a pest management programme,
- to carry out a validation of the planned treatment process,
- development of an application for approval of the installation to the District Veterinary Officer,
- participation in the inspection of biogas plants by the Veterinary Inspectorate,
- obtaining a decision approving the operation of the biogas plant by the District Veterinary Officer,
- periodic internal audits on the functioning of the HACCP system,
- updating or amending an existing HACCP system.