Approval of a biogas plant by the County Veterinary Officer: the procedure step by step

A biogas plant that processes animal by-products (UPPZ), including manure and slurry, may start work only after approval by the competent authority — in Poland the decisions in this matter are issued by the county veterinary officer competent for the place where the business is carried on. The procedure is based on Articles 24 and 44 of Regulation (EC) 1069/2009 and national provisions (Article 6 of the Act on animal health protection and combating infectious animal diseases). Below are the steps, from design to veterinary number.

Step 1: establish the substrate categories

Draw up a list of substrates from UPPZ and assign categories (1–3) to them. The category determines the requirements. For category 3 material the standard is hygienisation at 70°C for 60 minutes with particles up to 12 mm. For category 2, as a rule, it is pressure sterilisation (with exceptions including manure and milk). Category 1 material is not permitted in a biogas plant. If the installation is to receive different categories, the application should state whether they will be separated permanently or temporarily.

Step 2: design the installation in accordance with annex V

Annex V of Regulation 142/2011 gives rise to requirements including:

• a pasteurisation/hygienisation module that cannot be bypassed, with continuous temperature recording and a system protecting against underheating (does not apply to installations that handle only exempt materials);
• its own laboratory or cooperation with a laboratory approved, accredited or regularly supervised by the authority;
• separation from animals, feed and bedding, and, where animals are nearby, an adequate distance (does not apply to plants using only manure, milk or colostrum from those animals);
• a place for washing and disinfecting vehicles and containers that does not endanger the processed product;
• documented pest control, cleaning, inspections and calibration of measuring devices.

Step 3: submit the application to the county veterinary officer

The application contains the applicant's details, the address of the plant and a description of the planned activity (type, categories of material, processing capacity). It is worth attaching a description of the technology, material flow diagrams and the planned system of own checks. Do not submit it at the last minute: the act specifies how far in advance of the start it must be submitted, and the authority must have time for the inspection.

Step 4: on-site inspection before the start

Under Article 44 of Regulation 1069/2009, the authority approves a plant only after an on-site inspection carried out before operations begin, which confirms compliance with the requirements of Article 27. At this stage the infrastructure, equipment, hygiene procedures and inspection records are checked.

Step 5: conditional and full approval

• Conditional approval — if the infrastructure and equipment are adequate for carrying out procedures in accordance with the provisions.
• Full approval — after a second inspection, carried out within 3 months of conditional approval.
• Extension — if clear progress is visible but not everything is met, conditional approval may be extended; in total no longer than 6 months.

If approval is withdrawn or conditional approval is neither extended nor converted into full approval, operations must cease.

Step 6: identification number and obligations after approval

The plant receives a veterinary identification number and is entered in the lists of the Veterinary Inspectorate (biogas plants have a separate section in the GIW list). After approval the following apply: commercial documents when transporting UPPZ, receipt registers, temperature monitoring, tests of the digestate product (including absence of Salmonella in 25 g and indicator bacteria E. coli or Enterococcaceae within a limit of 5000 cfu/g) and notification of significant changes.

Related procedures

Veterinary approval does not replace other decisions: the building permit, environmental decisions, the waste processing permit (if the feedstock is waste) and — for agricultural biogas plants — entry in the register of agricultural biogas producers kept by the Director General of KOWR.

Sample document checklist for a conversation with the county veterinary officer

• A process diagram showing the UPPZ reception line, the buffer tank, shredding and the hygienisation unit.
• A list of substrates with UPPZ categories and estimated annual quantities.
• A description of the separation of the dirty zone (reception, vehicle washing) from the clean one (digestate).
• A description of the temperature recording system, alarms and the procedure in the event of underheating of a batch.
• A plan of own checks and an agreement with a laboratory.
• Procedures for washing, disinfection, pest control and staff training.
• The name of the person responsible for compliance with veterinary regulations.

Such preparation shortens the inspection time and reduces the risk that conditional approval will have to be extended to the six-month limit.

When changes require renewed agreement

Approval concerns a specific activity and category of material. A change of scope (e.g. adding category 2 to an installation that has so far worked on category 3), rebuilding of the hygienisation line, a change of operator or a significant increase in processing capacity should be agreed with the authority before implementation. Starting to receive a new type of material without agreement risks withdrawal of approval and suspension of operations.

How to arrange the investment schedule

The biggest mistake is ordering the process line before the authority knows its concept. A sensible sequence is: a preliminary conversation with the county veterinary officer about categories and layout; an application with documentation; purchase and installation of equipment in line with the agreed diagram; the pre-start inspection; commissioning under conditional approval; the post-commissioning inspection and full approval. Conditional approval allows the installation to be started up, but it comes with a limit of three months to the inspection and six months in total, so commissioning should be planned so that operation at full parameters can be documented within that time.

Common mistakes

1. Submitting the application before establishing the substrate categories.
2. Purchasing an installation without a hygienisation module or with the possibility of bypassing it.
3. No own laboratory or agreement with a recognised laboratory.
4. Starting to receive UPPZ before the inspection is completed.

This text is for information purposes only and does not constitute legal advice; before an investment or formal decision, check the current wording of the provisions and consult a lawyer or the competent authority.