Notice for the operators of IPPC installations in food industry, operators of IPPC farms and representatives of local self-governments responsible for issuance of integrated permits

We would like to remind you that the Rulebook on the list of activities that can cause soil pollution and degradation, procedure, data content, deadlines and other requirements for land monitoring was adopted in September 2019 (Official Gazette of RS, No. 68/19). The Rulebook provides more detailed provisions related to monitoring requirements – periodical analysis of the soil where industrial activities are performed, set by Law on soil protection, in order to obtain data on the status and quality of soil before, during and after these activities are performed. 

When drafting the application for an integrated permit (Monitoring plan) or drafting an integrated permit, the requirements and provisions of this Rulebook have to be taken into account. The list of activities referred to in this Rulebook mainly includes industrial activities from energy sector, processing industry and agriculture (ANNEX 1) and applies to both new and the existing installations. 

Within the food sector, the Rulebook applies to: 

  • Slaughterhouses with production capacity greater than 50 tonnes per day; 
  • Installations for treatment and processing of animal raw materials (other than milk) intended for the production of food products, with a finished product production capacity greater than 75 tonnes per day, 
  • Installations for treatment and processing of vegetable raw materials intended for the production of food products, with a finished product production capacity greater than 300 tonnes per day (average value on a quarterly basis); 
  • Installations for treatment and processing of milk, with the quantity of milk received being greater than 200 tonnes per day (average value on an annual basis). 

Within the agriculture sector, the Rulebook applies to installations for rearing of animals, with capacity to house more than: 

  • 40.000 places for poultry, 
  • 2.000 places for production pigs (over 30kg), 
  • 750 places for sows, 
  • 200 places for cattle. 

According to the Rulebook, soil analysis is to be performed before the construction of the installation (for new installations), during its operation and after the final cessation of activities. Soil analysis is performed periodically, every 5 years, except in the case when the analysis determines contamination of the soil with harmful substances as the result of activities carried out on site. In that case the analysis is performed on annual basis until the results of three consecutive annual analyses show that concentrations of pollutants are below limit values. 

Soil monitoring includes monitoring of parameters such as: 

  1. mechanical composition of the soil, 
  2. soil acidity (active acidity, pH in H2O; substitution acidity, pH in 1M KCl), 
  3. CaCO3 content, 
  4. cation exchange capacity, 
  5. degree of base saturation, 
  6. content of organic matter. 

Depending on the type of the activity performed on site, the analysis may also include determination of physical and chemical properties of soil and other parameters. 

According to the Law on soil protection, the owner or user of land or installation, whose activity may cause or causes pollution and degradation of soil, is responsible to carry out the monitoring of soil quality. Sampling and analysis of soil has to be performed by an accredited and authorized laboratory, subcontracted by the operator, in line with requirements of the Law. Data on soil quality is reported to the Serbian Environmental Protection Agency (SEPA), on an annual level, not later than March 31 of the current year for the previous calendar year. 

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