Fines for livestock waste. Changes to the Code of Administrative Offenses of the Russian Federation
Veterinary and sanitary rules for the collection, disposal and destruction of biological waste
(approved by the Chief State Veterinary Inspector Russian Federation December 4, 1995 N 13-7-2/469)
With changes and additions from:
1. General Provisions
1.1. Veterinary and sanitary rules for the collection, disposal and destruction of biological waste (hereinafter referred to as the “Rules”) are mandatory for animal owners, regardless of the method of farming, as well as organizations, enterprises (hereinafter organizations) of all forms of ownership engaged in production, transportation, procurement and processing of products and raw materials of animal origin.
1.2. Biological waste is:
Corpses of animals and birds, incl. laboratory;
Aborted and stillborn fetuses;
Veterinary confiscations (meat, fish, other products of animal origin), identified after a veterinary and sanitary examination at slaughterhouses, slaughterhouses, meat and fish processing organizations, markets, trade organizations and other facilities;
Other waste obtained from the processing of food and non-food raw materials of animal origin.
1.3. Animal owners, within a period of no more than 24 hours from the moment of death of the animal, discovery of an aborted or stillborn fetus, are obliged to notify a veterinary specialist who, based on the results of the inspection, determines the procedure for disposal or destruction of biological waste.
1.4. The responsibility for delivering biological waste for processing or burial (incineration) rests with the owner (head of a farm, personal, subsidiary farm, joint-stock company, etc., public utility service of the local administration).
1.5. Biological waste is disposed of by processing at veterinary and sanitary recycling plants (workshops) in accordance with current rules, disinfected in biothermal pits, destroyed by burning or, in exceptional cases, buried in specially designated areas.
1.6. Places designated for the burial of biological waste (livestock burial grounds) must have one or more biothermal pits.
1.7. With the introduction of these Rules, the destruction of biological waste by burial in the ground is strictly prohibited.
1.7.1. In the area served by the veterinary and sanitary recycling plant, all biological waste, except those specified in clause 1.9. of these Rules are processed into meat and bone meal.
1.7.2. In exceptional cases, when mass death animals from natural disaster and the impossibility of their transportation for disposal, burning or disinfection in biothermal pits, burial of corpses in the ground is allowed only by decision of the Chief State Veterinary Inspector of the republic, another subject of the Russian Federation.
1.7.3. In the reindeer breeding zone (permafrost areas), in the absence of the possibility of constructing and equipping cattle burial grounds, burial of biological waste in earthen pits is allowed. For this purpose, special areas are allocated in pastures and along the routes of nomadic herds, if possible in dry, elevated places not visited by deer.
It is prohibited to dump biological waste into water bodies, rivers and swamps.
1.9. Biological waste infected or contaminated with pathogens:
Anthrax, emphysematous carbuncle, rinderpest, camel plague, rabies, tularemia, tetanus, malignant edema, bluetongue of cattle and sheep, African swine fever, botulism, glanders, epizootic lymphangitis, melioidosis (false glanders), myxomatosis, hemorrhagic disease of rabbits, bird plague are burned on site, as well as in incinerators or in specially designated areas;
Encephalopathies, scrapie, adenomatosis, visnamaedi are processed into meat and bone meal. If it is impossible to process them, they must be burned;
Diseases that have not previously been recorded in Russia are burned.
1.10. If biological waste is radioactively contaminated at a dose of 1x10-6 Cu/kg or higher, it must be buried in special storage facilities in accordance with the requirements for radioactive waste.
1.11. These Rules define the conditions:
Collection, disposal and destruction of biological waste in livestock complexes (farms), farms, personal farms, subsidiary plots, populated areas, places of accumulation, nomadic (passage) of animals; when transporting animals and livestock products;
Non-proliferation of pathogens of infectious and invasive animal diseases;
Prevention of human diseases by zooanthroponotic diseases;
Security environment from pollution.
2. Cleaning and transportation
2.1. A veterinary specialist, when examining the corpse of an animal, a stillborn, an aborted fetus and other biological waste, gives an opinion on their collection, disposal or destruction.
With the approval of these Rules, the “Veterinary and sanitary rules for the disposal, cleaning and destruction of animal carcasses and waste obtained from the processing of raw animal products”, approved by the Ministry, do not apply on the territory of the Russian Federation Agriculture USSR on April 6, 1951 and agreed with the All-Union State Sanitary Inspectorate on March 14, 1951.
I approve
Agreed
Registration N 1005
Application
to the Veterinary and Sanitary Rules for Collection,
recycling and destruction of biological waste
dated December 4, 1995 N 13-7-2/469
Facilities for storing and recycling livestock waste are included in the general waste management scheme only in three constituent entities of the Russian Federation. 67 regions received a recommendation to monitor the clarification of regulations regarding animal waste. Such statistics, as reported on July 18 by the press service of the Russian Ministry of Energy, were announced at an operational meeting on the results of work to coordinate the actions of all participants in the process when adjusting territorial waste management schemes.
Also, according to Rosprirodnadzor, 12 subjects have not yet provided information on the presence/absence of livestock waste management facilities in their plans. There are no facilities for recycling and neutralization of such waste on the territory of 2 constituent entities of the Russian Federation. Information is being processed for 1 constituent entity of the Russian Federation.
For most regions, the issues of education, placement, storage, and disposal of livestock waste are very relevant. This area was not regulated for a long time, which led to negative consequences and dissatisfaction of residents of the territories, notes the press service of the Ministry of Natural Resources.
The head of the department, Dmitry Kobylkin, advised not to forget that for violations of legislation in the field of waste management, as well as the inaction of officials, the legislation has been tightened, which will be applied in all cases identified. Amendments to the Code of Administrative Offenses of the Russian Federation adopted in June tightened, including, liability for non-compliance with environmental protection requirements when handling livestock waste.
According to Article 8.2.3. Code of Administrative Offenses of the Russian Federation “Non-compliance with requirements in the field of environmental protection when handling livestock waste”, maximum fines for non-compliance with requirements when disposing of such waste:
- for citizens will be up to 8,000 rubles;
- for officials - up to 70,000 rubles;
- for entrepreneurs - up to 90,000 thousand rubles or suspension of activities for up to 90 days;
- for legal entities - up to 800,000 rubles or suspension of activities for up to 90 days.
If actions (inaction) caused harm to human health or the environment or caused an epidemic (in the absence of a criminal component), the maximum fine is:
- for citizens it will be 9,000 rubles;
- for officials - up to 80,000 rubles;
- for entrepreneurs - up to 100,000 rubles or suspension of activities for up to 90 days;
- for legal entities - up to 900,000 rubles or suspension of activities for up to 90 days.
According to Article 6.35 of the Code of Administrative Offenses of the Russian Federation, failure to comply with sanitary and epidemiological requirements for the disposal of animal waste, resulting in harm to human health or the environment or the occurrence of an epidemic or epizootic, if these actions (inaction) do not contain a criminal offense, entails the imposition of an administrative fine:
- for citizens up to 14,000 rubles;
- for officials - up to 100,000 rubles;
- for entrepreneurs - up to 130,000 rubles or suspension of activities for up to 90 days;
- for legal entities - up to 1,000,000 rubles or suspension of activities for up to 90 days.
Reading time: 14 min
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As of June 17, 2019, a new article has been added to the Code of Administrative Offenses of the Russian Federation - 8.2.3 “Failure to comply with environmental protection requirements when handling livestock waste.” Fines for livestock waste - we will look at this in this article.
Previously, administrative penalties related to violations in the field of handling livestock waste were applied under Article 8.2. Code of Administrative Offenses of the Russian Federation, the minimum amount of a fine for a legal entity was 100.0 thousand rubles.
From now on, the minimum amount of a fine for a legal entity is from 250.0 thousand rubles....
What is animal waste?
Neither the Federal Law “On Production and Consumption Waste” nor the Federal Law “On Environmental Protection” contains the term “livestock waste”. Therefore, let us turn to the Federal Classification Catalog of Waste, according to which livestock waste includes:
1 12 000 00 00 0 Animal waste (including animal keeping activities)
1 12 100 00 00 0 - Waste from cattle breeding
1 12 110 00 00 0 - Cattle manure
1 12 110 01 33 4 - fresh cattle manure
1 12 110 02 29 5 - rotted cattle manure
1 12 121 11 20 4 - bedding waste from sawdust when keeping cattle
1 12 200 00 00 0 - Waste from breeding and keeping horses and other animals of the equine family.
1 12 210 00 00 0 - Horse manure
1 12 210 01 33 4 - fresh horse manure
1 12 210 02 29 5 - rotted horse manure
1 12 221 11 40 5 - bedding waste from sawdust and shavings when keeping horses is practically non-hazardous
1 12 300 00 00 0 - Waste from breeding camels and other animals of the camelid family
1 12 310 00 00 0 - Camel manure
1 12 310 01 33 4 - fresh camel manure
1 12 310 02 29 5 - rotted camel manure
1 12 400 00 00 0 - Waste from sheep and goat breeding
1 12 410 00 00 0 - Small cattle manure
1 12 410 01 29 4 - fresh small cattle manure
1 12 410 02 29 5 - rotted small cattle manure
1 12 500 00 00 0 - Waste from pig breeding
1 12 510 00 00 0 - Pig manure
1 12 510 01 33 3 - fresh pig manure
1 12 510 02 29 4 - rotted pig manure
1 12 520 01 39 4 - bedding waste from sawdust when keeping pigs
1 12 551 11 32 4 - liquid fraction of pig manure separation with a self-floating manure removal system
1 12 551 12 39 4 - solid fraction of pig manure separation with self-floating manure removal system
1 12 551 21 32 4 - liquid fraction of pig manure separation in a flush manure removal system
1 12 551 22 39 4 - solid fraction of pig manure separation in a flush manure removal system
1 12 552 11 32 4 - manure-containing wastewater during hydraulic removal of pig manure
1 12 552 12 32 3 - manure waste from a self-floating pig manure removal system
1 12 553 11 33 4 - sludge of manure drainage from pigsties when settling in manure storage tanks
1 12 700 00 00 0 - Poultry breeding waste
1 12 710 00 00 0 - Bird droppings
1 12 711 01 33 3 - fresh chicken manure
1 12 711 02 29 4 - rotted chicken droppings
1 12 711 12 29 4 - chicken manure, kept in a manure storage facility, disinfected
1 12 712 01 33 3 - fresh duck and goose droppings
1 12 712 02 29 4 - duck, rotted goose droppings
1 12 713 01 33 3 - fresh droppings of other birds
1 12 713 02 29 4 - rotted droppings of other birds
1 12 720 00 00 0 - Waste from poultry incubators
1 12 721 11 29 4 - shell chicken eggs when incubating broiler chickens
1 12 790 00 00 0 - Other waste from poultry breeding
1 12 791 01 33 4 - litter waste from sawdust when keeping birds
1 12 791 02 39 4 - waste of straw bedding when keeping birds
1 12 796 11 41 5 - eggshell flour
1 12 798 00 00 0 - Waste from wastewater treatment at local treatment facilities for poultry breeding
1 12 798 91 39 4 - sediment mechanical cleaning wastewater generated during poultry farming
1 12 798 92 39 4 - mixture of sediments from biological and flotation treatment of wastewater generated during poultry breeding
1 12 900 00 00 0 - Other waste from breeding and keeping animals
1 12 910 00 00 0 - Waste from animal breeding in fur farms and nurseries
1 12 911 00 00 0 - Manure of fur-bearing animals
1 12 911 01 33 4 - fresh manure of fur-bearing animals
1 12 911 02 29 5 - rotted manure of fur animals
1 12 912 11 40 4 - bedding waste from sawdust when keeping fur-bearing animals
1 12 970 00 00 0 - Waste from breeding and keeping dogs
1 12 971 01 33 4 - fresh dog excrement
1 12 971 11 40 4 - bedding waste from sawdust when keeping dogs
1 12 971 21 20 4 - waste from hay bedding when keeping dogs
1 12 975 11 32 4 - liquid waste from washing off sewage when cleaning enclosures
1 12 980 00 00 0 - Waste from breeding farm animals and birds in a mixture
1 12 981 11 33 4 - low-hazard mixture of farm animal manure and fresh bird droppings
1 12 990 00 00 0 - Waste from keeping wild animals in captivity
1 12 991 11 33 4 - manure of wild animals kept in captivity, fresh
1 12 992 11 30 4 - bedding waste from sawdust when keeping wild animals in captivity.
Thus, Article 8.2.3 of the Code of Administrative Offenses of the Russian Federation can be applied to all of the above waste.
Part 1 of Article 8.2.3 of the Code of Administrative Offenses of the Russian Federation
1. Failure to comply with environmental protection requirements when collecting, accumulating, transporting, processing, recycling or neutralizing animal waste -
entails the imposition of an administrative fine on citizens in the amount of two thousand to three thousand rubles; for officials - from thirty thousand to forty thousand rubles; on persons carrying out entrepreneurial activity without forming a legal entity - from fifty thousand to sixty thousand rubles or administrative suspension of activities for a period of up to ninety days; for legal entities - from two hundred and fifty thousand to three hundred and fifty thousand rubles or administrative suspension of activities for a period of up to ninety days.
What applies to non-compliance with environmental protection requirements when collecting, accumulating, transporting, processing, recycling, and neutralizing production waste?
In fact, there are no specific environmental requirements for the management of livestock waste; there are requirements prescribed in sanitary and epidemiological legislation.
According to the above sanitary rules:
5.4. Methods and means for removing waste from premises must ensure their timely removal. Non-potable water must be used for hydroflushes.
5.5. Liquid manure and manure waste must be subjected to treatment: mechanical, artificial and natural biological treatment or physical and chemical treatment. The choice of cleaning is dictated by local conditions.
5.6. The solid fraction of liquid manure is subject to biothermal disinfection in piles with subsequent disposal in the fields, the liquid fraction - in storage tanks with further use on farmland. Treatment facilities should include waterproof storage tanks for activated sludge and raw sludge.
5.7. When zoonotic diseases occur infectious diseases manure must be disinfected by physical, chemical or biological methods. Each disadvantaged livestock farm must be provided with technical means for the disinfection of manure and its fractions (liquid and solid), as well as centrate, active excess sludge in accordance with the all-Union standards for the technological design of manure removal and preparation systems for use.
5.8. Disinfection of cattle and pig manure biological method should be carried out by keeping it for a long time - for 12 months. The period for deworming semi-liquid and liquid manure in open storage facilities using a biological method should be 6 months for cattle waste, 12 months for pig-breeding enterprises, and 5 months for semi-liquid cattle manure in underground manure storage facilities.
5.9. The solid fraction of manure from pig farms and cattle complexes, bedding manure, as well as compost should be disinfected biothermally on waterproof areas with a hard surface in specially constructed piles (their height is up to 2 m, width - up to 2.5 m, length - arbitrary , covering the top around the perimeter with a layer of earth 15 - 20 cm thick). The holding time of waste in piles when the temperature reaches 60 °C in all parts of the compost must be at least 1 month. in the warm season and for at least 2 months. - during the cold season. Manure infected with pathogens of particularly dangerous infections should be disinfected in accordance with current veterinary regulations.
5.10. Manure and manure drainage that meet reclamation, agronomic, veterinary, water protection and sanitary-hygienic requirements must be used on agricultural fields as fertilizers. Storm and melt water from walking areas and the territory of the complex are subject to collection, quarantine, purification and disposal.
5.11. The commissioning of production premises of livestock enterprises must be carried out simultaneously with the system for processing and using manure and manure waste.
5.12. Areas intended for the introduction of waste must be diked along open drains. Drainage runoff should be directed to retention ponds or reused for irrigation. All types of soils are suitable for irrigation fields, except gravelly, gravelly, and highly saline soils.
5.13. Distribution of the uninfected liquid fraction of manure on irrigation fields should be carried out using surface methods and mobile means.
5.14. Systems for processing and transporting waste to agricultural fields must include the mandatory use of special flow metering devices.
5.15. In projects of agricultural irrigation fields and fertilizing irrigation fields, it is necessary to provide engineering structures for collecting surface runoff from irrigated areas. If necessary, they are equipped with upland ditches to intercept surface runoff from overlying areas.
5.16. The use of liquid manure and manure drainage as fertilizer is not permitted in cases where agricultural land is located:
a) within the resort sanitary protection district;
b) on the territory of the 1st and 2nd zones of sanitary protection zones of underground sources of domestic water supply;
c) within a radius of 1 km from the water intake from a surface water source;
d) in the area of unprotected groundwater suitable for drinking purposes.
Requirements for the collection, accumulation, processing, and disposal of animal waste can be partially specified in the regulations for the production of fertilizers, in the technical specifications for fertilizers.
If the technical specifications and regulations regarding animal waste, or the requirements contained in the sanitary and epidemiological rules are not observed, the enterprise may be brought to administrative liability under Part 1 of Article 8.2.3 of the Code of Administrative Offenses of the Russian Federation.
Part 2 of Article 8.2.3. Code of Administrative Offenses of the Russian Federation
Code of Administrative Offenses of the Russian Federation Article 8.2.3. Failure to comply with environmental protection requirements when handling livestock waste
2. Repeated commission of an administrative offense under Part 1 within a year of this article, -
entails the imposition of an administrative fine on citizens in the amount of three thousand to four thousand rubles; for officials - from forty thousand to fifty thousand rubles; for persons carrying out entrepreneurial activities without forming a legal entity - from sixty thousand to seventy thousand rubles or administrative suspension of activities for a period of up to ninety days; for legal entities - from three hundred fifty thousand to four hundred fifty thousand rubles or administrative suspension of activities for a period of up to ninety days.
I think no comments are needed here.
Part 3 of Article 8.2.3. Code of Administrative Offenses of the Russian Federation
3.Actions (inaction) provided for in Part 1 of this article, resulting in harm to human health or the environment or the occurrence of an epidemic or epizootic, if these actions (inaction) do not contain a criminal offense, -
entail the imposition of an administrative fine on citizens in the amount of four thousand to five thousand rubles; for officials - from fifty thousand to sixty thousand rubles; for persons carrying out entrepreneurial activities without forming a legal entity - from eighty thousand to ninety thousand rubles or administrative suspension of activities for a period of up to ninety days; for legal entities - from five hundred thousand to six hundred thousand rubles or administrative suspension of activities for a period of up to ninety days.
This part can only be used in surface and underground water bodies, to catchment areas, to the subsoil and to the soil.
Part 4 of Article 8.2.3. Code of Administrative Offenses of the Russian Federation
4.Failure to comply with environmental requirements when disposing of livestock waste -
entails the imposition of an administrative fine on citizens in the amount of five thousand to seven thousand rubles; for officials - from forty thousand to sixty thousand rubles; for persons carrying out entrepreneurial activities without forming a legal entity - from sixty thousand to eighty thousand rubles or administrative suspension of activities for a period of up to ninety days; for legal entities - from five hundred thousand to seven hundred thousand rubles or administrative suspension of activities for a period of up to ninety days.
Waste disposal means its storage and burial.
waste storage - storage of waste in specialized facilities for a period of more than eleven months for the purposes of recycling, neutralization, and burial.
waste disposal - isolation of waste that is not subject to further disposal in special storage facilities in order to prevent the release of harmful substances into the environment.
According to Part 4 of Article 8.2.3. The Code of Administrative Offenses of the Russian Federation will attract enterprises rather for storing waste. To avoid this part of the article, it is necessary not to store animal waste for a period of more than 11 months.
Part 5 of Article 8.2.3 of the Code of Administrative Offenses of the Russian Federation
5. Repeated within a year committing an administrative offense provided for in Part 4 of this article -
entails the imposition of an administrative fine on citizens in the amount of seven thousand to eight thousand rubles; for officials - from sixty thousand to seventy thousand rubles; for persons carrying out entrepreneurial activities without forming a legal entity - from eighty thousand to ninety thousand rubles or administrative suspension of activities for a period of up to ninety days; for legal entities - from seven hundred thousand to eight hundred thousand rubles or administrative suspension of activities for a period of up to ninety days.
The management of livestock waste remains an important issue for environmental users, and for many the answer is not at all obvious. The legislation is structured in such a way that, from one point of view, manure and droppings are considered waste, and from the other, raw materials and goods, so at the same time different requirements apply to them. Milknews figured out how the waste management sector is regulated and how enterprises work with it in practice.
How does regulation work?
1. Waste as waste
Industrial waste is divided into 5 hazard classes according to the degree of negative impact on the environment; their list is contained in the Federal Classification Catalog of Waste, abbreviated as FKKO. In each group of livestock waste (cattle, horses, pigs, camels, etc.) the types of manure at different stages of rotting are prescribed - fresh manure (newly formed) and rotted (past natural process getting rid of moisture and decomposition). In accordance with the “condition” of the waste, they are assigned a certain hazard class, for example, fresh manure of cattle, small animals and wild animals after overheating moves from the fourth to the fifth hazard class, and fresh pig manure and droppings - from the third to the fourth.
2. Waste as fertilizer
At the same time, manure and droppings are considered organic fertilizers - there is a separate GOST R 53042-2008 “Organic Fertilizers”, which specifies its characteristics, as well as guidelines on preparing waste for use. The requirements are as follows: waste must be removed mechanically or hydraulically, transported by pumps and pipelines, and it must be neutralized either by composting in piles for six months or by anaerobic digestion in digesters.
Waste prepared for use as fertilizer must be free of pathogens and weed seeds, and the amount of nutrients must be normalized in accordance with veterinary and environmental requirements.
Can the waste be considered safe?
Member of the Academic Council of the All-Russian Research Institute organic fertilizers and peat, candidate of biological sciences, head of the ecology department Sergei Tarasov explained to Milknews why two requirements are simultaneously applied to waste. In accordance with the Federal Law “On Production and Consumption Waste”, waste refers to substances that are removed, intended or subject to disposal, at the same time, according to GOST 30772-2001, waste disposal is the collection, sorting, transportation and processing of waste with its burial or destruction.
“Based on these definitions, cattle manure cannot be classified as waste, since it is not destroyed and is not subject to burial, but is used either as organic fertilizer or raw material for their production. Currently, according to the clarification of the Ministry of Natural Resources, manure is defined as a by-product of production, which must have accompanying documentation with safety requirements: product passport - technical conditions,
establishing uniform requirements for their safety and quality, technological production regulations, test reports and accounting of volumes of production and use of organic fertilizers on the farm. In practice, the documents that regulate the safety of manure today are GOST R and the interstate GOST “Organic fertilizers based on livestock waste. Specifications”, which will soon be changed to apply only to manure and droppings.
These documents stipulate that the safety of cattle manure is regulated by biological, toxicological and radiological indicators - if the manure produced on farms meets the requirements of the standards, this product, in accordance with the instructions of VNIIVSGE, can be used in the form of fertilizer after undergoing quarantine. If the manure does not meet the requirements, the by-product is processed in accordance with standard technologies for the production of bedding-free manure and solid organic fertilizers,” Tarasov said.
Fifteen years ago, the All-Russian Research Institute of Veterinary Sanitation, Hygiene and Ecology conducted a study, as a result of which scientists came to the conclusion that agricultural waste is low-hazard and non-toxic, since it consists of organic matter. Then Rosprirodnadzor, which supervises the FKKO, rejected the recommendations of scientists, so the hazard classes of waste have not changed to this day, and all activities related to waste are subject to licensing.
In September 2018, at a meeting with Deputy Minister of Agriculture Dzhambulat Khatuov, the head of the laboratory of animal hygiene and environmental protection of VNIIVSGE Vladimir Tyurin defended the position of the institute, stating that litter and manure can be classified as low-hazard waste. When asked by Milknews to explain how the safety of the waste was justified, VNIIVSGE responded that they were no longer dealing with this problem.
Tarasov does not share the position of the researchers and does not believe that the hazard class of livestock waste needs to be reduced. According to him, without neutralization, waste cannot be considered safe, since unrotted manure releases ammonia, hydrogen sulfide and toxic gases. “If theory is not enough, there are also practical examples - in Soviet times, an accident occurred in one of the Suzdal farms; repairmen without gas masks climbed into the hatches of manure removal channels and died,” Tarasov summed up.
What are the challenges for the industry?
If we consider manure as an industrial waste, then the legislation requires its owner to develop a waste passport in accordance with the hazard class, conduct an environmental assessment of the design documentation of the facilities (!), obtain a separate license for activities related to waste of a certain hazard class (!!), enter manure storage facilities into the state register of waste disposal facilities (!!!) and, of course, pay a fee for negative impact on the environment.
Livestock waste is usually stored for about a year, so storage facilities must be entered into the GRORO (state register) and obtain a license. The law is structured in such a way that, for example, the use of rotted manure of the fifth hazard class from your cow as fertilizer for fields falls under the concept of disposal, and therefore must be licensed. The re-rotation of waste in lagoons, in turn, according to the law, fully falls within the scope of their neutralization, which, in turn, requires undergoing an examination and, again, obtaining a license.
Even if an enterprise has its own storage facilities that meet all the requirements and have all the necessary installations for waste disposal, but is located outside the main production site, it is necessary to obtain a license for both facilities. In addition, transport of manure between sites and waste preparation activities must also be licensed because they fall within the definition of waste treatment.
The costs of large enterprises for waste processing can reach up to 400-1500 rubles per ton, which on an annual basis can significantly affect the economy, and for small and medium-sized enterprises, in turn, it may be expensive to even obtain a license, not to mention the purchase of the necessary equipment . Websites that provide services for obtaining licenses for all types of activities offer to pay from 250 thousand to 2 million rubles for assistance in obtaining a license, depending on the hazard class and region.
In addition to the waste license, you will need an expert sanitary and epidemiological report, which is provided free of charge to the law. Websites with legal consulting services offer “help with registration” or get an urgent opinion for 30-150 thousand rubles. Registration and use of agrochemicals from manure and litter costs more - from 2 million rubles with a registration period of 6 months. To these costs should be added the cost of development and all the necessary equipment for processing.
How does a business find solutions?
As Ramon Schenk, Deputy General Director for Production at EkoNiva-APK Holding, told Milknews, the holding’s agricultural enterprises work with manure as follows: the manure is placed in lagoons, where separation into solid and liquid phases occurs around the clock. The solid fraction goes to bedding for animals, the liquid fraction goes completely to fertilizer, which is applied not superficially, but subsoil, through a hose system.
Dmitry Gritskikh, head of the environmental protection department of EkoNiva-APK Holding LLC, told Milknews that despite the seemingly transparency of regulatory requirements, there are contradictions between 89-FZ and regulations of other government departments.
“So, 99-FZ “On Licensing” is clearly aimed at the type of activity (OKVED). In our case, the main activity is cattle breeding, and not waste management and making a profit from it. By this logic, we do not need a license.
The second important point outlined in 89-FZ is that waste refers to substances and objects that are disposed of. However, in our case, the substances called “cattle manure” and “rotted cattle manure” remain in a closed cycle of auxiliary production that supports the main activity. Thus, we do not remove manure, but use it. Accordingly, Article 1 of 89-FZ conflicts with Art. 14. Three years ago, Article 1 stated that a legal entity independently determines what is waste in the process of production activities, but now it immediately states that waste is substances and objects that are disposed of,” Gritskikh said.
According to the expert, there is another contradiction in the legislation: according to the Federal Law “On Technical Regulation” legal entities in production processes, residues of raw materials and materials may be involved in production circulation.
“Thus, if an enterprise understands that it can use any by-product of its activities for its own benefit, then it is obliged to develop and approve Technological Regulations for the main production and Technological Regulations for auxiliary production. The latter, in our case, is the Technological Regulations for the production of bioorganic fertilizer based on cattle manure. Having developed specifications, we can safely use the by-product as a raw material, but we return to FKKO and see that at the legislative level, manure remains a waste at all stages of its occurrence and processing. Therefore, I believe that 89-FZ needs to be finalized in this part and break the fine line between the concepts of “waste” and “raw materials,” the expert comments.
“Work is underway to improve legislation. Last fall, I spoke as a representative of the Voronezh region at a meeting at the Ministry natural resources Russia with the participation of the largest agricultural enterprises, where he made his proposals on pressing issues and was heard,” concludes Gritskikh.
The history of the veterinary service in Russia goes back almost two centuries and goes back to the beginning of the 19th century, when a medical board was established in every provincial city and the position of a veterinarian was introduced.
At the medical board of the Kazan province, the position of a veterinarian was introduced in 1822, and 60 years later, in 1882, the zemstvo veterinary service was created as a separate organizational structure under the provincial government.
At the beginning of the 20th century, several separate veterinary services functioned in the Kazan province: government veterinary medicine, which included provincial and district veterinary inspectors, city, zemstvo, district, provincial, military, factory, volunteer and other services under various departments. They were all scattered and there was no coherence in their work.
By 1913, the Kazan City Veterinary Department had in its structure a veterinary hospital, a meat inspection station, a veterinary and sanitary control point and a diagnostic room. At the veterinary service there was a slaughterhouse, a recycling plant and a forge from the fire service.
IN Soviet time The city veterinary service has undergone a number of changes and transformations, and is currently part of the system of the state veterinary service of the Republic of Tatarstan. The State Budgetary Institution “State Veterinary Association of Kazan” carries out its activities in accordance with the Constitution and Civil Legislation of the Russian Federation, the federal Laws “On Veterinary Medicine”, “On Non-Profit Organizations”, the Law “On Veterinary Affairs in the Republic of Tatarstan”, other regulations - legal acts RF and RT, as well as orders, instructions and instructions of the Main Directorate of Veterinary Medicine under the Cabinet of Ministers of the Republic of Tatarstan.
The structure of the association includes: veterinary and sanitary examination laboratories, veterinary centers, local veterinary hospitals, a disinfection squad, a department for the safety and quality of products and raw materials of animal origin, a pharmacy, a department for organizing veterinary affairs, etc.
Laboratories of veterinary and sanitary examination and checkpoints examinations are carried out at food markets
products of animal and plant origin. The main activity of veterinary and sanitary examination laboratories is to protect humanity from terrible diseases that are common to humans and animals, the spread of which can be sick animals. The veterinary service guards the quality of products of animal and plant origin imported into the territory of Kazan. There is a mobile laboratory that serves agricultural fairs and exhibitions.
Local veterinary hospitals and veterinary centers are engaged in the prevention, diagnosis and treatment of animal diseases.
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