Daniil Bobkov: The Ministry of Agriculture answered the most popular questions about the law on manure and litter

“The document consists of recommendations from the Department of Animal Husbandry and Breeding regarding exactly how an economic entity should act in accordance with 248-FZ of 07/14/2022. Let me remind you that the law is voluntary and provides farmers with an additional option - but not an obligation - in terms of manure management. The agency clarified that there is no need to build any separate treatment facilities for runoff from animal housing facilities - previously such a risk was seen in a literal reading of the requirements for manure handling. According to the position of the Department, if the runoff from keeping animals (for example, when washing) goes into the lagoon and does not leave it anymore, the requirements are considered met - there is no need to create a separate treatment system.

In addition, the nuances of submitting an annual notification of classifying manure as LLS (rather than waste) have been clarified: it is indicated that the date of formation of these substances can be drawn up in the format of a period, and not an exact number in the calendar. It is spelled out how best to indicate information in the “purpose of use” column, how to calculate the amount of LLP generated for the period, etc. It is pointed out that it is necessary to refine the existing technical specifications for manure management in order to bring them into line with the new regulation.

In addition, an important issue has been clarified about the absence of the need to issue a VVD for reworked PLS. In case of recognition of WPP as a waste, based on the text of the clarifications, ROSSELKHOZNADZOR will be obliged to transfer information about this fact to Rosprirodnadzor within a certain period of time. I note that violation of the approved requirements will soon entail liability under the Code of Administrative Offenses of the Russian Federation (the amendments are already in the State Duma of the Federal Assembly of the Russian Federation), while the payment of an administrative fine and the recognition of LLP as waste does not exempt business entities from the requirements of already environmental legislation on production and consumption waste. We are also waiting for answers to a few more questions related to the analysis of LPG for pathogenic microflora - another letter from the Ministry of Agriculture of RUSSIA is in the process."