sewage sludge directive

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Report on the Implementation of the Sewage Sludge Directive 86/278/EEC

May 2009

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Contents

1 Introduction .....................................................................................................................3 1.1 The Sewage Sludge Directive ..................................................................................3 1.2 Remarks about this report ........................................................................................3

2 Incorporation into national law......................................................................................4

3 Implementation of the Directive.....................................................................................4 3.1 Specific conditions when sludge from septic tanks and other similar installations is used ..................................................................................................................................4 3.2 Concentration limit values for heavy metals in soil, sludge and maximum annual loads ..................................................................................................................................7 3.3 Maximum quantities of sludge (dry matter) applicable to soil .................................19 3.4 Conditions under which less stringent concentrations of heavy metals are permitted ................................................................................................................................21 3.5 Description of the technologies employed for treating sludge ................................23 3.6 Frequency of analysis.............................................................................................26 3.7 Specific conditions for authorising injection or working into the soil of untreated sludge ................................................................................................................................28 3.8 Periods of prohibition of spreading before grazing or harvesting ...........................29 3.9 Limit values or other measures for soils with a pH below 6....................................32 3.10 Soil analyses for other parameters than pH and heavy metals ..............................33 3.11 Minimum frequency of soils analysis ......................................................................35 3.12 Quantities of sludge produced, sludge used in agriculture and average concentration of heavy metals in sludge.............................................................................37 3.13 Exemptions granted to small sewage treatment plants ..........................................38

4 Resumé ..........................................................................................................................38 4.1 Mode of reporting by the Member States ...............................................................39 4.2 Possible Gaps and Implementation Issues.............................................................39

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1 Introduction

1.1 The Sewage Sludge Directive

The 86/278/EEC on Sewage Sludge, as amended, has a double purpose: to ensure that human beings, animals, plants and the environment are fully safeguarded against the possibility of harmful effects from the uncontrolled spreading of sewage sludge on agricultural land; and to promote the correct use of sewage sludge on such land. The main provisions of the Directive for Member States within the context of this implementation report are:

• Conditions for using sewage sludge in agriculture for the protection of human health and nature.

• Concentration limit values for heavy metals in soils, sludge and maximum annual loads

• Maximum quantities of sludge applicable to soil • Conditions under which less stringent concentrations of heavy metals are

permitted • Use of sludge treatment technologies • Frequency of analysis of sludge • Authorisations for the use of untreated sludge on soil • Periods of prohibition of spreading sludge before grazing or harvesting • Limit values or other measures for soils with a pH below 6. • Soil analyses for other parameters than pH and heavy metals • Minimum frequency of soil analyses • Up-to-date records on quantities of sludge produce, sludge used in

agriculture and average concentration of heavy metals in sludge • Exemptions granted to small sewage treatment plants

1.2 Remarks about this report

This report is a synopsis of the responses by Member States to the questionnaire (Commission Decision 97/622/EC) covering the period 2004-2006. The synopsis summarizes these responses article per article and country per country and observes a limit of 100 words per response. The report is only based on the responses, for practical reasons the report does not differentiate between direct quotes from the Member States’ responses and re-phrased or passages shortened with regard to the 100-words limit. All due care has been taken in completing this synopsis and in reflecting the quintessence of the responses. However, please mind that the original responses from the Member States constitute the only “authentic” document as submitted by the Member States.

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The report produced is solely based on the information made available by the Commission.

2 Incorporation into national law

All reporting Member States confirmed that they have provided the Commission with details of the current laws and regulations in force to incorporate the Directive 86/278/EEC on sewage sludge, as amended, into national law.

All reporting Member States, apart from Greece and Latvia, have notified the Commission of measures adopted pursuant to Article 5 to ensure that sewage sludge may not be used in soils with concentrations of one or more heavy metals that exceed the agreed limit values. In Greece no national measures have been set so far, because sewage sludge has not been used in agriculture. In the case of Latvia “No such situation has occurred / no such precedent has been set”.

All reporting Member States, apart from Greece, Portugal, Spain and Ireland, have notified the Commission of any adopted measures pursuant to Article 12 that are stricter than those provided for in the Directive. In its response Greece explains what the stricter limits are but not the reasons for not notifying the Commission of these. Portugal, Ireland and Spain have not notified the Commission because they do not have any stricter measures in place.

Resumé: All Member States have provided the Commission with details on the transposition of the Directive. Apart from Greece and Latvia, all Member States have notified the Commission of measures according to Article 5. Most Member States have notified the Commission on stricter measures. Portugal, Spain and Ireland do not have stricter measures in place but Greece has chosen not to inform the Commission of the stricter limits.

3 Implementation of the Directive

3.1 Specific conditions when sludge from septic tanks and other similar installations is used

According to Article 3(2) residual sludge from septic tanks may be used in agriculture subject to any conditions that the Member State concerned may deem necessary for the protection of human health and the environment. Member States were asked if any specific conditions have been deemed necessary for the protection of human health and the environment in accordance with the first indent of Article 3 (2), when using sludge residues from septic tanks and other similar installations for the treatment of waste water for agricultural purposes.

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Austria: The application of sludge may only occur on the basis of a certificate in the region of Steiemark based on evidence and that the limit values are not exceeded. The sludge has to also have certain standards of hygiene. The other regions refer to a paragraph in the legislation.

For Bulgaria the requirements governing the use of sludge from septic tanks and other similar installations for the treatment of waste water for agricultural purposes are the same as those governing the use of sludge from wastewater treatment plants. The sludge must be treated and meet the microbiological and parasitological requirements set out in Annex 3 of the transposing Regulation, as well as the requirements concerning heavy metal content. As regards the use of sludge in agriculture, two permits are required – one issued by the Ministry of Environment and Water (as regards the quality and composition of the sludge) and one by the Ministry of Agriculture and Food Supply (as regards the composition of the soil, the permitted quantity of sludge to be applied, and the application period).

In Cyprus the use of sludge from wastewater treatment plants for agricultural purpose is regulated by the Water Pollution Control Laws 2002-2006 and the Water Pollution Control (Use of Sludge in Agriculture) Regulations of 2002 (No. 517/2002) and the Code of Good Agriculture Practice Decree (No. 407/2002). Apart from the requirements set in the Directive, the Pollution Control Law, promotes the licensing of sludge management, including its use in agriculture. Furthermore, the Code of Good Agriculture Practice includes additional requirements.

Czech Republic: If sludge is not treated and does not meet the requirements of Decree No 382/2001 Coll. implementing Act No 185/2001 Coll. on waste, which is consistent with the Directive, it must not be used in agriculture.

In Denmark’s case, sludge residues from septic tanks must be treated either by stabilisation (anaerobic or aerobic digestion, composting, chemical stabilisation with lime/chalk or mineralisation) by composting at 55 degrees in minimum 2 weeks or by a controlled process, which secures hygienic. This could be thermal treatment at minimum 70 degrees in one hour, or treatment with quicklime so the material reaches a pH at 12 in minimum 3 months of digestion under predetermined specifications. In Estonia the use of untreated sludge in agriculture is prohibited.

Finland, Luxemburg, Spain and Flanders did not respond to this question.

In France, an obligation is in place to bury such sludge in the soil immediately after application using equipment adapted for that purpose, or for such sludge to be treated to meet certain standards of hygiene.

Under German water law, the contents of septic tanks with no drainage facilities (including similar installations) must be handed over to the local waste water management authorities and therefore cannot be used directly for agricultural purposes.

Greece: Up to now no sludge residues from septic tanks have been used in agriculture. In general, sewage sludge has not been used in agriculture, with an exception of very small quantities that have been used in the frame of research projects and few pilot studies.

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Hungary: Not allowed

Ireland: Article 3 of the Waste Management (Use of Sewage Sludge in Agriculture) Regulations 1998 states that sludge (definition includes "residual sludge from septic tanks and other similar installations) shall not be used or supplied for use in agriculture except in accordance with these Regulations.

In Italy the Decree No 99/1992, transposing the Directive, regulates the agricultural use of sewage sludge. Irrespective of its type or origin, the use of sludge in agriculture is authorised only if: a) it has been treated; b) it is suitable as soil fertiliser and/or improver and corrector; c) it does not contain substances that are toxic, harmful and/or persistent and/or bioaccumulable in concentrations that are harmful for the land, crops, animals, people and the environment in general.

In the case of Latvia sewage sludge from septic tanks may not be used in its pure form. Instead it must be transferred to treatment plants and processed with sewage sludge used in agriculture in accordance with Section 29 of Cabinet Regulation No 362. Treated sewage sludge and compost made from treated or untreated sewage sludge and whit a dry matter has a heavy-metal concentration by mass which does not exceed the limit concentrations referred to in Annex 9 to this Regulation may be used as fertiliser on agricultural land.

Lithuania: A person intending to use sludge as a fertiliser (in agriculture or for energy crops) must have a fertilisation plan approved by the regional environmental protection department within the administrative area of which fertilisation will be carried out. A fertilisation plan is to be drawn up for no longer than 6 months. The response lists several restrictions from the transposing regulation required for a fertilisation plan. It is unclear from the response to which sewage sludge category septic tank residues belong to and hence it is not possible to assess what measures are in place.

Netherlands: All sludge applied in agriculture must be treated by biological, chemical or thermal means, through long-term storage or any other suitable method which kills off the majority of the pathogens present in the waste water sludge.

The response by Poland is “not applicable”.

Portugal refers to the answer given in the preceding three-year period.

Romania: The Directive 86/278/CEE has been transposed through the Order of the Minister of Agriculture, Forests, Waters and Environment no. 344/2004 for the approval of Technical Guidelines on the protection of the environment and in particular of the soils when sewage sludge is used in agriculture(MO No. 344?2004). In accordance with the MO No 344 /2004, untreated sludge cannot be use in agriculture.

Slovakia: No specific conditions have been laid down. The application of such sludge residues on agricultural land is prohibited.

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Slovenia: The Decree stipulates that the input of sludge into farmland requires an environmental permit and lists a number of restrictions but septic tanks are not mentioned in the response.

Sweden: No specific conditions have been deemed necessary according to Article 3 (2), when using sludge residues defined in 2 a) ii). Sweden has equal requirements for sludge defined in 2 a) i) and 2 a) ii) referring to Article 3 (1).

UK: See Regulation 4 of the Sludge (Use in Agriculture) Regulations 1989.

Resumé: The measures used are based on equal requirements for all sludge, an outright prohibition of using sludge from a septic tank or specific measures required for sludge from a septic tank. However in the case of Cyprus it is unclear if sewage sludge from septic tanks would be covered by the restricting legislation and in the case of Lithuania it is unclear to which sludge category, setting different conditions for use, septic tank sludge belongs to. In addition Spain, Luxemburg, Finland and Flanders have not answered the question. Poland’s answer is “not applicable” and UK only refers to its Regulation. The reply from Greece gives the impression that sewage sludge has not been used in agriculture “up to now”. This is contradicted in other responses by Greece and hence it is unclear what the actual situation is regarding the use of sewage sludge in agriculture.

3.2 Concentration limit values for heavy metals in soil, sludge and maximum annual loads

3.2.1 Heavy Metals in Soil

Article 5.1 and Annex 1 A set the limit values prohibiting the use of heavy metals in soil.

Member States were asked to fill in national limit values required by Article 5.1 and Annex I A

All assessed Member States provided information apart from the Czech Republic. .

The response by Greece points out that the maximum values are registered due to technical problems at inserting the range of values. In the JMD 80568/91 a range of values in the limit values of toxic elements in the soil and sludge have been adopted as it is in the Directive.

All national limits have been combined in the Annex I table of this report. From this Annex a table has been produced based on three ranges (high medium and low) of national limit values for each compound.. In cases were a Member State has different national limit values based on pH, the value for pH 7 is given. In cases were a Member State gives a range of values without reference to pH, the country will be grouped based on the highest limit value. Austria has submitted their response per regions and the country is allocated in the tables based on the highest value.

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The intention is that this will provide a better overview of national limit values as well as indicate possible “geographical groups”. It might also identify countries that seem to belong to a “wrong group” based on stricter/less strict limits.

National Limit values for cadmium (mg/kg dry matter)

Member States (national limit value in brackets) (Directive Annex IA limit value is 1 -3)

High: Limit values ≥ 2 Austria (2), Bulgaria (2), Cyprus (1-3), Estonia (3), France (2), Greece (3), Luxemburg (1-3), Poland (3), Portugal (3), Romania (3), Sweden (2), UK (3), Spain (3)

Medium: 1 ≤ limit values < 2

Germany (1.5), Hungary (1), Ireland (1), Italy (1.5), Lithuania (1.5), Slovakia (1), Slovenia (1), Denmark (1.5)

Low: Limit values < 1 Finland (0.5), Flanders (0.9), , Latvia (0.9),

Table 1. National Limit values for cadmium

Of countries in same geographical areas, there is a clear difference in national limit values between the Baltic countries, Ranging from Latvia’s 0.9 to Estonia’s 3. The difference between Finland (0.5) and Sweden (2) seems surprisingly large as well.

National Limit values for copper(mg/kg dry matter)

Member States (national limit value in brackets) (Directive Annex IA limit value is 50 -140)

High: Limit values ≥ 120 Cyprus (50-140), Greece (140), Luxemburg (50-140), Spain 210


Austria (100), Bulgaria (100), France (100), Italy (100), Lithuania (80), Portugal (100), Romania (100), UK (80)

Low: Limit values < 80 Denmark (40), Flanders (49), Germany (60), Hungary (75), Ireland (50), Poland (75), Slovakia (50), Slovenia (60), Sweden (40), Estonia (100),

Table 2. National Limit values for copper

Most of the Member States have set national limit values that are lower than those allowed by the Directive. The national limit value for copper for Spain is over the limit allowed by Annex 1A. .

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National Limit values for nickel (mg/kg dry matter)

Member States (national limit value in brackets) (Directive Annex IA limit value is 30-75)

High: Limit values ≥ 60 Austria (60) ,Bulgaria (60), Cyprus (30-75), Finland (60), Greece (75), Italy (75), Latvia (15-70), Lithuania (60), Luxemburg (30-75), Portugal (75), Spain (112),


Estonia (50), France (50), Germany (50), Poland (50), Romania (50), Slovakia (50), Slovenia (50), Sweden (50), UK (50)

Low: Limit values < 45 Denmark (15), Flanders (18), Hungary (40), Ireland (30),

Table 3. National Limit values for nickel

The national limit value for nickel for Spain is over the limit allowed by Annex 1A. Denmark’s and Flanders’ limit values for Nickel is considerably lower than those of other Member States, especially if you contrast Denmark’s limit value with the other Nordic countries.

National Limit values for lead (mg/kg dry matter)


High: Limit values ≥ 200 Cyprus (50-300), Greece (300), Luxemburg (50-300), Portugal (300), Spain (300), UK (300)


Austria (100), Bulgaria (80), France (100), Germany (100), Hungary (100), Italy (100), Sweden (100), Estonia (100)

Low: Limit values < 100 Denmark (40), Finland (60), Flanders (56), Ireland (50), Latvia (20-40), Lithuania (80), Poland (80), Romania (50), Slovakia (70), Slovenia (85),

Table 4. National Limit values for lead

A majority of Member States have set limit values that are considerably below those allowed by the Directive. The limit value for Sweden is much higher than that of Finland and Denmark. There is also big difference between Ireland and the UK.

National Limit values for zinc (mg/kg dry matter)


High: Limit values ≥ 200 Austria (300), Bulgaria (250), Cyprus (150-300), France (300), Germany (200), Greece (300), Hungary (200),

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Italy (300), Lithuania (260), Luxemburg (150-300), Portugal (300), Romania (300), Slovenia (200), Spain (450), UK (200), Estonia (300)


Finland (150), Flanders (162), Ireland (150), Poland (180), Slovakia (150),

Low: Limit values < 150 Denmark (100), Sweden (100), Latvia (50-100)

Table 5. National Limit values for zinc.

National limit values for Zinc vary a lot between the Baltic countries. The national limit value for Spain exceeds that allowed by Annex IA

National Limit values for Mercury (mg/kg dry matter)

Member States (national limit value in brackets) (Directive Annex IA limit value is 1-1.5)

High: Limit values ≥ 1.2 Austria (1.5), Cyprus (1 - 1.5), Flanders (1.3), Luxemburg (1-1.5), Greece (1.5), Poland (1.5), Portugal (1.5), Spain (1.5),

Medium: 0.8 ≤ limit values < 1.2

Bulgaria (1), France (1), Germany (1), Ireland (1), Italy (1), Lithuania (1), Romania (1), UK (1)

Low: Limit values < 0.8 Denmark (0.5), Finland (0.2), Hungary (0.5), Latvia (0.1-0.5), Slovakia (0.8), Sweden (0.3), Estonia (0.5)

Table 5. National Limit values for mercury

Most of the Member States have set limit values lower than those allowed by the Directive. National limit values for Mercury are quite different between the Baltic countries. The national limit values for Flanders for mercury are surprisingly high, compared to its normally low limit values for other heavy metals.

National Limit values for chromium (mg/kg dry matter)

Member States (national limit value in brackets) (Directive Annex IA does not set a limit values)

High: Limit values ≥ 200 Bulgaria (200), Finland (200), Luxemburg (100-200), Spain (150), Portugal (200),


Austria (100), France (150), Germany (100), Poland (100), Romania (100), Slovenia (100), Sweden (100), Estonia (100)

Low: Limit values < 100 Denmark (30), Flanders (46), Ireland (0), Latvia (40-

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90), Lithuania (80), Slovakia (60), UK (0)

Table 6. National limit values for chromium

Most of the Member States have set limit values lower than those allowed by the Directive. Ireland and the UK have indicted that their National limit values are 0. It is assumed that this means that a limit value has not been set. There is also a wide spread of limit values between the Nordic countries. Greece, Italy and Cyprus have not set limits .for chromium.

Resumé: All assessed Member States provided information apart from the Czech Republic. Greece has inserted maximum values instead of a range of values due to technical problems. From the tables we can see that there is a wide variation in limit values. There are also surprisingly large differences in limit values between similar geographical areas, such between the Baltic states for cadmium (Latvia 0.9, Lithuania 1.5 and Estonia 3) or between the Nordic countries for cadmium (Sweden 2, Denmark 1.5 and Finland 0.5). Of the assessed countries Spain, Cyprus, Portugal and Greece have set the highest limit values. Spain has exceeded the limit values for copper, nickel and zinc (permitted, according to its questionnaire). On average Flanders’ has set the lowest limit values for the assessed heavy metals, apart from mercury.

3.2.2 Heavy Metals in Sludge

Article 5.2 (a) and Annex 1B set the limit values prohibiting the use of heavy metals in sludge.

Member States were asked to fill in national limit values required by Article 5.2(a) and Annex I B.

All the national limits have been combined in the table in Annex II of this report. As we can see there is a considerable variation in national limit values.

All assessed Member States provided information apart from Ireland and Latvia. The UK referred to its transposing Regulation.

All national limits have been combined in the Annex II table of this report. From this Annex a table has been produced based on three ranges (high medium and low) of national limit values for each compound. In cases were a Member State gives a range of values, the country will be grouped based on the highest limit value.


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National Limit values for cadmium (mg/kg dry matter)

Member States (national limit value in brackets) (Directive Annex IB limit value is 20-40)

High: Limit values ≥ 30 Austria (20-40), Bulgaria (30), Cyprus (20-40), Luxemburg (20-40), Spain (40), Sweden (40)


Portugal (20), Estonia (20)

Low: Limit values < 20 Czech Republic (5), Denmark (0.8), Finland (3), Flanders (6), France (10), Germany (10), Hungary (10), Latvia (10), Poland (10), Romania (10), Slovenia (2)

Table 7. National limit values for cadmium.

Most of the Member States have set limit values for cadmium that are below those set by the Directive. Of similar geographical areas, Sweden has much higher limit values than the other Nordic countries. There is also a big difference between Bulgaria and Romania.

National Limit values for copper (mg/kg dry matter)


High: Limit values ≥ 1200 Bulgaria (1600), Cyprus (1000-1750), Estonia (1200), Greece (1750), Luxemburg (1000-1750), Spain (1750), Sweden (1750)


Austria (500), Denmark (1000), France (1000), Germany (800), Hungary (1000), Latvia (800), Poland (800), Portugal (1000), Slovakia (1000)

Low: Limit values < 700 Czech Republic (500), Finland (600), Flanders (375), Romania (500), Slovenia (300)

Table 8. National limit values for copper.

There is a huge variation between national limit values, ranging from Slovenia’s 300 to Bulgaria’s 1600. Of countries in the same geographical area, there is a big difference between the limit values of Bulgaria and Romania. There is also a great variation in national limit values between the Nordic countries.

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National Limit values for nickel (mg/kg dry matter)


High: Limit values ≥ 300 Austria (300-400), Bulgaria (350), Cyprus (300 – 400), Greece (400), Luxemburg (300-400),Portugal (300), Slovakia (300), Spain (400), Sweden (400), Estonia (400)


Czech Republic (100), Finland (100), France (200), Germany (200), Hungary (200), Latvia (200), Poland (100), Romania (100)

Low: Limit values < 100 Denmark (30), Flanders (50), Slovenia (70)

Table 9. National limit values for nickel

Most of the countries have set limit values that are stricter than those set by the Directive. Sweden has much higher national limit values than the other Nordic countries assessed.

National Limit values for lead (mg/kg dry matter)


High: Limit values ≥ 750 Bulgaria (800), Cyprus (750-1200), France (800), Germany (800), Greece (1200), Hungary (750), Luxemburg (750-1200), Portugal (750), Spain (1200), Sweden (1200), Estonia (900)


Austria (500), Flanders (300), Latvia (500), Poland (500), Romania (300),

Low: Limit values < 400 Czech republic (200), Denmark (120), Finland (150), Romania (300), Slovenia (100),

Table 9. National limit values for lead

Most of the Member States assessed have set stricter limit values than those in the Directive. Sweden has considerably higher limit values than the other Nordic countries assessed.

National Limit values for zinc (mg/kg dry matter)


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High: Limit values ≥ 2500 Czech Republic (2500), Denmark (4000), France (3000), Germany (2500), Greece (4000), Hungary (2500), Latvia (2500), Poland (2500), Portugal (2500), Spain (4000), Sweden (4000), Estonia (3500), Zinc (2500-4000)

Medium: 1000≤ limit values < 2500

Austria (2000), Finland (1500), Slovenia (1200)

Low: Limit values <1000 Flanders (900),

Table 10. National limit values for zinc

Most of the Member States have set their limit values close to the maximum allowed by the Directive.

National Limit values for mercury (mg/kg dry matter)


High: Limit values ≥ 16 Bulgaria (16), Cyprus (16-25), Estonia (20), Greece (25), Luxemburg (16-25), Portugal (16), Spain (25), Sweden (25)

Medium:8 ≤ limit values < 16

Austria (10), France (10), Germany (8), Hungary (10), Latvia (10), Slovakia 10),

Low: Limit values < 8 Czech Republic (4), Denmark (0.8), Finland (8), Flanders (5), Germany (8), Poland (5), Romania (5), Slovenia (2)

Table 11.

Most of the Member States have set limit values considerably below those allowed by the Directive. National limit values for mercury. Of similar geographical areas there is big difference between Bulgaria and Romania in limit values, as well as between the Nordic countries.

National Limit values for chromium (mg/kg dry matter)

Member States (national limit value in brackets) (Directive Annex IB sets no limit value for

chromium)

High: Limit values ≥ 1500 Estonia (1200), Luxemburg (1000-1750), Spain (1500), Sweden (1500)

Medium:500 ≤ limit values Austria (500), France (1000), Germany (900), Hungary

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< 1500 (1000), Portugal (1000), Slovakia (1000), Latvia (600)

Low: Limit values < 500 Czech Republic (200), Denmark (100), Finland (300), Flanders (250), Slovenia (150),


Sweden has set a considerably higher limit than the other Nordic countries. Greece and Cyprus have not set a limit .for chromium. Bulgaria and Cyprus have not set limit values for chromium.

Resumé: All assessed Member States provided information apart from Ireland and Latvia. Most of the Member States have set their limit values below the maximums allowed by the Directive, apart from zinc, where a majority of Member States have set their limits close to those allowed by the Directive. From the tables we can see that there is a wide variation in limit values, national limit values, such as for copper, where the limit values range from Slovenia’s 300 mg/kg dry matter to Bulgaria’s 1600 mg/kg dry matter. There are surprisingly large differences in limit values between similar geographical areas, such between the Nordic countries for cadmium (Sweden 40, Denmark 0.8 and Finland 3). Of the assessed countries Spain, Cyprus, Portugal and Greece have set the highest limit values. On average Flanders and Slovenia have set the lowest limit values for the assessed heavy metals.

3.2.3 Maximum Annual Loads of Heavy Metals

Article 5.2 (b) and Annex I C set the limit values for the quantities of metals introduced into the soil.

Member States were asked to fill in national limit values required by Article 5.2(b) and Annex I C.

All the national limits have been combined in the table in Annex III of this report. All assessed Member States provided information apart from the Czech Republic, Germany, Italy and Poland.

All national limits have been combined in the Annex III table of this report. From this Annex a table has been produced based on three ranges (high medium and low) of national limit values for each compound. In cases were a Member State gives a range of values, the country will be grouped based on the highest limit value.


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National Limit values for cadmium (kg/ha/year)

Member States (national limit value in brackets) (Directive Annex IC limit value is 0.15)

High: Limit values ≥ 0.15 Bulgaria (0.15), Cyprus (0.15), Estonia (0.15), Hungary (0.15), Lithuania (0.15), Portugal (0.15), Romania (0.15), Spain (0.15), UK (0.15), Luxemburg (0.15)

0.03≤ limit values < 0.15 Ireland (0.05), Italy (0.05), Latvia (0.03 – 0.0035), Slovakia (0.03),

Low: Limit values < 0.03 Austria (0.01), Denmark (0.01), Finland (0.003), Flanders (0.012), France (0.02), Slovenia (0.025), Sweden (0.00075)

Table 12. National limit values for cadmium

Most of the countries have set limit values close to that allowed by the Directive. However, there is a huge difference between the countries having set the lowest limit values and those countries that have set their limit values close to the maximum allowed by the Directive.

National Limit values for copper (kg/ha/year)

Member States (national limit value in brackets) (Directive Annex IC limit value is 12)

High: Limit values ≥ 12 Bulgaria (12), Cyprus (12), Greece (12), Lithuania (12), Luxemburg (12), Portugal (12), Romania (12), Spain (12), Estonia (12)

7 ≤ limit values < 12 Denmark (7), Hungary (10), Ireland (7.5), Italy (7.5), UK (7.5)

Low: Limit values < 7 Austria (1.8), Finland (0.6), Flanders (0.75), France (1.50), Latvia (1-1.2), Slovakia (3), Slovenia (3), Sweden (0.3)

Table 13. National limit values for copper

Again a wide variety in national limit values, ranging from Sweden’s 0.3 to the highest allowed limit value of 12. Of similar geographical areas there is a considerable difference in the limit values between the Nordic countries.

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National Limit values for Nickel (kg/ha/year)


High: Limit values ≥ 3 Bulgaria (3), Cyprus (3), Estonia (3), Greece (3), Ireland (3), Italy (3), Lithuania (3), Luxemburg (3), Portugal (3), Romania (3), Spain (3), UK (3)

0.5 ≤ limit values < 3 Hungary (2), Slovakia (0.9), Slovenia (0.5)

Low: Limit values < 0.5 Austria (0.3), Denmark (0.21), Finland (0.1), Flanders (0.1), France (0.30), Latvia (0.25-0.3), Sweden (0.025)

Table 14. National limit values for nickel

Again the limit values are set on a wide range, with a group of Member States opting for maximum limit values allowed and others setting considerably lower ones. Latvia has set a much lower limit value for nickel than the other Baltic states.

National Limit values for lead (kg/ha/year)


High: Limit values ≥ 15 Bulgaria (15), Cyprus (15), Greece (15), Lithuania (15), Luxemburg (15), Portugal (15), Romania (15), Spain (15), UK (15), Estonia (15)

4 ≤ limit values < 15 Hungary (10), Ireland (4), Italy (4),

Low: Limit values < 4 Austria (1.25), Denmark (0.84), Finland (0.15), Flanders (0.6), France (1.50), Latvia (0.3-0.35), Slovakia (2.25), Slovenia (2.5), Sweden (0,025)

Table 15. National limit values for lead

Again the limit values are set on a wide range, with a group of Member States opting for maximum limit values allowed and others setting considerably lower ones. Latvia has again set a much lower limit value than the other Baltic states.

National Limit values for zinc (kg/ha/year)


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High: Limit values ≥ 25 Estonia (30), Bulgaria (30), Cyprus (30), Greece (30), Hungary (30), Lithuania (30), Luxemburg (30), Portugal (30), Romania (30), Spain (30), Denmark (28)

5 ≤ limit values < 28 Austria (5), Ireland (7.5), Ireland (7.5), Italy (7.5), Slovakia (7.5), Slovenia (10), UK (15), Latvia (5-6)

Low: Limit values < 5 Finland (1.5), Flanders (1.8), France (4.50), Sweden (0.6)

Table 16. National limit values for zinc

For zinc the limit values are more mixed than for the other heavy metals assessed. A majority of Member States have opted to set their national limits close to the maximum allowed. Large differences between the limit values of the Nordic countries.

National Limit values for Mercury (kg/ha/year)

Member States (national limit value in brackets) (Directive Annex IC limit value is 0.1)

High: Limit values ≥ 0.1 Bulgaria (0.1), Cyprus (0.1), Estonia (0.1), Greece (0.1), Hungary (0.1), Ireland (0.1), Italy (0.1), Lithuania (0.1), Luxemburg (0.1), Portugal (0.1), Romania (0.1), Spain (0.1), UK (0.1)

0.01 ≤ limit values < 0.1 Austria (0.025), Denmark (0.01), France (0.02), Latvia (0.008-0.01), Slovakia (0.03), Slovenia (0.025),

Low: Limit values < 0.01 Finland (0.00), Sweden (0.0015)

Table 17. National limit values for mercury

Most of the Member States have set their limit values to that allowed by the Directive. Again big differences in limit values with Finland and Sweden setting their limit values several magnitudes below those allowed by the Directive.

National Limit values for chromium (kg/ha/year)

Member States (national limit value in brackets) (Directive Annex IC sets no limit value for

chromium)

High: Limit values ≥ 5 Hungary (10), Lithuania (10), Romania (12), Greece (5)

1≤ limit values < 5 Austria (1.25), Estonia (4.5), France (1.50)Ireland (3.5), Italy (3.5), Luxemburg (4.5), Slovakia (3), Slovenia (2.5), Spain (3)

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Low: Limit values < 1 Denmark (0.7), Finland (0.3), Flanders (0.5), Latvia (0.6-0.7), Sweden (0.04), UK (0)


There is a wide variety in limit values. It is assumed that UK’s limit value 0 indicates that there is no limit value.

Resumé: All assessed Member States provided information apart from the Czech Republic, Germany, Italy and Poland. From the tables we can see that there is a wide variation in limit values, national limit values, However, for Annex IC limit values there tends to be a group consisting of Bulgaria, Greece, Cyprus, Lithuania, Romania, Spain and Portugal that set their limit values to those allowed by the Directive with other Member States set their limit values considerably lower. The exemption is mercury, where most Member States have set their limit values to that allowed by the Directive. The wide variety between limit values of similar geographical areas continues.

3.3 Maximum quantities of sludge (dry matter) applicable to soil

According to Article 5.2 (a)Member States shall lay down the maximum quantities of sludge expressed in tonnes of dry matter which may be applied to the soil per unit of area per year while observing the limit values for heavy metal concentration in sludge which they lay down in accordance with Annex I B or according to Article 5.2 (b) Member States shall ensure observance of the limit values for the quantities of metals introduced into the soil per unit of area and unit of time as set out in Annex I C.

Member States were asked to indicate the maximum quantity of sludge that may be applied to the soil per surface unit per annum (in tonnes of dry matter per hectare per annum), if the option proposed under Article 5 (2) (a) has been chosen.

Four of the regions in Austria have chosen option 5.2 (a). The quantities of sludge vary between regions, whit the highest allowed in Oberösterreich (ten tonnes of dry matter per hectare during three years).

Bulgaria has chosen option 5.2 (a). The maximum quantity of sludge that may be applied to soil is 55 tonnes of dry matter per hectare per annum. In 2006 an average of 31.9 tonnes of sludge (dry matter) was used per hectare.

Cyprus: No answer, hence assuming that Cyprus has chosen option 5.2(b).

In Czech Republic no more than five tonnes of dry matter of sludge per hectare may be used in the course of three successive years. This amount may be increased to as much as ten tonnes of dry matter of sludge in the course of five successive years provided that the sludge used contains less than half the limit values of each of the hazardous substances and elements monitored. The precise dose of dry matter will

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be calculated on the basis of the nitrogen content recorded. The nitrogen dose added in sludge must not exceed 70% of the total nitrogen requirement of the crop. The sludge dose is also dependent on the plants’ nutrient requirement, taking into account the available nutrients and the organic component in the soil.

Denmark: 7 tonnes of dry matter per hectare per annum.

Estonia: No answer, hence assuming that Estonia has chosen option 5.2(b).

Finland: No answer, hence assuming that Finland has chosen option 5.2(b).

Flanders: For all sludge which is used as a fertiliser or a “soil-improving method” (as a secondary raw material), where the sludge contains the maximum permissible concentrations, the maximum quantity which may be used in agriculture is two tonnes of dry matter per hectare per two-year period.

France: No answer, hence assuming that France has chosen option 5.2(b).

Germany: The maximum quantity of sewage sludge, that may be applied to soils used for agricultural and horticultural purposes, is 5 tonnes of dry matter per hectare over a three-year period. This translates into an annual quantity of 1.66 t/ha.

Greece: No such quantities have been laid down.

Hungary: No answer, hence assuming that Hungary has chosen option 5.2(b).

Ireland: No answer, hence assuming that Ireland has chosen option 5.2(b).

Italy: Sludge may be applied to soil if it doses not exceed 15 tonnes of dry substance per hectare over three years (corresponding to an average of 5 tonnes per hectare per year), provided that the soil has a cation exchange capacity (CEC) above 15 meq/100 g and pH between 6.0 and 7.5. The maximum quantity is decreased by 50% if it is used on soils with pH lower than 6 and CEC below 15 meq/100 g. Where the soil pH is above 7.5, the maximum useable quantity increase is by 50%. On soils with pH below 5 and CEC below 8 meq/100 g, its use is prohibited.

Latvia: Latvia has chosen the option referred to in Article 5(2)(b) of the Directive.

Lithuania: No answer, hence assuming that Lithuania has chosen option 5.2(b).

Luxemburg: Three tonnes.

The Netherlands: The Netherlands has chosen the option referred to in Article 5(2)(b) of the Directive.

Poland: The maximum quantity of sludge applied in agriculture is 2 tonnes of dry matter per hectare.

Portugal: Up to six tonnes of sludge, expressed as dry matter, may be used per hectare annually. Depending on the concentration of heavy metals in the sludge, the

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quantity used may (pursuant to Directive 86/278/EEC) be higher, on condition that the maximum annual limits for heavy metals are not exceeded.

Romania: In MO No 344 /2004, article 5(2) (b) from Directive 86/278/CEE has been chosen. Maximum quantity of sludge that can be applied to the soil per surface unit per annum is indicated in table 1.3 of this ministerial order.

Slovakia: The amount of sewage sludge applied to agricultural soil must not, over the course of five consecutive years, exceed 15 tonnes of dry matter per hectare, and the user of the soil, as acquirer of the sewage sludge, is responsible for ensuring compliance with this.

Slovenia: The maximum quantity of sludge that may be applied to the soil per surface unit (hectare) per annum is stipulated in the first indent of the first paragraph of Article 13 of the Decree and may not exceed three tonnes of dry matter per hectare per annum.

Spain: Not indicated, hence assuming that Spain has chosen option 5.2(b).

Sweden: Sweden has chosen the option referred to in Article 5(2)(b) of the Directive.

The UK: 5.2(a) is not chosen.

Resumé: Twelve Member States have opted for option 5.2 (a) and five have stated that they have opted for option 5.2.(b). Cyprus, Estonia, Finland, France, Hungary, Ireland, Lithuania and Spain have not answered the question. However, the wording of the question is such that not answering the question is opting for 5.2(b). Hence, assuming that Member States have not missed out on the question by mistake, 13 Member Sates have selected option 5.2 (b). Greece response is the unclear “no such quantities have been laid down”. For those Member States that have selected option 5.2(a), the maximum quantities vary from the two tonnes of dry matter per hectare for Poland and Flanders to the 55 tonnes per hectare for Bulgaria. Romania refers to its transposing legislation and does not provide any details on amounts.

3.4 Conditions under which less stringent concentrations of heavy metals are permitted

3.4.1 Land for growing crops intended exclusively for animal consumption

According to the first footnote of Annex IA, Member States may permit limit values to be exceeded in the case of the use of sludge on land which at the time of notification of this Directive is dedicated to the disposal of sludge but on which commercial food crops are being grown exclusively for animal consumption.

Member States were asked if any less stringent limit values for heavy metal concentrations in soils have been permitted in accordance with Annex 1.A, footnote

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1, and if so, to complete a table, stating whether any of the information given is an estimate.

None of the Member States have used less stringent limit values for heavy metals in soils permitted by Annex 1A and footnote 1. However, Portugal refers to its reply in the 1998-2000 questionnaire.

Resumé: None of the Member States assessed have used less stringent limit values for heavy metals in soils permitted by Annex 1A and footnote 1. However, Portugal refers to its reply in the 1998-2000 questionnaire.

3.4.2 Soils with a pH higher than 7

According to the second footnote of Annex IA, Member States may permit the limit values they fix to be exceeded in respect of these parameters on soil with a pH consistently higher than 7. The maximum authorized concentrations of these heavy metals must in no case exceed those values by more than 50 %.

Member States were asked if any less stringent limit values for heavy metal concentrations in soils have been permitted in accordance with Annex 1.A, footnote 2, and if so, to complete a table, stating whether any of the information given is an estimate.

No Member States apart from Ireland, Spain and UK have used this derogation. Portugal refers to its reply in the 1998-2000 questionnaire, which needs to be checked.

The limit values for Ireland for pH 7 are 75 mg/kg dry matter for copper, 45 mg/kg dry matter for nickel and 225 mg/kg dry matter for zinc.

The limit values for Spain for pH7 are 210 mg/kg dry matter for copper, 112 mg/kg dry matter for nickel and 450 mg/kg dry matter for zinc.

The limit values for the UK the pH7.1 are 200 mg/kg dry matter for copper, 110 mg/kg dry matter for nickel and 450 mg/kg dry matter for zinc.

Resumé: No Member States apart from Ireland, Spain and UK have used this derogation. Portugal refers to its reply in the 1998-2000 questionnaire.

The Directive requires that the pH is consistently higher than seven. Ireland and Spain has provided the derogations for pH 7, and the UK for pH 7.1, which does not seem to satisfy this criterion.

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3.4.3 Soils intended for fodder crops

According to the first footnote of Annex IC, Member States may permit these limit values to be exceeded in the case of the use of sludge on land which at the time of notification of this Directive is dedicated to the disposal of sludge but on which commercial food crops are being grown exclusively for animal consumption. Member States must inform the Commission of the number and type of sites concerned. Description of the technologies employed for treating sludge

Member States were asked if any less stringent limit values for heavy metal concentrations in soils have been permitted in accordance with Annex 1.C, footnote 1, and if so, to complete a table, stating whether any of the information given is an estimate.

None of the Member States have used less stringent limit values for heavy metals in soils permitted by Annex 1C and footnote 1. However, Portugal refers to its reply in the 1998-2000 questionnaire, which needs to be checked.

Resumé: None of the Member States have used less stringent limit values for heavy metals in soils permitted by Annex 1C and footnote 1. However, Portugal refers to its reply in the 1998-2000 questionnaire.

3.5 Description of the technologies employed for treating sludge

According to Article 6 sludge shall be treated before being used in agriculture.

With regard to Article 6, Member Sates were asked to briefly describe the technologies employed for treating sludge. Austria lists a number of technologies that vary considerably between the regions. The most limited response is for the regions of Vorarlberg that only requires drying or composting. In Bulgaria the sludge is dried for a minimum of six months (normally for approximately one year). The method involves both drying and stabilisation of the sludge. Another method, used to reduce water content, is filter press treatment. Sludge is also stabilised in open compost piles or methane tanks and by treatment with hydrated lime following aerobic digestion. In addition to the requirements set out in Annexes 1a and 1b to Directive 1986/278/EEC, the Bulgarian regulation includes requirements on the microbiological and parasitological characteristics of sludge intended for use in agriculture.

The treatment of sludge in Cyprus includes aerobic or mesophilic anaerobic digestion followed by mechanical dewatering using filter press or centrifuge. Treatment plants provide at least 6 months storage of sludge for further stabilization before use.

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In Czech Republic aerobic stabilisation is used for small treatment plants (under 5 000 p.e) and anaerobic stabilisation in larger and large treatment plants (over 5 000 p.e.)

In the case of Denmark sewage sludge must be treated either by stabilisation (anaerobic or aerobic digestion, composting, chemical stabilisation with lime/chalk or mineralisation) by composting at 55 degrees and minimum 2 weeks or by a controlled process, which secures hygienic. This could be thermal treatment at minimum 70 degrees in 1 hour, or treatment with quicklime so the material reaches a pH at 12 in minimum 3 months of digestion under the predetermined specifications.

Estonia: No information

In Finland anaerobic digestion, aerobic digestion, lime stabilization, composting and drying are used.

Flanders uses aerobic composting, mesophilic anaerobic stabilising, cold fermentation, thermal drying and lime stabilising.

France uses filter press treatment, centrifuge, lime stabilisation, thermal and solar drying, digestion, aerobic and anaerobic stabilisation, and composting.

The technologies applied in Germany for treating sludge generally involve a combination of procedures, e.g. anaerobic stabilisation followed by lime conditioning. Stabilisation itself is achieved by the following treatment types: (a) anaerobic (e.g. digester), (b) aerobic (e.g. oxidation ponds, long-term treatment) and (c) other types (e.g. chemical stabilisation by adding lime and other chemicals, thermal stabilisation).

Greece: So far there has not been interest in using sewage sludge in agriculture. Nevertheless sludge undergoes treatment such as dehydration, thermal treatment and lime addition.

Hungary uses biological, chemical, or heat treatment as well as storage for at least 6 months

Ireland uses dewatering on filter tables to solids content of 18%, followed by storage for 3 months prior to application to agricultural land, anaerobic digestion, thermal trying, thermuphilic aerobic digestion and lime stabilisation.

The most commonly used stabilisation techniques in Italy are anaerobic digestion (mostly used in medium to large-sized plants having a capacity above 50 000 inhabitants equivalent), aerobic digestion, including composting (generally reserved for medium to small-sized plants), mechanical dehydration (that may be achieved by means of drying beds, centrifuging, belt-pressing or, in larger plants, filter-pressing), heat-drying and chemical alkali treatment. Sanitation or conditioning treatments, which may also be performed outside the treatment plant, are carried out through physical (mostly heat-drying and pasteurisation), chemical (addition of lime or ammonia) or biological (composting) treatments.

In Latvia treated sludge is. sludge that has been subject to at least one of the following treatments:

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- storage, possibly in liquid form, for at least twelve months (cold fermentation) without mixing or transport while in storage;

- mesophyllic anaerobic digestion at a temperature of 35 0C (± 3 0C) with a minimum treatment time of 21 days (± five days);

- composting, during which the temperature within the pile, 50 cm from the surface layer, does not fall below 60 0C;

In Lithuania sewage is treated through: - digestion in gas reactors (anaerobic stabilisation); - stabilisation with lime to increase sludge pH>12 by keeping for longer

than 5 hours; composting at a temperature above 550C for no less than two weeks.

In the Netherlands all sludge applied in agriculture must be treated by biological, chemical or thermal means, through long-term storage or any other suitable method which kills off the majority of the pathogens present in the waste water sludge Treatment is compulsory, but any of the techniques may be used provided that the required end result is obtained.

Luxemburg lists treatment with chalk, composting and incineration.

Poland: Municipal sludge may be applied, provided that it has been stabilised and prepared in a manner appropriate to the purpose of its application, notably by subjecting it to biological, chemical, thermal or other processing which reduces the susceptibility of municipal sludge to putrefaction and eliminates the risk to the environment or public health.

Portugal refers in its reply to the 1998-2000 questionnaire.

Romania: According to MO No 344 /2004, only treated sludge shall be used in agriculture for whom Local Environmental Agency give the permit for sludge spreading according to the special agrochemicals report issue by Agrochemicals and Pedological Office and approved by Directorate for Agriculture and Rural Development from Ministry of Agriculture, Forests and rural Development. This report must describe the conditions for using sludge for environmental protection by producers and users of sludge. Currently, the sludge from the wastewater treatment plants (WWTP) is dried on the drying beds belonging to the WWTP. A part of it is landfilled after drying and a small quantity is incinerated. Only small quantities of sludge from municipal waste water treatment plants have been used in agriculture, and only in research projects. Research programmes concerning the treatment of sludge and its use in agriculture continue to be conducted in various areas of the country. Methods for sludge treatments are being examined in these research programmes.

Slovakia: The most widespread method of stabilising sludge is anaerobic stabilisation, which is used by 55.0% of waste water treatment plants, 16.8% of such plants using Imhoff tanks for stabilisation. Aerobic stabilisation of sludge has been introduced at 47.7% of waste water treatment plants. In the great majority of cases, this method of stabilisation is used at waste water treatment plants of < 20 000 p.e.

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One waste water treatment plant uses chemical stabilisation.

Slovenia: Sludge is treated by stabilisation, conditioning, drying and disinfection,

Spain: Anaerobic digestion, extended storage and composting

Technologies employed in Sweden for treating sludge are thickening (gravity thickening, flotation, centrifuge), stabilisation (anaerobic, aerobic, lime), conditioning, dewatering (centrifuge, filter belt press, air drying, reed beds), thermal drying, composting, hygienisation/conditioning (a process called KemCond is used at some treatment plants), stabilisation/hygenisation (anaerobic termophil treatment)

In the UK Mesophilic anaerobic digestion, thermophilic aerobic digestion, composting, lime stabilisation, liquid sludge, liquid storage, dewatering and storage and thermal drying are used.

Resumé: All Member States, apart from Estonia and Portugal, have provided information on sludge treatment technologies. Estonia has not answered the question and Portugal refers to the 1998-2000 questionnaire. In addition Poland only refers to treatments of municipal waste, which raises the question about treatment of other sludge, such as that from septic tanks.

.

3.6 Frequency of analysis

According to Annex IIA (1), as a rule, sludge must be analyzed at least every six months. Where changes occur in the characteristics of the waste water being treated, the frequency of the analyses must be increased. If the results of the analyses do not vary significantly over a full year, the sludge must be analyzed at least every 12 months.

Member States were asked if rules have been drawn up to ensure that analyses are carried out at more frequent intervals than those provided for in Annex II. A (1)

Austria: Five regions have reported their frequency of analysis. However, some of the regions only refer to a paragraph in the legislation.

Bulgaria: Pursuant to Article 8(5) of the Regulation, wastewater treatment plants which generate between 1000 and 4000 tonnes of sludge annually (dry matter) are checked every four months for heavy metals and every six months for other "agrochemical" indicators, as indicated in Annex 2 to the Directive (such as pH, nitrogen, phosphorus, etc.); wastewater treatment plants which generate more than 4000 tonnes of sludge (dry matter) annually are subjected to both types of analysis every three months.

In the Czech Republic the frequency of analysis depends on the production of sludge at a treatment plant. Sludge production (dry matter, tonnes per annum) and the minimum number of analyses per annum are showed below:

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Agrochemical Hazardous Organic

Parameters elements Microbiology pollutants

(AOX, PCB)

< 250 2 2 2 -

250-1000 4 4 4 -

1000-2500 4 4 6 1

> 2 500 12 12 12 1

Denmark: Frequencies are determined by the amount of sludge produced and the quality of sludge.

Finland: Refers to the report for the period 1995-1997. Regarding Åland Islands no rules have been drawn up.

Flanders: For plants with a production > 400 tonnes of dry matter per annum one analysis every two months is required. For plants with a production < 400 tonnes of dry matter per annum one analysis every six months is required.

In France, the frequency of analysis is proportionate to the quantity of sludge applied, and checks are strengthened during the first year of application.

In Hungary sludge should be analysed at least every 6 months and before each injection period.

In Italy sludge analyses are required whenever there is substantial change in treated water. In the case of plants for over 100 000 inhabitants equivalent, analyses must be carried out every three months.

For Latvia the frequency of analysis is based on the population equivalent of the sewage treatment plant load and the type of analysis taken place. All these are listed in Annex I of the transposing legislation.

In Luxemburg the frequency depends on the capacity of the wastewater treatment plant. For 5000 hab. equiv. the frequency is once a year, for 5000-50000 hab. equiv. twice a year and for 5000 hab. equiv. six times a year.

In Poland analyses of municipal sludge are carried out at different intervals, depending on the load entering the treatment plant.

Romania: The number of sludge analysis depends on the quantity of sludge produced at the wastewater treatment plant, used in agriculture and they are laid down in MO No 344 /2004 and ranges from 2 analyses (agronomic parameters and heavy metals) per annum in treatment plants producing less than 30 tonnes of dry matter per year used in agriculture to 18 analyses each year in plants producing over 6400 tonnes of dry matter used in agriculture.

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Slovenia: The Decree on the limit input concentration values of dangerous substances and fertilisers in soil stipulates, in table 9 of Annex 3, the frequency of sampling of sludge (minimum number of samples), which is based on annual capacity.

In Sweden analyses should be carried out with the following intervals: 200-2 000 peq, every 12 month; 2 001-20 000 peq, every 6 month; <20 000 peq, once every month

Cyprus, Estonia, Germany, Greece, Ireland, Lithuania, Portugal, Slovakia, Spain and Aland Islands (has autonomy from Finland) have not drawn up rules to ensure that analyses are carried out at more frequent intervals than those provided for in Annex II. A (1).

Resumé: Thirteen Member States conduct analysis more frequently than required by Annex II A(1). There is a great variety in the type and frequency of analysis. Cyprus, Estonia, Germany, Greece, Ireland, Lithuania, Portugal, Slovakia and Spain have not drawn up rules to ensure that analyses are carried out at more frequent intervals than those provided for in Annex II. A (1).

3.7 Specific conditions for authorising injection or working into the soil of untreated sludge

According to Article 6(a) Member States may authorize, under conditions to be laid down by them, the use of untreated sludge if it is injected or worked into the soil

Member States were asked whether conditions have been laid down for authorising the injection or working into the soil of untreated sludge (Article 6 (a)). Apart from Estonia and Sweden all Member States have prohibited the use of untreated sludge if it is injected or worked into the soil. In Estonia it is not permitted to use untreated sludge in agriculture. However, the transposing regulation permits the use of untreated sludge in landscaped areas and in recultivation. Untreated sludge spread on the ground must be worked in or covered with soil within two days of the spreading commencing, except where landfills are being covered. In France, untreated sludge can only be used if the following two conditions, as well as the principles stated in Decree 97-1133, are met: 1) when it concerns material from certain activities, where the waters used are less than 120 kg DBO5/day; 2) when the sludge is buried in the soil immediately after application using equipment adapted for that purpose.

In Sweden: Untreated sludge may be used if it is worked into the soil within a maximum of 24 hours after being spread and its use does not cause an inconvenience to local residents.

Resumé: Apart from Estonia, France and Sweden all Member States have prohibited the use of untreated sludge if it is injected or worked into the soil. In Estonia the transposing regulation permits the use of untreated sludge in landscaped areas and in recultivation. Untreated sludge spread on the ground must be worked in or covered

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with soil within two days of the spreading commencing, except where landfills are being covered. In Sweden untreated sludge may be used if it is worked into the soil within a maximum of 24 hours after being spread and its use does not cause a inconvenience to local residents. In France, untreated sludge can only be used for material from certain activities, where the waters used are less than 120 kg DBO5/day, and when the sludge is buried in the soil immediately after application using equipment adapted for that purpose. Also the principles in the French Decree have to be taken into consideration.

3.8 Periods of prohibition of spreading before grazing or harvesting

According to Article 7(a) Member States are required to prohibit the use of sludge or the supply of sludge for use on grassland or forage crops if the grassland is to be grazed or the forage crops to be harvested before a certain period has elapsed. This period is to be set by the Member States, taking particular account of their geographical and climatic situation, shall under no circumstances be less than three weeks.

Member States were asked, with regard to Article 7, where appropriate, the length of the period during which it is forbidden to use sludge on grassland before it is grazed, and on forage crops before harvest. In Austria the prohibition periods vary. In Burgenland it is four weeks and in Steiemark three weeks. The other regions refer to the national legislation.

In Bulgaria the use of sludge is not permitted on pastures or areas intended for forage crops if they are used for pasture or if forage crops are harvested within 45 days following application of the sludge.

According to the Water Pollution Control (Use of Sludge in Agriculture Regulations (No. 517/2002)), it is prohibited in Cyprus to use sludge on grassland three weeks before it is grazed and is also prohibited to use sludge on forage crops ten months before harvest.

Czech Republic: No information

Denmark: Minimum of one year In Estonia it is forbidden to use sludge on land where vegetable or berry crops, medicinal plants or herbs are grown. It is also forbidden to spread sludge on land: − to grow vegetable crops, medicinal plants or herbs for food or feed for one year

after the sludge is spread; − to graze animals or harvest feed crops for two months after the sludge is spread; Finland refers to the report for the period 1995-1997. Regarding Åland Islands it is permitted to use sludge on grassland just before snow, but it is not permitted to grow potatoes, root-crops and vegetables earlier than five years after spreading sludge.

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Flanders: The application of treated sewage as a fertiliser or soil-improving method is forbidden:

- on grassland being grazed or on fields where forage crops are cultivated when the forage crops are being harvested, subject to a waiting period of at least six weeks;

- on fruit and vegetable plantations, with the exception of fruit tree plantations during the growing period;

- on soil intended for the cultivation of fruit or vegetables which are customarily in direct contact with the soil and are customarily eaten raw, for a period of ten months prior to the harvest and during the harvest itself;

- in areas which, in accordance with the development plans in force, are intended for one of the uses included under use type 1 of the Vlarebo [Soil Cleaning Regulation of the Flemish Region], and municipal gardens which are accessible to the public in all urbanized locations.

France: Six weeks in the case of sludge that has not been treated to make it hygienic, and three weeks in the case of sludge that has been treated to meet certain standards of hygiene.

In Germany it is forbidden by law to use sewage sludge on meadows and pastures (permanent grassland) (§ 4(4) of the Sludge Order, AbfKlärV). Sludge may be applied to arable land used to grow forage crops - provided this is done prior to sowing and the sludge is worked deep into the soil. For the cultivation of silage maize and green maize, the sludge may be worked into the soil prior to sowing (§ 4(3) and (4) of the Sludge Order, AbfKlärV).

The response by Greece is “there are no such data”.

Hungary: Application of sludge is forbidden in the vegetation period of forage crops application is allowed before sowing and after harvest). Application of sludge is also forbidden on grassland for grazing.

Ireland: Three weeks.

Italian legislation bans the application of sludge on land intended as pasture, meadow-pasture and forage area, including in combination with other crops, in the 5 weeks preceding its use as pasture or the harvest of forage.

In Latvia the time period between working the sewage sludge and the compost into the soil and harvesting the agricultural crop must be no less than:

- 10 months where fruit and berries, edible roots, potatoes and vegetables that are in direct contact with the soil are open-grown;

- three months where other agricultural crops are grown, with the exception of perennial grasses which are cut or grazed.

Lithuania: Ground intended for the cultivation of fruit and vegetable crops which are normally in direct contact with the soil and normally eaten raw, may not be fertilised

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with sludge for a period of 10 months preceding the harvest of the crops and during the harvest itself; grasslands and fodder crops may not be fertilised with sludge more than three weeks preceding use (haymaking or grazing). In crop rotation, hoed crops may be grown after no less than one year following fertilisation with sludge.

Luxemburg refers to the Grand-Ducal Regulation.

In Poland the use of sludge on land used as pasture or meadow is prohibited.

Portugal: Transposing legislation prohibits the supply or spreading of sludges intended for pastures or fodder crops within a three-week period preceding grazing or the harvesting of the fodder. Romania: The use of sludge is forbidden on grasslands, on ground intended for the cultivation of fruit shrubs and vegetable crops and on soil in which fruit trees are growing for a period of 10 months preceding the harvest and during the harvest itself.

Slovakia: It is forbidden to apply sewage sludge:

a) to permanent grassland or to forage crops on arable soils, if the grass is to be

grazed or the forage crops are to be harvested within five weeks following

application,

b) to agricultural land on which fruit and vegetables, other than fruit trees, are being

grown,

c) to agricultural land intended for the cultivation of fruit and vegetables, the

harvested parts of which are in direct contact with the soil and are consumed raw,

for a period of ten months prior to harvesting and during the harvest itself.

Slovenia: It is forbidden to apply sewage sludge:

Spain: Those laid down in the Directive

Sweden: The length of the period during which it is forbidden to use sludge on grassland before it is grazed and on forage crops before harvesting is 10 months. UK: Three weeks

Resumé: Most of the analysed Member States have either a total ban in places or time periods during which is prohibited to use sludge. The time periods as well as the criteria used are varied. The conditions for using sludge can be very specific or not being mentioned at all, such as in the case of Ireland and the UK, where only the time period “three weeks” is given. Czech Republic has not answered the question and Greece has “no data”. It is also unclear what Spain refers to in “those laid in the Directive”. Finland refers to the 1995-1997 questionnaire.

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3.9 Limit values or other measures for soils with a pH below 6

Article 8 states that where sludge is used on soils of which the pH is below 6, Member States shall take into account the increased mobility and availability to the crop of heavy metals and shall, if necessary, reduce the limit values they have laid down in accordance with Annex I A.

Member States were asked if they have any reduced limit values or, where appropriate, any other measures, authorised at national level where the pH of the soil is below 6? Bulgaria, Cyprus, Czech Republic, Denmark, Greece, Ireland, Latvia, Lithuania, Romania, Spain and Sweden have not set limit values or other measures for soils with a pH below 6. Austria: Five regions have set limit values for soils with pH below 6. Estonia: Measures in place but the reduced limit values have not been determined. Also in soils where 5<pH<6, it is permitted to use lime-sterilised sludge. Finland: Reduced limit value of Cd is 0,5 and Hg 0,2. Sludge may be used only on cultivated soil with a pH value above 5.8. If lime-stabilized sludge is used, the pH value of the soil shall be above 5.5 (Government Decision 282/1994, Section 6). Refers also to the report for the period 1998 - 2000. Also reduced limit values for copper (100 mg/kg/DM), Nickel (60 mg/kg/DM), Lead (60 mg/kg/DM), Zinc (150 mg/kg/DM) and Chromium (200 mg/kg/DM).

Flanders: Treated sludge may only be applied to cultivated land if the pH of the soil is above 5. Moreover the limit values for the heavy metals in question are stricter in the Flemish Region than those set out in Annex IA of Directive 86/278.

In France, a number of other measures have been put in place, consisting of the following flow limits (in kg/ha/year) for lime stabilised sludge used on soil with a pH value in the 5-6 range: 0.015 for cadmium; 1.2 for copper; 0.3 for nickel; 0.9 for lead; 3 for zinc; 0.012 for mercury; and 1.2 for chromium.

Germany: Reduced limit value for zinc is 150 mg/kg/DM

Hungary: For pH < 5.5 application of sludge is forbidden and for 5.5 < ph >6.2 application of liming material is required with sludge application for all heavy metals covered by the Directive.

Italy: Yes, the max dose of useable sludge is reduced by 50%

Luxemburg states that EPA has the right to reduce the limit values fixed in Annexe I A (art 4 d of regulation of 14 April 1990). There is no indication of what these rights that EPA has might entail.

Portugal: Lower limits are applicable when the pH of the soil is below 5.5.

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Slovakia: If the pH is in the 5-6 range, sewage sludge may be applied only to agricultural soils or forest soils in which the concentration of high-risk substances is lower than is specified for pH 6 or higher. In these cases the limit values are for cadmium 0.5, copper 20, nickel 15, lead 70, zinc 60, mercury 0.1 and chromium mg/kg dry matter.

Slovenia: Reduced limit values are for cadmium 0.5, copper 20, nickel 15, lead 70, zinc 60, mercury 0.1 and chromium 30 mg/kg dry matter. But no pH range given.

UK: Yes, and refers to the transposing regulation

Resumé: Bulgaria, Cyprus, Czech Republic, Denmark, Greece, Ireland, Latvia, Lithuania, Romania, Spain and Sweden have not set limit values or other measures for soils with a pH below 6. However, many of the countries have not set a pH range for the limit values (such as Slovenia), whereas others have (such as Slovakia). UK refers to the transposing regulation. Luxemburg states that EPA has the right to reduce the fixed limit values but no indication if there are any limit values within which EPA has to operate.

3.10 Soil analyses for other parameters than pH and heavy metals

Article 9 sets out the analysis to be carried out on soils parameters in accordance with Annex II B(1), other than those mentioned in Annex IIB (3)(pH and heavy metals).

Member States were asked to indicate which types of analysis are carried out, pursuant to Article 9, on soil parameters in accordance with Annex II B (1), other than those mentioned in Annex II B (3) (pH and heavy metals).

Austria: Steiermark lists a number of substances (mostly organic. The others refer to paragraphs in the legislation.)

Bulgaria: Total and mobile forms of nitrogen, phosphorus and potassium and organic matter.

Czech Republic: Depending on soil type (category), average Mg, K and P content. Estonia: Humus layer properties, Ntot and Ptot, macroelements.

Flanders: Additional analyses are enforced for dry matter content, organic matter content, nitrogen, diphosphorous pentoxide, EOX and mineral oil. In principle monocyclic aromatic hydrocarbons, polycyclic aromatic hydrocarbons and other organic substances need to be also analysed.

An exemption from carrying out analyses on these compounds, can, however, be granted if:

• a statement is provided giving details of the complete production process, including all the raw materials and additives used, together with the analytical composition of these substances, where this is known;

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• the owner of the waste declares on their word of honour that the substances in question cannot, in normal practice, appear in the waste and that no catastrophes have occurred by means of which the waste flow could possibly have become polluted.

Germany: In addition to the pH and heavy metal analyses, analyses should also be carried out on the soil before sludge is applied to determine the plant-available phosphate, potassium and magnesium content (§ 3(4) of the Sludge Order, AbfKlärV). If the pH value is 5 or less, sludge may not be applied to areas used for agricultural or horticultural purposes (§ 4(9) of the Sludge Order, AbfKlärV).

Hungary: Organic matter content, CaCO3 equivalent, particle size distribution, exchangeable cations, toxic elements: As, Hg, Mo, Ni, Pb, Se and Zn.

Italy: Beside the analyses required under Annex II B to the Directive, soil must be analysed for its cation exchange capacity. In addition, a quick oxidising test (Bartlett and James) is required prior to spreading sludge in order to assess whether the soil has oxidising capacity from Cr(III) to Cr(VI). No sludge containing chromium may be applied to soil containing 1 microM of Cr VI or more.

Luxemburg: Refers to the Grand Ducal Regulation.

Poland: Besides the analysis of the pH and the quantity of heavy metals, an analysis of the assimilable phosphorus content, expressed as P2O5 (phosphorus pentoxide), is carried out.

Portugal: Besides the analysis of the pH and the quantity of heavy metals, phosphorous and nitrogen.

Romania: In accordance with MO No 344/2004, before the sludge is spread on land, a wider spectre of parameters is measured, including the pedological characteristics of the soil, the soil cation exchange capacity, pH and heavy metals.

Slovenia: Concentration values of dangerous substances and fertilisers in soil stipulates pedological analysis.

Cyprus, Denmark, Finland, Greece, Ireland, Latvia, Lithuania, Slovakia, Spain, Sweden and the UK have not set out any additional analysis to Annex II B (3).

Resumé: Cyprus, Denmark, Finland, Greece, Ireland, Latvia, Lithuania, Slovakia, Spain, Sweden and the UK have not set out any additional analysis to Annex II B (3). For those Member States that have additional assessment in place, the spectrum of elements being analysed is broad.

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3.11 Minimum frequency of soils analysis

According to Annex II, Member States have to decide on the frequency of further analysis, taking account of the metal content of the soil prior to the use of sludge, the quantity and composition of the sludge used and any other relevant factors.

Member States were asked of their minimum frequency of soil analysis (Annex II B (2)).

Austria: Once every ten years seems to be the norm. However, many of the regions refer to a paragraph in the legislation.

Bulgaria: The minimum frequency of soil analysis is always before the first application and after that in every 5 years.

Cyprus: Waste Discharge Licenses issued to Wastewater Treatment Plants under the Water Pollution Control require that soil analysis of the areas employed for sludge use should be carried out before sludge application. Therefore, the frequency of soil analysis depends on the frequency of sludge application in the specific area.

Czech Republic: Once every 10 years

Denmark: Sewage sludge is not allowed, if the limit values are exceeded. If an authority have reasons to believe the limits are exceeded, analysis are required Estonia: The main places where sludge is used are covered by points of the soil monitoring programme, and the frequency of the monitoring is once a year. The selection of components to be determined in the monitoring programme has been made on the basis of previous scientific research (by the Agricultural Research Centre). Finland: Refers to the report for the period 1995-1997. Regarding Åland Islands: Every 5th year.

Flanders: The soil should be analysed before the sludge is applied. The treated sludge must be analysed at least every six months. If changes appear in the quality of the treated waste water, the frequency of these analyses is doubled.

France: The soil should be analysed after the final application on the reference plot if it is not within the application perimeter, and at least every 10 years.

Germany: Soil analyses are to be carried out before sludge is applied for the first time, and then every 10 years (§ 3(2) and (3) of the Sludge Order, AbfKlärV).

Greece: Since sludge is not used in agriculture, soil analysis is not set as compulsory. Additional to the above answers it must be noted that, according to the National Legislation (JMD 80568/4225/1991) in order to use sludge in agriculture the appropriate permit must be granted to the user by the competent Prefectural Authority. In this permit the required terms and conditions for the use of sludge as set in the ANNEX II of Directive 86278 are laid down.

Hungary: Five years

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Ireland: Under the Waste Management (Use of Sewage Sludge in Agriculture) (Amendment) Regulations 2001 sludge shall not be used except in accordance with a nutrient management plan. The Schedule of the Regulations requires where sludge is used in agriculture, soil shall be analysed at a minimum frequency of once in 10 years.

Italy: Soil analyses must be carried out at least every three years.

Latvia: The frequency of analysis is not time limited but based on numbers of applications. The concentration by mass of heavy metals in soil shall be determined before the first and every fifth incorporation of sewage and its compost into the same area of land. Lithuania: No answer

Luxemburg: Refers to the Grand Ducal Regulation. Poland: Land should be subjected to analyses by the entity producing municipal sludge (on each occasion) before municipal sludge is applied to it. Moreover, analyses are carried out once a year on land to which municipal sludge has been applied.

Portugal: The soils must be analysed prior to each application of sludge, not more than six months before the date on which the application for a permit to use sludge on agricultural land is submitted.

Romania: The use of sludge where the concentration of one or more heavy metals in the soil exceeds the limit values which are laid down in MO No 344/2004 shall be forbidden, and the necessary measures shall be taken to ensure that these limit values are not exceeded as a result of the use of sludge. Soil has to be analysed prior to each spreading of sewage sludge.

Slovakia: No

Slovenia: The Decree on the limit input concentration values of dangerous substances and fertilisers in soil does not specifically state the frequency of soil analysis, but Article 12(5) stipulates that, in order to obtain an environmental permit to input sludge, applicants must also submit a soil analysis, which means that the minimum frequency of soil analysis is every five years because environmental permits are issued for a maximum period of five years.

Spain: No information given, set by Spain's autonomous communities.

Sweden: The concentration of metals the soil in Sweden is normally very low. Very few soils have concentrations at, or close to, the lower limits specified for each metal in Annex IA. Therefore, soil analysis shall be carried out only if it is probable that the concentration of one or more heavy metals in the soil in question exceeds the limit values stated in Bilaga B (Annex B) of the Swedish regulations 1994:2, because; 1. The natural metal content of the soil is high, 2. The soil has been polluted due to some accident, or 3. Emissions of heavy metals from industrial processes are occurring, or have occurred, in the surroundings.

UK: Where sludge is used on that land for the first time after the operative date. As soon as may be after the 20th anniversary of the date of when the soil was last tested. Where the sludge producer is asked to do so in writing by the occupier of

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the land or by the Secretary of State and not less than 5 years have elapsed since the soil was last tested.

Resumé: Most Member States have set time limits for the minimum frequency of soil analysis. They vary from one year (Poland) to 20 years (the UK). Some countries (such as Sweden) have not set a minimum frequency of soil analysis but instead an analysis is triggered if there is a possibility that limit values would be exceeded. In Latvia the frequency of analysis is not time limited but based on numbers of applications. The data from Finland, Greece, Lithuania, Slovakia and Spain is unclear.

3.12 Quantities of sludge produced, sludge used in agriculture and average concentration of heavy metals in sludge

According to Article 10 (a) and (b), Member States have to ensure that up-to-date records are kept, which register the quantities of sludge produced and the quantities supplied for use in agriculture as well as the composition and properties of the sludge in relation to the parameters in Annex II A.

Member States were asked to complete tables on quantities of sludge used and produced in agriculture and average concentration of heavy metals in sludge on the basis of the data contained in the records referred to in Article 10.

All values have been compiled in Annex IV and Annex V to enable a better comparison between national limits. Annex IV covers quantities of sludge used and produced and Annex V lists the heavy metal concentrations in sludge.

All assessed Member States provided information apart from Denmark and Greece. Ireland has not provided information of nitrogen, phosphorous and chromium content of sludge. For Romania there is no information of nitrogen, phosphorous and heavy metal content in sludge.

For Flanders no analysis results are available for 2006, as a decision was taken very rapidly in 2006 to stop using sludge from sewage treatment plants in agriculture due to the sharply rising costs of complying with the conditions governing the use of such sludge for such a purpose.

Resumé: All assessed Member States provided information apart from Denmark and Greece. Ireland has not provided information of nitrogen, phosphorous and chromium content of sludge. For Romania there is no information of nitrogen, phosphorous and heavy metal content in sludge.

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3.13 Exemptions granted to small sewage treatment plants

According to Article 11, Member States may exempt from Article 6 (b) and Article 10 (1) (b), (c) and (d) and paragraph 2, sludge from sewage treatment plants with a treatment capacity below 300 kg BOD5 per day, corresponding to 5 000 person equivalents, which are designed primarily for the treatment of domestic waste water.

Member States were asked for the number of cases, where exceptions were applied under Article 11.

Bulgaria: Currently in Bulgaria there is no WWTP with treatment capacity below 300 kg BOD5 and 5000 person equivalent.

Finland: Exemption concerning the required frequency of analyses of sludge / year have been granted to waste water treatment plants with less than 5000 person equivalents (for more information, see the report for the period 1995-1997). In the year 2006, there were about 350 such plants in Finland. Regarding Åland Islands sludge is not used in agriculture if the sludge is produced in ordinary waste water treatment plants.

Germany: The Sludge Order states that only waste-water treatment plants with a capacity of less than 1 000 population equivalents can be granted general exemption from the requirements specified in Article 6(b) and Article 10(1)(b), (c) and (d) and 10(2) of the above-mentioned Directive. No information has been collected to determine how many of these plants there are.

Italy: No exemption from the sludge analysis requirement is provided for. However, plants with a treatment capacity below 5 000 inhabitants equivalent are allowed to analyse sludge only once a year.

Portugal: The information given in reply to this question in respect of 1998-2000 remains valid.

All the other analysed Member States, Austria, Cyprus, Czech Republic, Denmark, Estonia, Flanders, France, Hungary, Latvia, Lithuania, Luxemburg, Poland, Romania, Slovakia and Ireland do not have any Article 11 exemptions in place.

Resumé: Only Bulgaria, Finland, Germany and Italy have Article 11 exemptions in place and they all appear to be appropriate.

4 Resumé

The following resumé and conclusions do not replicate all the detailed, article specific, conclusions drawn throughout the report with regard to the Member State compliance. This section aims to present the most important issues identified in the report and set out the priorities. For the more detailed article-related conclusions please relate to the preceding chapters.

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4.1 Mode of reporting by the Member States

The following issues have proved problematic in reporting.

• Copy/paste of transposing Regulation. In these cases the respondents (such as Lithuania and Latvia) have copied several pages of their transposing legislation under one question and most of the information is irrelevant.

• Reference to previous questionnaires. This is especially the case for Portugal and Finland

• Reference to transposing legislation, such as in the case of UK

• Conflicting information in the questionnaire, such as in the case of Greece and the use of sewage sludge in agriculture.

• Data missing. This is the case for several of the Member States

Also, in any future questionnaires it is recommended to word the questions in such a way that there will be no danger of “mistakenly unanswered questions” being interpreted in the same way as “deliberately unanswered questions”. Possible gaps in the implementation of Directive

4.2 Possible Gaps and Implementation Issues

The Directive provides a great flexibility in national implementation resulting in a great variety in approaches and limit values. These are not gaps per se and are discussed in more details under the previous section specific summaries. However, some of the initial gaps and recommendations are discussed here. It is anticipated that further issues will emerge in the analysis of the Annexes, using the approach described in more detail in section 3.2.1. The intention is that the suggested approach will provide a better overview of national limit values as well as indicate possible “geographical groups”. It might also identify countries that seem to belong to a “wrong group” based on stricter/less strict national limit values.

4.2.1 Transposition

All Member States have provided the Commission with details on the transposition of the Directive. Apart from Greece and Latvia, all Member States have notified the Commission of measures according to Article 5. Most Member States have notified the Commission on stricter measures. Portugal, Spain and Ireland do not have stricter measures in place but Greece has chosen not to inform the Commission of the stricter limits.

4.2.2 Limit values for heavy metals

For heavy metals in soil there is a wide variation in national limit values as well as surprisingly large differences in limit values between similar geographical areas, such between the Baltic states for cadmium (Latvia 0.9, Lithuania 1.5 and Estonia 3) or between the Nordic countries for cadmium (Sweden 2, Denmark 1.5 and Finland 0.5). Of the assessed countries Spain, Cyprus, Portugal and Greece have set the highest limit values. Spain has exceeded the limit values for copper, nickel and zinc (permitted, according to its questionnaire). On average Flanders’ has set the lowest limit values for the assessed heavy metals, apart from mercury.

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For heavy metals in sludge most of the Member States have set their limit values below the maximums allowed by the Directive, apart from zinc, where a majority of Member States has set their limits close to those allowed by the Directive. Again there is a wide variation in national limit values, such as for copper, where the limit values range from Slovenia’s 300 mg/kg dry matter to Bulgaria’s 1600 mg/kg dry matter. There are` also surprisingly large differences in limit values between similar geographical areas, such between the Nordic countries for cadmium (Sweden 40, Denmark 0.8 and Finland 3). Of the assessed countries Spain, Cyprus, Portugal and Greece have set the highest limit values. On average Flanders and Slovenia has set the lowest limit values for the assessed heavy metals.

For limit values of heavy metals introduced to the soil, there tends to be a group consisting of Bulgaria, Greece, Cyprus, Lithuania, Romania, Spain and Portugal that set their limit values to those allowed by the Directive with other Member States set their limit values considerably lower. The exemption is mercury, where most Member States have set their limit values to that allowed by the Directive. The wide variety between limit values of similar geographical areas continues.

4.2.3 Sewage Sludge from Septic Tanks

The measures used are based on equal requirements for all sludge, an outright prohibition of using sludge from a septic tank or specific measures required for sludge from a septic tank. However in the case of Cyprus it is unclear if sewage sludge from septic tanks would be covered by the restricting legislation and in the case of Lithuania it is unclear to which sludge category, setting different conditions for use, septic tank sludge belongs to. In addition Spain, Finland, Luxemburg and Flanders have not answered the question. Poland’s answer is “not applicable”. In addition Poland only refers to treatments of municipal waste in its response to treatment technologies, which raises the question about treatment of other sludge, such as that from septic tanks.

4.2.4 Maximum Amount of Sludge

Ten Member States have opted for option 5.2 (a) and five have stated that they have opted for option 5.2.(b). For those Member States that have selected option 5.2(a), the maximum quantities vary from the two tonnes of dry matter per hectare for Poland and Flanders to the 55 tonnes per hectare for Bulgaria. It is recommended to assess how the maximum quantities compare to the other information provided by the Member State in question and if this warranties any further action in terms of the maximum quantities indicated.

4.2.5 Use of Untreated Sludge Apart from Estonia, France and Sweden all Member States have prohibited the use of untreated sludge if it is injected or worked into the soil. In Estonia the transposing regulation permits the use of untreated sludge in landscaped areas and in recultivation. Untreated sludge spread on the ground must be worked in or covered with soil within two days of the spreading commencing, except where landfills are being covered. In Sweden untreated sludge may be used if it is worked into the soil within a maximum of 24 hours after being spread and its use does not cause a inconvenience to local residents. It is questionable if the Swedish criteria of “does not cause an inconvenience to local residents“ is appropriate for using untreated sludge. In France, untreated sludge can only be used for material from certain activities, where the waters used are less than 120 kg DBO5/day, and when the sludge is buried in the soil immediately after application using equipment adapted for that purpose. Also the principles in the French Decree have to be taken into consideration.

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