The italian legislation on sewage slude, based on the old EU directive, has been recently updated and new limits for specific pollutants has been defined.

1. W
H
I
T
E
October 2018
The legislation
on sewage
sludge
management in
Italy

2. Summary

3. The main legislation
The Italian main law that rules the use of sewage
sludge as fertilizer is the National Decree 99/1992
This law defines:
• Specific limit values for a limited number of
parameters
• Which are the treatments to stabilize the
sewage sludges
• The maximum amount that can be used in the
same area in a time interval of three years

4. The ban of use
1. where there are regular floods or marshland
2. slopes higher than 15%
3. soil with pH lower than 5
4. cationic exchange capacity (CEC) lower than 8
meq/100 gr
5. Used as pasture within 5 weeks before the use
6. Used for vegetable productions within 10 months
before the harvest

5. The permittingprocess
The collection, transport, storage and conditioning process shall be
authorized by the local authorities (Region)
The use of sewage sludge shall be authorized by the Region that can
define:
Specific local limits or ban of use based on soil composition, sludges composition and related treatments
Minimum distances between the area where the sludges will be used an a list of targets (as springs, rivers)
Specific plan to regulated the use of sludges (Piani di utilizzazione Agronomica) based on nutrients needs and soil
compositions

6. Sludge use permit
The use of sludge shall be authorized by the Regional Authorities
The user shall notify, at least 10 days in advance, the use of sludge
The request shall include:
1. Type of sludges
2. Type of crop that will be farmed
3. Information about the storage and condition plant that provide the sludges
4. Chemical analysis of sludes
5. GPS information or cadastral information of fields where sludges will be used
6. Composition of soil
7. Dates when the sludges will be spread
8. Agreement between farmer and sludges provider
The permit has a duration of five years

7. Soil composition
The soil shall be analysed in compliance with Annex IIA of the law
(parameters and sampling method)
The concentration of heavy metals in soil shall be lower than the value
listed in Annex IA (Table below)
The frequency of analysis is three years
Maximum concentration in soil
Parameter Limit value (mg/kg DM)
Cd 1,5
Hg 1
Ni 75
Pb 100
Cu 100
Zn 300

8. Sludges analysis
The sludges shall be analysed in compliance with the following table
Dimension of WWTP Frequency
Higher than 100.000 PE (Popolation Equivalent) 3 months
Lower than 100.000 PE 6 months
Lower than 5.000 PE 12 months
Parameter Limit value (mg/kg DM)
Cd 20
Hg 10
Ni 300
Pb 750
Cu 1000
Zn 2500
Parameter Limit value (mg/kg DM)
Organic Carbon % DM 20 (minimum)
P ( % DM) 0,4 (minimum)
N ( % DM) 1,5 (minimum)
Salmonella (MPN/ g DM) 103

9. Technical provisions
The law defines specific provisions for
collection, transport and treatment of sludges
in order to minimize the impacts on health and
environment (e.g. the trucks used for transport
shall be cleaned before any other transport of
different goods)
Specific provisions for the spreading phase in
order to minimize the odour impacts

10. The evolution of
Europeanlegislation

11. The evolution of the European law
The Decree 99/1992 is based on the
Directive 86/278/CEE
The directive was under a revision process
since years 2000 in order to include new
pollutants as PCB, PCDD and PAC
The EU commission has approved a draft of
the new legislation and several studies are
available on EU DG Environment website
(http://ec.europa.eu/environment/waste/sl
udge/index.htm)

12. The role of Circular
Economy
The use of sludges as fertilizer is widely adopted in EU, but
presented in several problems related to the content of
micropollutants and their effects on soils
One of the main problem is the progressive reduction of
organic matter in soil, in particular in the south of EU
The sludges present an high content of P that is a non-
renewable element. The main sources of P are located in
Africa and South America. P is a macronutrient for crops
and its role is fundamental to maintain the soil fertility.
http://ec.europa.eu/environment/natres/phosphorus.htm

13. The Italian situation

14. TheItalianscenario
Several regions has adopted specific local legislation to integrate the national
legislation
• Veneto: Regional Decree 235/2009 based on the third draft of EU directive
proposal
(https://bur.regione.veneto.it/BurvServices/pubblica/Download.aspx?name
=235_AllegatoA_213270.pdf&type=9&storico=False)
• Lombardia: Regional Decree 7076/2011
(http://www.regione.lombardia.it/wps/portal/istituzionale/HP/DettaglioRe
dazionale/servizi-e-informazioni/Enti-e-Operatori/ambiente-ed-
energia/Rifiuti/disposizioni-integrative-valori-limite-fanghi-in-
agricoltura/disposizioni-integrative-valori-limite-fanghi-in-agricoltura)

15. The emergencydecree
Some judgement has blocked the use of sludges in
agriculture because they was considered as source of
soil pollution.
The ban of use of sewage sludges in agriculture
caused a huge increase of prices for their disposal, in
many cases the sludges has been sent to foreign
countries as Hungary, in compliance with Reg.
1013/2006 to be used as fertilizer or to incineration
plant
The Italian parliament has approved an amendment
to the decree 99/1992 to overtake the emergency and
increase the level of controls on sewage sludges

16. The content of the amendment
New limit values for the following
substances derived form the III draft of EU
Directive on Sewage sludges
Substance Limit value EU Sludge directive III draft
proposal
Hydrocarbons 1000 mg/kg
PAH (as defined in tab.1 Annex 5, Title V of National
Decree 152/06)
6 mg/kg DM 6 mg/kg DM
PCCD/PCDF (dioxines) + PCB DL 25 ng WHO TEQ/Kg DM 100 ng WHO TEQ/Kg DM
PCB 0,8 mg/Kg DM 0,8 mg/Kg DM
Toluene 100 mg/Kg DM
Se 10 mg/Kg DM
Be 2 mg/Kg DM
As 20 mg/Kg DM
Cr (tot) 200 mg/Kg DM
Cr VI 2 mg/Kg DM
The decree n. 109/2018 aka
“Decreto Morandi” provide at
art. 41 specific new provisions

17. The limit value for Hydrocarbons
In relation with the limit value for Hydrocarbon
there is specific derogation because some
hydrocarbons are naturally included in sewage
sludges.
The decree bans the use of sludge contaminate
by hydrocarbons derived from crude oil or
mineral oil
The available methods to identify these
substances are not clearly defined
The Health instituted proposed a methodology
based on markers identification in 2006 and
improved in 2009
(http://old.iss.it/ampp/index.php?lang=1&id=390
&tipo=18)

18. The amendment in the second paragraph explains:
If the concentration of hydrocarbon is lower than 1000 mg/kg DM the use of sludges is allowed
If the concentration of hydrocarbon is higher than 1000 mgKg DM it is necessary to demonstrate the absence of
mineral oil derived markers as described in the note L of Annex VI of Reg. EU 1272/2008 CLP as specified in the
document drafted by National Health Institute (ISS) n. 36565 of July 5th, 2006 and its amendments
The limit value for Hydrocarbons
Hydrocarbon
Content
Lower than 1000
mg/Kg DM
Higher than 1000
mg/Kg DM
Marker Analysis
based on note L
and ISS
Document
Contamination
of mineral
hydrocarbon
The use is
admitted
The use is
banned
No
Yes

19. The list of PAH defined by ISS
Index number CAS Name Limit value (mg/kg)
601-032- 00-3 50-32-8 Benzo (a) pyrene 100
601-041- 00-2 53-70-3 Dibenzo (a,h) anthracene 100
601-034- 00-4 205-99-2 Benzo[e]acephenantrhylene 1000
601-049- 00-6 192-97-2 Benzo[e]pyrene 1000
601-035- 00-X 205-82-3 Benzo[j]fluoranthene 1000
601-036- 00-5 207-08-9 Benzo[k]fluoranthene 1000
601-033- 00-9 56-55-3 Benzo[a]anthracene 1000
601-048- 00-0 218-01-9 Chrysene 1000

20. The note L of Annex VI of CLP
The note L of CLP says:
The classification as a carcinogen need not apply
if it can be shown that the substance contains
less than 3 % DMSO extract as measured by IP
346 ‘Determination of polycyclic aromatics in
unused lubricating base oils and asphaltene free
petroleum fractions — Dimethyl sulphoxide
extraction refractive index method’, Institute of
Petroleum, London. This note applies only to
certain complex oil-derived substances in Part 3.
The ISS document underline that this method,
specifically developed to evaluate the content
of PAH in used oil is not applicable to waste.
For this reason the Institute proposes the
development of markers methodology

21. An EU surveyof sludges use as fertilizer
Limit values for heavy
metals in EU country –
Febraury 2018 (source:
EU perspective and
German legislation
concerning sludge - Dr.
Claus – Gerhard Bergs)

23. Circonvallazione Gianicolense,
216E
00152 Roma, Italia
www.wasteandchemicals.eu
Mail:info@wasteandchemicals.eu
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