Twenty-five officer roles, all live todayArt. 33 GDPR, 72 hours to report a breach93 controls under ISO/IEC 27001:202237 ready-to-run audit templates in the workspace§ 130 OWiG, supervisory duty of the management boardOfficer appointment letter, signed, filed, evidencedOne workspace for tasks, trainings, audits, documentationDIN 14095 fire protection plans, standardisedEU AI Act, the first horizontal AI regulation worldwideTwenty-five officer roles, all live todayArt. 33 GDPR, 72 hours to report a breach93 controls under ISO/IEC 27001:202237 ready-to-run audit templates in the workspace§ 130 OWiG, supervisory duty of the management boardOfficer appointment letter, signed, filed, evidencedOne workspace for tasks, trainings, audits, documentationDIN 14095 fire protection plans, standardisedEU AI Act, the first horizontal AI regulation worldwide
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Water Protection Officer

Water-hazard inventory per AwSV, tank and separator inspections, leakage response, annual report. Required for facilities handling water-hazardous substances above thresholds.

Focus areas
§ 64 WHGAwSVTank inspectionLeakage response
Legal basis

§ 64 WHG · AwSV

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What is a water protection officer?

The water protection officer (Gewässerschutzbeauftragter) is the statutory function under § 64 WHG (Federal Water Act) for internal supervision of wastewater discharge and handling of water-hazardous substances. The duty is specified by the Federal Ordinance on Installations Handling Water-Hazardous Substances (AwSV) of 18 April 2017, which replaced the former state ordinances (VAwS) and applies uniformly across Germany since 1 August 2017. § 64 paragraph 1 WHG covers operators discharging more than 750 cubic metres of wastewater per day and operators of installations handling, storing or producing water-hazardous substances of water hazard classes WGK 1, WGK 2 or WGK 3 under Annex 1 AwSV above the volumes in Annex 7 AwSV. Indirect dischargers with sector-specific duties under the Wastewater Ordinance (AbwV), e.g. Annex 22 chemicals, Annex 40 electroplating or Annex 49 refineries, typically fall in scope as well.

Water-hazardous substances are classified under § 3 AwSV into WGK 1 (slightly), WGK 2 (clearly) and WGK 3 (severely water-hazardous), plus floating liquid substances and generally water-hazardous (awg). Classification and installation hazard tier (A, B, C, D) under Annex 1 AwSV determine LAU duties (storage, filling, transhipment) and HBV duties (production, treatment, use). JGS installations for slurry, manure, silage liquor and dung fall under § 62 AwSV with specific technical requirements in Annex 7. Stricter requirements apply in drinking water protection zones I and II; the LAWA guidance applies in zone III.

The officer advises on water rights permits under §§ 8 ff. WHG, reviews notifications under § 40 AwSV before substantial changes, coordinates recurring expert inspections under § 46 AwSV by approved expert organisations (SVO) and prepares the annual report under § 65 WHG in conjunction with § 58b BImSchG. § 66 WHG ensures functional independence and dismissal protection. Breach of the appointment duty is an administrative offence under § 103 WHG with fines up to 50,000 EUR. Criminal liability under § 324 StGB (water pollution) applies with prison sentences up to five years, or up to three years for negligence.

Duties of the water protection officer

  • Monitor compliance with water rights permits under §§ 8 to 12 WHG and the sector-specific Annexes of the Wastewater Ordinance (AbwV).
  • Maintain the installation register under § 43 AwSV with location, WGK, volume, hazard tier (A, B, C, D) and inspection interval.
  • Notify the competent water authority at least six weeks in advance of erection, extension or substantial change of installations under § 40 AwSV.
  • Coordinate recurring inspections under § 46 AwSV by approved expert organisations (SVO) such as TUEV, DEKRA, GTUE, every 2.5 or 5 years depending on hazard tier.
  • Verify firewater retention under LoeRueRL and requirements under TRwS 779 (general technical rules for LAU installations).
  • Advise on JGS installations under § 62 AwSV including collection volume sizing and inspection records.
  • Prepare the annual report under § 65 WHG with measures, incidents, inspection results and recommendations.
  • Train staff on operating instructions under § 44 AwSV and emergency procedures for leakages.
  • Accompany official self-monitoring of wastewater discharge under the state SuEVO ordinances and validate measurement data.
  • Verify fire-fighting equipment, containment trays, double walls and leak monitoring devices against TRwS and AwSV requirements.

When is appointment mandatory?

§ 64 paragraph 1 WHG requires the appointment of a water protection officer when (a) a water rights permit allows the discharge of more than 750 cubic metres of wastewater per day or (b) installations handling water-hazardous substances exceed the volume thresholds in Annex 7 AwSV. Thresholds vary by WGK and installation type: 100 cubic metres of WGK 3 substances or 1,000 cubic metres of WGK 1 substances in above-ground installations can already trigger the duty. Separate thresholds apply to underground installations and to double-walled tanks with leak monitoring. § 64 paragraph 2 WHG allows the authority to order appointment in individual cases, in particular where installations lie within drinking water protection zones I and II or have a pollution history.

The appointment must be in writing, with a specific task catalogue, and notified to the lower water authority without delay. A joint appointment for several installations at the same site is permitted provided proper performance is ensured. § 65 WHG refers to the analogous application of §§ 55 to 58b BImSchG, so external appointments under § 55 paragraph 2 BImSchG are permitted by analogy; market hourly rates range from 130 to 250 EUR. Qualifications follow state administrative rules and the TRwS: relevant technical degree in engineering or natural sciences, at least two years of practical experience and an accredited training course of about 60 hours, with refresher training every two years. Removal is only effective for good cause under § 58 BImSchG by analogy.

  • Water rights permit for wastewater discharge exceeding 750 m3 per day (daily maximum under the permit).
  • Storage or use of WGK 3 substances above 100 m3 or WGK 2 substances above 1,000 m3 in above-ground installations (Annex 7 AwSV).
  • Operation of a JGS installation for slurry, manure, silage liquor or dung under § 62 AwSV above sizing threshold.
  • Authority order under § 64 paragraph 2 WHG (drinking water protection zone I/II, IPPC installation, pollution history).
  • Indirect discharge to public sewer with sector-specific obligations under the AbwV (e.g. Annex 40 electroplating, Annex 22 chemicals).
  • Erection or substantial change of an LAU or HBV installation of hazard tier C or D under Annex 1 AwSV.

Affected sectors

  • Chemicals, pharmaceuticals and petrochemicals with tank farms and reactors
  • Electroplating and surface treatment subject to AbwV Annex 40
  • Food and beverage with large wastewater volumes
  • Pulp, paper and textiles
  • Metal processing and pickling
  • Filling stations, tank farms and mineral oil distribution
  • Logistics and transhipment of water-hazardous substances
  • Large agricultural operations with JGS installations under § 62 AwSV
  • Wastewater treatment plants and industrial waterworks
  • Power generators with cooling water discharge and fuel storage
CIVAC

How CIVAC supports the water protection officer

CIVAC maintains a digital installation register under § 43 AwSV with WGK, volume, hazard tier and next inspection date. The sampling and self-monitoring calendar for wastewater discharge is linked to the AbwV Annexes; measurements from in-house laboratories are imported and benchmarked against the permit. Expert inspections under § 46 AwSV are escalated with lead time, inspection reports are archived in version-controlled PDFs, defects are dispatched with SLAs to plant managers and maintenance. AwSV notifications under § 40 are scheduled automatically with the six-week lead time. The annual report under § 65 WHG is generated from operational data. External officers operate jointly across sites.

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