How to draw up and implement plant documentation correctly in accordance with the AwSV

The AwSV requires full documentation for every installation involving substances that pose a risk to water. We explain which installations are affected, what the documentation should include, and how long it must be kept.

Key points at a glance

Since 2017, the AwSV has applied nationwide to all facilities where substances hazardous to water are handled.
The documentation requirement under Section 43 of the AwSV applies to volumes exceeding the de minimis threshold of 0.22 m³, even if the installation is not subject to inspection.
The documents must be updated whenever changes are made and must be kept for at least five years.

Requirements, fundamentals and practical guidance: Understanding the implications for industrial coating companies.

Key questions about AwSV documentation

What is the AwSV?

The AwSV (“Ordinance on Installations for the Handling of Substances Hazardous to Water”) has been in force nationwide since 2017 and replaces the previously state-specific VAwS regulations. It follows the precautionary principle set out in Section 62 of the Water Act (WHG): facilities must be designed in such a way that they cannot adversely affect water bodies.

When do I need system documentation in accordance with AwSV?

The de minimis threshold for installations subject to the AwSV is 0.22 m³. Individual small installations (e.g. with a single 200-litre drum of stock) do not fall within the scope of the AwSV. This also applies, for example, to machine tools filled individually with cooling lubricants or oils up to this volume.

Which facilities are affected?

This requirement applies to all facilities handling substances that pose a risk to water – including HBV facilities (e.g. electroplating or anodising plants) and LAU facilities (e.g. chemical storage facilities or tank farms).

The documentation requirement under Section 43 of the AwSV applies to all AwSV installations in which water-polluting substances are handled, regardless of whether they are subject to inspection or not.

How can we ensure that all legal requirements are met?

AwSV documentation is crucial for safety, legal compliance and environmental protection. Missing or incomplete documentation can result in fines, shutdowns or liability risks.

Drawing on our team of experts’ many years of experience and comprehensive expertise, we ensure that your plant documentation complies with all legal standards under the AwSV. In our newsletter, we keep you informed of any relevant changes to the law.

Contents of the plant documentation

Complete AwSV plant documentation comprises:

Type of investment
Substances used & WGK classification
Risk level (Section 39 of the AwSV)
Safety precautions
Technical Specifications
Operating instructions/information sheets
Contingency plan

Are there any documents missing for individual assets?

We will cross-check your asset register against the existing documentation and provide any missing information required by the authorities.

For advice

AwSV and VAwS – The differences

Whilst the VAwS used to vary from one federal state to another, the AwSV has, since 2017, regulated the handling of substances hazardous to water in a centralised and uniform manner. Older documents may still be relevant, but are no longer legally valid.

Updating and retention

Update: in the event of changes to plant, substances or safety measures; an annual inspection is recommended.
Storage: at least 5 years, even after decommissioning. In individual cases, longer periods may apply.

Collaboration with QUBUS

Practical example

Successful optimisation of hazardous substances documentation in a medium-sized company

At a medium-sized company, we were able to reduce a list of hazardous substances comprising around 1,300 substances to 450 relevant entries – without any loss of information.

The result: legally compliant, clearly structured and practical documentation that not only meets statutory requirements but also significantly simplifies the internal handling of hazardous substances.

Synergies with the secure bath management system created additional value, enabling processes to be made more efficient and transparent.

5 tips for your plant documentation

Identify and demarcate installations; note the de minimis limit of 220 litres
Determine the data: content (substance and water hazard class, WGK), concentration and quantity (volume), classification into hazard levels A–D
Drawing up plant documentation; compiling information; and producing and displaying operating instructions or information sheets
If necessary, arrange for expert inspections and notify the relevant authority
When constructing new installations or making alterations to existing ones, ensure that the necessary work is carried out and be aware of any reporting requirements

Your contact person

Frank Schüle

Graduate Engineer (FH) Head of the Environment, Health and Safety / Fire Safety Department

+49 7171 10408-17 schuele@qubus.de

Is your AwSV documentation complete?

We carry out an inventory of your facilities, classify substances and hazard levels, and produce documentation that will stand up to scrutiny during the next regulatory inspection.

Have the documentation checked