The emergency amendment to the Water Act (Act No. 182/2024 Coll., amending Act No. 254/2001 Coll., on Water) has brought changes to Section 39(2)(a). A new obligation to enter digitised emergency plans into the ISPOP system (Integrated Reporting Obligations Fulfilment System) is being introduced.

Main changes introduced by the amendment:

• Maintaining existing obligation: The obligation to prepare an emergency plan remains unchanged and does not extend the range of subjects, to whom it applies.
• Digitization of the plans: The amendment introduces an obligation to digitise emergency plans, but does not introduce a direct obligation to update them. However, Grant Thornton recommends that plans are updated in compliance with Section 41 (Accident) and Section 42 (Obligations in the event of an accident).
• Transition period: Existing emergency plans must be uploaded to ISPOP at the next update, no later than 1 August 2026.
• New plans: Digitisation applies without delay to plans created after 1 August 2024.
• Limited scope: The obligation to enter plans in the ISPOP only applies to emergency plans if the accident may affect a watercourse.

Obligation under Section 39(2)(a):

Entities handling pollutants on a large scale or at increased risk to water must:

1. Develop an emergency plan, approve it with the relevant water authority and discuss it with the relevant watercourse manager, if an accident may affect the watercourse.
2. Entities that handle hazardous substances that may affect the watercourse in case of an accident must enter the plan into the ISPOP after approval.

Details of the essentials of an emergency plan are defined in Decree No.450/2005 Coll., on the essentials regarding the handling of hazardous substances and the essentials of an emergency plan, the manner and extent of reporting accidents, their disposal and the elimination of their harmful consequences. In connection with the adoption of the emergency amendment, an update is currently being prepared. This amendment will probably also include a template for a new ISPOP form that will include key information from the emergency plan, such as:

• The type and quantity of hazardous substances handled.
• Details of the recipient that may be affected by an accident.
• Accident mitigation measures.
• Contact information.

This form will be available from 1 December 2024.

Our company has a team of experienced environmental experts who will help with the creation of emergency plans and their digitization and subsequent input into the ISPOP system. With our knowledge and experience, we ensure that all steps are carried out efficiently and in compliance with legislative requirements.

We also offer a complete internal audit of your environmental management system (EMS). We perform audits from A to Z, from the identification of deficiencies to the design and implementation of measures to meet legal obligations. Our goal is to help you not only identify gaps in your system, but also to successfully fill them and strengthen your procedures in compliance with applicable regulations.

By working with us, you can be sure that your system meets all legal requirements and is ready to handle any challenges.