A warm welcome to the H&S Working Group

11

A warm welcome to the H&S Working A warm welcome to the H&S Working GroupGroup

22

Federation of European Federation of European Explosives ManufacturersExplosives Manufacturers

Meeting of the H&S Meeting of the H&S Working Group Delegates Working Group Delegates

onon01 October 201401 October 2014

in Lisbon, Portugalin Lisbon, Portugal

33

Meeting of the Transport Working Group

List of ParticipantsList of Participants

1.1. Jean-Paul Reynaud, Titanobel, France ChairmanJean-Paul Reynaud, Titanobel, France Chairman

2.2. Severine Gautreau, DB, FranceSeverine Gautreau, DB, France

3.3. Janusz Dryzga Janusz Dryzga , Nitroerg, Poland, Nitroerg, Poland

4.4. Jaroslav Konarik, Austin Detonator, PolandJaroslav Konarik, Austin Detonator, Poland

5.5. Ashley Haslett, EOC, UKAshley Haslett, EOC, UK

6.6. Javier Lopez Amigo, Maxam, SpainJavier Lopez Amigo, Maxam, Spain

7.7. Jose M. Castresana, Maxam, SpainJose M. Castresana, Maxam, Spain

8.8. Jens Schlierf, Orica, GermanyJens Schlierf, Orica, Germany

9.9. Matti Vähäpassi, Forcit, FinlandMatti Vähäpassi, Forcit, Finland

10.10.Maurice Delaloye, SSE, SwitzerlandMaurice Delaloye, SSE, Switzerland

11.11.Martin Klein, DynaEnergetics, GermanyMartin Klein, DynaEnergetics, Germany

12.12.Marin Dorobantu, Weatherford, RomaniaMarin Dorobantu, Weatherford, Romania

13.13.Thierry Rousse, EPC, FranceThierry Rousse, EPC, France

ApologyApology

1.1. Walter Panchyrz, Orica, GermanyWalter Panchyrz, Orica, Germany

2.2. Hans Karlström, Kimit, SwedenHans Karlström, Kimit, Sweden

In attendance: Hans H. Meyer, FEEM, BelgiumIn attendance: Hans H. Meyer, FEEM, Belgium

44

Compliance with European Competition LawCompliance with European Competition Law

As an Association, FEEM operates in strict compliance with As an Association, FEEM operates in strict compliance with

European competition laws. Respect for these laws is a core European competition laws. Respect for these laws is a core value value

applying to all FEEM activities. All members of this Working applying to all FEEM activities. All members of this Working Group Group

have been informed by the Secretary General about prohibited have been informed by the Secretary General about prohibited

discussion topics which apply not only during meetings but also discussion topics which apply not only during meetings but also to to

social gatherings before and after meetings. By signing the social gatherings before and after meetings. By signing the

participation form, the delegates declare their adherence to the participation form, the delegates declare their adherence to the

Competition Compliance Programme and agree to comply with Competition Compliance Programme and agree to comply with

Competition Law.Competition Law.

An up-dated CEFIC checklist of competition compliance An up-dated CEFIC checklist of competition compliance regulations regulations

has been handed out at the previous meeting in Bonn to the has been handed out at the previous meeting in Bonn to the working working

group delegates.group delegates.

55

Compliance with European Competition LawCompliance with European Competition Law

Very clearly: You are not allowed to discuss or Very clearly: You are not allowed to discuss or exchange information exchange information

which is not in conformity with competition which is not in conformity with competition legislation, including legislation, including

e.g. on:e.g. on:

1.1. PricesPrices

2.2. Production detailsProduction details

3.3. Transportation ratesTransportation rates

4.4. Market proceduresMarket procedures

66

Meeting of the H&S Working Group(Draft) Agenda for 01 October 2014(Draft) Agenda for 01 October 2014

1.1.Opening remarks by the chairmanOpening remarks by the chairman Jean-Paul Jean-Paul ReynaudReynaud

2.2.Compliance with the European and Compliance with the European and National Competition Laws and RegulationsNational Competition Laws and RegulationsHans MeyerHans Meyer

3.3.Agenda and Approval Agenda and Approval Jean-Paul Jean-Paul ReynaudReynaud

4.4.Minutes of the last meeting on 13 March 2014 Minutes of the last meeting on 13 March 2014 in Prague and approvalin Prague and approvalJean-Paul ReynaudJean-Paul Reynaud

5.5.Secretary General’s Report Secretary General’s Report Hans Hans MeyerMeyer

77

Meeting of the H&S Working Group(Agenda cont.)

with, in particular:with, in particular:

1.DIRECTIVE 2014/28/EU2.2.CLP UP-DATECLP UP-DATE

1.1.New requirements for mixtures as of New requirements for mixtures as of 1 June 2015 1 June 2015

2.2.Proposal for review of Chapter 2.1 Proposal for review of Chapter 2.1 (Explosives) in the GHS (Explosives) in the GHS

6.6.Any other BusinessAny other Business1.1.Globally harmonized standard for Globally harmonized standard for

explosives security markingsexplosives security markings2.2.Marking of large diameter detonating Marking of large diameter detonating

cordscords

88

Meeting of the H&S Working Group(Agenda cont.)(Agenda cont.)

7.7.Lead tetroxide/lead monoxide, situation as Lead tetroxide/lead monoxide, situation as per September 2014per September 2014

8.8.The Color-Codingof ExplosivesThe Color-Codingof Explosives9.9.Subjects for discussion at the next Subjects for discussion at the next

meetingmeeting10.10.StatisticsStatistics11.11.Date, place and time of next meetingDate, place and time of next meeting

99

Meeting of the H&S Working Group

Do you agree to this Agenda?Do you agree to this Agenda?

1010


Item 4

Approval of the Approval of the Minutes of the H&S Group Minutes of the H&S Group Meeting held in Prague on Wednesday, Meeting held in Prague on Wednesday,

26th March 201426th March 2014

1111


Item 4

Do you approve these Do you approve these Minutes ?Minutes ?

1212

DIRECTIVE 2014/28/EU OF THE EUROPEAN PARLIAMENT

AND OF THE COUNCIL of 26 February 2014

Item 5Item 5Secretary General’s ReportSecretary General’s Report

1313

You are aware that a new Directive has You are aware that a new Directive has been published this year, regulating been published this year, regulating the harmonization of the laws of the Member States relating to the making available on the market and supervision of explosives for civil uses. This . This Directive incorporates a number of other Directive incorporates a number of other Directives and Regulations such as Directives and Regulations such as 93/15 & 2008/43, 93/15 & 2008/43, 2004/57, 765/2008, 768/2008, 96/82, 2013/29, 91/477 and others, dealing and others, dealing with explosives and pyrotechnical with explosives and pyrotechnical articles.articles.

Directive 2014/28Directive 2014/28

1414

This is the new “Bible” for the This is the new “Bible” for the Explosives Industry!Explosives Industry!

What is covered by the new Directive?What is covered by the new Directive?

All explosives according to the definitions based on the definition of such products as set out in the United Nations recommendations on the transport of dangerous goods.


1515

What is not covered?What is not covered?


(a)explosives, including ammunition, intended for use, in accordance with national law, by the armed forces or the police

(b)pyrotechnic articles falling within the scope of Directive 2013/29/EU

(c) ammunition, save as provided for in Articles 12, 13 and 14.

1616

Major emphasis is focused on:Major emphasis is focused on:

1. Obligations of manufacturers, such as

– When placing their explosives on the market or when using them for their own purposes, manufacturers shall ensure that they have been designed and manufactured in accordance with the essential safety requirements.

– Where compliance of an explosive with the applicable requirements has been demonstrated by that procedure, manufacturers shall draw up an EU declaration of conformity and affix the CE marking.


1717

Manufacturers shall keep the technical documentation and the EU declaration of conformity for 10 years after the explosive has been placed on the market.


1818

Manufacturers shall ensure that explosives which they have placed on the market bear a unique identification in accordance with the system for the identification and traceability of explosives. For explosives excluded from that system, manufacturers shall:

1. Ensure that explosives which they have placed on the market bear a type, batch or serial number or other element allowing their identification, or, where the small size, shape or design of the explosive does not allow it, that the required information is provided on its packaging or in a document accompanying the explosive.


1919

oror

2. Indicate on the explosive their name, registered trade name or registered trade mark and the postal address at which they can be contacted or, where that is not possible, on its packaging or in a document accompanying the explosive. The address shall indicate a single point at which the manufacturer can be contacted. The contact details shall be in a language easily understood by end-users and market surveillance authorities.


2020


3. Manufacturers shall ensure that 3. Manufacturers shall ensure that explosives which they have placed on the explosives which they have placed on the market are market are accompanied by instructions and accompanied by instructions and safety information in a language which can safety information in a language which can be easily understood by end-usersbe easily understood by end-users, as , as determined by the Member State concerned. determined by the Member State concerned. Such instructions and safety information, as Such instructions and safety information, as well as any labelling, shall be clear, well as any labelling, shall be clear, understandable and intelligible. understandable and intelligible.

2121

The other articles regulate the obligations of

• Authorized representatives• Importers• Distributors

This group shall be considered like a manufacturer for the purposes of this Directive and they shall be subject to the obligations of the manufacturer, where he places an explosive on the market under his name or trade mark or modifies an explosive already placed on the market in such a way that compliance with this Directive may be affected.


2222

The Directive also deals with the qualification of the conformity assessment body (NB), e.g.

1. their personnel shall carry out the conformity assessment activities with the highest degree of professional integrity and requisite technical competence.

2. a conformity assessment body shall have at its disposal the necessary personnel with technical knowledge and sufficient and appropriate experience to perform the conformity assessment tasks.


2323

3. The personnel responsible for carrying out the conformity assessment tasks shall have the following:

(a) sound technical and vocational training covering all the conformity assessment activities in relation to which the conformity assessment body has been notified;

(b) satisfactory knowledge of the requirements of the assessments they carry out and adequate

authority to carry out those assessments.


2424

Conformity assessments shall be carried out in a proportionate manner, avoiding unnecessary burdens for economic operators. Conformity assessment bodies shall perform their activities taking due account of the size of an undertaking, the sector in which it operates, its structure, the degree of complexity of the product technology in question and the mass or serial nature of the production process.


2525

Union market surveillance and control of explosives entering the Union market (formally Regulation (EC) No 765/2008)

Member States shall take all appropriate measures to ensure that explosives may be placed on the market only if, when properly stored and used for their intended purpose, they do not endanger the health or safety of persons.


2626

Where the market surveillance authorities of one Member State have sufficient reason to believe that an explosive presents a risk to the health or safety of persons, or to property or the environment, they shall carry out an evaluation in relation to the explosive concerned covering all relevant requirements laid down in this Directive. The relevant economic operators shall cooperate as necessary with the market surveillance authorities for that purpose.


2727

Where the relevant economic operator does not take adequate corrective action, the market surveillance authorities shall take all appropriate provisional measures to prohibit or restrict the explosive’s being made available on their national market, to withdraw the explosive from that market or to recall it.


2828

You can find the complete text of the You can find the complete text of the Directive on our home-page or down-load Directive on our home-page or down-load it from the EU web-side:it from the EU web-side:

http://eur-lex.europa.eu/legal-http://eur-lex.europa.eu/legal-contentcontent

Directive 2014/28

2929

3030

3131

There has been a proposal from the There has been a proposal from the working group side to put CLP up on working group side to put CLP up on the Agenda, because for explosives the Agenda, because for explosives (mixtures), the deadline will be (mixtures), the deadline will be 1 1 June 2015June 2015. The CLP Regulation will . The CLP Regulation will ultimately replace the current rules ultimately replace the current rules on classification, labelling and on classification, labelling and packaging of substances (packaging of substances (Directive 67/548/EECDirective 67/548/EEC) and preparations ) and preparations ((Directive 1999/45/ECDirective 1999/45/EC) after this ) after this transitional period.transitional period.

CLP UP-DATECLP UP-DATE

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31967L0548:EN:NOT

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:1999L0045:20090120:EN:PDF

3232

CLPCLP

(The classification, labelling and (The classification, labelling and packaging of chemical substances packaging of chemical substances

and mixtures)and mixtures)

(DIRECTIVE 2008/112/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 December 2008 amending Council Directives 76/768/EEC, 88/378/EEC, 1999/13/EC and Directives 2000/53/EC,2002/96/EC and 2004/42/EC of the European Parliament and of the Council in order to adapt them to Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures)

3333

CLP BackgroundCLP Background

The production and use of chemicals is The production and use of chemicals is fundamental to all economies all over the world. fundamental to all economies all over the world. However, it is also recognized that chemicals However, it is also recognized that chemicals pose risks that should be indicated throughout pose risks that should be indicated throughout the supply chain. Many countries have developed the supply chain. Many countries have developed systems for providing information on hazardous systems for providing information on hazardous properties and control measures of chemicals properties and control measures of chemicals aimed at ensuring their safe production, aimed at ensuring their safe production, transport, use and disposal. Yet, those systems transport, use and disposal. Yet, those systems are currently not always compatible with each are currently not always compatible with each other and often require multiple labels and Safety other and often require multiple labels and Safety Data Sheets for the same product.Data Sheets for the same product.

3434

CLP BACKGROUNDCLP BACKGROUND

Consequently, companies involved in Consequently, companies involved in international trade need to follow multiple international trade need to follow multiple regulations regarding hazard classification regulations regarding hazard classification and labelling depending on where they do and labelling depending on where they do business and users may see inconsistent business and users may see inconsistent label warnings and Safety Data Sheets for label warnings and Safety Data Sheets for the same chemical. the same chemical.

3535

CLPCLP

The classification and labelling of explosive The classification and labelling of explosive mixtures is changing on 1 June 2015! mixtures is changing on 1 June 2015!

New pictograms with a white background New pictograms with a white background are replacing the orange ones in the EU. are replacing the orange ones in the EU. From 1 June 2015 companies are required From 1 June 2015 companies are required to classify and label both substances and to classify and label both substances and mixtures according to the CLP mixtures according to the CLP Regulation. Make sure you learn what the Regulation. Make sure you learn what the labels mean and read the instructions to labels mean and read the instructions to ensure safe use. Information on the CLP ensure safe use. Information on the CLP pictograms and on the label is available on pictograms and on the label is available on the the European Chemical Agency website.European Chemical Agency website.

http://echa.europa.eu/clp-2015

3636

Geographical Limits of GHSGeographical Limits of GHS

3737

GHS - Overview (I)

– – The UN-developed system „GHS“ stands for „Globally The UN-developed system „GHS“ stands for „Globally Harmonized System of Classification and Labelling of Harmonized System of Classification and Labelling of Chemicals“.Chemicals“.

– – With GHS, globally harmonized criteria have been created With GHS, globally harmonized criteria have been created for the classificationfor the classification

and labelling of chemicals. GHS wants to ensure and labelling of chemicals. GHS wants to ensure internationally comparable highinternationally comparable high

standards for health and consumer protection, occupational standards for health and consumer protection, occupational health and safety,health and safety,

and environmental protection.and environmental protection.

– – GHS regulates ...GHS regulates ...

• • criteria for the classification of physical, toxicological and criteria for the classification of physical, toxicological and environmental relevant properties ...environmental relevant properties ...

• • classification and labeling ...classification and labeling ...• • harmonized hazard communication ...harmonized hazard communication ...

(e.g. harmonized label statements and harmonized safety (e.g. harmonized label statements and harmonized safety data sheets)data sheets)

... of chemicals.... of chemicals.

3838

GHS - Overview (II)

3939

GHS - Overview (III)

– GHS affects manufacturers, suppliers, and users of chemicals

– The global implementation of GHS should take place during 2008.The registration phase of REACH, the uniform chemical law

applicable within the EU, also begins in 2008.

– Because of the numerous interconnections between GHS and REACH, the European Commission has scheduled the implementation of the two regulations to follow each another in

quick succession.

– The implementation of GHS is progressing at different places around the world. In many Asian countries, for example, GHS has already been introduced.

40

GHS - Current Status (July 2014)

Transport of dangerous goods planned, Other sectors plannedTransport of dangerous goods implemented, Other sectors plannedTransport of dangerous goods implemented, Other sectors implemented

Argentina Czech Republic Japan Nigeria Slovenia

Australia Denmark Norway South Africa

Austria Ecuador Latvia Paraguay Spain

Belgium Estonia Liechtenstein Peru Sweden

Bolivia Finland Lithuania Philippines Switzerland

Brazil France Luxembourg Poland Thailand

Brunei, Darussalam Gambia Madagascar Portugal United

Kingdom

Bulgaria Germany Malaysia Republic of Korea United States of

America

Cambodia Greece Malta Romania Uruguay

Canada Hungary Mauritius Russian Federation Viet Nam

Chile Iceland Mexico Senegal Zambia

China Indonesia Myanmar Serbia

Colombia Ireland Netherlands Singapore

Cyprus Italy New Zealand Slowakia

Laos

Implementation by the national authorities

4141

REACH / GHS - Contact points

REACH GHS

Substance = SubstancePreparation ↔ MixtureArticle = ArticleRegistrant = Registrant Manufacturer = ManufacturerImporter = Importer Downstream User = Downstream User Distributor = DistributorOnly RepresentingManufacturing = ManufacturingImport = Import

hazard classhazard category

hazard pictogramhazard statement

signal wordprecautionary statement

4242

GHS – What must be done?

The conversion to GHS has significant effects on the handling of chemicals.

– All products have to be checked to be in line with the requirements of GHS.

– Within the transition periods,• labelling shall be adapted to the new

requirements.• safety data sheets shall be correspondingly

changed.

– All substances which meet the criteria for classification as hazardous and are placed on the market shall be notified to the European Chemicals Agency (ECHA) for inclusion in the classification and labelling inventory.

4343

REACH / GHS - Timeline

Substance:Classification in SDS

Labeling

Mixture:Classification in SDS

Labeling

*) Also: CMR-Substances ≥ 1 t/a/LE, R50/53-Substances ≥ 100 t/a/LE

Dangerous preparations Directive

Substance Directive

Substance Directive

> 1000 t/a/LE*)

100 – 1000 t/a/LE

1 – 100 t/a/LE

Pre-registration

REACHTransition periodRegistration process

01.06.2007 01.12.2008 01.12.2010 01.06.2013 01.06.2015 01.06.2018

GHS

GHS-regulation

GHS-regulation

GHS-regulation

Dangerous preparations Directive GHS-regulation

←

←

←←

← means: former use of GHS possible

4444

GHS - What essential changes does GHS involve?

– GHS introduces globally harmonized criteria for the classification of physical,

toxicological, and environmental relevant properties.

– GHS establishes globally harmonized criteria for hazard communication. In the

overview, this relates to the introduction of new or modified:

• hazard classes,• hazard categories,• hazard pictograms,• signal words,• hazard statements,• precautionary statements.

– GHS offers the opportunity to bring product safety to a high level all over the

world. GHS will thus contribute to improving measures for protecting human

health and the environment on a global scale.

4545

GHS - New Labelling Elements

Signal word

The signal word on the label gives information about the relative hazard level of a substance or mixture and alerts the reader to a potential hazard.

Hazard pictogram

• Square set on a point,• Red border,• White background,• Black symbols.

4646

Hazard symbols according to directive 67/548/EEC, Annex II Gases

no own Symbol

CMRno own Symbol

Hazard pictograms according to directive EC No. 127272008, Annex V

GHS – Hazard pictograms

4747

GHS - Hazard statement

64 R-Phrases 62 Hazard Statements (H)

24 European Hazard Statements (EUH)

A hazard statement is a phrase, assigned to a hazard class and category that describes the nature / intrinsic property of a hazardous product as well as the hazard level.

Hazard statement group

H200 – Unstable Explosive

2 Physical hazards3 hazards4 all hazards

Sequence in the group

Hazard statement

4848

GHS - Precaution statement

54 S-Phrases 136 Precaution statements (P)

A precautionary statement is a phrase (and/or pictogram) that describes the recommended measures that should be taken to prevent / minimize adverse effects resulting from exposure to a hazardous product.

Precaution statement group

P201 – Obtain special instructions before use.

1 General2 Prevention3 Response4 Storage5 Disposal

Sequence in the group

Precaution statement

4949

GHS - Example of Labeling

Infuences MSDS and also Labelling

5050

5151

Übergangsfristen

GHS - correlation table

Some samples

5252

GHS – Derogations from Labeling

Derogations from labelling requirements for special cases (Article 23(e))The specific provisions on labelling laid down in section 1.3 of Annex I shall apply in respect of the following:(e) explosives, as referred to in section 2.1 of Annex I, placed on the market with a view to obtaining an explosive or pyrotechnic effect.

5353

GHS – General rules of Labeling

General rules (Article 17)1. A substance or mixture classified as hazardous and contained in packaging shall bear a label including the following elements:(a) the name, address and telephone number of the supplier (s);(b) the nominal quantity of the substance or mixture in the package made available to the general public, unless this quantity is specified elsewhere on the package;(c) product identifiers as specified in Article 18;(d) where applicable, hazard pictograms in accordance with Article 19;(e) where applicable, signal words in accordance with Article 20;(f) where applicable, hazard statements in accordance with Article 21;(g) where applicable, the appropriate precautionary statements in accordance with Article 22;(h) where applicable, a section for supplemental information in accordance with Article 25.2. The label shall be written in the official language (s) of the Member State (s) where the substance or mixture is placed on the market, unless the Member State (s) concerned provide (s) otherwise. Suppliers may use more languages on their labels than those required by the Member States, provided that the same details appear in all languages used.

5454

General rules for the application of labels (article 31)

1. Labels shall be firmly affixed to one or more surfaces of the packaging immediately containing the substance or mixture and shall be readable horizontally when the package is set down normally.

2. The colour and presentation of any label shall be such that the hazard pictogram stands out clearly.

3. The label elements referred to in Article 17(1) shall be clearly and indelibly marked. They shall stand out clearly from the background and be of such size and spacing as to be easily read.

4. The shape, colour and the size of a hazard pictogram as well as the dimensions of the label shall be as set out in section 1.2.1 of Annex I.

5. A label shall not be required when the label elements referred to in Article 17(1) are shown clearly on the packaging itself. In such cases, the requirements of this Chapter applicable to a label shall be applied to the information shown on the packaging.

GHS – General rules of application

5555

Location of information on the label

1. The hazard pictograms, signal word, hazard statements and precautionary statements shall be located together on the label.

2. The supplier may decide the order of the hazard statements on the label. However, subject to paragraph 4, all hazard statements shall be grouped on the label by language. The supplier may decide the order of the precautionary statements on the label. However, subject to paragraph 4, all precautionary statements shall be grouped on the label by language.

3. Groups of hazard statements and groups of precautionary statements referred to in paragraph 2 shall be located together on the label by language.

4. The supplemental information shall be placed in the supplemental information section referred to in Article 25, and shall be located with the other label elements specified in Article 17(1)(a) to (g).

5. In addition to its use in hazard pictograms, colour may be used on other areas of the label to implement special labelling requirements.

6. Label elements resulting from the requirements provided for in other Community acts shall be placed in the section for supplemental information on the label referred to in Article 25.

GHS – Location of Information

6060

Classification Classification

In most of the cases, suppliers need to In most of the cases, suppliers need to decide on the classification of a substance decide on the classification of a substance or mixture. This is called self-or mixture. This is called self-classification.classification.

CLP Up-dateCLP Up-date

ProcessesProcesses

6363

2.2.LabellingLabelling

Suppliers must label a substance or Suppliers must label a substance or mixture mixture contained in packaging according contained in packaging according to CLP before to CLP before placing it on the market placing it on the market either when:either when:

1.1. A substance is classified as hazardous A substance is classified as hazardous 2.2. A mixture contains one or more A mixture contains one or more

substances classified substances classified as hazardous above as hazardous above a certain threshold. a certain threshold.


6464

2.2.Labelling (cont.)Labelling (cont.)

The Elements of CLP Compliant Label The Elements of CLP Compliant Label (GHS Label) (GHS Label) The CLP label should be firmly affixed to The CLP label should be firmly affixed to one or more surfaces of the packaging one or more surfaces of the packaging immediately containing your substance or immediately containing your substance or mixture. They should be legible mixture. They should be legible horizontally when the package is set down horizontally when the package is set down normally. A CLP compliant label shall normally. A CLP compliant label shall contain the following elements:contain the following elements:


6565


Hazard pictograms Hazard pictograms A hazard pictogram is a pictorial A hazard pictogram is a pictorial presentation of a particular hazard. presentation of a particular hazard. Accordingly, the classification of your Accordingly, the classification of your substance or mixture determines the substance or mixture determines the hazard pictograms that should be hazard pictograms that should be displayed on your label, for example: displayed on your label, for example: Note: Hazard pictograms should be in the Note: Hazard pictograms should be in the shape of a square set at a point (diamond shape of a square set at a point (diamond shape), and should have a black symbol on shape), and should have a black symbol on a white background with a red border. a white background with a red border. Each hazard pictogram should cover at Each hazard pictogram should cover at least one fifteenth of the surface area of least one fifteenth of the surface area of the harmonised label, but the minimum the harmonised label, but the minimum area shall not be less than 1 square area shall not be less than 1 square centimetrescentimetres..


6666


Signal wordsSignal words

A signal word indicates to the reader if a A signal word indicates to the reader if a hazard is generally more severe or less hazard is generally more severe or less severe. The label should include the severe. The label should include the relevant signal word in accordance with relevant signal word in accordance with the classification of the hazardous the classification of the hazardous substance or mixture. In case your substance or mixture. In case your substance or mixture displays a more substance or mixture displays a more severe hazard, the label should bear the severe hazard, the label should bear the signal word signal word ‘danger‘danger’, and in case of less ’, and in case of less severe hazards, it should bear the signal severe hazards, it should bear the signal word ‘word ‘warning’warning’..


6767

Labelling (cont.)Labelling (cont.)

Hazard statementsHazard statementsYour labels should also bear the relevant Your labels should also bear the relevant hazard statements describing the nature hazard statements describing the nature and severity of the hazards of your and severity of the hazards of your substance or mixture. substance or mixture.

Hazard statement codesHazard statement codes: H2physical : H2physical hazards; H3 health hazards; H4 hazards; H3 health hazards; H4 environmental hazardsenvironmental hazards

Hazard class:Hazard class:H252: Self-heating in large quantities; may H252: Self-heating in large quantities; may

catch firecatch fireH362: May cause harm to breast-fed H362: May cause harm to breast-fed

childrenchildrenH410: Very toxic to aquatic life with long H410: Very toxic to aquatic life with long

lasting effects.lasting effects.


6868


Precautionary statements Precautionary statements Your labels should bear the relevant Your labels should bear the relevant precautionary statements, giving advice on precautionary statements, giving advice on measures to prevent or minimize adverse effects measures to prevent or minimize adverse effects to human health or the environment arising from to human health or the environment arising from the hazards of your substance or mixture. the hazards of your substance or mixture. Furthermore, the precautionary statements of one Furthermore, the precautionary statements of one language should be grouped together with the language should be grouped together with the hazard statements on the label. hazard statements on the label. Precautionary statement codes: For example P1 Precautionary statement codes: For example P1 GeneralGeneral ; P2 Prevention; P3 Response; P4 Storage; P2 Prevention; P3 Response; P4 Storage

Precautionary measurements: Precautionary measurements: P102: Keep out of reach of children; P102: Keep out of reach of children; P210: Keep away from heat/sparks/open flames/ hot P210: Keep away from heat/sparks/open flames/ hot

surfaces. surfaces. P311: Call a poison center or doctor/physician P311: Call a poison center or doctor/physician P403: Store in a well-ventilated placeP403: Store in a well-ventilated place


6969

3.3. Safety Data SheetsSafety Data Sheets

Safety data sheets are the main tool for Safety data sheets are the main tool for ensuring that manufacturers and ensuring that manufacturers and importers communicate enough importers communicate enough information along the supply chain to information along the supply chain to allow safe use of their substances and allow safe use of their substances and mixtures.mixtures.

Note: There is a new format!Note: There is a new format!


7070

4. Harmonised Classification and Labelling4. Harmonised Classification and Labelling Certain situations require that the Certain situations require that the

classification of a substance is harmonized classification of a substance is harmonized and made obligatory at Community level to and made obligatory at Community level to ensure an adequate risk management ensure an adequate risk management throughout the European Community.throughout the European Community.


7171

5. Alternative chemical name in mixtures5. Alternative chemical name in mixtures

Suppliers who are concerned about Suppliers who are concerned about disclosing the full composition of a disclosing the full composition of a mixture, on the label or in the safety data mixture, on the label or in the safety data sheet, can request the use of an sheet, can request the use of an alternative chemical name for a substance alternative chemical name for a substance to protect the confidential nature of their to protect the confidential nature of their business, and in particular, their business, and in particular, their intellectual property rights.intellectual property rights.


7272

6. C & L Inventory6. C & L Inventory

The Classification & Labelling (C&L) The Classification & Labelling (C&L) Inventory is a database that will contain Inventory is a database that will contain basic classification and labelling basic classification and labelling information on notified and registered information on notified and registered substances received from manufacturers substances received from manufacturers and importers.and importers.


7373

Proposal from Australia for Proposal from Australia for CLP ReviewCLP Review

for explosivesfor explosivesProposal for review of Chapter 2.1 (Explosives) in Proposal for review of Chapter 2.1 (Explosives) in the GHS, transmitted by the expert from Australia the GHS, transmitted by the expert from Australia and by the Australian Explosives Industry and and by the Australian Explosives Industry and Safety Group (AEISG)Safety Group (AEISG)

(Google for: ST/SG/AC.10/C.3/2014 / 79−ST / SG / (Google for: ST/SG/AC.10/C.3/2014 / 79−ST / SG / AC.10 / C.4 / 2014/15 and you are directly directed AC.10 / C.4 / 2014/15 and you are directly directed to the document on the UNECE.ORG home-page.to the document on the UNECE.ORG home-page.

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The key issues being considered are: The key issues being considered are:

(a)(a)Is the classification and hazard communication Is the classification and hazard communication information provided for explosives packaged information provided for explosives packaged for transport appropriate for other sectors, for transport appropriate for other sectors, e.g. manufacture, storage and use?e.g. manufacture, storage and use?

(b)(b) For explosives that are not packaged for For explosives that are not packaged for transport – including those that have been transport – including those that have been removed from their transport packaging and removed from their transport packaging and those that are not transported – what is the those that are not transported – what is the correct classification of those explosives and correct classification of those explosives and what hazards need to be communicated to what hazards need to be communicated to persons who manufacture, handle, store or use persons who manufacture, handle, store or use them?them?

Proposal for CLP ReviewProposal for CLP Review

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It is proposed that:It is proposed that:

(a)(a) Chapter 2.1 of the GHS be reviewed to determine Chapter 2.1 of the GHS be reviewed to determine where amendments are needed, including development where amendments are needed, including development of additional guidance if required, on classification and of additional guidance if required, on classification and hazard communication requirements for explosives to hazard communication requirements for explosives to meet the needs of sectors other than transport, e.g. meet the needs of sectors other than transport, e.g. manufacture, storage and use;manufacture, storage and use;

(b)(b) Where additional guidance is deemed necessary, Where additional guidance is deemed necessary, the content of such guidance be developed;the content of such guidance be developed;

(c)(c) The work would not include a review of The work would not include a review of requirements for the transport of explosives, or requirements for the transport of explosives, or changes to the tests of the Manual of Tests and Criteria changes to the tests of the Manual of Tests and Criteria for explosives;for explosives;

(d)(d) The review would be cognisant of previous The review would be cognisant of previous proposals by Germany, referred to above;proposals by Germany, referred to above;

(e)(e) A correspondence group led by the expert from A correspondence group led by the expert from Australia be established to undertake this work inter - Australia be established to undertake this work inter - sessionally and include any interested parties from the sessionally and include any interested parties from the TDG Sub-Committee, the Working Group on Explosives TDG Sub-Committee, the Working Group on Explosives and relevant NGOs. and relevant NGOs.

Proposal for CLP Proposal for CLP ReviewReview

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7. Any other business7. Any other business

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a) Globally harmonized standard for a) Globally harmonized standard for explosives security markings explosives security markings

Transmitted by the Institute of Makers of Transmitted by the Institute of Makers of Explosives (IME) to the “Explosives (IME) to the “Committee of Committee of Experts on the Transport of Dangerous Experts on the Transport of Dangerous Goods and on the Globally Harmonized Goods and on the Globally Harmonized System of Classification and Labelling of System of Classification and Labelling of Chemicals Sub-Committee of Experts on Chemicals Sub-Committee of Experts on the Transport of Dangerous Goods” at the Transport of Dangerous Goods” at the forty-sixth session in the forty-sixth session in Geneva on 1 – 9 Geneva on 1 – 9 December 2014December 2014

7. Any other business7. Any other business

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Globally harmonized standard for explosives Globally harmonized standard for explosives security markings security markings

SummarySummary

In this paper, for certain In this paper, for certain explosive devices and substances, explosive devices and substances, IME seeks to establish a globally IME seeks to establish a globally harmonized format for explosives harmonized format for explosives security markings by adding a security markings by adding a new Section 1.4.4 to Chapter 1.4 new Section 1.4.4 to Chapter 1.4 of the Model Regulations.of the Model Regulations.

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Introduction:Introduction:1.1. At the forty-third session of the Sub-At the forty-third session of the Sub-

Committee, in informal document INF.18, Committee, in informal document INF.18, IME discussed that there is a critical need IME discussed that there is a critical need for successful tracing of recovered for successful tracing of recovered explosives, and that the placement of explosives, and that the placement of marks on articles and substances of Class marks on articles and substances of Class 1 based on a globally harmonized marking 1 based on a globally harmonized marking format would be a critical component of format would be a critical component of successful tracing globally.successful tracing globally.


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2. 2. The Working Group on The Working Group on Explosives (EWG) agreed that a Explosives (EWG) agreed that a globally harmonized format for globally harmonized format for marking, most likely based on marking, most likely based on the European Union format, the European Union format, might be worthwhile. The Sub-might be worthwhile. The Sub-Committee agreed with the Committee agreed with the EWG and encouraged IME to EWG and encouraged IME to submit a formal proposal.submit a formal proposal.


8282

3. 3. At the forty-fifth session of the Sub-At the forty-fifth session of the Sub-Committee, a formal proposal was Committee, a formal proposal was submitted in working paper submitted in working paper ST/SG/AC.10/C.3/2014/5 (2014/5). ST/SG/AC.10/C.3/2014/5 (2014/5). Several experts supported the proposal; Several experts supported the proposal; however, several questions of principle however, several questions of principle were raised that IME had not addressed were raised that IME had not addressed in 2014/5. It was suggested that IME in 2014/5. It was suggested that IME further investigate those questions of further investigate those questions of principle and address them in an principle and address them in an improved proposal at the 46th Session of improved proposal at the 46th Session of the Sub-Committee.the Sub-Committee.


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DiscussionDiscussion

1 It is well known that many countries and law 1 It is well known that many countries and law enforcement agencies desire to have explosives enforcement agencies desire to have explosives uniquely identified to facilitate their traceability uniquely identified to facilitate their traceability in the event of loss or theft, or for security in the event of loss or theft, or for security purposes. When present, such security purposes. When present, such security markings would assist law enforcement and markings would assist law enforcement and government officials to determine from where government officials to determine from where confiscated, discovered, and/or recovered confiscated, discovered, and/or recovered explosives were acquired. Establishing from explosives were acquired. Establishing from where in the chain of custody such explosives where in the chain of custody such explosives were acquired may assist these officials in were acquired may assist these officials in identifying those who may have illicitly obtained identifying those who may have illicitly obtained such explosives and may aid in reducing the such explosives and may aid in reducing the availability of such explosives, thus increasing availability of such explosives, thus increasing the overall security of the world from attacks the overall security of the world from attacks using explosive articles and/or substances.using explosive articles and/or substances.

Globally harmonized standard for explosives Globally harmonized standard for explosives security markingssecurity markings

8484

2. 2. Indeed, within the European Union, Indeed, within the European Union, Directive 2008/43/EC mandates such a Directive 2008/43/EC mandates such a marking system. Other countries have also marking system. Other countries have also mandated, or have under consideration, mandated, or have under consideration, requirements for marking, serialization requirements for marking, serialization and/or traceability of explosives.and/or traceability of explosives.

These include: Argentina, Australia, These include: Argentina, Australia, Brazil, Canada, China, India, Kazakhstan, Brazil, Canada, China, India, Kazakhstan, Peru, Russia, and the USA.Peru, Russia, and the USA.


8585

3. 3. The result is a proliferation of disparate The result is a proliferation of disparate systems utilizing differing formats of systems utilizing differing formats of marking for traceability. These disparate marking for traceability. These disparate systems create unintended consequences. systems create unintended consequences. Such disparate systems undermine the Such disparate systems undermine the ability of countries to trace products that ability of countries to trace products that illegally cross national boundaries, illegally cross national boundaries, needlessly complicate efforts of needlessly complicate efforts of manufacturers to identify, maintain manufacturers to identify, maintain inventories and record individual lots that inventories and record individual lots that are destined for the different countries, are destined for the different countries, and mean that the same marking could and mean that the same marking could have different meanings in different have different meanings in different countries defeating the purpose for the countries defeating the purpose for the marks. marks.


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4. 4. IME proposes to globally standardize such IME proposes to globally standardize such security markings into a harmonized format security markings into a harmonized format so that, when marks are used, interpretation so that, when marks are used, interpretation of those markings can be done quickly and of those markings can be done quickly and efficiently, enabling law enforcement officials efficiently, enabling law enforcement officials to advance their investigations without undue to advance their investigations without undue delays. Since almost all Class 1 articles and delays. Since almost all Class 1 articles and substances must at some time be transported, substances must at some time be transported, the United Nations Recommendations on the the United Nations Recommendations on the Transport of Dangerous Goods, in the form of Transport of Dangerous Goods, in the form of the Model Regulations, appears to be the the Model Regulations, appears to be the most appropriate instrument to enable such most appropriate instrument to enable such harmonized identification information to be harmonized identification information to be adopted universally. adopted universally.


8787

5. The structure proposed by IME 5. The structure proposed by IME recognizes that the key information for recognizes that the key information for traceability is the name and location of traceability is the name and location of the manufacturer of the product and a the manufacturer of the product and a code that can be used to uniquely code that can be used to uniquely identify the individual explosive item. identify the individual explosive item. This proposal only deals with the format This proposal only deals with the format of such a marking and does not advocate of such a marking and does not advocate any physical or chemical modification of any physical or chemical modification of the explosive material contained in the the explosive material contained in the product (chemical or microscopic product (chemical or microscopic identifiers or taggants).identifiers or taggants).


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Globally harmonized standard for explosives Globally harmonized standard for explosives security markings security markings 6. The format proposed by IME is based on

the harmonized system of the European Commission Directive 2008/43/EC (as amended by Directive 2012/4/EU), which is believed to be the most commonly used marking format. Much of global industry has already adopted this format for transport to, within, and through the European Union. Since the proposed marking format simply extends the country identifier beyond that of the EU, it is believed that such a format would have no impact on markings already being used within the European Union.

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7. 7. It is IME’s hope that those countries outside of It is IME’s hope that those countries outside of the European Union that have already mandated the European Union that have already mandated security marking requirements will authorize the security marking requirements will authorize the proposed format as an acceptable alternative to proposed format as an acceptable alternative to that which they have already mandated. that which they have already mandated. Additionally, it is hoped that those countries Additionally, it is hoped that those countries planning to mandate such marking will accept the planning to mandate such marking will accept the proposed format as their mandated format or at proposed format as their mandated format or at least as an acceptable alternative. The USA’s least as an acceptable alternative. The USA’s Bureau Alcohol, Tobacco, Firearms, and Bureau Alcohol, Tobacco, Firearms, and Explosives (ATF) has already accepted the EU-Explosives (ATF) has already accepted the EU-based format as an alternative for use in that based format as an alternative for use in that country. Additionally, Brazil has accepted the country. Additionally, Brazil has accepted the format on a case-by-case basis.format on a case-by-case basis.


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9. Proposal9. Proposal

The Sub-Committee is requested to add a The Sub-Committee is requested to add a note to Table 1.4.1 in Chapter 1.4 of the note to Table 1.4.1 in Chapter 1.4 of the Model Regulations directing the reader to Model Regulations directing the reader to the provisions of a new Section 1.4.4 to the provisions of a new Section 1.4.4 to be added to Chapter 1.4. The proposed be added to Chapter 1.4. The proposed note is shown in “Amendment 1” in note is shown in “Amendment 1” in Annex 1. Further, the Sub-Committee is Annex 1. Further, the Sub-Committee is requested to a add a new section 1.4.4 to requested to a add a new section 1.4.4 to Chapter 1.4 of the Model regulations Chapter 1.4 of the Model regulations describing the globally harmonized describing the globally harmonized explosives security marking format as explosives security marking format as shown in “Amendment 2” in Annex 1.shown in “Amendment 2” in Annex 1.


9191

Introduction:Introduction:At the forty-third session of the Sub-At the forty-third session of the Sub-Committee, in informal document INF.18, Committee, in informal document INF.18, IME discussed that there is a critical need IME discussed that there is a critical need for successful tracing of recovered for successful tracing of recovered explosives, and that the placement of explosives, and that the placement of marks on articles and substances of Class marks on articles and substances of Class 1 based on a globally harmonized marking 1 based on a globally harmonized marking format would be a critical component of format would be a critical component of successful tracing globally.successful tracing globally.


9292

Lead Azide Situation as per Lead Azide Situation as per September 2014September 2014

9393

The on the 21 substances proposed by ECHA to be The on the 21 substances proposed by ECHA to be placed on the 6th priority list will be delayed until 1 placed on the 6th priority list will be delayed until 1 September. The September. The PUBLIC CONSULTATION WILL PUBLIC CONSULTATION WILL LAST FOR THREE MONTHS AND WILL END 30 LAST FOR THREE MONTHS AND WILL END 30 NOVEMBER 2014.NOVEMBER 2014. The consultation will focus on two aspects: The consultation will focus on two aspects: information on uses and response to prioritisation, information on uses and response to prioritisation, which will be assessed by ECHA for their which will be assessed by ECHA for their recommendation, and additional socio-economic recommendation, and additional socio-economic information which will be transmitted to the information which will be transmitted to the Commission. The latter, will help the Commission Commission. The latter, will help the Commission gain more information on the impacts of gain more information on the impacts of authorisation on the European economy before authorisation on the European economy before making any final decisions on which substances will making any final decisions on which substances will be added to Annex XIV (authorisation list). be added to Annex XIV (authorisation list).

PUBLIC CONSULTATIONPUBLIC CONSULTATION

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9595

Lead Azide Situation as per Lead Azide Situation as per September 2014September 2014

9696

Lead Oxides – Latest DevelopmentsLead Oxides – Latest Developments(Comment from Jose)(Comment from Jose)

We think that the restriction of use of Lead-Tetroxide is approaching (at least in Europe) and we have to send some comments to ECHA in order to show the joint position of FEEM. The next WG meeting in Lisbon could be a good opportunity to discuss about this topic. We propose the following guidelines concerning the future comments from FEEM to ECHA:Is it advisable to insist on the reasons (low tonnage, well controlled manufacturing processes, good H&S results, etc) already communicated to ECHA in June 2013?We may explain the socio-economic importance of detonators and delay elements in the developments of other European sector (mining, civil works, etc). Do you agree?Could it be convenient to explain something about the Electronic Detonator? Cost/benefit ratio?Could it be convenient to say something about the alternative substances to Lead-tetroxide in delay elements? Are there really alternative substances at industrial scale? We have time to send comments till 30 November.

9797

Lead Oxides – Latest DevelopmentsLead Oxides – Latest Developments

There has been numerous correspondence in the past There has been numerous correspondence in the past years between FEEM, ECHA, ILA and the Commission years between FEEM, ECHA, ILA and the Commission concerning the handling of lead and its derivates in the concerning the handling of lead and its derivates in the detonator industry. However, for formal reasons there detonator industry. However, for formal reasons there was no way to avoid that these substances appeared on was no way to avoid that these substances appeared on the Candidate List.the Candidate List.

21 lead compounds were included on the candidate list at the end of 2012 in addition to the six lead compounds that were already listed, 27 in total. The Member State Committee will soon be debating the proposals by ECHA for compounds to be included in the 6th Annex XIV Recommendation. Although volumes of some lead compounds manufactured in the EU are relatively high (automotive, glass, paint) the use in Explosives and Pyrotechnics is very small (<50t/a). FEEM believe that REACH Authorisation would not be the most efficient Risk Management Option for reasons of effectiveness and proportionality.

9898


Our main arguments were:Our main arguments were:

1. Prioritizing a chemical prior to the communication of an RMO* is inappropriate

- All 27 lead compounds on the candidate list have been subject to an RMO completed by ECHA and provided to the Commission. Including them now on the Priority List seems inappropriate especially since there are serious concerns about the effectiveness of REACH authorization as the most effective RMM* for lead compounds.

• Risk Management Option• Risk Management Measures

9999


2. Lead compounds are already regulated by the

EU – The manufacturing and use of lead

compounds is already regulated by long-standing lead specific risk management measures. This consideration must be taken forward in the verbal approach to scoring and assessment of regulatory effectiveness as the value and effectiveness of additional measures will be disproportionate.

100100


3. Priority scoring concerns

- If priority scoring relies only on information submitted in 2010 Registration dossiers we are concerned that it will produce an incorrect score. Regrettably the dossiers included out-dated information in some exposure scenarios. New information has already been provided to ECHA and dossiers are currently being updated to reflect this. Industry has recently completed a priority scoring exercise using the latest ECHA methodology and current use information and this highlighted that Lead Tetroxide (Orange Lead) would have the highest priority score

101101


4. The compounds have industrial uses only

– There are no consumer uses!

102102


5. Workers are already protected by existing EU legislation

– All applications of the 10 lead compounds subject to this paper are Industrial. Industrial use of lead is already regulated by legal requirements to protect workers in the form of a Binding Limit Value in the Chemicals Agents Directive that establishes EU-wide minimum standards.

103103


6. Intermediate arguments need to be considered in priority scoring

- Use of Lead Dinitrate and Lead Monoxide in

explosives has been demonstrated to be an “intermediate” use as the substances are integral to detonators. Fortunately, both Lead Dinitrate and Fortunately, both Lead Dinitrate and Lead Monoxide are used by FEEM members as Lead Monoxide are used by FEEM members as intermediate substances (see article 3 (15) of intermediate substances (see article 3 (15) of REACH). In other words, these substances are used REACH). In other words, these substances are used for chemical production of other substances. for chemical production of other substances. According to information received by member According to information received by member companies, Lead Dinitrate is used as raw material in companies, Lead Dinitrate is used as raw material in the manufacture of Lead Azide, Lead Styphnate and the manufacture of Lead Azide, Lead Styphnate and other primary explosives. Similarly, Lead Monoxide is other primary explosives. Similarly, Lead Monoxide is used as raw material in the production of other lead used as raw material in the production of other lead compounds that are used in the production of the compounds that are used in the production of the above mentioned primary explosives. Intermediate above mentioned primary explosives. Intermediate substances are exempted for Authorisation (see substances are exempted for Authorisation (see article 2(8) of REACH) so these substances are not in article 2(8) of REACH) so these substances are not in the scope of this threat of jumping to the Annex XIV the scope of this threat of jumping to the Annex XIV at least for FEEM members.at least for FEEM members.

104104


Then, the only substance that could be included in the Then, the only substance that could be included in the future in the Authorisation List is the Orange Lead.future in the Authorisation List is the Orange Lead.

That is why FEEM took the initiative in order to avoid That is why FEEM took the initiative in order to avoid the inclusion of Orange-lead in the Authorisation List the inclusion of Orange-lead in the Authorisation List and send a relevant letter to the ECHA Directorate on and send a relevant letter to the ECHA Directorate on 19 June 2013.19 June 2013.

The reasons for supporting the low priority for Orange The reasons for supporting the low priority for Orange Lead (regarding priority for jumping from the Lead (regarding priority for jumping from the Candidate List to the Annex XIV) are quite similar to Candidate List to the Annex XIV) are quite similar to the reasons that were compiled by FEEM for the lead the reasons that were compiled by FEEM for the lead primary explosive compounds (lead azide and lead primary explosive compounds (lead azide and lead styphnate) according to our letter to ECHA of 3 styphnate) according to our letter to ECHA of 3 October 2011.October 2011.

105105

Lead monoxide EC# 215-267-0

ES number

ES 6

Linked to Identified Use

Use of orange lead in

explosive manufacture

Note Orange-Lead (lead tetroxide, Pb3O4) is a substance used as a raw material for detonator manufacturing. This substance has no explosive properties and it is used as an oxidizer to obtain a controlled chemical reaction within the detonator structure to obtain a chemical delay in the blasting applications. Orange Lead (Pb3O4) and silicon (or other reducing agents) totally react during use of delay elements and the chemical reaction is complete and irreversible. After detonation, the chemicals inside the delay system react and the final products are silica (SiO2), metallic lead (Pb), and unreacted silicon (Si).

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Lead OxidesLead Oxides

As mentioned before, FEEM is in regular As mentioned before, FEEM is in regular contact with the International Lead Association contact with the International Lead Association (ILA) about the public consultation on Lead (ILA) about the public consultation on Lead Compounds. They have distributed several Compounds. They have distributed several documents as reference from other industries documents as reference from other industries which have been passed to the Detonator which have been passed to the Detonator Manufacturers in FEEM . I have asked our Manufacturers in FEEM . I have asked our relevant members for assistance and guidance relevant members for assistance and guidance of how to proceed. of how to proceed.

107107

Lead OxidesLead OxidesIn our last letter to Echa we argued that In our last letter to Echa we argued that fortunately, fortunately, both Lead Dinitrate and Lead Monoxide are used by both Lead Dinitrate and Lead Monoxide are used by FEEM members as intermediate substancesFEEM members as intermediate substances (see (see article 3 (15) of REACH). In other words, these article 3 (15) of REACH). In other words, these substances are used for chemical production of substances are used for chemical production of other substances. According to information received other substances. According to information received by company members, Lead Dinitrate is used as raw by company members, Lead Dinitrate is used as raw material in the manufacture of Lead Azide, Lead material in the manufacture of Lead Azide, Lead Styphnate and other primary explosives. Similarly, Styphnate and other primary explosives. Similarly, Lead Monoxide is used as raw material in the Lead Monoxide is used as raw material in the production of other lead compounds that are used in production of other lead compounds that are used in the production of the above mentioned primary the production of the above mentioned primary explosives. explosives. Intermediate substances are exempted Intermediate substances are exempted for Authorisation (see article 2(8) of REACH)for Authorisation (see article 2(8) of REACH) so so these substances are not in the scope of this threat these substances are not in the scope of this threat of jumping to the Annex XIV at least for FEEM of jumping to the Annex XIV at least for FEEM members. members.

108108

Lead OxidesLead OxidesThe only substance that could be included in the The only substance that could be included in the future in the Authorisation List is the Orange Lead. future in the Authorisation List is the Orange Lead. That is why FEEM has taken the initiative in order to That is why FEEM has taken the initiative in order to avoid the inclusion of Orange-lead in the avoid the inclusion of Orange-lead in the Authorisation List.Authorisation List.

Is this type of action considered to be sufficient, as Is this type of action considered to be sufficient, as the draft recommendation of substances for the draft recommendation of substances for inclusion into Annex XIV is based on Article 58.2 of inclusion into Annex XIV is based on Article 58.2 of the REACH Regulation, stating that “categories of the REACH Regulation, stating that “categories of uses may be exempted from the authorisation uses may be exempted from the authorisation requirement provided that, on the basis of the requirement provided that, on the basis of the existing specific Community legislation imposing existing specific Community legislation imposing minimum requirements relating to the protection of minimum requirements relating to the protection of human health or the environment for the use of the human health or the environment for the use of the substance, the risk is properly controlled?substance, the risk is properly controlled?

You are the experts, so I have to rely on your You are the experts, so I have to rely on your recommendations! Please let me have your thoughts.recommendations! Please let me have your thoughts.

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Color-Coding of ExplosivesColor-Coding of Explosives

In July 2014 FEEM has distributed to their members the I.R.E. (ISTITUTO RICERCHE ESPLOSIVISTICHE) report with recommendations to the EU Commission (Directorate – General Home Affairs) toward setting standards and regulating the colour-coding of explosives and blasting accessories such as igniters, detonators and detonating cords.

110110


These recommendations were developed by AID – Stabilimento Militare Ripristini e Recuperi del Munizionamento (Ammunition Refurbishing and Recovery Plant) in collaboration with I.R.E. – Istituto Ricerche Esplosivistiche (Explosive Research Institute) and ECA Italia (European Consulting Agency Srl). The work was funded with the financial support from the Prevention of and Fight against Crime Programme of the European Union – European Commission – Directorate – General Home Affairs.

111111


Although this project is obviously ongoing for some years already, this is the first time the EXPLOSIVES INDUSTRY is being informed about such a research called: “ICEA – Identification Colors of Explosives and Blasting Accessories” submitted under the call for proposal “ISEC 2010 ACTION GRANT” of the “Prevention and Fight against Crime” Program. The goal of the ICEA project is to provide help Governments and Police forces in simplifying counter-terroristic and crime investigation measures and in simplifying the recognition and identification procedure of cables and detonating cords.

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Some of their arguments:

At present, there are almost 50 manufacturers of explosives and similar materials. Due to the absence of standardisation or unified norms, explosive devices often present sheaths of different colours within the same geographic area or can also be confused with products destined to other uses. The nature of certain devices is hard to be identified even by experts, if they are located at a distance. Such an uncertainty causes inevitable consequences concerning security, protection and crime investigations.

113113


Detonating cord still appears as an object totally harmless, like so many others, such as wire for hanging wet clothes. Few years ago, a member of the Camorra in one district of Naples hung his clothes on some detonating cords. The concealment was discovered only thanks to the K9 police dog units.

114114


They strongly recommend that a dedicated and unique coloring for cords and detonators wires should be imposed. To reach this goal, the ICEA research team has identified 30 different color combinations. Starting from these color combinations, a standardization of products could be easily achieved.

115115


An example could be:a color combination (chosen among our proposals) for instantaneous electric detonators; a color combination for electric delay detonators plus a color combination for micro delay electric detonators (chosen among our proposals); a color combination (chosen among our proposals) for low, medium and high intensity detonators;

116116


a color combination (chosen among our proposals) for 3-6-10-12-15-20-40-40-80 and 100 grams of PETN per meter detonating cords. We worked on two sets of 10 different color combinations in order to distinguish items for civilian and items for military use. We propose that color combinations with stripes (which could be embossed in order to be distinguished just by touching them) could be dedicated to detonating cords intended for military use, while the set of 10 color combinations with dots may be dedicated to the civilian sector.

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118118


119119


120120


121121


What is your conclusion?What is your conclusion?

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Any other businessAny other business3. Detonating Cords3. Detonating Cords

FEEM received the following question from a FEEM received the following question from a member:member:

Detonating cords with more than Ø8,5 mm should Detonating cords with more than Ø8,5 mm should have a “marking” every 5 m on the cord and a have a “marking” every 5 m on the cord and a “marking” on the spool. Since the Directive “marking” on the spool. Since the Directive doesn’t mention an associated label on the spool doesn’t mention an associated label on the spool the member assumes that the marking on the the member assumes that the marking on the detonation cords is identical with the unique detonation cords is identical with the unique identification on the spool. This would mean that identification on the spool. This would mean that the 5 m markings are all identical when they the 5 m markings are all identical when they come from one spool. Is this assumption correct? come from one spool. Is this assumption correct? If this is the case, then the spools would be an If this is the case, then the spools would be an item and of course also the cord on the spool. If item and of course also the cord on the spool. If this would not be the case, then spools with cords this would not be the case, then spools with cords of >Ø 8.5 mm would logically be an in "inner of >Ø 8.5 mm would logically be an in "inner packing" and the 5m-pices "items“. packing" and the 5m-pices "items“.

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3. Detonating Cords3. Detonating Cords

Detonating cords and safety fuses (Article 10)Detonating cords and safety fuses (Article 10)

For detonating cords and safety fuses, the unique For detonating cords and safety fuses, the unique Identification shall consist of an adhesive label or direct Identification shall consist of an adhesive label or direct printing on the bobbin. The unique identification will be printing on the bobbin. The unique identification will be marked every 5 meters on either the external envelope of marked every 5 meters on either the external envelope of

the the cord or fuse or the plastic extruded inner layer cord or fuse or the plastic extruded inner layer

immediately immediately under the exterior fibre of the cord or fuse. An associated under the exterior fibre of the cord or fuse. An associated label shall be placed on each case of detonating cord or label shall be placed on each case of detonating cord or fuse.fuse.

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6. Subjects for discussion at the next 6. Subjects for discussion at the next meetingmeeting

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Statistics 2013Statistics 2013

126126

Explosives 2013Explosives 2013

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The volume of explosives consumed (not The volume of explosives consumed (not manufactured!) in Europe (EU27 + Norway & manufactured!) in Europe (EU27 + Norway & Switzerland) in 2013 amounted toSwitzerland) in 2013 amounted to

580.000 tons580.000 tons

This is 9 % higher compared to 2012.This is 9 % higher compared to 2012.

Explosives Statistic 2013

128128

532,1580,4

300

350

400

450

500

550

600

Year 2012 Year 2013

Total Explosives 2013

+ + 9,1%9,1%

129129

385

353

399410

442 439 440450

477497

561

587584602

586 588

621

532

580

300

350

400

450

500

550

600

650

Year1995

Year1996

Year1997

Year1998

Year1999

Year2000

Year2001

Year2002

Year2003

Year2004

Year2005

Year2006

Year2007

Year2008

Year2009

Year2010

Year2011

Year2012

Year2013

EXPLOSIVES DEVELOPMENT 1995 – 2013 (1.000 EXPLOSIVES DEVELOPMENT 1995 – 2013 (1.000 tons)tons)

130130

EXPLOSIVES MARKET EXPLOSIVES MARKET

BY SHARES (2013 ./. 2012)BY SHARES (2013 ./. 2012)

Cartr. EMS10% (10%) Bulk EMS

50% (47%)

NG8% (8%)

Others3% (4%)

ANFO29%

(31%)

131131

132132

NG Development 1995 - 2013

73

6469

78

84

76

70 69 69 70

58 58

6562

71

5760

4246

30

40

50

60

70

80

90

133133

243,7

289,6

100

120

140

160

180

200

220

240

260

280

300

Year 2012 Year 2013

Bulk Emulsions in Ktons

+ 18,8%

134134

5456,7

40

42

44

46

48

50

52

54

56

58

Year 2012 Year 2013

Packaged Emulsions in Ktons

+ 5%

135135

Yea

r 19

95

Yea

r 19

97

Yea

r 19

99

Yea

r 20

01

Yea

r 20

03

Yea

r 20

05

Yea

r 20

07

Yea

r 20

09

Yea

r 20

11

Yea

r 20

13

R1

93 86 98 100108 107108139 132 137 137 144 145

188

290 295 290 298

346

0

50

100

150

200

250

300

350

400

Emulsions 1995 - 2013 in 1.000 tons (incl. Packaged Products)

136136

169,9 170,8

100

110

120

130

140

150

160

170

180

Year 2012 Year 2013

ANFO in Ktons

+ 0,5%

137137

Yea

r 19

95

Yea

r 19

96

Yea

r 19

97

Yea

r 19

98

Yea

r 19

99

Yea

r 20

00

Yea

r 20

01

Yea

r 20

02

Yea

r 20

03

Yea

r 20

04

Yea

r 20

05

Yea

r 20

06

Yea

r 20

07

Yea

r 20

08

Yea

r 20

09

Yea

r 20

10

Yea

r 20

11

Yea

r 20

12

Yea

r 20

13

R1

232

246250

235 237

217

227 229 229227 227 228 229

226

217213

217

170 171150

160

170

180

190

200

210

220

230

240

250

ANFO 1995 - 2013 in 1.000 tons

138138

22,4

17,8

0

5

10

15

20

25

Year 2012 Year 2013

Others in Ktons

- 10,5%

139139

Detonators 2013Detonators 2013

140140

The amount of detonators consumed (not The amount of detonators consumed (not manufactured!) in Europe (EU27 + Norway manufactured!) in Europe (EU27 + Norway & Switzerland) in 2013 amounted to& Switzerland) in 2013 amounted to

61,870 mio. units61,870 mio. units

This is more or less the same than in 2012 This is more or less the same than in 2012 (61,132)(61,132)

Detonator Statistic 2013

141141

61.132 61.870

10000

20000

30000

40000

50000

60000

70000

Year 2012 Year 2013

Total Detonators 2013 in 1.000

+ 1,2%

142142

Electric; 25,7

Electronic; 0,98

Non-electric;

35,1

DETONATORS MARKET SHARES (mio. units)

143143

25.088 25.764

5000

10000

15000

20000

25000

30000

Year 2012 Year 2013

Electric Detonators in 1.000

+ 2,7%

144144

35.078 35.130

5000

10000

15000

20000

25000

30000

35000

40000

Year 2012 Year 2013

Non-Electric Detonators in 1.000

+ 0,01%

145145

966 976

100

200

300

400

500

600

700

800

900

1000

Year 2012 Year 2013

Electronic Detonators in 1.000

+ 0,01%

146146

Detonating Cords 2013Detonating Cords 2013

60,9

71,3

10

20

30

40

50

60

70

80

Year 2012 Year 2013

147147

Boosters & Primers 2013Boosters & Primers 2013

1.500.000

1.200.000

1.900.000

5.000.000

1.000.0001.000.000,0

1.500.000,0

2.000.000,0

2.500.000,0

3.000.000,0

3.500.000,0

4.000.000,0

4.500.000,0

5.000.000,0

5.500.000,0

148148

Explosive Explosive ProductionProduction Sites & Staff 2013 Sites & Staff 2013

Sites; 92 Sites; 94

Staff; 5.430 Staff; 5.520

0

1000

2000

3000

4000

5000

6000

Year 2012 Year 2013

149149

8. Date & Place of the next meeting:8. Date & Place of the next meeting:

Wednesday, 11 March 2015Wednesday, 11 March 2015from 09h00 to 13h00from 09h00 to 13h00

atatHotel Manos Premier Hotel Manos Premier

100-106 Chaussée de Charleroi, 100-106 Chaussée de Charleroi, 1060 Bruxelles, Belgique1060 Bruxelles, Belgique

Tel : +32 2 537 96 82 Tel : +32 2 537 96 82 Fax : +32 2 539 36 55 Fax : +32 2 539 36 55

Email : Email : [email protected]

(We meet on Tuesday, 10 March for dinner in the hotel at (We meet on Tuesday, 10 March for dinner in the hotel at 19h00)19h00)

150150

Thank you for your attentionThank you for your attention

A warm welcome to the H&S Working Group

Documents

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european competition

working group delegates

european competition

european competition

competition legislation

national competition

european parliament