University of Brighton - DOC 4

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					                               University of Brighton
                             Health & Safety Department

    SIB                                       Safety Information Bulletin
    Subject: Legislation                     Number: 19/05
    Keywords: Chemical                       Date:22/08/05
    Priority: H                              Ref No: n/a
    Action Required : Y                      Information Only : Y

   Circulation To:                           Cc
   Selected Heads of Schools                 Selected School Safety Coordinators
   Selected Deans                            Selected Technical Managers
                                             Safety Committee
                                             Safety List

New Legislation and licensing for ‘Precursor Chemicals’

You may have received information from chemical companies stating that they will not
supply certain chemicals (category 1 precursor chemicals) to the University after 18th
August 2005 unless the University has an appropriate licence.

These changes are due to 2 new regulations (EC) No 273/2004 on EU internal trade (Feb
2004) and (EC) No 111/2005 on trade between EU and third countries (Dec 2004), which
are available from the Home Office web site, relating to the trade in substances that can
be used as Precursor Chemicals in the manufacture of illicit drugs.

The Home Office has published information on their website on the new licensing
arrangements for precursor chemicals and the majority of Universities across the UK are
currently in the process of assessing these new requirements. (Also include the salts of
the specified substances)

Category 1 chemicals

       Ephedrine
       Ergometrine
       Ergotamine
       Lysergic acid
       1-phenyl-2-propanone (BMK)
       Pseudoephedrine
       N-acetylanthranilic acid
       3-4 Methylenedioxy -phenylpropan-2-one (PMK)
       Isosafrole
       Piperonal
       Safrole
       Norephedrine

       Learning, living and working in a safe environment
Category 2 chemicals

       Acetic anhydride
       Potassium permanganate
       Anthranilic acid
       Phenylacetic acid
       Piperidine

Further Information

The Home Office website has a number of publications on this issue which may be of

       Precursor Chemicals Page Home Office
       List of Precursor Chemicals (xls) Home Office

Further information has also been produced by Universities UK ‘Information for members
‘briefing note 1/05/116.


Licences - I have not seen anything on the cost of licences - it seems free to me.
The Category 1 licence is applicable as it refers to possession as well as supply.

The licence will be issued, in principal for an unlimited duration, and during that period the
conditions under which that licence is granted may be checked, at intervals not exceeding
three years, by the enforcing authority. The enforcing authority is the Home Office.
Licences may be revoked at any time by the Home Office if they feel that the conditions
under which the licence is issued are not being fulfilled.

Compliance Officer - the person is responsible for policing a system within the
organisation and not directly responsible for whether a small group has obtained a licence.

The designated Compliance officer for the University Of Brighton will be the Head of
School for the individual School ordering the chemicals. It will be necessary for the
Compliance Officer to act as Guarantor of the staff ordering the chemical.

Customer Declaration - Any division or School who receives chemicals from categories 1
or 2 shall supply the operator with a customer declaration. The customer declaration form
can be found on the HO site. The declaration should be made on headed notepaper which
is relevant to the division or department ordering the chemical.

A supplier may accept a single declaration from the division or department if the operator
regularly supplies that division or department. This single declaration shall not exceed
transactions over one year in period. The form relating to multiple transactions shall be
completed in this case.

The operator supplying the scheduled chemicals shall stamp and date a copy of the
declaration certifying it to be a true copy of the original and a copy must accompany
category 1 substances being moved within the European Community.

       Learning, living and working in a safe environment
The following exemptions apply to category 2 substances where the quantities do not
exceed the amounts in the table below over a period of one year.

              Substance                                               Threshold
Acetic anhydride                                                         100l
Potassium permanganate                                                  100kg
Anthranilic acid and its salts                                           1 kg
Phenylacetic acid and it’s salts                                         1kg
Piperidine and it’s salts                                               0.5 kg

This seems to be the same type of legislation as the Misuse of Drugs Act (as far as
licensing is concerned), Chemical Weapons Act and the Anti-terrorism, Crime and Security
Acts as far as H&S is concerned.

Action Required

Assess the implications of the legislation in relation to relevant chemicals and identify
suitable School procedures.

Implement a system of monitoring and controlling of the ordering of all relevant chemicals.

Circulate School rules and guidelines to staff.

Further updates on these new requirements and how they affect the University will be available on this page
as soon as information is available.

    For further information please contact: Health and Safety Department, Room 224, Mithras House, Moulsecoomb Site

Alan Cowen                Head of Health and Safety                    Tel:              01273 643143
                                                                       Mobile:           07733 322781
Phil Thompson             Fire Safety Adviser                          Tel:              01273 643671
                                                                       Mobile:           07946 638093
Paul West                 Fire Safety Support Officer                  Mobile:           07944 052808
Jacqui Norman             Joint Office Administrator                   Tel:              01273 643144
Ann Smith                                                              Email:  

     Learning, living and working in a safe environment

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