[Alt-photo] Antwort: Re: 3. Update EU-Regulation 98/2013 and REACH

GILLES LORIN gilles.lorin at mac.com
Wed Apr 13 05:41:17 UTC 2016


Good morning Udo, 

I will register and email you when I get to my computer later today, so that we can continue the conversation. 

In regards to Puretech, I've not tried as it only produces half tones. Currently I use Dragon tissue. Jennifer Page of Cape Fear did some testing with DAS but without much success... Indeed such photopolymer film resist would be ideal for photogravure on copper, and would bypass the dichromate sensitizer. 

All the best, 

Gilles

Gilles Lorin
+49 160 127 3448
---------------------------
Sent from my mobile

> On Apr 13, 2016, at 07:15, BJ68 via Alt-photo-process-list <alt-photo-process-list at lists.altphotolist.org> wrote:
> 
> Hello Gilles, 
> 
> Thank you for the reply, I have contact to a German Lawyer and for the first run he will charge 2500 Euros (10 h Work) to look up the possibilities. If we would be more persons, it will become cheaper for us. I have no business in Germany and if I am affected from some regulations, then it will be the Swiss or Austrian ones.... 
> If you and OTHERS want to join, please register at https://ivntforum.phoerauf.de/ and write a mail to me, that I can activate you. Here we can discuss the questions for the lawyer....and you can join even if you do not want to contribute at the money issue....it´s easier to talk at a forum then over a mailing list....
> 
> 
> More OT: Have you ever used Puretch Photopolymer-Film http://www.polymetaal.nl/siteUK/shopukwork/en-gb/dept_183.html for etching copper? I tried it one times (fast shoot) and got as result a etched plate what was like I think a heliography plate which is made with gelatin/dichromate and etched with FeCl3.
> If I have time I will try it on glass and etching with HF-Mixture....
> 
> 
> Greetings 
> 
> Udo
> 
> 
> -----"Alt-photo-process-list" <alt-photo-process-list-bounces at lists.altphotolist.org> schrieb: -----
> An: alt-photo-process-list at lists.altphotolist.org
> Von: GILLES LORIN via Alt-photo-process-list    
> Gesendet von: "Alt-photo-process-list" 
> Datum: 11.04.2016 09:37
> Kopie: GILLES LORIN <gilles.lorin at mac.com>
> Betreff: Re: [Alt-photo] 3. Update EU-Regulation 98/2013 and REACH
> 
> Hello Udo, 
> 
> I am sorry for not following through with this, but I am still interested. I did not apply for an exemption. I would be willing to contribute to hiring a lawyer as you suggested to see what our options are, but I think we would need a few of us to cover the costs. 
> 
> I’m still wondering if we cannot do a petition and see if we can get an exemption for artists using dichromate (in reasonable manner), in effort to safeguarding of our cultural heritage. In fact, I think it would fit perfectly with the realm of the Intangible Cultural Heritage of UNESCO: http://www.unesco.org/culture/ich/en/what-is-intangible-heritage-00003
> 
> All the best, 
> 
> Gilles 
> 
> 
> On Apr 8, 2016, at 9:31 PM, BJ68 via Alt-photo-process-list <alt-photo-process-list at lists.altphotolist.org> wrote:
> 
> It seems the Dutch government makes now new regulations which are incorporating REACH, 98/2013 and other regulations.
> 
> Here a posting from Woelen at sciencemadness:
> http://www.sciencemadness.org/talk/viewthread.php?tid=23212&page=7#pid444708
> which is covering this issue.
> 
> And again for the second Update I got a few new sources:
> http://www.sciencemadness.org/talk/viewthread.php?tid=23212&page=7#pid444569
> 
> Other question: How far is the petition or have affected people made something or is the interest gone?
> 
> 
> Sincerely 
> 
> Udo
> 
> 
> -----Udo Schnitzbauer/at/UZH schrieb: -----
> An: alt-photo-process-list at lists.altphotolist.org
> Von: Udo Schnitzbauer/at/UZH
> Datum: 24.03.2016 07:44
> Betreff: Antwort: Re: [Alt-photo] Update EU-Regulation 98/2013
> 
> Dear List:
> 
> 
> a) REACH (Sunset-Dates)
> 
> I got contact with a German lawyer who knows EU and German Chemical Law. He said that a assessment of the situation will be 10 working hours for him. So will pay the fees (2500 Euro) and ask him this questions:
> a) Is there at all a way to get authorization?
> b) Are artists and persons working as a freelancer targeted from REACH? 
> c) What is the case with private persons, which are making gum- and bromoil prints and sporadically selling a few prints?
> d) What is the case with people which are making workshops? Because in the German translation REACH regulation you will find following definition:
> [...]12. Inverkehrbringen: entgeltliche oder unentgeltliche Abgabe an Dritte oder Bereitstellung für Dritte. Die Einfuhr gilt als Inverkehrbringen;[...]
> The term "Bereitstellen" means in English: to provide sth.
> Here the English definition:
> [...]12. placing on the market: means supplying or making available,whether in return for payment or free of charge, to a third party. Import shall be deemed to be placing on the
> market;[...] 
> For me it seems that if you make a gum printing workshop even if I do not take money, you will be in targeted with REACH....
> 
> If you have other questions or aspects. please write it to me....
> 
> 
> b) New developments 98/2013:
> 
> [...]3) Substances proposed for addition into Annex I
> The United Kingdom presented its proposal to transfer Sulphuric acid (in concentration of 40 % w/w or higher) into Annex I. This amendment can only be introduced via the adoption by the Commission of a legislative proposal. The main consumer products identified were some drain cleaner products in niche markets where the number of sales are very low.
> In the ensuing discussion, Denmark and Sweden noted that they already restrict sulphuric acid over specific concentrations, and that they have not experienced any problems in doing so.
> Sulphuric acid is scheduled under the Drug Precursors Regulation. It is subject to the reporting of suspicious transactions in that context, to export authorisations to third countries in some instances, and to a registration requirement also in some instances.
> [...]
> 
> http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetailDoc&id=21879&no=1
> http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetailDoc&id=22208&no=2
> 
> That will affect in the first line private persons but the recent developments indicate that this regulation will be put in force for business use, too. 
> 
> 
> c) I wrote a mail to the admin of http://holowiki.org/wiki/Main_Page and asked for support for the dichromate-sunset-date-issue....
> 
> 
> d) Once again:
> 
> People which are interested in this whole issues, please register at https://ivntforum.phoerauf.de/ and write to me at "udos  followed by an @ sign followed by hawaii.edu" with your chosen pseudonym, because I have to activate every user.
> 
> 
> Thank you for your attention..
> 
> Udo
> 
> 
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