[Alt-photo] Update EU-Regulation 98/2013

John Brewer john at johnbrewerphotography.com
Thu Mar 17 15:42:18 UTC 2016


Disposal is normally, for me, is easy as my supplier deals with it. I think
as a business I have a higher chance of getting authorization than an
individual albeit a small chance!

The difference about when you apply for authorisation is use after the
sunset date. So applying *now,* even without authorisation you can use
dichromates after the sunset date while you wait for authorisation.
Applying *after* this current, March if you haven't had authorisation you
have to stop using dichromates at the sunset date until you do (hopefully!)
get authorisation.

Interestingly there is a company asking to use ammonium dichromate use in
photo sensitivity
http://echa.europa.eu/addressing-chemicals-of-concern/authorisation/applications-for-authorisation/-/substance-rev/12472/term

Information regarding application is here. It does look like a lot of
bureaucracy but with chemicals of high toxicity I guess it's justified. I
wonder if as a group we could make an application? I'm sure that would have
more clout than an individual, certainly a group of registered businesses
maybe?

John

On 17 March 2016 at 14:08, Jacques Kevers via Alt-photo-process-list <
alt-photo-process-list at lists.altphotolist.org> wrote:

> I agree with Gilles, for the deadline as well as for the chances to get an
> agreement with realistic safety, disposal & reporting prescriptions.
> Moreover, even if you get an authorization to continue selling dichromate,
> the private users we are won't be authorized to buy & use your stuff...
> My 2 cents...
> Jacques
>
> Jacques Kevers
> Beau Site
> Première Avenue 7
> B-1330 Rixensart
> Belgium
> +32 2 653 56 02
>
> 2016-03-17 13:05 GMT+01:00 GILLES LORIN via Alt-photo-process-list <
> alt-photo-process-list at lists.altphotolist.org>:
>
> > Hi John,
> >
> > The deadline is the end of this month. I'm curious if anyone put in an
> > application and what the outcome was. My concern is that even if there
> is a
> > chance, the safety and disposal requirements would be beyond what we
> could
> > do, and only feasible for the big fish.
> >
> > Gilles
> >
> > Gilles Lorin
> > +49 160 127 3448
> > ---------------------------
> > Sent from my mobile
> >
> > > On Mar 17, 2016, at 10:03, johnbrewerphotography--- via
> > Alt-photo-process-list <alt-photo-process-list at lists.altphotolist.org>
> > wrote:
> > >
> > > No but I am seriously considering it. I do think there's a fighting
> > chance.
> > >
> > > John
> > >
> > > Sent from my iPhone
> > >
> > >> On 17 Mar 2016, at 7:33 am, GILLES LORIN via Alt-photo-process-list <
> > alt-photo-process-list at lists.altphotolist.org> wrote:
> > >>
> > >> Thank you for this update. Has anyone filed an exemption for potassium
> > dichromate with REACH?
> > >>
> > >> Gilles
> > >>
> > >> Gilles Lorin
> > >> +49 160 127 3448
> > >> ---------------------------
> > >> Sent from my mobile
> > >>
> > >>> On Mar 17, 2016, at 06:55, BJ68 via Alt-photo-process-list <
> > alt-photo-process-list at lists.altphotolist.org> wrote:
> > >>>
> > >>> To whom it may concern and who is interested:
> > >>>
> > >>>
> > >>> a)  Threat assessment of matchsticks:
> > >>> [...]The Commission reported back from consultations held with the
> > European Chemicals Agency (ECHA), and internally (with the JRC, the REACH
> > Unit in DG GROW, and also the Commission's Legal Service), on the
> question
> > of whether or not matchsticks fall under Regulation 98/2013.
> Consultations
> > seem to indicate that matchsticks cannot be exempted from the Regulation
> on
> > the grounds that they are articles as defined in REACH. At this stage,
> the
> > Commission has therefore followed the current practice in the Regulation
> to
> > calculate the concentration when there is a combination of a manufactured
> > part and a substance (fertilizer granules). The preliminary view is that
> > matchsticks do not fall within the restrictions of Article 4(1), but
> since
> > they contain potassium chlorate, they are in principle subject to the
> > reporting obligation under Article 9. However, following Recital (20) in
> > the Regulation, the measures applied for new explosive precursors should
> > match their threat level. In view of this, a threat assessment of
> > matchsticks will be made in combination with the upcoming review of the
> > Regulation.
> > >>> Some Members raised objections to matchsticks being a significant
> > threat and falling under the scope of the Regulation.
> > >>> [...]
> > >>>
> > >>> b) Inhibitor addition to precursors:
> > >>> [...]4. Presentation by the FP7 Research project EXPEDIA on inhibitor
> > additives
> > >>> The EXplosives PrEcursor Defeat by Inhibitor Additives (EXPEDIA)
> > project is an FP7 project coordinated by the Swedish Defence Research
> > Agency (FOI). The project aims to 1) inhibit some frequently used
> explosive
> > precursors and 2) increase knowledge about the so-called 'garage
> > chemistry'. The project will develop a European guide for first
> responders.
> > >>> More information is available on the Commission's CORDIS website
> > (link) and the presentation is available on the CIRCABC Library (link).
> > >>> [...]
> > >>>
> > >>> Both from
> > >>>
> >
> http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetailDoc&id=22209&no=2
> > >>>
> > >>>
> > >>> c) Metal powders will be added to Annex II (watched chemicals):
> > >>> [...]Another Member announced that in the weeks after the meeting it
> > would circulate a proposal to amend Annex II of the Regulation to add
> metal
> > powders.[...]
> > >>>
> > >>>
> >
> http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetailDoc&id=19513&no=2
> > >>>
> > >>> d) Important for people who visit or even passing through Austria:
> > >>>
> > >>> [...]Introduction: Where a member of the general public intends to
> > introduce those restricted
> > >>> explosive precursors (hydrogen peroxide in concentrations above 12 %
> > w/w up to 35% w/w
> > >>> nitromethane in concentrations above 30% w/w up to 40% w/w; and
> nitric
> > acid in
> > >>> concentrations above 3 % w/w up to 10 % w/w) into the Austrian
> > territory the member of the
> > >>> general public has to transfer information appropriate to Art. 8
> > Regulation. (EU) No 98/2013 to
> > >>> the Ministry of Agriculture, Forestry, Environment and Water
> > Management.
> > >>> [...]
> > >>>
> >
> http://ec.europa.eu/dgs/home-affairs/what-we-do/policies/crisis-and-terrorism/explosives/docs/austria_-public_overview_of_measures_en_en.pdf
> > >>>
> > >>> Higher concentrations are not allowed for members of the general
> > public and the fine is 500 Euro minimum (first time). This means that you
> > can forget to etch copper, prepare silver nitrate with nitric acid.
> > >>>
> > >>> e) Overview for the public:
> > >>>
> >
> http://ec.europa.eu/dgs/home-affairs/what-we-do/policies/crisis-and-terrorism/explosives/explosives-precursors/index_en.htm
> > >>> Single measurements of the states:
> >
> http://ec.europa.eu/dgs/home-affairs/what-we-do/policies/crisis-and-terrorism/explosives/explosives-precursors/docs/list_of_measures_en.pdf
> > >>> Say good bye to concentrated nitric acid in the EU....if you are a
> > private citizen...
> > >>>
> > >>> f) For US citizens in the case if you think you live on the other
> side:
> > >>> http://www.darpa.mil/news-events/2016-03-11
> > >>>
> > >>>
> > >>> Bj68
> > >>>
> > >>>
> > >>>
> > >>>
> > >>>
> > >>> _______________________________________________
> > >>> Alt-photo-process-list | altphotolist.org
> > >> _______________________________________________
> > >> Alt-photo-process-list | altphotolist.org
> > > _______________________________________________
> > > Alt-photo-process-list | altphotolist.org
> > _______________________________________________
> > Alt-photo-process-list | altphotolist.org
> >
> _______________________________________________
> Alt-photo-process-list | altphotolist.org
>



-- 
John Brewer
www.thevictorianphotographer.com
www.johnbrewerphotography.com
workshops:equipment sales:chemistry sales


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