Transcript Federation of European Explosives Manufacturers 135th

Federation of European Explosives
Manufacturers
The Products which are effected by the
Track & Trace Directive
Detonating Cord
Detonators
Explosives
FEEM
Packed Explosives (25% of the total explosives’ market)
1. Dynamites
2. Emulsion Explosives
3. ANFO (Ammonium Nitrate Fuel Oil)
4. Black Powder
5. Permitted Explosives for Underground Mining
6. Powderous explosives containing demilitarized explosives
FEEM
Bulk Explosives (75% of the total explosives’ market which are not effected by
the T&T Directive):
(are mixed in pump trucks from 2 or 3 non explosive substances at the site of
application)
1. Emulsion explosives
2. ANFO
FEEM
Initiation Devices:
1. Detonators
• Electrical
• Non-Electrical
• Electronic
2. Detonating Cords
3. Boosters / Primers
FEEM
Typical Applications
FEEM
Filling of a blast hole with Dynamite
Traffic Project Construction Works
FEEM
Blasting in a Quarry
Demolition Blast
FEEM
Underground Mining
FEEM
Tunneling
FEEM
Close to 700.00 tons of explosives and 80 Million
detonators are detonated every year in Europe for
civil purposes. Almost all of these explosives are
manufactured, transported, stored and used without
causing any major incident or alarm to the general
public.
The safety & security record of the explosives
industry is considerably higher than almost any
other industry of a similar nature.
FEEM
These volumes represent 350 Million separate
explosives items annually (packaged explosives,
detonators, detonating cord, boosters, primers etc.
without bulk explosives) with a value of 1.500
Million Euro. Within the Supply Chain
(manufacturer – carrier - dealer – distributor – end
user) these items change location 3 to 4 times.
The frequency of civil explosive shipments in EUEurope is around 500.000 movements per year (this
doesn’t include pyrotechnics, military and hunting
& sporting ammunitions).
FEEM
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The general public is often unaware that
explosives enable:
the production of aggregate for road
building and for concrete
the production of limestone for the
manufacture of cement
the production of gypsum for the
manufacture of plaster
the extraction of almost all other minerals &
ores
Civil Explosives are an important tool for
modern mining and civil engineering.
FEEM
Without the use of high explosives for civil
purposes, it is difficult to see how civilization could
have advanced to such a state as it has done today.
“Guidance Note on the FEEM European
Explosives Code Structure”.
Arguments why to modify & postpone
the Directive
Since the Directive was published, FEEM members have
actively participated in the effort to bring about its
implementation by collaborating with its members to achieve a
better and more efficient application of the Directive
throughout its supply chain. A relevant milestone in the process
has been the preparation, distribution and acceptance by the
industry of the:
“Guidance Note on the FEEM European Explosives Code
Structure”.
We are particularly proud of this Guidance Note due to its
wholehearted acceptance by all our membership and have
made this available to other Civil Explosive organisations
outside the EU, who may wish to consider introducing the
standards we established.
During the studies and previous pilot projects necessary for the
implementation of the Directive, all parties (both the Authorities
and our Members) detected practical and fundamental problems,
some of which had previously been brought to the attention of the
Commission, (e.g. matters such as primers and safety fuse),
which, in our opinion, will more than likely require an amendment
to the Directive:
1. Transposition of the Directive
2. Re-packaging by Dealers, Distributors, Agents and Logistic
Service Companies.
3. Crystalline explosives
4. Articles which are too small to affix the unique product code to
or where it is technically impossible so to do.
1. Transposition of the Directive
Transposition of the Directive
The Directive was supposed to be adopted and
published by the EU-Member Countries by 5 April 2009
at the latest ( Article 15). Some Member States were
rather late in transposing.
This creates not only legal and juridical uncertainties
but also technical problems and potentially unfair
competition, as this delay seriously shortens the time of
preparation for an homogenous traceability system for
parties in the supply chain.
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2. Re-packaging by Dealers, Distributors, Agents
and Logistic Service Companies.
Re-packaging by Dealers, Distributors , Agents and Logistic Service Companies
A large proportion of the explosive distribution in
some countries is handled through dealers/agents
who are not manufacturers/importers according to
Article 3.1 of the Directive (in some countries this
could amount to as much as 30% of the total
movements) .
Generally these are small entities that are required
to “break bulk” from the deliveries they receive
from the manufacturers and repackage them into
smaller deliveries that are required by their
customers.
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Re-packaging by Dealers, Distributors , Agents and Logistic Service Companies
The new packaging must also be labelled according
to the requirements of the Directive. But
distributors have actually no possibility to use a
unique identification because they are not assigned
a production site number . They have no
alphanumeric coding for the production site and
therefore cannot use field (90) of the FEEM code
labelled by the manufacturer. One of the safety and
security standards in the explosives industry is not
to open packaging if not absolutely necessary.
Therefore, a standard for a unique identification of
packaging by distributors is required.
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3. Crystalline explosives
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3. Crystalline explosives
Some EU countries consider crystalline explosives such as RDX,
PETN, HMX, HNS and others which are intended for the use in
detonators, detonating cords and perforators for civil applications
as Defence Products. Even though these explosives are CE marked
according to Council Directive 93/15/EEC of 5 April 1993 on the
harmonization of the provisions relating to the placing on the
market and supervision of explosives for civil uses. This implies that
these explosives and the products containing these explosives fall
under the War Weapons Control Act for military arms and munitions.
The establishment of a clean Directive process is hampered and this
has got a significant negative influence on the production, sales,
marketing, logistics and competition situation i n these countries
and Europe.
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4. Articles which are too small to affix the unique
product code to or where it is technically
impossible so to do.
Articles which are too small to affix the unique
product code to or where it is technically impossible
so to do
Actual tests carried out by some of our members
have confirmed that it is impossible to affix, even
the reduced information laid down in point 3 of the
ANNEX (for articles too small to affix the unique
product code …..) and to read the bar codes on
small articles such as low gram detonating cords,
small primers, plain detonators, elemented
detonators and others.
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Technical Modification
FEEM therefore suggests changing ANNEX 3 of the Directive
accordingly:
“For articles too small or where it is technically
impossible due to their shape, design or
specification to affix the unique product code and
logistical in formation designed by the
manufacturer the product identification shall only
be marked on each smallest packaging unit.”
FEEM has already initiated a working group who
will prepare a Guidance Document defining in
detail the articles which fall under this exemption.
A first draft will be ready by end February 2011.
“Old” Stocks
The possible postponement could provide the
Industry with enough time to ensure that all
stocks, other than those with extensive shelf
lives, held by April 5th 2015 will be in compliance
with the Directive.
It is important to remind everyone that our
industry does have products with shelf lives in
excess of 5 years.
FEEM is of the opinion that this Security System
can be made even more secure and better and that
unintended flaws and consequences which impact
the security issue can be avoided. Therefore, extra
time would be needed to make the system safer.
In view of these arguments FEEM, together with the European
Federations and Associations of the
1. Mining Industry (Euromines)
2. Aggregates Industry (UEPG) &
3. Explosives Engineers (EFEE)
is asking the Commission and the delegates of the Explosives
Working Group to favorably consider a technical modification
as well as a postponement of the application of the Directive,
from 5 April 2012 to 5 April 2015.
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A postponement of the application of
the Directive will provide the
explosives industry & all other supply
chain participants with extra time to
fully develop and thereby to increase
the security of the electronic datacollecting systems required to
implement the Directive.
Thank you