Federation of European Explosives Manufacturers

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Federation of European Explosives Manufacturers
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The Products which are effected by the Track
Trace Directive
Detonating Cord
Detonators
Explosives
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FEEM

• Packed Explosives (25 of the total explosives
  market)
• Dynamites
• Emulsion Explosives
• ANFO (Ammonium Nitrate Fuel Oil)
• Black Powder
• Permitted Explosives for Underground Mining
• Powderous explosives containing demilitarized
  explosives

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FEEM

• Bulk Explosives (75 of the total explosives
  market which are not effected by the TT
  Directive)
• (are mixed in pump trucks from 2 or 3 non
  explosive substances at the site of application)
• Emulsion explosives
• ANFO

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FEEM

• Initiation Devices
• Detonators
• Electrical
• Non-Electrical
• Electronic
• Detonating Cords
• Boosters / Primers

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FEEM
Typical Applications
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FEEM
Filling of a blast hole with Dynamite
Traffic Project Construction Works
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FEEM
Blasting in a Quarry
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Demolition Blast
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FEEM
Underground Mining
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FEEM
Tunneling
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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.
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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 EU-Europe is around 500.000
movements per year (this doesnt include
pyrotechnics, military and hunting sporting
ammunitions).
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FEEM

• 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.

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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.
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Guidance Note on the FEEM European Explosives
Code Structure.
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Arguments why to modify postpone the Directive
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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.
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• 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
• Transposition of the Directive
• Re-packaging by Dealers, Distributors, Agents
  and Logistic Service Companies.
• Crystalline explosives
• Articles which are too small to affix the unique
  product code to or where it is technically
  impossible so to do.

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1. Transposition of the Directive

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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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1. Re-packaging by Dealers, Distributors, Agents and
   Logistic Service Companies.

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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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1. Articles which are too small to affix the unique
   product code to or where it is technically
   impossible so to do.

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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.
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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.
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Old Stocks
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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.
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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.
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• In view of these arguments FEEM, together with
  the European
• Federations and Associations of the
• Mining Industry (Euromines)
• Aggregates Industry (UEPG)
• 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 data-collecting
systems required to implement the Directive.
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Thank you