FEEM GUIDANCE NOTE ON THE EUROPEAN CODE STRUCTURE

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FEEM GUIDANCE NOTE ON THE EUROPEAN CODE
STRUCTURE
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UPGRADE OF FEEM GUIDANCE NOTE ON THE
EUROPEAN
CODE STRUCTUREAfter several meetings of the
Security Working Group FEEM finally agreed on the
modifications and approved the final version at
our March 2013 meeting in Brussels. In April FEEM
distributed the document to its members
end-user organisations (e.g. UEPG, EASSP,
Euromines, EURACOAL, EFFEE, Eurocement) and to
the EU Commission, Notified Bodies and Competent
Authorities. The text with its appendices was
edited on FEEMs home-page and it was also
officially published on the COMMISSIONS
HOME-PAGE in JUNE 2013. This has got official and
regulatory character now and will enable LAW
ENFORCING BODIES and PUBLIC AUTHORITIES to work
according to FEEM standards.You can down-load
the revised document on FEEMs web-site.
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EUROPEAN TRACK TRACE CODE
The UN Committee of Experts on the Transport of
Dangerous Goods and on the Globally Harmonized
System of Classification and Labelling of
Chemicals (Sub-Committee of Experts on the
Transport of Dangerous Goods) have met in Geneva
on 23 June 02 July 2013 for their forty-fifth
session. Under Item XX of the agenda they
proposed a HARMONIZED INTERNATIONAL STANDARD FOR
EXPLOSIVES TRACEABILITY MARKINGS The
sub-committee is requested to add a new paragraph
1.4.4, Provisions for Unique Identification of
Class 1 Explosives (when required by National
Authority), to Chapter 1.4, Security Provisions,
of the Model Regulations. The paragraph 1.4.4
is identical to the European Track Trace
regulations and matches the FEEMs coding
structure.
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EUROPEAN TRACK TRACE CODE (cont.)
During the latest meeting of the EU Explosives
Working Group on 18 October 2013 the US IME
presented a room document setting out its
preliminary proposals to the forty-fifth session
in mid-2014 of the Sub-Committee of Experts on
the Transport of Dangerous Goods of the UN
Committee of Experts on the Transport of
Dangerous Goods and on the Globally Harmonized
System of Classification and Labelling of
Chemicals, for a harmonised format for
traceability markings based on the EU FORMAT and
the FEEM GUIDANCE.
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EUROPEAN TRACK TRACE CODE (cont.)
FEEM is all in favour towards such a harmonized
marking format which enhances the security of
explosives on a global level and it is of course
of practical and economic value to the European
explosives industry.
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EUROPEAN TRACK TRACE CODE (cont.)

• HOWEVER, FEEM PROPOSED SOME CHANGES TO THE IME
  PAPER
• Unique identification that shall be marked on or
  firmly affixed to each explosive article
  concerned and each smallest packaging unit, in A
  DURABLE WAY AND SO TO ENSURE THAT IT IS CLEARLY
  LEGIBLE.  MARKINGS SHALL NOT BE EASY TO REMOVE
  AND BE AS PERMANENT AS TECHNICALLY AND
  PRACTICALLY FEASIBLE ( IME text)
• FEEM suggests to delete SMALLEST PACKAGING
  UNIT, because this term is unknown in ADR.
  Within the terminology of ADR a packing unit is
  defined as sales-packaging or
  outer-packaging. The IME proposal could be
  interpreted in such a way, that the unique
  identifications have to be printed or labelled on
  the sales packagings as well. The EU-Directive
  however, is mentioning associated labels for
  each case of detonators, cartridges

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EUROPEAN TRACK TRACE CODE (cont.)

• The wording "...SHALL NOT BE EASY TO REMOVE AND
  BE AS PERMANENT AS TECHNICALLY AND PRACTICALLY
  FEASIBLE could be tricky e.g.
• Does a simple adhesive tag on detonator wires or
  shock-tubes comply with this requirement "shall
  not easy to be remove" if it could easily be
  removed with a knife, a scissors or by other
  means? There are very expensive multi-layer
  plastic labels with cutting protection on the
  market, which also offer only a limited
  protection. However, they are state-of-the-art
  and reflect what is technically and practically
  feasible today.
• Is a normal inkjet-paint for the printing on
  cartridges sufficient or does only a special ink
  with insoluble ink-particles reflects the todays
  state of technology?
• Does the industry have to apply
  state-of-technology adhesive labels with a
  special hard-to-remove adhesive? (which are
  extremely expensive but of course such special
  glues are available on the market)?

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EUROPEAN TRACK TRACE CODE (cont.)

• FEEM SUGGESTED TO DELETE THESES PASSAGES
  COMPLETELY BECAUSE IT MIGHT ONLY PROVOKE USELESS
  DISCUSSIONS AND PROBLEMS.

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A modified paper will be presented at the next UN
meeting in Geneva in June 2014. If it is accepted
by the committee it will most probably enter into
the Orange Book and subsequently into ADR (Accord
Européen relatif au transport international des
marchandises Dangereuses par Route) in 2016.
EUROPEAN TRACK TRACE CODE (cont.)
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• SECURITY VETTING OF PERSONNEL INVOLVED IN THE
  WHOLE SUPPLY CHAIN OF EXPLOSIVES AND CBRN
  MATERIALS
• Within the 48 measures to enhance the security
  of explosives in Europe was the intention to
  consider possible measures at the EU level to
  adopt a harmonized pre-Employment Background
  Check (EBC) to be used in all Member States.

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SECURITY VETTING OF PERSONNEL

• The Commission made a study in order to give an
  overview of existing policies and practices in
  the area of personnel vetting and background
  checks in the EU and to explore areas where
  possible policy initiatives at EU level would
  have added value in terms of enhancing security.
  This relates to personnel dealing professionally
  with explosives and high-risk CBRN material,
  including external workers, contractors and
  personnel who may have access to sensitive
  information that could be misused for malicious
  purposes. The study covered 15 Member States and
  approximately 85 of the EU27 population.

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SECURITY VETTING OF PERSONNEL

• A specific objective of the study was to analyze
  the EU dimension and cross-border aspects
  connected with security vetting / background
  checking practices. In particular given that the
  FREE MOVEMENT OF WORKERS is a fundamental
  principle of the EU and a policy chapter of the
  ACQUIS COMMUNAUTAIRE of the European Union, an
  authority in one Member State should be able to
  verify that an individual from another Member
  State holds an appropriate and current clearance/
  certificate. However, although this principle is
  enshrined in Article 45 of the TREATY ON THE
  FUNCTIONING OF THE EUROPEAN UNION, the study
  established that this is currently not possible
  across all Member States for many employers. As
  an example, the Criminal Records Bureau (CRB) in
  different Member States apply differing criteria,
  depth of checks and period of validity and so to
  ensure compliance with the principle, it is
  necessary to calibrate them against each other.

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SECURITY VETTING OF PERSONNEL

• The overall key recommendation of the study and
  the first in the group of Best Practice
  Recommendations is
• To adopt a harmonized pre-Employment Background
  Check (EBC) to be used in all EU- Member States.

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SECURITY VETTING OF PERSONNEL

• The Study identified that a harmonized best
  practice EBC standard is already used widely in
  both the private sector and the public sector in
  a majority of Member States. Research has also
  shown that regulated industries in the UK, USA,
  Canada, Australia and the EU e.g. Nuclear,
  EXPLOSIVE and Global Telecommunication industries
  use their own harmonized robust EBC standards.

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SECURITY VETTING OF PERSONNEL

• The overarching principle of the EBC is
  confirmation of the following elements
• Identity and address
• Nationality and immigration status (including
  entitlement to undertake the work in question)
• Employment history (minimum past 3 years) and
  details of education
• Financial check through a recognized credit
  reference bureau
• Unspent criminal convictions or other police
  checks
• Checking of at least 2 character referees
• Additionally, prospective employees should be
  required to give a reasonable account of any
  significant periods (six months or more in the
  past 3 years) of time spent abroad.

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SECURITY VETTING OF PERSONNEL

• Concerning the EXPLOSIVES INDUSTRY the Experts
  stated
• European legislation regulates the physical and
  personnel security of virtually all aspects of
  the EXPLOSIVES INDUSTRY. There is recognition
  that diversion of raw materials and finished
  product for terrorist activity is a real threat.
  Consequently, personnel screening, regulation and
  audit are routine in some Member States and there
  is a ready acceptance of the need for these
  measures. Where fully adopted, the EXPLOSIVES
  INDUSTRY in some Member States demonstrates BEST
  PRACTICE which could be adopted across the CBR
  industries.

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SECURITY VETTING OF PERSONNEL

• In this context CEFIC has developed and
  published a Security Vulnerability Assessment
  Tool
• The Security Vulnerability Assessment Toolkit
  (SVA) of Industrial Sites seeks to identify those
  risks which may result in catastrophic effects,
  it offers a methodology to both modify the risk
  and suggestions for controls which may mitigate
  or reduce the risks. The SVA TOOLKIT develops a
  risk log which will record information on which
  risks the company chooses to mitigate and which
  to accept. Ultimately the only mitigation of the
  risk available may be through financial means by
  accessing enhanced specialist insurance premiums
  and even these may still leave some residual risk
  with the company, however the SVA Toolkit will
  ensure that the full extent of these residual
  risks will have been identified.
• You find more information about this tool on
  FEEMs web-site.

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UPDATE ON SCEPYLT (paperless European transfer
process), THE PAN-EUROPEAN INFORMATION SYSTEM ON
EXPLOSIVES CONTROL TO PREVENT AND FIGHT AGAINST
TERRORISM, AND ITS FUTURE

The Spanish SCEPYLT coordinator recalled some of
the obstacles to implementation of the system in
the period up to the end of 2013, when the DG
Home grant expired. Only eight Member States had
made financial contributions to the project
(13,847 EUR each), which had a final budget of
around 980,000 in 2013 (80 funded by DG Home).
Since then the system continued to be used 12
Member States were connected, with just 5 using
it (Spain, France, Portugal, Belgium and the
Netherlands), 3 others (Germany, Poland and UK)
using it on a test basis and Italy to start
testing soon. In 2013 about 75 approvals had
been granted for transports with about 50 pending.
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UPDATE ON SCEPYLT (cont.)

• Italy explained that further training of
  prefecture staff would be necessary before Italy
  could start the operational phase. National
  funding for this would be facilitated if the
  system was linked to TRACEABILITY, which Italy
  saw as an important objective of the system, with
  access provided to operators to input the
  necessary data.
• Portugal confirmed that it was using the system,
  which was working well. It no longer used a
  paper-based system for approvals involving other
  SCEPYLT users. Extending the system to cover
  TRACEABILITY would however require careful
  reflection.

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UPDATE ON SCEPYLT (cont.)

• Germany also had concerns about extending the
  system to TRACEABILITY. Internal transfers would
  not be covered by the system and it would be
  difficult to manage, given the large volume of
  data that would be involved (e.g. as regards
  shipments of fuses and detonators). Germany also
  pointed out that the vast majority of transfer
  approvals continued to be paper-based and
  wondered whether fees may be a barrier to greater
  use of the system. The chairman noted, that it
  would be useful if Member States could provide
  updated information about their fee structures
  for transfer approvals so that there was an
  overview on this.

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UPDATE ON SCEPYLT (cont.)

• The UK said that it hoped to resolve connectivity
  issues and be able to use the system shortly. It
  echoed the concerns about using SCEPYLT as an
  instrument for traceability at this time.
• The representatives from FEEM, Switzerland and
  EFEE reiterated the doubts expressed about
  including traceability and questioned what useful
  purpose would be served linking such information
  to the transfer approval system.

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IMPLEMENTATION OF COMMISSION DIRECTIVE
2008/43/EC SETTING UP A SYSTEM FOR THE
IDENTIFICATION AND TRACEABILITY OF EXPLOSIVES FOR
CIVIL USES
STATUS OF PREPARATIONS BY INDUSTRY, INCLUDING
GUIDANCE FEEM reported to the Commission, that
from 5 April 2013 all explosives manufactured by
FEEM member companies are being marked in
accordance with the Directive. FEEM is assisting
end-user organisations like UEPG in their efforts
to ensure that customers are aware of the system
and its requirements. All member companies are
using FEEM's European Code Structure, the
guidance on which was updated in April 2013 (EU
Doc 5.a.1) to cover not only the mandatory
information requirements, but also
recommendations to distributors and re-packagers
to voluntarily use THREE LETTER CODES to identify
them. FEEM also offered to develop a
password-protected software application (APP)
that would enable competent national authorities
to identify the manufacturing site for each
explosive, providing information about the EU
manufacturer or importer, their address and
contact details, etc.
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ITEM 8IME Letter by Debra Satkowiak
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Our old friend Chris Ronay has retired from IME.
Chris became the president of the IME on October
1, 1994. He came to the Institute following a
career of 23 years as a Special Agent of the FBI.
Chris sent these words to FEEM In many ways
this will be a melancholy affair.  IME has been
such a great part of my life for nearly 20 years
that Im not sure how to deal with leaving it all
behind.  It seems like a replay of my first
retirement from the FBI, leaving friends and
colleagues from many sectors.
Chris Ronay
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During my time with IME, no other organization
has held the influence and importance for me as
FEEM.  Most remarkably you Hans, John Dolan and
Frank Murray have embodied the Federation and
become so close to IME.  For this and your
friendship I am most grateful and thank you.  May
we always stay in touch!
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HIS SUCCESSOR AS PRESIDENT IS DEBRA SATKOWIAK.
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Press Release by the IME
The Institute of Makers of Explosives, the safety
and security organization of the commercial
explosives industry, is very pleased to announce
the hiring of Debra Satkowiak as IMEs new
President.  Until recently, Debra had been the
Chief  of the Firearms and Explosives Industry
Division of the Bureau of Alcohol, Tobacco,
Firearms and Explosives (ATF).  Deb has had
an outstanding career with the ATF.  No one knows
more about explosives regulation or better
understands the need for industry and government
to work together to achieve mutually shared
explosives safety and security objectives than
Deb Satkowiak, stated Tim OBrien, President of
Detotec North America, Inc. and Chairman of the
IME.  He added, As the new President of IME,
Debs ability to encourage and foster cooperation
between the industry and government agencies will
be a key strength moving forward.
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Press Release by the IME
Ms. Satkowiak served for 23 years in a variety of
positions at ATF, culminating in her appointment
to the Firearms and Explosives Industry Division
in 2010.   Over those 23 years, Debs experience
encompassed field inspections, advanced training,
development of explosives policy and regulations,
media and legislative affairs, and executive
leadership.  Her background, which includes
extensive interaction with blasters and other
direct users of commercial explosives,
distributors, manufacturers, consultants, and
company executives, has provided her with a sound
background in the technical aspects of the
products IMEs member companies handle every day.
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Unfortunately Debra will not be able to attend
this FEEM AGM in Warsaw.  She writes, that she is
disappointed, but a combination of her new
arrival to the job and preparing for IMEs Spring
Meeting beginning of June is preventing her from
traveling to Europe. However, she sends this
message to FEEM 
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• FEEM WORKING GROUPS

• Item 9
• THE FEEM WORKING GROUPS

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• FEEM WORKING GROUPS

• 4 FEEM Working Groups have
• been active in 2013 and 2014
• HEALTH AND SAFETY
• TRANSPORT
• BLASTING PRACTICES
• TRACK TRACE AD-HOC WORKING PARTY (2013)

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HEALTH AND SAFETY WORKING GROUP

• Members
• Severine Gautrau, Davey Bickford, France
• Jean-Paul Reynaud, Titanobel, France
• Maurice Delaloye, SSE, Switzerland
• Martin Klein, DynaEnergetics, Germany
• Jaroslav Konarik, Austin Detonators, Czech
  Republic
• Hans Karlström, Kimit, Sweden
• Jose Castresana, Maxam, Spain
• Xavier Lopez Amigo, Maxam, Spain
• Walter Panchyrz, Orica, Germany
• Thierry Rousse, EPC, France
• Janusz Drzyzga, Nitroerg, Poland
• David White, EPC, U.K.
• Matti Vähäpassi, Forcit, Finland
• Marin Dorobantu, Weatherford Atlas, Romania

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HEALTH AND SAFETY WORKING GROUP

• The Group has met two times since the 2013 AGM
• on 16 September 2013 in Budapest
• on 25 March 2014 in Prague

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HEALTH AND SAFETY WORKING GROUP

• The main subjects which were discussed are
• Trace Track Directive
• Practical experience in production application
• The IPPC process the impact on explosives sites
  
• Elaborating the Best Available Techniques
  Reference (BREF) documents concerning HS
• New environmental requirements for IPPC
  production sites
• Precursors Guidance
• Preparation of a new FEEM guidance note on
  categorisation classification of incidents (CGP
  32)
• Near misses unusual occurrences
• Exchange of experiences learnings

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HEALTH AND SAFETY WORKING GROUP

• HS Group Chairmanship
• Since 2011 the chairmanship of this group has
  been vacant.
• The last chairman was Pat Cosgove from Irish
  Industrial
• Explosives, who left the European explosives
  business in 2011.
• Since then the SG has taken over the duties of
  this job.
• However it is of importance for the
  sustainability of this group
• to select a member of this group to this
  position.

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HEALTH AND SAFETY WORKING GROUP

• HS Group Chairmanship
• The group suggested Jean-Paul Reynaud from
  Titanobel as
• their new Chairman.
• Jean-Paul was elected unanimously by all the
  delegates. He
• accepted the vote and the group and the SG
  congratulated
• Jean-Paul to this important and responsible
  position.

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• BLASTING PRACTISE WORKING GROUP
• MEMBERSHIP
• Mark Pegden EPC UK
• Frank Hammelmann Orica, Germany
• Marcos Perena Maxam, Spain
• Knut Tanbergmoen Forcit, Norway

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BLASTING WORKING GROUP

• The Blasting Practice Working Group has met
  twice since the last AGM 2013
• On 17 September 2013 in Prague, Czech Rep.
• On 27 March 2014 in Brussels, Belgium

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BLASTING PRACTISE WORKING GROUP

• The main working subjects were
• Finalization of a new Technical Bulletin Safe
  Operation on the Bench
• New TG 12 "Loading of bulk explosives
• Learnings from blasting related near misses
  unusual occurrences.

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TRANSPORT WORKING GROUP

• Membership
• Bengt Folkesson (Chairman), EPC Group, Sweden
  (until Sept. 2013)
• Marlies Becker, Orica Europe, Germany
• Francois-Xavier Dugres, Davey Bickford, France
• Marcin Slimak, Nitroerg, Poland
• Jon Jones, Austin International, UK
• Ivana Jakubkova, Austin Detonators, CZ
• Martin Klein, DynaEnergetics, Germany
• Jean-Paul Reynaud, Titanobel, France
• Janusz Drzyzga, Nitroerg, Poland
• Maurice Delaloye, SSE, Switzerland
• Rafael Lopez-Loriente, Maxam, Spain
• Marin Dorobantu, Weatherford Atlas, Romania
• Joanna Flak, Nitroerg, Poland

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TRANSPORT WORKING GROUP

• The FEEM Transport and Storage Working Group has
  met
• two times since the last AGM in 2013.
• on 16 September 2013 in Budapest
• on 25 March 2014 in Prague

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TRANSPORT WORKING GROUP

• The main working subjects were
• Directives 93/15 2008/43 and its impact on the
  Supply Chain Processes
• FEEM Guidance Note XML fields ISO Code
• Requirement for Transporters to Maintain Records
• CLP Process related Directives and Regulations
• Learnings from transport related incidents and
  accidents
• Intra-EU transfer of explosives procedure for
  returned consignments
• Status Of Preparations By Industry, Including
  Guidance
• Trace Track Directive after implementation of
  1st step UEPGs (European Federations of
  Aggregate, Cement Mining Ind.) Action Plan
  regarding European process of cascading down to
  national end-user organisations.

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TRANSPORT WORKING GROUP

• The Transport Working Group is also dealing with
  a proposal by the European truck manufacturers to
  modify the existing ADR requirements concerning
  the construction of Type III vehicles and MEMUs
  (chapt. 9.2) regarding
• Do away with the Battery Master Switch
  (9.2.2.3)!
• Do away with the 24 Volts regulation (9.3.7.2)!
• To 1) The intention to remove the Master Switch
  is not quite clear to us!
• To 2) Here the background is the use of Xenon
  lights, which need much higher voltages!

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TRANSPORT WORKING GROUP

• ELECTION OF A NEW CHAIRLADY FOR THE TRANSPORT
  WORKING GROUP
• Since Bengt Folkesson from EPC Nordic has
  retired from this Group it was necessary to elect
  a new chair.
• Marlies Becker from Orica offered herself for
  election and she was voted unanimously by the
  delegates. The group and the SG congratulated
  Marlies and wished her lots of success in this
  important position.

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Statistics 2013
ITEM 12 OF THE AGENDA
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Explosives Detonator Statistic 2013
For several years FEEM has managed a confidential
statistics service for its members. It acts as a
trustee company in compliance with competition
laws. In order to estimate accurate annual sales
per product in Europe we need from you all your
best sales estimates from all the countries your
are represented in. We will consolidate your data
and give global figures of the European sales
estimate per product only to those companies
which provided figures. The numbers are based on
FEEM members input and represent the arithmetic
average of the reported country numbers.
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Explosives 2013
48
Explosives Statistic 2013

• The volume of explosives consumed (not
  manufactured!) in Europe (EU27 Norway
  Switzerland) in 2013 amounted to
• 580.000 tons
• This is 9 higher compared to 2012.

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9,1
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EXPLOSIVES DEVELOPMENT 1995 2013 (1.000 tons)
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EXPLOSIVES MARKET BY SHARES (2013 ./. 2012)
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Detonators 2013
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Detonator Statistic 2013

• The amount of detonators consumed (not
  manufactured!) in Europe (EU27 Norway
  Switzerland) in 2013 amounted to
• 61,870 mio. units
• This is more or less the same than in 2012
  (61,132)

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DETONATORS MARKET SHARES (mio. units)
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Detonating Cords 2013
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Explosive Production Sites Staff 2013
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Item 12 of the Agenda (RE)ELECTION TO THE
EXECUTIVE COMMITTEE
70

• 1.) Re-election to the Executive Committee 2014
• According to the 2 year rule and according to
  Article 7.2 of FEEMs Constitution the following
  Executives Committee Members have to step down at
  this meeting and stand for re-election
• Gianni Facchinetti
• Ulf Sjöblom
• Vicente Huelamo

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• 1.) Re-election to the Executive Committee 2014
• Gianni Facchinetti
• Vicente Huelamo
• Ulf Sjöblom
• I would like to ask the Delegates for their
  votes
• Votes Against
• Votes For
• Abstentions

72
2.) Election to the Executive Committee

• The Executive Committee Member Stephen Connolly
  from Orica has stepped down from the Committee as
  of 4 October 2013 and has suggested co-opting
  Jeff Court, Vice-President Orica Europe to the
  Executive Committee according to Article 7.2 of
  FEEMs Constitution (CO-OPTION TO THE EXECUTIVE
  COMMITTEE). The Executive Committee has agreed
  unanimously to this process at their meeting on 4
  October 2013.
• According to the Constitution Jeff has to step
  down at this meeting and has to offer himself for
  election.

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2.) Election to the Executive Committee

• Jeff Court
• I would like to ask the Delegates for their
  votes
• Votes Against
• Votes For
• Abstentions

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Item 13CHANGE IN FEEMS PRESIDENCY
According to Articles 7.6 (ELECTION OF OFFICERS)
and 9.2 (TERM OF OFFICE) of the Constitution the
EXECUTIVE COMMITTEE has elected a new President
and a new Vice-President from the members of the
Committee.
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Item 13CHANGE IN FEEMS PRESIDENCY
After two years of excellent service Mr. Daniel
Antille from SSE, Switzerland will step down and
pass the Presidency on to Mr. Bertrand Pougny
from EPC, France.
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Item 13CHANGE IN FEEMS PRESIDENCY
The Assembly welcomes the new officers and thanks
Daniel Antille for his endeavoring service with a
big applause.
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ITEM 14Any other business ?
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DATE AND PLACE OF THE NEXT ANNUAL GENERAL
MEETINGinRome, ItalyonWednesday, 03 June
2015a Gala Dinner on Tuesday, 02 June 2014
ITEM 15