Information on Drugs Precursors
Further Guidance on EC Regulation of Drugs Precursors
Bangor University has compiled this guide from briefing notes supplied by the Home Office and Universities UK .
EC Regulation of Drugs Precursors
1. Background
Following a review of the effectiveness of European Union illicit drug precursor control, new regulations were introduced in 2005 relating to category 1, 2 and 3 substances. The regulations relating to category 3 substances are not relevant to universities as they relate to the export of substances abroad.
The relevant regulations are Regulation (EC - internal trade) No 273/2004 and Regulation (EC trade between EU and third countries) no 111/2005. All references in this paper are to Articles in 273/2004 as 111/2005 is not relevant to universities. The Regulations and the forms referred to in this further guidance can be found at the Home Office website at :
http://www.drugs.gov.uk/drugs-laws/licensing/precursor-forms/
Bangor University [BU] uses numerous chemicals, which are listed in these regulations, as part of its everyday science and research activities.
This Guidance document advises on control measures necessary to comply with drug control legislation only and does not advise on health, safety and environmental requirements for those chemicals listed. Health and Safety information on the chemicals listed is available from the appropriate Departmental COSHH Risk Assessments and from the Departmental Safety Co-ordinator; information on disposal of chemicals is available from Laboratory Supervisors and Technicians.
2. The Regulations
There are two key activities that universities have to undertake for Category 1 and 2 substances.
For Category 2 substances a customer declaration (Declaration of Specific Use) is needed before a supplier can provide the substances to BU (see Appendix 2), however a licence is not needed. For Category 1 substances both a licence and a customer declaration are needed. BU will also have to report annually on its use of these substances.
Applications for licenses to be supplied with Category 1 substances will be handled through the University Compliance Officer (Details at section 4).
3. Category 1 and 2 substances
Category 1 Substances
This regulation relates to:
- 1-phenyl-2-propanone
- N-acetylanthranilic acid
- Isosafrol (cis+trans)
- 3,4-methylenedioxyphenyl-propan-2-one
- Piperonal
- Safrole
- Ephedrine
- Pseudoephedrine
- Norephedrine
- Ergometrine
- Ergotamine
- Lysergic acid
II. Category 2 Substances
This regulation relates to:
- Acetic anhydride
- Phenylacetic acid
- Anthranilic acid
- Piperidine
- Potassium permanganate
Currently the guidance from the Home Office indicates that universities do not need to register or apply for a licence to be supplied with Category 2 substances, even if the quantities they use go above the thresholds outlined in Appendix 1. They will however need to complete a Declaration of Specific Uses form (see Appendix 2 or available from the Home Office website), leaving out the details of registration and licence. One single declaration for a 12 month period may be accepted providing the institution has purchased the substance at least three times in the previous 12 months.
4. Compliance Officer
The regulations require a responsible officer to be appointed for the "trade" in category 1 and 2 substances, the officer will be responsible to ensure that the "trade in scheduled substances" takes place in compliance with the regulations. In addition the officer shall "be empowered to represent Bangor University and to take the decisions necessary" to ensure compliance with the regulations.
The Compliance Officer for Bangor University, who must be consulted and informed of all transactions involving Category 1 and Category 2 substances is -
Mrs Gwenan Hine
Head of Compliance
Planning & Governance Office
e-mail:- gwenan.hine@bangor.ac.uk
5. Licence and Declaration of Specific Use
As well as providing Declaration of Specific Uses forms to suppliers when ordering these substances in the future the University will also need to hold a licence before the substances can be supplied. For further details on the licence please contact the Compliance Officer.
6. Further information for Schools and Departments
It is essential that Schools and Departments notify the Compliance Officer of all transactions involving Category 1 and 2 substances (see point 3. above).
It is recommended that Category 1 and 2 substances are kept in limited access facilities at all times and a record is kept of quantities and purpose of amounts purchased, used and disposed of. Stock checks should be performed by the Department on a regular basis to ensure that there are no discrepancies.
The Compliance Officer will carry out an audit each year to ensure that the necessary security measures remain in place to guard against the unauthorised removal of the Category 1 and 2 substances, as well ensuring that the Schools/Departments' use of the substances remains as notified to the Home Office.
Schools and Departments should ensure that if they commence using new substances (not currently notified) from either category 1 or 2 as noted above, these should be notified immediately to the Compliance Officer to ensure that the terms of our current licence are adhered to.
7. Contacts
Gwenan Hine
Head of Compliance
Planning & Governance Office
Bangor University
College Road
Bangor
Gwynedd LL57 2DG
Tel: (01248) 38 2413
E-mail: gwenan.hine@bangor.ac.uk
Appendix 1
List of Category 1 and 2 Substances and Thresholds
Category 1 Substances
Substance | CN code (1) | CAS No (2) |
---|---|---|
1-phenyl-2-propanone |
2914 31 00 |
103-79-7 |
N-acetylanthranilic acid |
2924 23 00 |
89-52-1 |
Isosafrol (cis + trans) |
2032 23 00 |
120-58-1 |
3,4-methylenedioxyphenyl-propan-2-one |
2932 92 00 |
4676-39-5 |
Piperonal |
2932 93 00 |
120-57-0 |
Safrole |
2932 94 00 |
94-59-7 |
Ephedrine |
2939 41 00 |
299-42-3 |
Pseudoephedrine |
2939 42 00 |
90-82-4 |
Norephedrine |
ex 2939 49 00 |
14838-15-4 |
Ergometrine |
2939 61 00 |
60-79-7 |
Ergotamine |
2939 62 00 |
113-15-5 |
Lysergic acid |
2939 63 00 |
82-58-6 |
Category 2 Substances
Substance | CN code (1) | CAS No (2) |
---|---|---|
Acetic anhydride |
2915 24 00 |
108-24-7 |
Phenylacetic acid |
2916 34 00 |
103-82-2 |
Anthranilic acid |
2922 43 00 |
118-92-3 |
Piperidine |
2933 32 00 |
110-89-4 |
Potassium permanganate |
2841 61 00 |
7722-64-7 |
Category 2 Substances - Thresholds
Substance | Threshold |
---|---|
Acetic anhydride |
100 lt |
Phenylacetic acid |
100 kg |
Anthranilic acid |
1 kg |
Piperidine |
1 kg |
Potassium permanganate |
0.5kg |
Appendix2 - Relevant Forms
from the Home Office website:
Customer declaration of specific uses of the scheduled category 2 substances (multiple transactions)