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

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: https://www.gov.uk/guidance/precursor-chemical-licensing

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.

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 coordinated by Health and Safety.

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 (A & B) Substances. This regulation relates to:

2A

• Acetic anhydride

• Red Phosphorous

2B

• 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.

Domestic Licensing & Registration

Domestic licences are required for organisations that exceed stated limits of drug precursors. The University does not exceed those limits and therefore does not poses a Domestic Licence.

It is imperative that all Category 2A and 2B precursors are notified to Health and Safety before ordering or receiving to ensure the University remains below the registration threshold. No Category 1 precursor may be ordered or received.

Licence and Declaration of Specific Use

When ordering Category 2A & 2B substances a  Declaration of Specific Uses form will be requested from the supplier. These must be completed in liaison with Health and Safety.

Further information for Schools and Departments

It is essential that Schools and Departments notify Health and Safety of all transactions involving Category 1 and 2 substances (see above) BEFORE USE.

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.

Appendix 1

List of Category 1 and 2 Substances and Thresholds:

Category 1 Substances

Category 2 A & B Substances

Category 2 Substances - Thresholds

Appendix 2 - Relevant Forms

From the Home Office website:

• Customer declaration of specific uses of the scheduled category 1 or 2 substances (individual transactions)
• Customer declaration of specific uses of the scheduled category 2 substances (multiple transactions)