COMMENTS ON AN ANNEX XV DOSSIER FOR IDENTIFCATION OF A SUBSTANCE AS SVHC AND RESPONSES TO THESE COMMENTS

Substance name:	Lead dipicrate	
CAS number:	6477-64-1	
EC number:	229-335-2	

The substance is proposed to be identified as meeting the following SVHC criteria set out in Article 57 of the REACH Regulation: CMR

PART I: Comments and responses to comments on the SVHC proposal and its justification

General comments on the SVHC proposal
Number	Date	Submitted by (name, Organisation/MSCA)	Comment	Response	
28	2011/10/13	National Authority
RIVM
Netherlands	NL supports the proposal to include Lead dipicrate in the candidate list of substances of very high concern. 
The information provided for lead diazide and styphnate were screened. Based on these comments it can be concluded that, although lead depricate meets the criteria of Article 57 (c) there seems to be no need to give the substance a high priority for inclusion in Annex XIV or to restrict the uses which result in the highest exposure, i.e. use of lead dipricate in explosives.	Thank you for your support	
27	2011/10/13	Industry or trade association
ATIC - Associação Técnica da Indústria de Cimento
Portugal	Comments are made from a user point of view:
Lead dipicrate is a substance that:
- Is commonly called as lead primary explosives.
- Is a lead compound having explosive properties and applications.
- Is incorporated in explosive items and the final products (detonators, primers, etc).
As far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
26	2011/10/13	Industry or trade association
ATIC - Associação Técnica da Indústria de Cimento
Portugal	Comments are made from a user point of view:
Lead dipicrate is a substance that:
- Is commonly called as lead primary explosives.
- Is a lead compound having explosive properties and applications.
- Is incorporated in explosive items and the final products (detonators, primers, etc).
As far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
25	2011/10/13	Company
Germany	It is not justified that Lead dipicrate is identified and classified as SVHC because neither the manufacture of the substance, mixtures and articles nor the use of the final products are of very high concern.
Thus there is no reason for prioritisation.	Lead dipicrate is classified as toxic to reproduction 1A according to Annex VI, part 3, Table 3.1 of Regulation (EC) No 1272/2008. Consequently the substance fulfils the criteria of Article 57(c) of the REACH Regulation and can be identified as a Substance of Very High Concern following the procedure set out in article 59 of the same regulation.
We thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
20	2011/10/13	National NGO
Centrum pro životní prostředí a zdraví (Center for Environment and Health)
Czech Republic	We support nomination of lead dipicrate on the Candidate list of Substances of Very High Concern.	Thank you for your support	
18	2011/10/12	Member State
Belgium	Belgium supports the identification of Lead dipicrate as SVHC according to article 57 (c )	Thank you for your support	
16	2011/10/12	National Authority
Allgemeine Unfallversicherungsanstalt
Austria	Again we strongly support grouping in the authorisation process. Especially in the case of lead compounds that have similar dangerous properties. Grouping will fasten and facilitate the authorisation process.
Lead or lead compounds are listed (entry 112) in the Commission Recommendation concerning the European schedule of occupational diseases (2003/670/EC). Substituting them is a main goal in prevention in the workplace.
Further we see the need of putting all three lead compounds of this consultation process on the candidate list to avoid substitution of one lead compound, by one of the others.	Thank you for your support and opinion	
15	2011/10/12	Company
Orica Europe Pty Ltd & Co KG
Germany	Please find general comment in the attachement	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
			See also:
Comment 15 attachment (Comments on Annex XV dossier - Lead picrate.pdf).pdf		
14	2011/10/12	Industry or trade association
Gremi d'Àrids de Catalunya
Spain	Comments are made from a user point of view:
Lead dipicrate is a substance that:
- Is commonly called as lead primary explosives.
- Is a lead compound having explosive properties and applications.
- Is incorporated in explosive items and the final products (detonators, primers, etc).
As far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
13	2011/10/12	International NGO
Health and Environment Alliance
Belgium	HEAL supports the nomination of lead dipicrate to the candidate list based on the information in the documents.	Thank you for your support	
11	2011/10/11	Individual
Belgium	Comments are made from a user point of view:
Lead dipicrate diazide is a substance that:
- Is commonly called as lead primary explosives.
- Is a lead compound having explosive properties and applications.
- Is incorporated in explosive items and the final products (detonators, primers, etc).
As far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
10	2011/10/11	Member State
Germany	The German CA agrees that identifying lead dipicrate as a substance of very high concern is a good measure to exclude it as a possible alternative for the use of lead diazide and lead styphnate. We understand that although pre-registration occurred, the substance was not registered. Identifying lead dipicrate as SVHC is supposed to prevent a further consideration of registration.	Thank you for your opinion	
8	2011/10/10	Trade union
European Trade Union Confederation
Belgium	ETUC supports the identification of Lead dipicrate as a SVHC.	Thank you for your support	
7	2011/10/10	Company
Spain	The substance does not meet the priority criteria (Article 58(3) REACH) for inclusion in Candidate List. The substance is not PBT nor vPvB. The substance has not a widespread use. The tonnage is very low (no European producer has been pre-registered nor registered because tonnage is well below 1.000 Kg/year).	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
					
6	2011/10/07	International NGO
ChemSec
Sweden	We fully support the inclusion of this substance into the candidate list.	Thank you for your support	
5	2011/10/07	Industry or trade association
COMINROC
Spain	Comments are made from a user point of view:
Lead dipicrate is a substance that:
- Is commonly called as lead primary explosives.
- Is a lead compound having explosive properties and applications.
- Is incorporated in explosive items and the final products (detonators, primers, etc).
As far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
4	2011/10/07	Industry or trade association
ANEFA
Spain	Comments are made from a user point of view:
Lead dipicrate is a substance that:
- Is commonly called as lead primary explosives.
- Is a lead compound having explosive properties and applications.
- Is incorporated in explosive items and the final products (detonators, primers, etc).
As far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
3	2011/10/07	Industry or trade association
Federación de Áridos
Spain	Comments are made from a user point of view:
Lead dipicrate is a substance that:
- Is commonly called as lead primary explosives.
- Is a lead compound having explosive properties and applications.
- Is incorporated in explosive items and the final products (detonators, primers, etc).
As far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations. 	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
2	2011/10/06	International NGO
WWF European Policy Office
Belgium	WWF supports the inclusion of this substance in the candidate list owing to its classification as toxic to reproduction category 1 A.	Thank you for your support	
1	2011/10/06	Member State
Norway	The Norwegian CA supports that lead dipicrate should be identified as a substance of very high concern and should be included in the Candidate List.	Thank you for your support	

Specific comments on the justification
Number	Date	Submitted by (name, Organisation/MSCA)	Comment	Response	
30	2011/10/13	Industry or trade association
Mineral Products Association
United Kingdom	The quantities involved in Lead Dipicrate use are very small, a few tons per year for the total explosives industry.

As explosives users, since Lead Dipicrate is hermetically closed into detonators, primers, etc, there is no health risk to workers in quarries. Additionally by necessity workers are kept well clear of blasting operations.

No quantity of Lead remains after use because of the high temperatures and huge pressures that occur during the detonation processes in quarries. As primary explosives, Lead Dipicrate explodes in the initial moment of blasting (primary explosion) initiating the chemical and thermal reaction of the explosive used in the operation (secondary explosion); in both explosions, Lead Dipicrate totally reacts and disappears in an irreversible way. In that reaction, Lead and Nitrogen Oxides are produced in infinitesimal amount due to the fact that the quantity of lead is lower than a gram by blast hole. These few grams of oxides are disseminated within the tons of blasted rocks.

As mentioned above, as far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for the safety of workers due to misfires during blasting operations that create missed holes with undetonated explosive. These missed holes are one of the worst incidents that can occur during blasting operations leading to unacceptable risks for workers. Indeed such incidents are notifiable to the UK Health and Safety Executive under the UK Reporting of Injuries, Diseases and Dangerous Occurrences Regulations. Finally, these substances have not a widespread dispersive use.

As a consequence of the above mentioned reasons, based on the criteria formulated in Article 58 (3) REACH and the corresponding score system prioritization, the inclusion of Lead Dipicrate compounds in the Candidate List (article 58) is not justified. This substance does not meet the criteria because:
-	it is not a PBT nor vPvB substances.
-	it does not have wide spread dispersive uses.
-	it’s production volume in Europe is very small.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
29	2011/10/13	Member State
Ireland	Lead dipicrate is classified as Repr. 1A according to Regulation EC No. 1272/2008, and therefore the Irish CA agrees that the substance meets the criteria for identification as an SVHC in accordance with Article 57 (c) of REACH. 

We note that a specific concentration limit (Repr. 2 H361f; C≥2.5%, which may need to be corrected in a future ATP to CLP) applies for the lead entry in Annex VI and therefore any corrected specific concentration limit should be carried forward to the candidate list entry for lead dipicrate.	Thank you for your opinion. We noticed that the concentration limit for the toxicity to reproduction was not correct and this will be amended.	
19	2011/10/13	Member State
Sweden	The Swedish CA agrees that lead dipicrate, being classified as Repr. 1A, meets the criteria according to Article 57(c) in REACH and is thus eligible for identification as a substance of very high concern.	Thank you for your opinion	
17	2011/10/12	Company
DynITEC GmbH
Germany	It is DynITEC’s firm conviction that it is not justified to classify Lead Picrate as a substance of very high concern (SVHC). 	Lead dipicrate is classified as toxic for reproduction 1A according to Annex VI, part 3, Table 3.1 of Regulation (EC) No 1272/2008. Consequently the substance fulfils the criteria of Article 57(c) of the REACH Regulation and can be identified as a Substance of Very High Concern and included on the Candidate List following the procedure set out in article 59 of the same regulation.
In addition we thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
			See also:
Comment 17 attachment (Comments on Annex15_Lead Picrate_DynITEC.pdf).pdf		
14	2011/10/12	Industry or trade association
Gremi d'Àrids de Catalunya
Spain	- The quantities involved in Lead dipicrate uses are very small, a few tons per year for the total explosives industry

- As explosives users, since Lead dipicrate is hermetically closed into detonators, primers, etc.), no risk for health exists for workers in quarries

- No quantity of Lead dipicrate remains after use because of the high temperatures and huge pressures that occurs in the industrial use (detonation processes in quarries, mining, civil works, etc). As primary explosives, Lead dipicrate explodes in the initial moment of blasting (primary explosion) initiating the chemical and thermal reaction of the explosive used in the operation (secondary explosion); In both explosions, Lead dipicrate totally react and disappear in an irreversible way, producing the expansive energy. In that reaction, Lead and Nitrogen Oxides are produced in infinitesimal amount due to the fact that the quantity of lead is lower than a gram by blast hole. These few grams oxides are disseminated within the tons of blasted rocks.

- As mentioned above, as far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations creating missed holes with undetonated explosive. These missed holes are one of the worst incidents that con occur during blasting operations leading to unacceptable risks for workers. Finally, these substances have not a widespread dispersive use.

- As a consequence of the above mentioned reasons, based on the criteria formulated in Article 58 (3) REACH and the corresponding score system prioritization, the inclusion of Lead dipicrate compounds in the Candidate List (article 58) is not justified. This substances do not meet the criteria because:
-	They are not PBT nor vPvB substances.
-	They have not wide spread dispersive uses.
-	Their production volumes in Europe are very small.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
11	2011/10/11	Individual
Belgium	- The quantities involved in Lead diazide uses are very small, a few tons per year for the total explosives industry

- As explosives users, since Lead diazide is hermetically closed into detonators, primers, etc.), no risk for health exists for workers in quarries
- No quantity of Lead diazide remains after use because of the high temperatures and huge pressures that occurs in the industrial use (detonation processes in quarries, mining, civil works, etc). As primary explosives, Lead diazide explodes in the initial moment of blasting (primary explosion) initiating the chemical and thermal reaction of the explosive used in the operation (secondary explosion); In both explosions, Lead diazide totally react and disappear in an irreversible way, producing the expansive energy. In that reaction, Lead and Nitrogen Oxides are produced in infinitesimal amount due to the fact that the quantity of lead is lower than a gram by blast hole. These few grams oxides are disseminated within the tons of blasted rocks.

- As mentioned above, as far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations creating missed holes with undetonated explosive. These missed holes are one of the worst incidents that con occur during blasting operations leading to unacceptable risks for workers. Finally, these substances have not a widespread dispersive use.

- As a consequence of the above mentioned reasons, based on the criteria formulated in Article 58 (3) REACH and the corresponding score system prioritization, the inclusion of Lead diazide compounds in the Candidate List (article 58) is not justified. This substances do not meet the criteria because:
-	They are not PBT nor vPvB substances.
-	They have not wide spread dispersive uses.
-	Their production volumes in Europe are very small.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
5	2011/10/07	Industry or trade association
COMINROC
Spain	See below in part II	See response in part II	
4	2011/10/07	Industry or trade association
ANEFA
Spain	See below in part II	See response in part II	
3	2011/10/07	Industry or trade association
Federación de Áridos
Spain	See below in part II	See response in part II	

PART II: Comments and responses to comments on uses, exposures, alternatives and risks

Specific comments on use, exposure, alternatives and risks
Number	Date	Submitted by (name, Organisation/MSCA)	Comment	Response	
30	2011/10/13	Industry or trade association
Mineral Products Association
United Kingdom	The quantities involved in Lead Dipicrate use are very small, a few tons per year for the total explosives industry.

As explosives users, since Lead Dipicrate is hermetically closed into detonators, primers, etc, there is no health risk to workers in quarries. Additionally by necessity workers are kept well clear of blasting operations.

No quantity of Lead remains after use because of the high temperatures and huge pressures that occur during the detonation processes in quarries. As primary explosives, Lead Dipicrate explodes in the initial moment of blasting (primary explosion) initiating the chemical and thermal reaction of the explosive used in the operation (secondary explosion); in both explosions, Lead Dipicrate totally reacts and disappears in an irreversible way. In that reaction, Lead and Nitrogen Oxides are produced in infinitesimal amount due to the fact that the quantity of lead is lower than a gram by blast hole. These few grams of oxides are disseminated within the tons of blasted rocks.

As mentioned above, as far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for the safety of workers due to misfires during blasting operations that create missed holes with undetonated explosive. These missed holes are one of the worst incidents that can occur during blasting operations leading to unacceptable risks for workers. Indeed such incidents are notifiable to the UK Health and Safety Executive under the UK Reporting of Injuries, Diseases and Dangerous Occurrences Regulations. Finally, these substances have not a widespread dispersive use.

As a consequence of the above mentioned reasons, based on the criteria formulated in Article 58 (3) REACH and the corresponding score system prioritization, the inclusion of Lead Dipicrate compounds in the Candidate List (article 58) is not justified. This substance does not meet the criteria because:
-	it is not a PBT nor vPvB substances.
-	it does not have wide spread dispersive uses.
-	it’s production volume in Europe is very small.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
27	2011/10/13	Industry or trade association
ATIC - Associação Técnica da Indústria de Cimento
Portugal	- The quantities involved in Lead dipicrate uses are very small, a few tons per year for the total explosives industry

- As explosives users, since Lead dipicrate is hermetically closed into detonators, primers, etc.), no risk for health exists for workers in quarries

- No quantity of Lead dipicrate remains after use because of the high temperatures and huge pressures that occurs in the industrial use (detonation processes in quarries, mining, civil works, etc). As primary explosive, Lead dipicrate explodes in the initial moment of blasting (primary explosion) initiating the chemical and thermal reaction of the explosive used in the operation (secondary explosion); In both explosions, Lead dipicrate totally reacts and disappears in an irreversible way, producing the expansive energy. In that reaction, Lead and Nitrogen Oxides are produced in infinitesimal amount due to the fact that the quantity of lead is lower than a gram by blast hole. These few grams oxides are disseminated within the tons of blasted rocks.

- As mentioned above, as far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations creating missed holes with undetonated explosive. These missed holes are one of the worst incidents that con occur during blasting operations leading to unacceptable risks for workers. Finally, this substance has not a widespread dispersive use.

- As a consequence of the above mentioned reasons, based on the criteria formulated in Article 58 (3) REACH and the corresponding score system prioritization, the inclusion of Lead dipicrate compounds in the Candidate List (article 58) is not justified. This substance does not meet the criteria because:
-	It´s not a PBT nor a vPvB substance.
-	It has not  wide spread dispersive uses.
-	Its production volumes in Europe are very small.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
26	2011/10/13	Industry or trade association
ATIC - Associação Técnica da Indústria de Cimento
Portugal	- The quantities involved in Lead dipicrate uses are very small, a few tons per year for the total explosives industry

- As explosives users, since Lead dipicrate is hermetically closed into detonators, primers, etc.), no risk for health exists for workers in quarries

- No quantity of Lead dipicrate remains after use because of the high temperatures and huge pressures that occurs in the industrial use (detonation processes in quarries, mining, civil works, etc). As primary explosive, Lead dipicrate xplodes in the initial moment of blasting (primary explosion) initiating the chemical and thermal reaction of the explosive used in the operation (secondary explosion); In both explosions, Lead dipicrate totally reacts and disappears in an irreversible way, producing the expansive energy. In that reaction, Lead and Nitrogen Oxides are produced in infinitesimal amount due to the fact that the quantity of lead is lower than a gram by blast hole. These few grams oxides are disseminated within the tons of blasted rocks.

- As mentioned above, as far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations creating missed holes with undetonated explosive. These missed holes are one of the worst incidents that con occur during blasting operations leading to unacceptable risks for workers. Finally, this substance has not a widespread dispersive use.

- As a consequence of the above mentioned reasons, based on the criteria formulated in Article 58 (3) REACH and the corresponding score system prioritization, the inclusion of Lead dipicrate compounds in the Candidate List (article 58) is not justified. This substance does not meet the criteria because:
-	It's not a PBT nor a vPvB substance.
-	It has not wide spread dispersive uses.
-	Its production volumes in Europe are very small.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
25	2011/10/13	Company
Germany	See explanations on Lead Styphnate and Lead diazide which can be transferred to Lead dipicrate as well when looking on military uses.	See RCOM for lead styphnate and lead diazide	
22	2011/10/13	Industry or trade association
GIFAS
France	please refer to attachment (2 pages)	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
			See also:
Comment 22 attachment (20033_2011_Echa_SVHCconsultation.pdf).pdf		
17	2011/10/12	Company
DynITEC GmbH
Germany	see uploaded document	Lead dipicrate is classified as toxic for reproduction 1A according to Annex VI, part 3, Table 3.1 of Regulation (EC) No 1272/2008. Consequently the substance fulfils the criteria of Article 57(c) of the REACH Regulation and can be identified as a Substance of Very High Concern and included on the Candidate List following the procedure set out in article 59 of the same regulation.
In addition we thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
			See also:
Comment 17 attachment (Comments on Annex15_Lead Picrate_DynITEC.pdf).pdf		
14	2011/10/12	Industry or trade association
Gremi d'Àrids de Catalunya
Spain	- The quantities involved in Lead dipicrate uses are very small, a few tons per year for the total explosives industry

- As explosives users, since Lead dipicrate is hermetically closed into detonators, primers, etc.), no risk for health exists for workers in quarries

- No quantity of Lead dipicrate remains after use because of the high temperatures and huge pressures that occurs in the industrial use (detonation processes in quarries, mining, civil works, etc). As primary explosives, Lead dipicrate explodes in the initial moment of blasting (primary explosion) initiating the chemical and thermal reaction of the explosive used in the operation (secondary explosion); In both explosions, Lead dipicrate totally react and disappear in an irreversible way, producing the expansive energy. In that reaction, Lead and Nitrogen Oxides are produced in infinitesimal amount due to the fact that the quantity of lead is lower than a gram by blast hole. These few grams oxides are disseminated within the tons of blasted rocks.

- As mentioned above, as far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations creating missed holes with undetonated explosive. These missed holes are one of the worst incidents that con occur during blasting operations leading to unacceptable risks for workers. Finally, these substances have not a widespread dispersive use.

- As a consequence of the above mentioned reasons, based on the criteria formulated in Article 58 (3) REACH and the corresponding score system prioritization, the inclusion of Lead dipicrate compounds in the Candidate List (article 58) is not justified. This substances do not meet the criteria because:
-	They are not PBT nor vPvB substances.
-	They have not wide spread dispersive uses.
-	Their production volumes in Europe are very small.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
12	2011/10/11	European institution
Laboratorio Oficial Madariaga (LOM)
Spain	•	From the contributions of Annex XV, the necessity to identify these lead explosive compounds as substance meeting the criteria of Article 57 (c) of Regulation (EC) 1907/2006 (REACH) is not strictly necessary.
•	The replacement of Explosive Lead Compounds for another similar product is very cost-intensive and requires a lot of research, development, and a lot of safety testing and formal certification according to other European legal requirements of Directive 93/15/ECC.	Lead dipicrate is classified as toxic for reproduction 1A according to Annex VI, part 3, Table 3.1 of Regulation (EC) No 1272/2008. Consequently the substance fulfils the criteria of Article 57(c) of the REACH Regulation and can be identified as a Substance of Very High Concern and included on the Candidate List following the procedure set out in article 59 of the same regulation.
In addition we thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
			See also:
Comment 12 attachment (INFORME LOM Annexe XV_eng.doc).doc		
11	2011/10/11	Individual
Belgium	- The quantities involved in Lead diazide uses are very small, a few tons per year for the total explosives industry

- As explosives users, since Lead diazide is hermetically closed into detonators, primers, etc.), no risk for health exists for workers in quarries

- No quantity of Lead diazide remains after use because of the high temperatures and huge pressures that occurs in the industrial use (detonation processes in quarries, mining, civil works, etc). As primary explosives, Lead diazide explodes in the initial moment of blasting (primary explosion) initiating the chemical and thermal reaction of the explosive used in the operation (secondary explosion); In both explosions, Lead diazide totally react and disappear in an irreversible way, producing the expansive energy. In that reaction, Lead and Nitrogen Oxides are produced in infinitesimal amount due to the fact that the quantity of lead is lower than a gram by blast hole. These few grams oxides are disseminated within the tons of blasted rocks.

- As mentioned above, as far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations creating missed holes with undetonated explosive. These missed holes are one of the worst incidents that con occur during blasting operations leading to unacceptable risks for workers. Finally, these substances have not a widespread dispersive use.

- As a consequence of the above mentioned reasons, based on the criteria formulated in Article 58 (3) REACH and the corresponding score system prioritization, the inclusion of Lead diazide compounds in the Candidate List (article 58) is not justified. This substances do not meet the criteria because:
-	They are not PBT nor vPvB substances.
-	They have not wide spread dispersive uses.
-	Their production volumes in Europe are very small.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
9	2011/10/11	Industry or trade association
TEDAE
Spain	This substance has not suitable safer alternative chemicals of equivalent performance and quality. 	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
			See also:
Comment 9 attachment (ECHA comments.doc).doc		
7	2011/10/10	Company
Spain	The substance is encapsulated inside a closed container. The substance totally decomposed during use. Lead dipicrate is only used as an explosive material and therefore the substance detonate and produce high pressure and temperature. No quantity of substance remains after detonation. No exposure to environment.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
					
5	2011/10/07	Industry or trade association
COMINROC
Spain	- The quantities involved in Lead dipicrate uses are very small, a few tons per year for the total explosives industry

- As explosives users, since Lead dipicrate is hermetically closed into detonators, primers, etc.), no risk for health exists for workers in quarries

- No quantity of Lead dipicrate remains after use because of the high temperatures and huge pressures that occurs in the industrial use (detonation processes in quarries, mining, civil works, etc). As primary explosives, Lead dipicrate explodes in the initial moment of blasting (primary explosion) initiating the chemical and thermal reaction of the explosive used in the operation (secondary explosion); In both explosions, Lead dipicrate totally react and disappear in an irreversible way, producing the expansive energy. In that reaction, Lead and Nitrogen Oxides are produced in infinitesimal amount due to the fact that the quantity of lead is lower than a gram by blast hole. These few grams oxides are disseminated within the tons of blasted rocks.

- As mentioned above, as far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations creating missed holes with undetonated explosive. These missed holes are one of the worst incidents that con occur during blasting operations leading to unacceptable risks for workers
Finally, these substances have not a widespread dispersive use.

- As a consequence of the above mentioned reasons, based on the criteria formulated in Article 58 (3) REACH and the corresponding score system prioritization, the inclusion of Lead dipicrate compounds in the Candidate List (article 58) is not justified. This substances do not meet the criteria because:
-	They are not PBT nor vPvB substances.
-	They have not wide spread dispersive uses.
-	Their production volumes in Europe are very small.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
4	2011/10/07	Industry or trade association
ANEFA
Spain	- The quantities involved in Lead dipicrate uses are very small, a few tons per year for the total explosives industry

- As explosives users, since Lead dipicrate is hermetically closed into detonators, primers, etc.), no risk for health exists for workers in quarries

- No quantity of Lead dipicrate remains after use because of the high temperatures and huge pressures that occurs in the industrial use (detonation processes in quarries, mining, civil works, etc). As primary explosives, Lead dipicrate explodes in the initial moment of blasting (primary explosion) initiating the chemical and thermal reaction of the explosive used in the operation (secondary explosion); In both explosions, Lead dipicrate totally react and disappear in an irreversible way, producing the expansive energy. In that reaction, Lead and Nitrogen Oxides are produced in infinitesimal amount due to the fact that the quantity of lead is lower than a gram by blast hole. These few grams oxides are disseminated within the tons of blasted rocks.

- As mentioned above, as far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations creating missed holes with undetonated explosive. These missed holes are one of the worst incidents that con occur during blasting operations leading to unacceptable risks for workers
Finally, these substances have not a widespread dispersive use.

- As a consequence of the above mentioned reasons, based on the criteria formulated in Article 58 (3) REACH and the corresponding score system prioritization, the inclusion of Lead dipicrate compounds in the Candidate List (article 58) is not justified. This substances do not meet the criteria because:
-	They are not PBT nor vPvB substances.
-	They have not wide spread dispersive uses.
-	Their production volumes in Europe are very small.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	
3	2011/10/07	Industry or trade association
Federación de Áridos
Spain	- The quantities involved in Lead dipicrate uses are very small, a few tons per year for the total explosives industry

- As explosives users, since Lead dipicrate is hermetically closed into detonators, primers, etc.), no risk for health exists for workers in quarries

- No quantity of Lead dipicrate remains after use because of the high temperatures and huge pressures that occurs in the industrial use (detonation processes in quarries, mining, civil works, etc). As primary explosives, Lead dipicrate explodes in the initial moment of blasting (primary explosion) initiating the chemical and thermal reaction of the explosive used in the operation (secondary explosion); In both explosions, Lead dipicrate totally react and disappear in an irreversible way, producing the expansive energy. In that reaction, Lead and Nitrogen Oxides are produced in infinitesimal amount due to the fact that the quantity of lead is lower than a gram by blast hole. These few grams oxides are disseminated within the tons of blasted rocks.

- As mentioned above, as far as we know, no substitution is possible with the same level of safety when blasting. Substitution can cause high risk for safety of workers due to failures in blasting operations creating missed holes with undetonated explosive. These missed holes are one of the worst incidents that con occur during blasting operations leading to unacceptable risks for workers
Finally, these substances have not a widespread dispersive use.

- As a consequence of the above mentioned reasons, based on the criteria formulated in Article 58 (3) REACH and the corresponding score system prioritization, the inclusion of Lead dipicrate compounds in the Candidate List (article 58) is not justified. This substances do not meet the criteria because:
-	They are not PBT nor vPvB substances.
-	They have not wide spread dispersive uses.
-	Their production volumes in Europe are very small.	Thank you for the submitted information. Provided that the substance will be identified as SVHC, this information may, where relevant, be considered at later stages of the risk management process.	

Attachments

Comment number	Public attachment	
9	
Comment 9 attachment (ECHA comments.doc).doc	
12	
Comment 12 attachment (INFORME LOM Annexe XV_eng.doc).doc	
15	
Comment 15 attachment (Comments on Annex XV dossier - Lead picrate.pdf).pdf	
17	
Comment 17 attachment (Comments on Annex15_Lead Picrate_DynITEC.pdf).pdf	
22	
Comment 22 attachment (20033_2011_Echa_SVHCconsultation.pdf).pdf