Change to legislation imposes a new duty on chemical ordering

The Control of Poisons and Explosives Precursors Regulations 2023 introduced new substances to the lists of regulated explosives precursors and poisons.

Offences relating to the acquisition, importation, supply, possession and use of these substances were added and are effective from 1 October 2023.

From this date, businesses supplying regulated explosives precursors to professional users have been required to take additional steps to verify the legitimacy of the professional user or business.

One of the required steps is to obtain a form of photographic identification of the individual making the purchase.

We have seen one instance of a supplier emailing a form direct to the PI responsible for the order requesting the information, but we don’t know, at this early stage, how individual suppliers will gather this information.

Whilst we will endeavour to work with Procurement colleagues and suppliers to find a solution which minimises the day-to-day impact on individuals, this is ultimately an individual supplier decision on how they want to fulfil their duties under these Regulations.

If you receive a form, you will be required to complete and return it to the supplier. Photographic ID can be provided in a number of forms, but in order to protect your personal data as far as possible, we suggest that you complete the form then scan it with your university ID badge positioned somewhere on the page, then email the resulting PDF back to the supplier (see the example in the right-hand column)

These changes only apply to the following substances above the stated concentrations, but some are in quite widespread and common use:-

• ammonium nitrate (above 16% N)
• hexamine
• hydrochloric acid (above 10% w/w)
• hydrogen peroxide (above 12% w/w)
• nitromethane (above 30% w/w)
• nitric acid (above 3% w/w)
• phosphoric acid (above 30% w/w)
• potassium chlorate (above 40% w/w)
• potassium perchlorate (above 40% w/w)
• sodium chlorate (above 40% w/w)
• sodium perchlorate (above 40% w/w)
• sulfuric acid (above 15% w/w)