Requirements for premises for storing precursors in Ukraine

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License for operations with precursor chemicals in Ukraine
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The issue of storage facilities is extremely important in the process of obtaining a Precursor Chemical License. Space requirements vary depending on the type of precursors that will be stored there and many other factors.

We will talk about the case from our practice, which will demonstrate the algorithm of actions when choosing the precursor and psychotropic substances storage facilities.

You may also like: Common Mistakes Made When Applying For A Precursor Chemical License

Fact situation: Basic questions about the precursor storage facilities 

In February 2020, we were contacted by a Client, a dairy plant from Sumy region, who needed precursors for testing the products and, accordingly, a license to deal in them. The Client was interested in the following questions:

  • What are the basic requirements for a precursor storage facilities, including its minimum area?
  • What main difficulties may arise when applying for a licence for dealing in narcotic and psychotropic substances?

To answer the question about the requirements for storage facilities, we first need to determine what kind of precursors the Client will deal in. After all, there are different storage facilities requirements for different types of precursors.

It turned out that the Client needed precursors from list 2 in Table 4. They’re mainly used in the food industry.

Read also: Import Of Precursors: Permit Or License?

Legal assistance: Requirements for precursor storage facilities in the food industry

When selecting the storage facilities for precursors from list 2 in table 4, two main criteria should be followed: fire safety and burglary protection. Which means:

  • The storage facilities shall have capital external walls. The interior walls and floor should be made of non-combustible materials. In other words, the use of drywall partitions, wooden floors and wallpaper is strictly prohibited.
  • The walls of the precursor storage facilities shall not be adjacent to the ownerless premises, as well as to the premises that belong to other enterprises.

As we can see, along with the characteristics of the building materials used for precursor storage facilities, one of the key roles has their location.

Requirements for windows and doors of the storage premises:

  • Entrance doors must be well fitted to the door frame and have at least two mortise locks, that are not self-locking;
  • The windows must be fitted with metal grilles. Decorative grids or blinds can be used, as long as they are as strong as the usual grid.

Requirements for the storage facilities equipment:

  • Existing safes or metal cabinets attached to the floor (can be wall-mounted);
  • There must be technical means of security (alarm);
  • Door locks shall be installed on the breach/opening, and walls are installed on the breakage and impact.

Please note! There are no requirements for minimum or maximum storage space for precursors.

The space requirements for precursor-related activities will depend not only on a specific list in a specific table in the List, but also on the type of facility (medical facility, veterinary facility, scientific institution, etc.).

You may also like: Maximum Number Of Persons Allowed To Work With Precursors

What common difficulties may arise when applying for a Precursor Chemical Licence?

The main difficulties in the licensing process, apart from the choice of the storage facilities and personnel, are related to obtaining a certain list of certificates in advance.

For example, even before applying for the license, it is necessary to obtain the permission from the National Police to use the premises. And it should be the Permission, not a certificate, as many may think.

Certificates from a narcologist must be issued by a state or municipal institution. Of course, it would be faster to use the services of private clinics. But for the purposes of obtaining a Precursor Chemical License, certificates from private clinics would not be suitable.

And if you run ahead - even before getting the abovementioned permission of the National Police, you should see what activities are specified in the company’s charter. If it does not specify activities related to precursors, there is a high probability that there will be misunderstandings with the issuing authority when obtaining the permission.

Thus, the better the preparatory stage is thought out, the less misunderstandings there are in the process of obtaining the license.

Remember, if you make everything right at once and get exactly those certificates, which are required by the licensing regulations, you can avoid such difficulties.

If you plan to start a business related to the use of precursors, you can get all the necessary starting information here.

And if you have any questions about the precursor storage facilities or want to make sure you are ready to start, don’t hesitate to call us.

Publication date: 06/04/2020
Marina Losenko

About author

Name: Marina Losenko

Position: Associate

Education: National Aviation University

Knowledge of languages: Russian, Ukrainian

Email: [email protected]

Marina Losenko is a lawyer of the company, specializing in corporate law and intellectual property law.

Marina has extensive experience of registration and dissolution of enterprises, charities and non-governmental organizations, representative offices of foreign companies as well as formalization of changes to registration information of the entities.

For quite a long time she has been working in the field of licensing and obtained licenses for different types of business activities including sale of medicines (license for activities of drugstores); wholesale of pesticides and agrochemicals; activities with scrap; activities with hazardous wastes; operations with scrap of precious metals and gemstones; private security services; transportation; tour services; use of redio frequency resource; IPTV services, etc.

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