Regolamento (UE) n. 649/2012 (PIC)

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Autore: R.Bigoni

La Convenzione di Rotterdam (Convenzione PIC – Prior Informed Consent) è entrata in vigore nel 2004, regola le esportazioni e le importazioni di alcuni prodotti chimici e pesticidi pericolosi ed è basata sul principio fondamentale del consenso informato preliminare: l’esportazione di prodotti chimici vietati o soggetti a rigorose restrizioni può avvenire solo con il consenso preliminare informato da parte del Paese importatore. Promuove la condivisione delle responsabilità e la collaborazione tra le Parti interessate agli scambi internazionali di prodotti chimici pericolosi, con l’obiettivo di proteggere la salute umana e l’ambiente.

Le Parti notificano al Segretariato della Convenzione tutti gli atti normativi definitivi che vietano o impongono rigorose limitazioni a un prodotto che rientra nell’ambito della Convenzione.

Le informazioni trasmesse sono valutate dal Comitato di esame per i prodotti chimici (Chemical Review Committee) che elabora un documento di orientamento da sottoporre alla Conferenza delle Parti (COP). Se la COP decide di inserire il prodotto all’interno della procedura PIC, le Parti esportatrici e importatrici sono tenute a garantire il rispetto delle decisioni assunte.

La Convenzione è stata ratificata da 161 Paesi (Parti), tra cui l’Italia (con Legge 11 luglio 2002 n. 176), ed attualmente include, nell’allegato III, 52 sostanze soggette alla procedura PIC, tra le quali 35 pesticidi e 16 sostanze chimiche industriali e 1 sostanza di categoria pesticida e chimica industriale.

All’interno dell’Unione Europea la Convenzione di Rotterdam è stata attuata dal Regolamento (CE) n. 649/2012 del Parlamento Europeo e del Consiglio del 4 luglio 2012 (“Regolamento PIC”). Tale Regolamento conferma l’impegno dell’Unione Europea a garantire un controllo adeguato degli scambi dei prodotti chimici su scala mondiale per proteggere la salute umana e l’ambiente oltre i confini dell’Unione europea. Per motivi di chiarezza e di coerenza con il resto della legislazione pertinente dell’Unione sono introdotte o chiarite alcune definizioni e armonizzata la terminologia con quella utilizzata, dal regolamento (CE) n. 1907/2006 del Parlamento europeo e del Consiglio, del 18 dicembre 2006 (REACH), e, dal regolamento (CE) n. 1272/2008 del Parlamento europeo e del Consiglio, del 16 dicembre 2008 (CLP). Per la partecipazione dell’Unione Europea alla convenzione, è essenziale disporre di un unico referente che consenta all’Unione di interagire con il segretariato della convenzione (il «segretariato»), le altre parti della convenzione e altri paesi ed è stato individuato nella Commissione il referente in tal senso.

Per garantire un coordinamento e una gestione efficaci degli aspetti tecnici e amministrativi del Regolamento (CE) n. 649/2012 a livello di Unione si è ritenuto che gli Stati membri e l’Agenzia europea per le sostanze chimiche («l’agenzia», ECHA), istituita dal regolamento (CE) n. 1907/2006, dispongono di competenza ed esperienza nell’attuazione della legislazione dell’Unione sulle sostanze chimiche e di accordi internazionali in tale settore. Occorre pertanto che gli Stati membri e l’agenzia svolgano le funzioni inerenti agli aspetti amministrativi, tecnici e scientifici dell’attuazione della convenzione tramite lo stesso regolamento e dello scambio di informazioni.

Gli obiettivi del Regolamento sono:
a) attuare la convenzione di Rotterdam sulla procedura di assenso preliminare in conoscenza di causa per talune sostanze chimiche e pesticidi pericolosi nel commercio internazionale (la «convenzione»);
b) promuovere la condivisione delle responsabilità e la collaborazione nel settore dei movimenti internazionali di sostanze chimiche pericolose al fine di tutelare la salute umana e l’ambiente da potenziali danni;
c) contribuire all’uso ecocompatibile di sostanze chimiche pericolose.

Articolo 2 – Ambito di applicazione

  1. Il Regolamento si applica a:
    a) determinate sostanze chimiche pericolose soggette alla procedura dell’assenso preliminare in conoscenza di causa ai sensi della convenzione (la «procedura PIC»);
    b) determinate sostanze chimiche pericolose vietate o soggette a rigorose restrizioni all’interno dell’Unione o di uno Stato membro;
    c) le sostanze chimiche esportate, per quanto concerne la classificazione, l’etichettatura e l’imballaggio.
  2. Il Regolamento non si applica a:
    a) alle droghe e alle sostanze psicotrope [v. Regolamento (CE) n. 111/2005 del Consiglio, del 22 dicembre 2004].
    b) ai materiali e alle sostanze radioattive [v. direttiva 96/29/Euratom del Consiglio, del 13 maggio 1996].
    c) ai rifiuti [v. direttiva 2008/98/CE del Parlamento europeo e del Consiglio, del 19 novembre 2008].
    d) alle armi chimiche [v. Regolamento (CE) n. 428/2009 del Consiglio, del 5 maggio 2009].
    e) agli alimenti e agli additivi alimentari [v. Regolamento (CE) n. 882/2004 del Parlamento europeo e del Consiglio, del 29 aprile 2004].
    f) ai mangimi [v. Regolamento (CE) n. 178/2002 del Parlamento europeo e del Consiglio, del 28 gennaio 2002].
    g) agli organismi geneticamente modificati [v. Direttiva 2001/18/CE del Parlamento europeo e del Consiglio, del 12 marzo 2001].
    h) ai prodotti medicinali per uso umano [v. Direttiva 2001/83/CE del Parlamento europeo e del Consiglio, del 6 novembre 2001] e ai prodotti medicinali veterinari [v. Direttiva 2001/82/CE del Parlamento europeo e del Consiglio, del 6 novembre 2001], fatto salvo l’articolo 3, paragrafo 5, lettera b), dello stesso regolamento.
  3. Il Regolamento non si applica alle sostanze chimiche esportate per fini di ricerca o analisi in quantità che verosimilmente non producono effetti sulla salute umana o sull’ambiente e, in ogni caso, in quantità non superiore a 10 kg da ogni esportatore a ogni paese importatore per anno civile.

Articolo 3 – Definizioni


Nel suo ambito applicativo, il Regolamento fornisce le seguenti definizioni (parecchie derivate o collegabili a REACH e CLP) :


1) «sostanza chimica», una sostanza presente allo stato puro o contenuta in una miscela, o una miscela, fabbricata o ricavata dalla natura, a esclusione degli organismi viventi, che
rientra in una delle seguenti categorie:
a) pesticidi,
b) sostanze chimiche industriali.
2) «sostanza», qualsiasi elemento chimico e i suoi composti secondo la definizione di cui all’articolo 3, punto 1, del regolamento (CE) n. 1907/2006 [REACH];
3) «miscela», una miscela o una soluzione secondo la definizione di cui all’articolo 2, punto 8, del regolamento (CE) n. 1272/2008 [CLP];
4) «articolo», un prodotto finito che contiene o include una sostanza chimica il cui impiego, è vietato o soggetto a rigorose restrizioni in base alla legislazione dell’Unione se tale prodotto non rientri nei punti 2 o 3; [per una definizione più rigorosa di articolo: articolo 3 del regolamento REACH: un articolo è un oggetto a cui sono dati durante la produzione una forma, una superficie o un disegno particolari che ne determinano la funzione in misura maggiore della sua composizione chimica.
5) «pesticidi», le sostanze chimiche appartenenti a una delle due seguenti sottocategorie:
a) pesticidi utilizzati come prodotti fitosanitari di cui al regolamento (CE) n. 1107/2009 del Parlamento europeo e del Consiglio, del 21 ottobre 2009, relativo all’immissione sul mercato dei prodotti fitosanitari;
b) altri pesticidi, quali:
I) i biocidi disciplinati dalla direttiva 98/8/CE del Parlamento europeo e del Consiglio, del 16 febbraio 1998, relativa all’immissione sul mercato dei biocidi;
II) i disinfettanti, gli insetticidi e gli antiparassitari di cui alle direttive 2001/82/CE e 2001/83/CE.
6) «sostanze chimiche industriali», le sostanze chimiche appartenenti a una delle due seguenti sottocategorie:
a) sostanze chimiche a uso professionale (qui compare una differenza rispetto a REACH e CLP che prevedono tre categorie di utilizzatori o Downstream User: Industriale, Professionale (Artigiani, Professionisti) e Consumatore finale o l’utente privato che acquista il prodotto presso le rivendite al consumo.
b) sostanze chimiche destinate all’uso da parte del consumatore finale;
7) «sostanza chimica soggetta a obbligo di notifica di esportazione», qualsiasi sostanza chimica, vietata o soggetta a rigorose restrizioni nell’ambito dell’Unione in riferimento a una o più categorie o sottocategorie, e qualsiasi sostanza chimica elencata nella parte 1 dell’allegato I, soggetta alla procedura PIC;
8) «sostanza chimica assoggettabile a notifica PIC», qualsiasi sostanza chimica vietata o soggetta a rigorose restrizioni nell’ambito dell’Unione o di uno Stato membro in riferimento a una o più categorie; elenco nella parte 2 dell’allegato I;
9) «sostanza chimica soggetta alla procedura PIC», qualsiasi sostanza chimica elencata nell’allegato III della convenzione e nella parte 3 dell’allegato I,del regolamento;
10) «sostanza chimica vietata», una delle seguenti sostanze: a) una sostanza chimica il cui impiego sia stato vietato nell’ambito di una o più categorie o sottocategorie mediante una misura di regolamentazione definitiva dell’Unione, per la protezione della salute umana o dell’ambiente;
b) una sostanza chimica cui sia stata rifiutata l’autorizzazione di primo impiego o per la quale siano stati disposti dall’industria il ritiro dal mercato dell’Unione o l’esclusione da ogni ulteriore fase del procedimento di notifica, registrazione o autorizzazione, quando è dimostrato che tale sostanza desta preoccupazioni per la salute umana o l’ambiente;
11) «sostanza chimica soggetta a rigorose restrizioni», una delle seguenti sostanze:
a) sostanza chimica il cui impiego sia stato vietato, teoricamente per qualsiasi uso, nell’ambito di una o più categorie o sottocategorie, mediante misura di regolamentazione definitiva dell’Unione, per la protezione della salute umana o dell’ambiente, ma il cui utilizzo sia ancora ammesso in alcuni casi particolari;
b) sostanza chimica cui sia stata rifiutata l’autorizzazione, teoricamente per qualsiasi uso, o che l’industria abbia ritirato dal mercato dell’Unione o da ogni ulteriore esame nell’ambito di una procedura di notifica, registrazione o autorizzazione, e ove sia dimostrato che tale sostanza desta preoccupazioni per la salute umana o l’ambiente;
L 201/64 Gazzetta ufficiale dell’Unione europea 27.7.2012 IT (1) GU L 309 del 24.11.2009, pag. 1.(2) GU L 123 del 24.4.1998, pag. 1.
12) «sostanza chimica vietata o soggetta a rigorose restrizioni in uno Stato membro», qualsiasi sostanza chimica che sia vietata o soggetta a rigorose restrizioni mediante una misura di regolamentazione definitiva di uno Stato membro;
13) «misura di regolamentazione definitiva», qualsiasi atto giuridicamente vincolante che abbia lo scopo di vietare o assoggettare a rigorose restrizioni una determinata sostanza chimica;
14) «formulato pesticida altamente pericoloso», qualsiasi sostanza chimica destinata a essere utilizzata come pesticida, che provoca gravi danni alla salute umana o all’ambiente, osservabili entro un breve lasso di tempo dopo un’applicazione unica o ripetuta, effettuata in modo conforme alle prescrizioni d’uso;
15) «territorio doganale dell’Unione», il territorio come definito all’articolo 3 del regolamento (CEE) n. 2913/92 del Consiglio, del 12 ottobre 1992, che istituisce un codice doganale comunitario;
16) «esportazione»:
a) l’esportazione permanente o temporanea di una sostanza chimica in base alle condizioni di cui all’articolo 28, paragrafo 2, TFUE (Trattato sul Funzionamento dell’ Unione Europea avente il seguente link: https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:12012E/TXT:IT:PDF )
b) la riesportazione, in condizioni diverse da quelle stipulate all’articolo 28, paragrafo 2, TFUE, di una sostanza chimica alla quale si applica una procedura doganale diversa dalla procedura di transito esterno dell’Unione per le merci che si spostano attraverso il territorio doganale dell’Unione;
17) «importazione», l’introduzione fisica nel territorio doganale dell’Unione di una sostanza chimica cui si applichi una procedura doganale diversa dalla procedura di transito esterno dell’Unione per le merci che si spostano attraverso il territorio doganale dell’Unione;
18) «esportatore», una delle seguenti persone fisiche o giuridiche:
a) la persona a nome della quale viene rilasciata una dichiarazione di esportazione, vale a dire la persona che, al momento dell’accettazione della dichiarazione, è titolare del contratto stipulato con il destinatario ubicato nel territorio di una parte o di un altro paese e che ha la facoltà di decidere che la sostanza chimica sia spedita fuori dal territorio doganale dell’Unione;
b) ove non sia stato concluso un contratto di esportazione o il titolare del contratto non agisca per proprio conto, la persona che ha la facoltà di decidere che la sostanza chimica sia spedita fuori dal territorio doganale dell’Unione;
c) ove il diritto di smaltimento della sostanza chimica spetti a una persona stabilita al di fuori dell’Unione in base al contratto cui fa riferimento l’esportazione, la parte contraente stabilita nel territorio dell’Unione;
19) «importatore», la persona fisica o giuridica che, al momento dell’importazione nel territorio doganale dell’Unione, è destinataria della sostanza chimica;
20) «parte della convenzione» o «parte», qualsiasi Stato od organizzazione di integrazione economica regionale che abbia accettato di essere vincolato/a dalla convenzione e per
il/la quale sia in vigore la convenzione;
21) «altro paese», un paese che non è una parte della convenzione;
22) «agenzia», l’Agenzia europea per le sostanze chimiche [ECHA] istituita dal regolamento (CE) n. 1907/2006;
23) «segretariato», il segretariato della convenzione, salvo altrimenti disposto nel presente regolamento.

Link per il Regolamento 649/2012: https://eur-lex.europa.eu/legal-content/it/TXT/PDF/?uri=CELEX:32012R0649&from=EN

Per l’Italia, le funzioni di Autorità Nazionale Competente per l’attuazione del regolamento PIC sono svolte dal Ministero della Salute, Direzione Generale della Prevenzione Sanitaria.

Aggiornato il 22 maggio 2020

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  116. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

  118. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

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  121. Right now it appears like Movable Type is the top blogging platform out there right now. (from what I’ve read) Is that what you’re using on your blog?

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  140. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

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  150. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

  151. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

  152. Right now it seems like Expression Engine is the preferred blogging platform out there right now. (from what I’ve read) Is that what you’re using on your blog?

  153. Wow that was strange. I just wrote an very long comment but after I clicked submit my comment didn’t show up. Grrrr… well I’m not writing all that over again. Anyway, just wanted to say excellent blog!

  155. Aw, this was an incredibly nice post. Taking the time and actual effort to produce a superb article… but what can I say… I put things off a whole lot and don’t manage to get nearly anything done.

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  160. Right now it appears like BlogEngine is the best blogging platform available right now. (from what I’ve read) Is that what you are using on your blog?

  161. Wow that was unusual. I just wrote an very long comment but after I clicked submit my comment didn’t appear. Grrrr… well I’m not writing all that over again. Anyway, just wanted to say fantastic blog!

  162. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

  163. May I simply say what a relief to uncover a person that actually knows what they are talking about on the internet. You definitely realize how to bring a problem to light and make it important. A lot more people ought to look at this and understand this side of the story. I can’t believe you aren’t more popular since you surely possess the gift.

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  168. Right now it sounds like Expression Engine is the top blogging platform available right now. (from what I’ve read) Is that what you’re using on your blog?

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  182. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

  183. At this time it sounds like Movable Type is the preferred blogging platform available right now. (from what I’ve read) Is that what you’re using on your blog?

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  188. At this time it seems like BlogEngine is the preferred blogging platform out there right now. (from what I’ve read) Is that what you’re using on your blog?

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  201. Aw, this was an incredibly good post. Taking a few minutes and actual effort to produce a really good article… but what can I say… I hesitate a whole lot and don’t seem to get anything done.

  203. At this time it appears like BlogEngine is the preferred blogging platform available right now. (from what I’ve read) Is that what you are using on your blog?

  205. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

  206. Aw, this was a very nice post. Finding the time and actual effort to create a very good article… but what can I say… I hesitate a whole lot and never manage to get nearly anything done.

  207. Wow that was strange. I just wrote an extremely long comment but after I clicked submit my comment didn’t show up. Grrrr… well I’m not writing all that over again. Regardless, just wanted to say excellent blog!

  208. Currently it appears like BlogEngine is the preferred blogging platform out there right now. (from what I’ve read) Is that what you are using on your blog?

  209. At this time it looks like WordPress is the best blogging platform available right now. (from what I’ve read) Is that what you are using on your blog?

  210. Currently it seems like Expression Engine is the top blogging platform available right now. (from what I’ve read) Is that what you are using on your blog?

  211. Right now it looks like WordPress is the best blogging platform out there right now. (from what I’ve read) Is that what you are using on your blog?

  212. Can I just say what a relief to discover a person that actually knows what they’re talking about over the internet. You definitely understand how to bring a problem to light and make it important. More and more people need to look at this and understand this side of the story. I was surprised that you are not more popular since you definitely possess the gift.

  213. Currently it seems like Movable Type is the preferred blogging platform out there right now. (from what I’ve read) Is that what you are using on your blog?

  214. Can I just say what a relief to uncover someone that genuinely understands what they are discussing on the web. You certainly know how to bring a problem to light and make it important. More and more people need to read this and understand this side of the story. I was surprised you aren’t more popular given that you definitely possess the gift.

  215. At this time it appears like Drupal is the top blogging platform out there right now. (from what I’ve read) Is that what you’re using on your blog?

  216. At this time it appears like WordPress is the preferred blogging platform available right now. (from what I’ve read) Is that what you are using on your blog?

  220. Aw, this was a very good post. Finding the time and actual effort to produce a superb article… but what can I say… I procrastinate a lot and don’t seem to get anything done.

  221. May I simply say what a relief to discover someone that truly knows what they are discussing on the internet. You actually realize how to bring an issue to light and make it important. More people must look at this and understand this side of the story. I was surprised that you’re not more popular because you surely possess the gift.

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  223. Aw, this was a really good post. Taking the time and actual effort to create a good article… but what can I say… I put things off a lot and don’t seem to get nearly anything done.

  224. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

  226. Right now it appears like Movable Type is the best blogging platform out there right now. (from what I’ve read) Is that what you’re using on your blog?

  227. At this time it appears like WordPress is the preferred blogging platform available right now. (from what I’ve read) Is that what you’re using on your blog?

  228. Can I simply just say what a relief to find an individual who really knows what they’re discussing on the internet. You definitely realize how to bring a problem to light and make it important. More people really need to check this out and understand this side of your story. It’s surprising you’re not more popular given that you most certainly possess the gift.

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  242. Can I simply just say what a comfort to uncover a person that genuinely understands what they are talking about over the internet. You definitely understand how to bring a problem to light and make it important. More and more people need to look at this and understand this side of the story. It’s surprising you are not more popular since you certainly possess the gift.

  243. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

  244. May I just say what a relief to uncover a person that genuinely understands what they’re talking about on the internet. You actually know how to bring an issue to light and make it important. A lot more people ought to look at this and understand this side of the story. It’s surprising you’re not more popular since you most certainly have the gift.

  245. Can I just say what a relief to discover someone who really knows what they are talking about on the internet. You actually realize how to bring an issue to light and make it important. More people should read this and understand this side of your story. I can’t believe you are not more popular given that you surely possess the gift.

  246. Currently it looks like BlogEngine is the preferred blogging platform out there right now. (from what I’ve read) Is that what you are using on your blog?

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  259. Right now it looks like BlogEngine is the top blogging platform available right now. (from what I’ve read) Is that what you’re using on your blog?

  260. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

  261. At this time it appears like WordPress is the top blogging platform out there right now. (from what I’ve read) Is that what you are using on your blog?

  263. Currently it sounds like Movable Type is the best blogging platform out there right now. (from what I’ve read) Is that what you’re using on your blog?

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  267. May I just say what a relief to find an individual who genuinely knows what they are discussing on the net. You certainly understand how to bring a problem to light and make it important. More people need to read this and understand this side of the story. It’s surprising you are not more popular given that you surely have the gift.

  268. At this time it looks like Movable Type is the best blogging platform available right now. (from what I’ve read) Is that what you are using on your blog?

  270. May I simply just say what a comfort to uncover an individual who genuinely understands what they’re talking about on the web. You certainly realize how to bring an issue to light and make it important. More people must read this and understand this side of the story. I was surprised that you are not more popular since you surely have the gift.

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  276. Right now it looks like Expression Engine is the best blogging platform out there right now. (from what I’ve read) Is that what you are using on your blog?

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  278. Right now it sounds like Expression Engine is the best blogging platform out there right now. (from what I’ve read) Is that what you’re using on your blog?

  280. Aw, this was a really good post. Spending some time and actual effort to produce a really good article… but what can I say… I put things off a lot and never seem to get anything done.

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  292. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

  294. Wow that was strange. I just wrote an very long comment but after I clicked submit my comment didn’t show up. Grrrr… well I’m not writing all that over again. Anyhow, just wanted to say excellent blog!

  295. Hi there, You have performed a great job. I’ll definitely digg it and for my part recommend to my friends. I’m sure they will be benefited from this site.

  296. Right now it looks like Movable Type is the preferred blogging platform available right now. (from what I’ve read) Is that what you’re using on your blog?

  298. Wow that was odd. I just wrote an very long comment but after I clicked submit my comment didn’t appear. Grrrr… well I’m not writing all that over again. Anyhow, just wanted to say wonderful blog!

  299. Right now it appears like Movable Type is the preferred blogging platform available right now. (from what I’ve read) Is that what you’re using on your blog?

  300. Can I simply just say what a relief to discover someone that genuinely understands what they’re discussing on the internet. You actually understand how to bring a problem to light and make it important. A lot more people ought to check this out and understand this side of the story. It’s surprising you are not more popular because you definitely possess the gift.

  302. Aw, this was an incredibly good post. Taking a few minutes and actual effort to create a really good article… but what can I say… I procrastinate a lot and don’t manage to get anything done.

  304. Currently it sounds like BlogEngine is the top blogging platform out there right now. (from what I’ve read) Is that what you’re using on your blog?

  305. Currently it appears like Movable Type is the preferred blogging platform out there right now. (from what I’ve read) Is that what you are using on your blog?

  306. Right now it seems like WordPress is the best blogging platform out there right now. (from what I’ve read) Is that what you are using on your blog?

  307. Hey there, You’ve done a great job. I will definitely digg it and in my view recommend to my friends. I am confident they will be benefited from this site.

  308. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

  309. Hi there, You have performed an excellent job. I’ll definitely digg it and in my view recommend to my friends. I’m confident they’ll be benefited from this site.

  310. Currently it seems like Expression Engine is the preferred blogging platform available right now. (from what I’ve read) Is that what you are using on your blog?

  312. Wow that was unusual. I just wrote an very long comment but after I clicked submit my comment didn’t show up. Grrrr… well I’m not writing all that over again. Anyhow, just wanted to say great blog!

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  317. Currently it sounds like Expression Engine is the top blogging platform available right now. (from what I’ve read) Is that what you are using on your blog?

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  321. Right now it seems like WordPress is the top blogging platform available right now. (from what I’ve read) Is that what you are using on your blog?

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  327. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

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  336. Right now it looks like WordPress is the preferred blogging platform out there right now. (from what I’ve read) Is that what you are using on your blog?

  337. May I just say what a comfort to find an individual who really understands what they are talking about on the net. You certainly realize how to bring an issue to light and make it important. A lot more people have to read this and understand this side of the story. I was surprised you are not more popular given that you certainly have the gift.

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  341. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

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  344. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

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  346. Great blog! Is your theme custom made or did you download it from somewhere? A theme like yours with a few simple tweeks would really make my blog jump out. Please let me know where you got your theme. Thanks

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  351. Right now it sounds like Drupal is the best blogging platform available right now. (from what I’ve read) Is that what you’re using on your blog?

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  358. Wow that was unusual. I just wrote an really long comment but after I clicked submit my comment didn’t appear. Grrrr… well I’m not writing all that over again. Regardless, just wanted to say fantastic blog!

  359. Hey I know this is off topic but I was wondering if you knew of any widgets I could add to my blog that automatically tweet my newest twitter updates. I’ve been looking for a plug-in like this for quite some time and was hoping maybe you would have some experience with something like this. Please let me know if you run into anything. I truly enjoy reading your blog and I look forward to your new updates.

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