Manufacturing explosives

A licence is required for most manufacturing activities. You need to decide whether your activities are classed as manufacturing under the Manufacture and Storage of Explosives Regulations 2005 (MSER).

What is manufacture?

Manufacturing includes processes where explosive articles or explosive substances are made or assembled, or unmade or disassembled. For example, gunpowder manufacture, filling fireworks, breaking down jet perforating guns, removing fuses from artillery shells.

The term also includes the repair or modification of explosive articles and the reprocessing, modification or adaptation of explosive substances.

What is not manufacture?

A number of processes are not considered to be ‘manufacture’ under MSER. These include:

packing, unpacking or repacking explosives or explosive articles
breaking down explosives stored in bulk into smaller storage containers
labelling explosives or explosive articles
testing and proofing explosives or explosives articles and
using explosives articles as components to make a product which is not classified as an explosive (for example, preparing an explosive actuator into a fire drencher system, or fitting air bags to vehicles)

Do I need a licence?

Regulation 9(2) of MSER sets out which manufacturing activities do not require a licence. The main examples are:

fusing firework displays
preparing theatrical television and cinematic special effects
on-site mixing of explosives (either those made using ammonium nitrate emulsions, or by mixing ammonium nitrate with fuel oil)

However, although such activities do not require a licence, they are still subject to other requirements of the Regulations.

Fusing firework displays

A manufacturing licence is not required for the preparation, assembly and fusing of firework displays, ie:

removing individual fireworks from their transport boxes, packaging or other containers
connecting individual fireworks together and/or attaching them to frames or other structures for display
linking individual firework fuses together and
attaching a main fuse to ignite the assembled display

Note that the manufacture of individual fireworks used in the display will need a licence.

On-site mixing

A manufacturing licence is not required for mixing ammonium nitrate and fuel–oil mixtures at a mine or quarry. These processes are considered to be part of the blasting operations and therefore subject to the requirement to produce shot-firing rules and a blasting specification. All of the issues that would be addressed in the licence will be covered in these documents.

If ammonium nitrate blasting intermediates were to be manufactured at the site, a licence from HSE would be required.

A licence will be required for on-site mixing at sites which are not subject to the Quarries Regulations 1999 (ie civil engineering works).

Other exclusions

Two other manufacturing activities are excluded from the requirement to hold a licence:

reprocessing an explosive substance to produce a product which is not classified as an explosive (for example the preparation of nitroglycerine-based pharmaceutical products)
using desensitised explosives in processes, including laboratory analysis, that do not produce a product that is itself an explosive