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Manufacturing explosives

A licence is required for most manufacturing activities. You need to decide whether your activities are classed as manufacturing under the Explosives Regulations 2014 (ER2014).

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 or fusing of fireworks, assembling fireworks displays from components, breaking down jet perforating guns, removing fuses from artillery shells and filling shotgun cartridges and other cartridges for small arms).

The activities covered by ER2014 also include the manufacture of explosives and intermediate products for on-site mixing and storage.

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

What is not manufacture?

A number of processes are not considered to be ‘manufacture’ under ER2014. These include:

Do I need a licence?

Regulation 6 of ER2014 sets out which manufacturing activities do not require a licence under certain circumstances. These include:

However, although such activities do not always 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, disassembly and fusing of firework displays,  at the place of intended use, or generally where small quantities of fireworks are fused at a site that is licensed for the storage of explosives ie:

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 the mixing for the immediate use of 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).

Insurance

Most employers are required by law to insure against liability for injury or disease to their employees arising out of their employment. The Employers’ Liability (Compulsory Insurance) Act 1969 ensures that you have at least a minimum level of insurance cover against any such claims.

Public liability insurance is not required by health and safety law. However, if you are manufacturing or storing explosives (including fireworks) you may wish to take out public liability insurance. Many industry trade associations and professional bodies require this as a condition of membership. Professional display operators using category F4 fireworks, T2 theatrical pyrotechnics or P2 pyrotechnic articles are required by product safety law to have public liability insurance in place covering their use.

Updated: 2017-07-03