Withdrawal of the (UN 0349) 1.4S classification for DynaEnergetics HMX 165 Octocord from the List of Classified Explosives and Fireworks

Health and Safety Executive - Safety alert

Introduction:

Figure 1 - outer packaging

DynaEnergetics 165 HMX Octocord was classified in the UK by recognising the classification assigned by two Competent Authorities (one of a country that is not a Contracting Party to ADR and the other an ADR signatory).Z

HSE carried out compliance checks on this product, as part of its role as the Competent Authority for the classification of non-military explosives.

The tests showed that the hazards associated with this item were incorrectly identified by the labelling and that it did not comply with a 1.4S (low hazard) classification. Therefore HSE has withdrawn this classification.

As a result, carriage of this item within the UK is prohibited as a 1.4S, but it may be carried as Hazard Division 1.1D in accordance with the requirements of ADR 2013. This item must be stored as Hazard Type 1 and re-labelled appropriately 'UN 0065, 1.1D, CORD, DETONATING, flexible.'

Figure 2 - inner packaging

The outer packaging for this item resembles a "pizza" style box (shown in Figure 1). The inner packaging is configured as shown in Figure 2 (This contains 5 reels of 100ft lengths of detonating cord, with a total NEQ of 2.7kg).

Background:

The hazards associated with the carriage of explosives within the UK are assessed in accordance with the United Nations Model Regulations for the Carriage of Dangerous Goods, commonly referred to as the 'Orange book'. The system used to determine which division, amongst divisions 1.1 (mass explosion hazard), 1.2, 1.3 and 1.4, corresponds most closely to the behaviour of a product if a load is involved in a fire resulting from internal or external sources, or an explosion from internal sources. The results are also necessary to assess whether a product can be assigned to Compatibility Group S of Division 1.4.

There are four types of test used to assess the hazard:

• 6(a) - Single package test
• 6(b) - Stack test
• 6(c) - External bonfire test
• 6(d) - Unconfined package test

Test types 6 (a), 6 (b), 6 (c) and 6(d) are performed in alphabetical order.

Figure 3 - damaged witness plate

Test 6(a) is a test on a single package to determine if there is a mass explosion of the contents. HSL performed the UN series 6(a) test to the detonating cord in line with the stated procedure in the UN Manual of Tests and Criteria (5th Revised edition). The result indicated a mass explosion. Mass explosion (as defined in Chapter 2.1.1.4 of the Model Regulations) indicates that the product should be covered by Division 1.1.

Figure 4 - damaged witness plate

Evidence of the test includes:

1. Damage to the witness plate beneath the package; (Figures 3 and 4)
2. Disruption and scattering of the confining material. (Figure 5)

Based on the results of the Series 6(a) test undertaken on HMX 165 Octocord, the existing 1.4S classification is no longer considered valid, and the LOCEF entry for 1.4S has been withdrawn.

Figure 5 - disruption and scattering of confining material

A classification of 1.4S can only be assigned if the thermal, blast or projection effects would not significantly hinder fire-fighting or other emergency response efforts in the immediate vicinity and the hazardous effects are confined within the package.

Action required:

1. Any person who holds stock of this product must re-label all boxes containing this item as UN 0065 1.1D and apply the proper shipping name of CORD, DETONATING, flexible. Transporting this item as UN 0349 1.4S is prohibited
2. All boxes must be stored in an appropriate magazine, ie one which has a Hazard Type 1 allowance and that the specified separation distances are maintained (See Schedule 5 - separation distances and Regulation 27 of the Explosives Regulations 2014

Relevant legal documents:

Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (as amended) (CDG) Regulation 5. No person is to carry dangerous goods, or cause or permit dangerous goods to be carried, where that carriage is prohibited by ADR or RID, including where that carriage does not comply with any applicable requirement of ADR or RID.

Health and Safety at Work etc Act 1974 (HSWA) section 3(1). It shall be the duty of every employer to conduct his undertaking in such a way as to ensure, so far as is reasonably practicable, that persons not in his employment who may be affected thereby are not thereby exposed to risks to their health or safety.

Explosives Regulations 2014 Regulation 7(1). No person may store explosives unless that person holds a Licence for their storage and complies with the conditions of that Licence

Explosives Regulations 2014 Regulation 27(1). Every person who stores explosives at a site must ensure that the relevant separation distance prescribed by Schedule 5 is maintained between a store and a building or other place to which that schedule applies

References:

Recommendations on the Transport of Dangerous Goods. Manual of Tests and Criteria 5^th revised edition

Recommendations on the Transport of Dangerous Goods. Model regulations 18^th revised edition

Further information:

Health and Safety Executive
CEMHD7 - Explosives Inspectorate
Redgrave Court
Bootle L20 7HS
Website: http://www.hse.gov.uk/explosives/index.htm

General note:

Please pass this information to a colleague who may have this Product.