Explosives sector strategy 2012-15
- Relatively small but significant, and diverse, sector – approximately 150 commercial dutyholders (220 sites) plus Ministry of Defence (MOD) (50 significant sites and many hundreds of smaller sites)
- A few large multi-site companies, but also many smaller businesses and small specialist offshoots of larger organisations
- 10,000 to 15,000 workers handling explosives (excluding armed forces)
- Uneven geographic spread: larger, older sites mostly in the west of Britain, newer, smaller sites mostly in south of England
- General decline in manufacturing explosive substances, replaced by storage / assembly / processing of bought-in explosives, but increase in military demand
The sector covers manufacture and storage of explosives. It excludes industries that use explosives in the course of their primary work (eg demolition or mineral extraction).
- MOD (influential on standards setting as a customer and self regulates on licensing and classification)
- Fragmented industry representation: main industry bodies are Confederation of British Industry (CBI) Explosives Industry Group, British Pyrotechnists Association and British Fireworks Association
- Institute of Explosives Engineers now emerging as a coherent professional body
Safety & health issues
- Potential for catastrophic major incidents
- 4 fatalities in the last 7 years
- Asset integrity - both aging plant / infrastructure and new safety-critical designs
- Loss of experienced competent staff (aging workforce, industry shift away from manufacture)
- Leadership - business leaders must actively manage their major hazard risks and ensure that staff are suitably competent and follow procedures
There are typically 3–4 major accidents per year, plus around 20 dangerous occurrences (potential precursors). Consequences of a major incident can be loss of key products for essential uses, as well as harm to people and environment.
Due to the potential for mass explosion, inappropriate classification and storage of fireworks and other explosives can have catastrophic consequences, as illustrated by the Festival Fireworks and Enschede incidents.
Poor risk assessment, inadequate supervision, lack of competence and failure to comply with licence conditions have all contributed to recent incidents. These incidents have also highlighted the need for a sound scientific understanding of hazards.
There is no evidence of significant health issues specific to explosives manufacture and storage. The industry has virtually eliminated the manufacture of toxic explosive materials, eg TNT, and the handling of explosives which pose health hazards is increasingly carried out remotely.
Legislation and regulation
The regulatory approach centres on licensing manufacturing and storage sites. Licensing and enforcement activity for sites storing less than 2 tonnes is carried out by local authorities, police or fire and rescue services.
HSE has an important role in the classification of all commercial explosives manufactured or imported into GB and provides advice to other government departments and agencies, eg to Department for Environment, Food and Rural Affairs (DEFRA) on the regulations controlling the import of ammonium nitrate.
All HSE work on preparing licences and explosives classifications is subject to cost recovery.
Legislation has developed over a long time and is numerous and complex, which can create difficulties in compliance. European legislation is increasingly being applied to explosives security and product safety. All HSE-sponsored explosives legislation and guidance is currently the subject of an Explosives Legislative Review which will run until 2014.
HSE has taken on a new role of regulating product safety for the extensive range of fireworks and pyrotechnics used in an 'at work' context.
Fireworks imported for display / consumer use have shown a long-term trend towards more energetic materials, and higher hazards for bulk storage. Changes to fireworks compositions have been introduced, which have inadvertently increased the hazards in transport and storage, or to the environment. These developments provide a continuing challenge to those classifying fireworks.
While new blasting explosives are less sensitive than their nitro-glycerine-based predecessors (and so generally safer to handle), emerging international evidence suggests that potentially inadequate control measures are being used and operators may underestimate the hazards (lack of knowledge, complacency).
In the field of military pyrotechnics, new product development is driven by the needs of the armed forces and is leading to the use of novel compositions. A recent incident suggests that some products may be taken into production before the process hazards are fully appreciated.
Strategic regulatory and sector approach
This small but high-hazard sector has a range of permissioning regimes to identify, control and mitigate risks (eg explosives licences, requirements of Control of Major Accident Hazards Regulations (COMAH), product classifications etc).
A full range of regulatory intervention approaches is relevant such as risk-based proactive interventions, reactive investigations, assessment of safety reports and licence applications, research and promotion of competence, leadership and performance indicators with stakeholders.
HSE is leading a review of explosives regulations and guidance as well as supporting product surveillance and delivering sound specialist advice to other government departments.
Aims for 2012–15
- Maintain a robust, consistent and credible regulatory framework operating in an environment of statutory provisions, reinforced with risk-based inspections, targeted investigation and statutory enforcement
- Dutyholders and key stakeholders demonstrate strong leadership to ensure major hazards are controlled
- Major hazard dutyholders manage asset integrity risks including those arising from aging plant and equipment and new-build assets
- Dutyholders are able to provide assurance to themselves and others that major hazard risks are under control, through increased adoption of safety performance indicators
- Dutyholders are competent to lead and manage major hazard risks at all levels and the regulator remains competent to meet its responsibilities and provide independent assurance to society
- Industry and other stakeholders play a key role in driving forward improvements in major hazard control through sharing of good practice, learning and sharing lessons from actual or potential incidents.
- HSE provides effective and timely support to high priority requirements of other government departments in respect of explosives
- To ensure that pyrotechnic articles (including fireworks) and civil explosives, when placed on the market, meet their essential safety requirements