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Record keeping

Civil explosives

 From the 5th April 2015, Manufacturers, importers, distributors, and anyone who acquires or keeps civil explosives will have to keep a record of the explosives throughout the supply chain and life cycle,

Records are not required to be kept for civil explosives that are:

The records should allow tracking and identification of an explosive at any time, and should be kept for 10 years after the date when the explosive was used, transferred to another person or destroyed, even if the manufacturers, importers, distributors, and anyone who acquires or keeps the explosives, have ceased trading.

If they do cease trading, they must notify the enforcing authority and provide any records to them to keep for the remainder of the 10 years.

Up to date records must include:

The system applied for collecting the  records must be quality controlled and tested at regular intervals for its effectiveness, and the quality of the information recorded. The record must be protected against accidental or malicious damage or destruction
The information as to the origin and location of each civil explosives to which the record relates, must also be made available to the enforcing authority when requested.

Relevant explosives

Most people who acquire possession of or keep relevant explosives are subject to the record-keeping requirements of the Regulations. Records are not required to be kept for relevant explosives that are:

Agents and records

An agent who acts to acquire relevant explosives for another person but who never has physical possession of the relevant explosives is not required to keep a record of those relevant explosives. This is because records will be kept by the person in physical possession of the relevant explosives.

Private individuals acquiring relevant explosives for their own use

Private individuals who acquire and keep explosives other than in connection with their work and solely for their own personal use are not required to keep a record of the relevant explosives. They should however have systems in place to retain sufficient information to be able to report losses under regulation 37.

Record keeping and explosives that are NOT relevant explosives

A person acquiring or keeping:

Will not have to keep records meeting the requirement of regulation 35 because those explosives are not relevant explosives. Records should however be kept to ensure compliance with any licence or permission or in order to provide information to the emergency services.

Information to be recorded

A record should provide an accurate indication of the relevant explosives acquired or kept at any time and enable rapid detection and identification of any loss.

The record must to be kept up to date and should identify;

and the date of any such further manufacturing process, use, transfer or destruction. The records must be kept for 3 years from when the relevant was used, transferred to another person or destroyed.

After the 5th of April 2015 this regulation will cease to apply to those relevant explosives that are also civil explosives subject to regulation 36.

Further information on record keeping can be found in L151 overarching guidance – security provisions.

Updated: 2019-03-12