Explosives use at mines

SPC/TECH/SI1/03 - Previously spc/tech/ld5/03


This SPC brings together, updates and replaces previous advice to mines inspectors relating to the storage and transport of explosives and advises on joint working with HID SI2. It does not address the use of explosives underground.


1  The investigation of accidents and dangerous occurrences relating to explosives storage, transport or use at mines is the responsibility of SI1. 

2  SI2 is responsible for the issue of licences for storage of explosives above ground at mines but it is for SI1 to ensure compliance with licence conditions and that separation distances are not compromised.


3  Storage of explosives is licensed under the Manufacture and Storage of Explosives Regulations 2005 (MSER). For storage above ground at mines HID SI2 are responsible for the licensing and licence amendments and will usually carry out an initial inspection and may make follow-up inspections. When explosives inspectors or the HID SI2 Regulatory Contact Officer (RCO) need to visit mine premises on licensing issues they will liaise with the relevant mines inspector.

4  Most mines will have fixed rule licences (for storage of up to 2000 kg) or registrations (for storage of up to 30 kg). These fixed rule licences or registrations are prepared by the RCO and signed by the SI2 principal inspector.

5  Essential requirements of MSER include:

  • Prevention of fires and explosion, limiting their extent and protecting people from their effects (Regulation 4)
  • Maintaining separation distances (Regulation 5)
  • Disposing of explosives and decontaminating explosives items safely (Regulation 6)
  • Preventing unauthorised access (Regulation 8)

6  In addition, Section 23 of the Explosives Act 1875 (as amended by MSER and extended by Section 39) requires occupiers of registered or licensed premises to take all due precautions for preventing unauthorised access to the premises or the explosives.

Multiple registered premises

7  Storage at some mines is subject to a long standing arrangement for multiple registrations at the same site. These arrangements are under review and will be the subject of separate guidance.

Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2007 (the Carriage Regulations)

8  These Regulations apply the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR) to domestic carriage. The Regulations are enforced by HSE, Police and the Vehicle and Operator Services Agency (VOSA). Enforcement for explosives will chiefly be undertaken by explosives inspectors during their visits to manufacturing and storage sites licensed by HSE, and through incident investigation. The police and VOSA inspectors report to HSE any instances of apparent "on-the-road" non-compliance with the Regulations.

9  Mines Inspectors are not normally expected to examine compliance with the Carriage Regulations in detail when vehicles carrying explosives are seen during their inspections. Where mines Inspectors do encounter vehicles that have carried, or are about to carry explosives on the road, certain basic checks can be made of the following good practices that should be adhered to during the carriage of explosives:

  • the driver or attendant should be in possession of information in writing giving the mass of explosives carried, their classification (division and compatibility group) and the name and address of the consignor, operator and consignee;
  • there should be no cigarettes/tobacco, matches or lighters in the vehicle or smoking by the operator/driver/attendant during the loading or unloading of the vehicle;
  • the vehicle should be free of any obvious defect which could result in an accident or fire;
  • engine should be switched off during loading and unloading;
  • fire extinguishers should be carried on the vehicle; (at least 1 2kg dry powder for vehicles up to 3.5 tonnes gross; more for larger vehicles)
    the vehicle should not be left unattended while explosives are on board;
  • packages containing explosives should not be damaged or leaking;
  • explosives should be securely stowed in load compartment to prevent significant movement;
  • no other dangerous goods or unsecured metal objects should be present in the load compartment.

10  A vehicle is deemed to be engaged in carriage of explosives from the commencement of loading it with explosives for the purpose of carrying those explosives by road until the vehicle has been unloaded.

11  Where mines inspectors suspect non-compliance with the Carriage Regulations, they should seek the advice of an explosives inspector.

12  Vehicles used to carry explosives, other than internal vehicles used to transport explosives within the same mine site, must meet the construction requirements of ADR (EXII or EXIII) appropriate to the quantity of explosives carried. Mines Inspectors may encounter the use of vehicles being used to transfer explosives between mines. Any vehicle that is not certified as EXII or EXIII is permitted to carry up to 50 kg explosives of Hazard Division 1.1.

13  Explosives classifications are approved under The Classification and Labelling of Explosives Regulations 1983 (CLER). Mining explosives are normally hazard code 1.1D, and detonators 1.1B; the letter refers to the compatibility group

14  Carriage of compatibility groups B and D together on the same vehicle is prohibited, unless they are effectively segregated such that there is no danger of transmission of detonation from the "B" to the "D".  Segregation is normally achieved by use of a special containment system. The segregation method must however be approved by the competent authority (HSE).

15  Explosives of Class 1 may be considered as high consequence dangerous goods and if the quantity of detonators and/or blasting explosives exceeds 50kg then the provisions of Chapter 1.10 of ADR (security provisions) apply. Chapter 1.10 is enforced by VOSA.

The Placing on the Market and Supervision of Transfers of Explosives Regulations 1993

16  These regulations require explosives to meet the essential safety requirements set down in harmonised standards and provide for CE marking. All explosives supplied for use in mines should be CE marked. Further guidance on CE marking is available on the HSE Web site.

17  The regulations also apply to the transfer of explosives from place to place, apart from movements on the same site. The supplier (consignor) must ensure that the receiver (consignee) has a Recipient Competent Authority (RCA) document covering the explosives to be transferred. RCAs are issued by HSE, Mines, Quarries and Explosives Policy Section to the person or company that will be in physical possession of the explosives after the transfer has taken place.

18  The consignee (eg mine) has to send to the consignor (eg explosive supplier) a valid RCA document or certified true copy for the explosives to be transferred; the RCA then accompanies the explosives throughout the entire journey. Regular consignees may send their consignor a batch of individually certified true copies to avoid delays. If a person moves his own explosives from place to place (even in small quantities) an RCA document must accompany the load.

The Control of Explosives Regulations 1991 (COER)

19  These regulations are primarily concerned with persons and record keeping. Enforcement is generally by the Police, including above ground at mines. SI1 is responsible for enforcement of record keeping for explosives underground at mines under Regulation 12(1). Regulation 15 gives details of enforcement.

20  The main requirements are:

  • persons acquiring or keeping certain explosives must have an Explosives Certificate issued by the police. (Reg. 7);
  • restrictions on persons involved in transfer of explosives. This generally involves the transferor ensuring that the transferee holds a valid Explosives Certificate (Reg.8);
  • a person who has committed certain offences (defined as a prohibited person) can not acquire, keep, handle or control certain explosives. Employers are also forbidden from knowingly employing such persons in any position involving these activities (Reg. 9),such as shot firers, trainee shot firers, store and reserve station attendants and any other person with access to explosives. In the case of bulk transport of explosives in locked containers, persons having access to the explosives (ie holding the key to the locked container) should be considered as handling or controlling explosives. Others (eg haulage drivers) who do not have access are not considered to handle or control explosives;
  • a requirement for a person who occupies a site and has a licence for the manufacture or storage of explosive at that site to appoint a person responsible for security of explosives (Reg. 11);
  • a requirement for keeping records of certain explosives to enable accurate accounting and identification of any loss (Reg. 12);
  • a requirement to report any loss of explosives to the police and, in the case of the larger HSE licensed sites (> 2000 kg) also to HSE (Reg. 13);

Action by Mines Inspectors

21  Any mines inspector finding instances of:

  • significant deficiencies in procedures involving storage or transport of explosives above ground found during any inspection or investigation:
  • non-compliance with licence conditions;
  • illegal manufacture of explosives or destruction of explosives;
  • theft of explosives; or
  • having concerns about compliance with carriage regulations should copy his report to the mines inspector with operational policy lead on explosives issues to provide an outline of the matter and any action taken to remedy it.

22  The investigating mines inspector should liaise directly with the police in the case of suspected theft of explosives or with the appropriate principal inspector of explosives otherwise.

Further information

For further information or to contact any mines inspector, please contact HID SI1(Mines Inspectorate), at Edgar Allen House, Sheffield.

To contact any explosives Inspector or the SI2 RCO, please contact HID SI2 (Explosives Inspectorate) at 1.2 Redgrave Court Bootle.

Appendix 1: Legal provisions and guidance

Acts and regulations

  • Explosives Act, 1875
  • Manufacture and Storage of Explosives Regulations 2005
  • Mines and Quarries Act 1954
  • Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2007
  • The Classification and Labelling of Explosives Regulations 1983
  • The Coal and Other Safety Lamp Mines (Explosives) Regulations 1993
  • The Control of Explosives Regulations 1991
  • The Miscellaneous Mines (Explosives) Regulations 1959
  • The Placing on the Market and Supervision of Transfers of Explosives Regulations 1993
  • The Stratified Ironstone, Shale and Fireclay Mines (Explosives) Regulations 1956

Published HSE guidance

  • Manufacture and storage of explosives – Approved Code of Practice and Guidance –L139- ISBN 0-7176-2816-7
  • A guide to the Control of Explosives Regulations 1991 - L10 - ISBN 0 11 885670 7
  • A guide to the Placing on the Market and Supervision of Transfers of Explosives Regulations 1993 (POMSTER) - L66 - ISBN 0 7176 0877 8
  • Storing & Handling Ammonium Nitrate - INDG 230

Other guidance

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Updated 2020-12-09