Storage of explosives
Where explosives are stored, it is the net explosive content (NEC) or net explosive quantity (NEQ) that is the licensable amount. The NEC is the amount of explosive in the article, not including the packaging. In the case of fireworks the NEC is assumed to be 25% of the weight of the firework but can be as high as 70%, so a store licensed for 2 tonnes NEC may actually contain 8 tonnes gross weight including packaging. Licences for storage of less than 2 tonnes NEC are issued by the appropriate licensing authority that, depending on the quantity stored and the location in the UK, can be the police service, metropolitan fire and rescue authority, local authority or, in harbour areas and mines, the Health and Safety Executive. Where lower quantities are stored then the appropriate licensing authority may issue a registration rather than a licence. For stores involving more than 2 tonnes the HSE will issue a licence.
Licensed sites and military establishments storing and using explosives should conform to UK legislation and regulation.
A licence is required for most manufacturing or storage activities. Manufacturing includes processes where explosive articles or substances are made or assembled/ disassembled, repaired or modified. The Health and Safety Executive (HSE) is the licensing authority for all manufacturing. Depending on the quantity and type of explosives, the licensing authority for storage could be the local authority, metropolitan fire and rescue authority, police service or the HSE. There are a number of licensing exemptions for the storage of small quantities and for temporary storage; for example, there are allowances for storing limited quantities of shooters’ powders, certain lower-risk pyrotechnics and articles such as flares, fog signals, car airbags and seatbelt pre-tensioners.
During the fireworks season, fire and rescue services should be aware that they may encounter illegally-stored fireworks. Situations could include:
- Transport haulier depots
- Shops on short lets
- Warehouse or lockup storage
Identifying sites is a key element as it enables fire and rescue services to determine those sites that present the greatest potential hazard, in turn allowing fire and rescue services to prioritise each site for gathering information, pre-planning, response plans, etc.
The Manufacture and Storage of Explosives Regulations Approved Code of Practice requires that manufacturing and/or storage sites should contact the fire and rescue service, who may wish to undertake familiarisation visits to explosives sites. However, it is good practice for fire and rescue services to be proactive and not rely on the manufacture and or storage site contacting them.
The relevant licensing authority maintains a register of licensed sites and will be able to provide details.
It is estimated that there are between 20 and 30 thousand premises licensed to store explosives. The vast majority of these are shops and supermarkets are licensed for storing fireworks during the firework season. These premises are licensed either by the fire and rescue service (in the metropolitan counties and Cornwall) or by the local licensing authority.
In Scotland and Wales, for explosives not requiring an explosives certificate the enforcing authority is the local council. The fire authority may administer licensing on its behalf.
Sites storing the larger quantities of explosives are licensed by the HSE, who license about 230 sites in the UK. These sites range from manufacturers of blasting explosives and munitions through to firework importers and firework display operators.
Sites holding smaller quantities of high explosives are licensed by the police service (e.g. quarries). The police service also grants explosives certificates to private individuals holding black powder (gunpowder). This can be up to 5kg of black powder.
Fire and rescue services should contact the HSE and other licensing authorities with a view to identifying HSE-licensed sites in their areas, so that they can undertake visits to gather information. This will give them the information on the most hazardous sites in their area. A close and effective working relationship with the police service, HSE, Customs & Excise and the local authority planning and trading standards should be adopted to ensure that information about the movement, storage and use of explosives is made available to all partner organisations.
Sites owned and/or used by firework display operators store quantities of fireworks within ISO containers and as such should be treated as falling into the priority group for risk based visits/inspections. Fire and rescue services should also ensure that operational crews are reminded that explosives can be encountered at domestic homes and many retail businesses (e.g. flares stored at retail chandlers or RNLI property; shotgun cartridges in homes, etc.).
There should be effective systems for gathering information identifying the information fire and rescue services require and arrangements for updating that information at regular intervals.
Close liaison with the licensing/enforcing authority, ideally via joint site visits, will assist the fire and rescue services to:
- Establish the explosives and quantities that should be on site
- Identify the buildings, construction type and any potential and/or actual structural hazards, where they are processed or stored
- Determine that the buildings, etc. are correctly marked to identify their contents
- Determine any special conditions imposed by the site’s licence
- Ensure all of the above conform with the site’s licence
- Obtain other valuable information about the site (layout, water supplies, etc.)
- Obtain a copy of the site operator’s emergency arrangements
Accurate, clear and up-to-date information is essential and should be gathered by the fire and rescue service through regular visits (in addition to any joint visits) supplemented by other sources, such as operational intelligence. The recommendations above represent the minimum that fire and rescue services should be considering as part of their operational tactical planning.