The Explosives Industry Group of the CBI represents the majority of the UK industry explosive companies including the UK Ministry of Defence.
EIG acts as a lobby group and information source for members and includes members with interests in:-
- Manufacture, import and export of explosives
- Transport and Storage of explosives
- Explosives for Civil Uses
- Fireworks and Pyrotechnics
The EIG is represented on many Government committees and works with many UK Government Departments including:-
- The Explosive Industry Forum (EIF)
- The Explosive Storage and Transport Committee of the MOD (ESTC)
- The COMAH and Gas Charging Panel
- The British Standards Institute (BSI)
- The Explosive Inspectorate of HSE (HSE XI)
- The Department for Transport (DfT)
- The Department for Business, Innovation and Skills (BIS)
The EIG publishes a number of FREE guides for Industry which are available for members and non-members to download
Following the M5 incident in 2011 and many meetings with both the Coroner and various Government departments we agreed to highlight some of the potential issues surrounding the generation of firework smoke and fog – particularly in the run up to the November 5th period.
Firstly, however, it is important to appreciate that the Coroner found that firework smoke was not to blame for the tragic accident on the M5 near Taunton, but he did state that it could not be ruled out as a contributory factor.
In conditions of very high humidity it is possible that smoke from any source can trigger and contribute to the production of a dense fog.
This possibility should form part of the overall site and product specific risk assessment at any display but particularly when:-
- The location is near to a river or other source of high humidity (eg dew)
- When certain wind directions could carry smoke towards a road
- There is little wind to disperse fog or smoke
The Coroner recommended that all display sites should have some means of assessing the wind strength and direction and had means to stop the display if smoke became a serious issue. As part of the risk assessment process therefore we recommend that you consider:-
- Whether the site and the display have the potential to impact on local roads should the conditions become foggy
- What cancellation or curtailment criteria are appropriate for the display – and that all parties understand and “sign up” to these
- How the wind strength and direction can be assessed – this could be from local measurements and/or from local sources
- Whether the site merits “spotters” to be able to report back to the firers if smoke becomes an issue
- How the information will be communicated to the firing team
- How the emergency services (usually through the Police) might be alerted and by whom in case smoke and/or fog threatens a nearby road
The UK has an excellent safety record for professionally fired displays, and no-one wants to see displays cancelled or not commissioned because of the M5 accident. The consideration of the effects of firework smoke in a sensible and proportionate risk assessment, taking into consideration all the above factors, is the best way (alongside training) to prevent any similar occurrence in the future.
The BPA firers and senior firers qualifications now include a section on the effects of smoke, and we recommend that your firing teams are brought up to date with this new section before the time of their next renewal of their qualification. A special short presentation is available on the BPA website titled smoke issues click here
The Explosives Regulations 2014 (ER2014) came into force on 1st October 2014. They replace many old explosive specific Regulations (including MSER and COER) and although the layout of the Regulations has changed significantly, the general content of them remain the same.
Two overarching guides and a series of subsector guides have been published and EIG is delighted to host the subsector guides for you to download free of charge
These guides have been prepared by working groups involving industry and HSE, but EIG has no control over their content or their suitability for your operation. Please ensure that you read the introduction to each guide and determine how you may need to react to comply.
The text of the Explosive Regulations can be found here
In addition to the Regulations themselves there are 2 “Overarching” guides published by HSE
Futher subsector guidance will be available here shortly
The ER2014 team at HSE would welcome feedback in terms of editorial changes, or on the content of the guides. Please use the form below to submit comments to the ER2014 team
The Home Office will be implementing EU regulation 98/2013 on the Marketing and Use of Explosives Precursors on 2 September 2014.
The Control of Explosives Precursors Regulations 2014 restricts the sale of certain chemicals that can be used in the illicit manufacture of explosives precursors to members of the general public unless they hold a licence. Businesses selling restricted chemicals must ensure a warning label is affixed and must verify the buyer has a licence.
The regulation also introduces requirements to report suspicious transactions and significant thefts and disappearances.
More information can be found at: https://www.gov.uk/government/publications/licensing-for-home-users-of-explosives-precursors.
OSCT CBRNE unit
Please find below the derogation from the provisions of ADR, Annex B, UN 0335 and UN 0336 fireworks.
Be prepared – 12 months until new COMAH Regulations 2015 come into force
New Control of Major Accident Hazards (COMAH) Regulations will come into force in Great Britain on 1 June 2015. The main COMAH duties will stay the same as now but there are some important changes particularly on how dangerous substances are classified and information that has to be made available to the public. For the first time, lower tier operators will have to provide public information about their site and its hazards. Both top tier (now referred to as upper tier) and lower tier operators will need to provide public information electronically and keep it up to date.
Steps you can take in the next 12 months to help you prepare include:
- Be involved in the consultation – get a good indication of how you may be affected by looking at the draft new COMAH Regulations 2015. Have your say – the consultation closes on 27 June http://www.hse.gov.uk/consult/condocs/cd266.htm
- Check whether your COMAH status is likely to change (in or out of scope, upper or lower tier)by referring to Schedule 1 of the draft Regulations to see the hazard categories and named dangerous substances that are in scope and their quantities, and then compare to your substance inventory. You will need to convert your inventory from CHIP classification to CLP. Guidance on classification is available at http://www.hse.gov.uk/chemical-classification/classification/index.htm
- Be aware that all COMAH operators are likely to have to send a new notification to the Competent Authority (CA) by 1 June 2016; the updated information includes CLP categories of dangerous substances and more detail about site surroundings (draft Regulation 6). More information will follow on this shortly
- Consider what new information may need to be included in major accident prevention policies and off-site emergency plans (draft Regulations 7 and 12)
- Start putting plans in place for your summary of public information that will be provided electronically by looking at what information will be required (draft Regulation 16). The CA is planning to provide an IT system to host this information, more detailed guidance on this will follow
- Review draft Regulation 9 setting out the requirements and timescales for submission of Safety Reports and consider what new information may be required.
- Note that upper tier operators will still have to prepare public information zone (PIZ) information as now (draft Regulation 17).
In the next 12 months the CA will help you prepare by:
- Making guidance available for upper tier operators who are reviewing safety reports before June 2015 on what new information will need to be included after June 2015. If operators chose to, the new information can be included in advance thereby avoiding the need to update safety reports when the new Regulations come into force. This guidance should also be useful for all upper tier operators to indicate what new information will be required
- Publishing a response to the consultation document in Autumn 2014 to say how we will take the new Regulations forward
- Publishing guidance on the new Regulations in March 2015
- Aiming to launch the IT system for public information in advance of the Regulations coming into force.
Updating the Seveso and COMAH pages on HSE’s website. We will develop the list of FAQs from questions submitted to the email enquiry account Seveso.III.Enquiries@hse.gsi.gov.uk