If you are reading this, then you either currently deal with Enola Gaye/EG Smoke and pyrotechnics or are going to.
All smokes and pyrotechnics e.g. smokes, bangs, flashes, paint and frag grenades from Enola Gaye/EG or any other manufacturer are classed as explosives; yes people, you are dealing with explosives, there are bound to be some rules and that you will have to follow. It’s not rocket science (sorry about the pun) and these guidance notes are here to help, however these notes are just that, guidance and a summary of the full regulations. For the detailed rules and regulations please follow one of the links at the end of this document. If you are unsure of what you need to do, then you should consult your Local Authority or the Health and Safety Executive Explosives Inspectorate for advice.
So, how do these regulations affect me I hear you ask? Well, if you are storing anything different from that described in the list below then you will need a storage licence.
- A maximum of 5 Kg Net Explosive Content (NEC) of Hazard Type 4 explosives (e.g. Enola Gaye/EG smokes and pyrotechnics) for as long as you like.
- Any quantity of Hazard Type 4 explosives for no longer than 24hrs.
- A maximum of 250 Kg of Hazard Type 4 explosives for no longer than 5 days in their place of intended use.
Hazard Types (HT)
For those explosives that have been tested, classified (allocated a Hazard Division by HSE) and are being kept in their correct transport packaging, there will generally be a direct correlation between the UN Hazard Division for transport and the hazard type (HT) they should be allocated for storage purposes.
The HT of packaged explosives is in part dependant on the packaging, if the explosives are stored in different or without packaging then the Hazard Type for storage may change, usually to a more severe Hazard Type. Always store Enola Gaye/EG Pyrotechnics and any other smokes, pyrotechnics or explosives in the packaging they are supplied in.
Net Explosive Content (NEC)
You will hear or have heard people banging on about NEC or the Net Explosive Content; It is the combined weight of the explosive composition(s) and the fuses within a device or within a package. NEC is also sometimes referred to as Net Explosive Quantity (NEQ) or Net Explosive Weight (NEW) but they all mean the same thing. The NEC of Enola Gaye/EG products are shown here.
So, how much do you want to store and where or how are you going to store it?
The guidance given in this document focuses on the storage of Enola Gaye/EG products up to a maximum of 250 Kg NEC. Enola Gaye/EG products are all Hazard Type 4 explosives, this guidance is also applicable to other explosives/pyrotechnics of Hazard Type 4. The “Storage” quantity includes all explosive articles on the storage site whether they are in transit, being loaded, unloaded, packed, dispatched or in a store.
Short Term Storage (less than 5 days)
The Explosive Regulations 2014 permits the following quantities of Hazard Type 4 explosives to be stored for a limited period without a licence/permit.
- An unlimited quantity for a maximum of 24hrs.
- 250Kg NEC for a maximum period of 5 days, when stored at their place of intended use.
Long Term Storage
If in total you are storing more than 100g NEC but less than 5 Kg NEC of Enola Gaye/EG products at any one time then you can breathe easy as you do not have to do anything apart from follow the “General Guidance” section later.
This table shows what 5 Kg and 250 Kg NEC generally relates to for some Enola Gaye/EG smokes and pyrotechnics.
|Pyrotechnic||Device NEC/g||Quantity / 5Kg||Quantity / 250 Kg|
|Large Friction Smokes||40||125||6,250|
|Wire Pull Smokes||40||125||6,250|
|WP Flash Grenade 3||3||1,666||83,333|
|WP Flash 1||1||5,000||250,000|
Storage of other HT4 Pyrotechnics, HT4 Fireworks and HT4 explosives is also allowed so long as the total NEC does not exceed 5Kg in total.
To store more than 5 Kg but less than 2000 Kg NEC of smokes and pyrotechnics and other HT4 explosives you will need a local authority license. The amount you will be allowed to store will be determined by the type of store you have, location of the store and the quantity or NEC weight you want to store. The more you want to store the greater the precautions and the isolation from other buildings and people.
The simplest store is for a maximum of 250 Kg NEC. Details of what is required for this NEC are explained in this guide.
For all stores above 5Kg NEC you will need to apply to the local licensing authority covering the area where the store will be physically located.
The local licensing authorities are:
Metropolitan counties (West Midlands, Merseyside, Greater Manchester, Tyne and Wear, South, and West Yorkshire), as well as in Cornwall is the Fire and Rescue Service.
For all other areas, the licensing authority will normally be the trading standards department of the local authority (in some parts of England this will be part of the county council).
Scotland and Wales
The licensing authority is the local council. Where a district council or city council has taken over the functions of the county council, the authority may have agreed with the police or combined fire authority for the fire authority to enforce and to administer licensing on its behalf.
Explosive Storage License Application
Applications should be made using form ER1
When you apply you will need to include the following information along with the application form:
- A postal address and scale plan (minimum 1:25000) showing the location of the storage site in relation to its surroundings (i.e. named or numbered roads, other buildings and businesses, hamlets, villages or geographical features).
- If the store is subject to separation distances (5-250 Kg separation distance is 0m) you will also need to provide a 1:1250 scale Ordnance Survey Site plan (or similar) map showing the location of the store and distances to any neighbouring buildings.
- If you intend to store or display more than 12.5kg of fireworks, pyrotechnics or HT4 explosives on a shop floor, the licensing authority will require you submit a floor plan of the sales area.
- If you intend to store, process or manufacture explosives within a building that is also used for other purposes you should include a floor plan showing the places within the building where you intend storing the explosives.
- The application fee will also need to be submitted with the application. The fee is dependant on the type of application (new or Renewal), the number of years the licence is granted for (1-5) and the separation distance required. Information on fees can be found here (Fees for licences granted by local licensing authorities) or contact your licensing authority for advice.
Licences for storing 5 - 250Kg of HT4 Explosives
This guide will focus on this NEC weight range. There is no restriction on the type of store you could have. Everything from metal shipping containers, brick buildings, wooden sheds, garages and segregated areas within buildings are all permitted to be licensed as a store up to 250 Kg. You will need to ensure the store is secure so a flimsy wooden shed whilst acceptable, is not advisable.
The regulations surrounding the storage of more than 5Kg NEC of HT4 explosives, is dependant in part on separation distances. The separation distance is the distance required between the explosive store and potential hazards or potential risk e.g. a road, an inhabited building or another explosive store. The separation distances for a store containing a maximum of 250Kg HT4 explosives is 0 metres. This means that the store can be pretty much anywhere, although you will need to avoid storing next to petrol stations, fuel dumps and gas stores.
Licences for storing 250Kg - 2000Kg of HT4 Explosives
Again there is no limitation on the type of store, however, the quantity you will be allowed to store will be determined by the separation distance you have from the store to the various buildings, dwellings, roads etc. that are in the vicinity. If you want to store the maximum NEC (2000Kg) then look at having your store in an isolated area with not a lot around it.
Licences for the storage of 250Kg -2000Kg NEC are more involved. This guide does not focus on storing more than 250Kg NEC; Our advice is that if you want to store more than 250Kg NEC, contact our office and we can point you in the right direction, or you can contact your local authority directly as they are there to help.
All persons who store Enola Gaye/EG pyrotechnics or other HT4 explosives must take appropriate measures to prevent unplanned fires or explosions, limit the extent and spread of any fire or explosion and protect all people from the effects of fire or explosion.
This section highlights the important factors to think about and do when storing Enola Gaye/EG pyrotechnics and/or other HT4 smokes, pyrotechnics and explosives. Where we have given examples to help clarify various points, do not interpret the examples as a definitive, they are examples and you are expected to do a little thinking for yourself. This is guidance, a means to help you and get your thought juices going, and help you assess the hazards and risks, it is not intended to do the job for you!
Ensure that the people operating the store are competent to carry out activities under normal conditions. They should understand the hazards and risks which may arise and the actions to take in abnormal or emergency situations.
Competent people understand the risks and hazards associated with storing and handling pyrotechnics and explosives; how to store these safely and how to prevent fire and explosion. They understand how fire can be prevented from spreading or communicating to other explosives and buildings and know what to do to protect people including themselves.
To be competent an organisation or individual must have a combination of training, skills, experience and knowledge and the ability to apply those to perform a task safely. Factors such as attitude and physical ability and behaviours can also affect someone’s competence.
It is important to have a range of competencies involved in explosives operations, directors, managers, workers and contractors, recognise different hazards and risks in their different situations, leading to the correct safety measures and controls to manage the hazards and risks.
Competence develops over time. Individuals develop their competence through a mix of initial training, on-the-job learning, instruction, assessment and formal qualification. People in the early stages of training and experience, should be closely supervised, as experience is gained the need for direct supervision can be reduced.
Companies should have systems in place to identify training and competency needs and follow up when those training needs are identified, or when competency needs to be developed.
The need for training is ongoing as the experience and competency levels within the company change due to changes in operation(s), including the storage of new explosives or new Hazard Types, the introduction of new facilities or equipment, changes in staff or other people involved in the explosives operation(s), changes in recognised industry practice(s) and/or changes in the regulations.
Good Working Practices
Safe systems of work should be developed in order that activities with explosives are carried out safely. Explosive activities can range in their risk and hazard and can also include operations that can be obvious or not so obvious. For example, collecting product from a store in the winter when its dark, what lighting is there? Do you need torches or other lighting system like a generator and internal lights? Which ever you choose will have different consequences and outcomes. The choice of tools and equipment is also important as these may introduce new risks and hazards. In the above example, what type of torch? Where will it be kept? If a generator and internal lights are used, what type of lights, could they cause a fire, where will the generator be located and the fuel for the generator?
Another example could be collecting products from a store during the day when there are other people are around. The risks and hazard are different and so the operating procedure will need to take account of this. Where do the explosives have to be taken? What route? Will the route take you through area that can cause increased risks or hazards for example through your designated smoking area or past members of the public?
The Explosive Store
Construction and type of Store
Depending on the quantity or Hazard Type of the smoke, pyrotechnics (explosives) you are planning to store the type or construction of the store can vary greatly. Rooms within buildings, shipping containers, sturdy sheds or isolated buildings can all be used to store explosives.
The store must be suitably weatherproof. Enola Gaye/EG pyrotechnics like other pyrotechnics will not work if they get wet! Also, some pyrotechnic compositions start to react and decompose producing heat when they get or have got wet.
Location of Store
For up to 250 Kg of Hazard Type 4 materials there is very little limitation as to where the store can be located. Explosive stores cannot be situated within a dwelling. Garages connected to dwellings may be used (but best avoided) if all other factors are adhered to and that there is enough fire protection between the garage and dwelling.
DO NOT situate the store in the path of a fire exit or escape route. If the store is within another building then the store could be a room, so don’t have the room on an escape route next to a fire door. If the store is a building or shipping container, shed or similar building in a garden or larger site, then ensure that there is an escape route from that area that doesn’t lead people past the explosive store.
Explosive stores should only be used for storing explosives and should be separated from areas used for non-explosive storage and activities. Storing explosives separately from other hazardous goods (e.g. fuel, gas canisters) and combustible materials, ensures these materials do not increase the hazards in the event of a fire. Keeping explosive stores separate from storage of food stuffs prevents contamination.
Explosive stores and activities should be separated from activities that do not include explosives e.g. general office work, toilets, general storage. This will help to ensure that materials involved in other activities do not increase the risk of a fire or increase the effects of an explosive event. Separating activities will reduce the number of people at risk and ensure that workers and the general public who are not directly engaged in the explosives storage or activities are protected should a fire or explosion occur.
Other explosive stores and activities involving explosives e.g. packing/dispatch/selling etc. need to be separated from the explosive store by at least 11 metres.
Explosive stores must be adequately secured, preventative measures should be taken to stop unauthorised access to the store including access by children that maybe on the premises where the store is located e.g. paintball field or a garage next to a dwelling. Keeping the store secure will also prevent loss of stock through theft which will not only have a financial impact but will also prevent the explosives being stolen and used for criminal activities.
All doors of a store that are locked for security reasons must be unlocked when the store is in use. If a store has a separate fire exit, then for security you may choose to lock this door when not in use. When the store is in use this door and all others must be unlocked.
Electric Lights (if present) should be dust tight (IP54) or at the very least covered fluorescent tube lights should be used. Electrical connections must be covered/sealed and secure to prevent sparks.
Light switches should be sealed or located outside of the store.
Stores should be kept above freezing and humidity should be kept below 70% – successive freezing and thawing will damage most pyrotechnics and explosives. At times of elevated temperatures e.g. height of summer ventilation may be considered. At times of very low temperatures e.g. in winter, heating the store may be considered.
If heating is required within a store, then oil or water filled electric heaters/radiators should be used; these should be guarded to prevent boxes of pyrotechnics touching the hot surfaces. The control panel/switches should either be located outside of the store or suitably protected against dust and emission of sparks. A tamperproof thermostat should be used to prevent the temperature increasing too much.
Electric Sockets (if present) should be sealed or at very least blanked off. Electrical connections must be covered/sealed and securely made to prevent sparks.
If you require power within a store (heating/lighting etc) and you are not connected to the grid, there are a couple of options, solar panels, battery banks or generators. Which ever you choose, consider where you locate the batteries, generator and fuel. Locate them a suitable distance away from the store so that if they cause a fire then it won’t easily spread to the explosive store. Do not store batteries, fuel, generators or similar items within an explosive store.
A source of fire that is outside of our control is lightning, explosive stores should be suitably protected against lightning except in the following instances:
- The store is temporary (for example, for no more than a few weeks on a seasonal basis) when only storing HT4 explosives;
- The store is used to keep less than 75 kg NEC of HT4 explosives only;
- The store is made by excavation and is thereby inherently protected from lightning;
- is within another building (not residential) e.g. warehouse, garage etc.
Steel ISO containers (shipping containers) are self-protecting so long as the walls are lined with wood (or other appropriate lining) or the explosives are kept at least 150 mm away from the container’s walls, the side container walls/panels and doors are electrically bonded with straps of a cross section of at least 50 mm2,
two earthing points connected to earth rods are provided at opposite corners and resistance from the top of the container to earth is less than 10 ohms.
Steel-framed structures with metal cladding may be regarded as self-protecting provided the individual earth resistance of each stanchion, in a standalone condition, does not exceed 10 ohms. The metallic cladding should be bonded to the structure by suitable metal fixings and electrically bonded with straps of the same cross-sectional area as the main down conductor, and at least 50 mm2. Where these conditions cannot be met, a ring conductor, bonded to each stanchion and with earth electrodes at each end of the structure, should be provided.
Earthing systems/lightening protection should be adequately maintained so that the protection does not deteriorate.
Surfaces and Surface Finishing
Exterior surfaces e.g. outside of steel containers should be painted to prevent against rust. Internal surfaces (walls, floor, shelving etc) within the store should be smooth and easy to clean to prevent the build-up any pyrotechnic dust.
No person under 16 years of age may work in the storage facility or handle Enola Gaye/EG or any other HT4 pyrotechnics or explosives. People between 16 and 18 years of age must be supervised at all times when working with smokes and pyrotechnics.
- Ensure that all sources of ignition are excluded from the store. These are commonly but not limited to:
- Naked Lights and Flames (e.g. matches, lit cigarettes, lighters).
- Heat and Temperature (e.g. wood burners, exposed heating elements, combustion engines).
- Electricity (e.g. static electricity from body, batteries, pagers, mobile phones).
- Sparks from Mechanical and Frictional Contact (e.g. Flint & Fire Steel, Staple gun, metal tools, rusty tools).
- Impact and Friction (e.g. Grit/stones against floor, dropping boxes and articles, puncturing boxes).
- Pressure (e.g. stacking boxes too high).
- Chemical Incompatibility (e.g. storing loose striker caps with exposed friction fuses, some pyrotechnic compositions can heat up when damp).
- Smoking must not be allowed anywhere near the store.
- Ensure that all exit routes are easily accessible and are always kept clear.
- Explosive articles should be stored in their correct transport packaging. Opened packages must be kept closed.
- Any flammable material or liquid inside or outside of a store can act as a “stepping stone” for fire, making it easier and quicker for a fire to spread. Removal of stepping stones inside and out e.g. Diesel, Petrol, Gas Canisters, Aerosols, Paint, pyrotechnics waiting to be dispatched, vehicles, waste paper and boxes will reduce the chance of a fire spreading, slow down the spread of fire and stop the fire escalating.
- No Food or drink should be taken into or consumed within the store or whilst handling/dealing with pyrotechnics.
House Keeping and Maintenance
Good House Keeping and Maintenance is essential to safety, additional to the normal housekeeping of any business e.g. removal of rubbish, removal of hazards such as trip hazards and good hygiene. Housekeeping surrounding explosive stores also includes:
- Regular removal of dust to prevent build up on heating surfaces e.g. oil filled radiators, light fittings, shelves, windowsills, and floors.
- Regular removal of waste both within the store e.g. packaging materials, and external to the store e.g. surrounding vegetation will reduce the chance of a fire spreading.
- Regular removal of grit and stones or any other particulate that may cause heat through friction.
- All tools and equipment not required for working need to be removed from the store when not in use.
- Condition of store – The store should be regularly checked for leaks and deterioration, any problems found should be fixed within appropriate timescales i.e. leaks fixed immediately but repainting can be scheduled in for an appropriate time.
- Maintenance work – When maintenance work using tools and equipment that may give heat e.g. gas welding and soldering torches, cutting equipment (sparks), pliers and screwdrivers (friction) then it is essential that all pyrotechnics are removed from the store and the store clean prior to the maintenance work being carried out. It is advised that a system of checking is put into place.
- Inspection & Record Keeping – The store should be inspected regularly to ensure good housekeeping and maintenance. A record of all checks should be kept.
There should be a plan for the action to be taken in the case of emergency e.g. fire in or around an explosive store. The following common aspects will help to form that plan but other site dependant aspects may also be required.
- Fire Detection – How will the fire be detected? Is there a need for smoke/heat alarms or will it be visual i.e. seeing smoke and or flames?
- Warning – How and when will other persons on site be alerted to the situation? Fire alarm, Hand Bell, shouting, word of mouth?
- When will the fire warning be given, all situations or ones just affecting the store directly?
- Firefighting – In general the fighting of fires in the vicinity of a store should be limited to preventing a small fire growing and protecting escape routes, e.g. tackling small grass fires a safe distance from the store. Fires within explosive stores no matter how big or small should not be tackled.
- Firefighting equipment such as water buckets and beaters should be made available outside of a store, thus, having access for small grass fires etc but not encouraging the fighting of fires within a store.
- Escape and Evacuation – What are the escape routes, and where is the assembly point? Escape routes should not take persons past other hazards that may be affected by any fire on site e.g. gas bottle storage or other pyrotechnic stores. The assembly point should be at a safe distance away from any potential hazards and should be clear of any routes that may be used by the emergency services. It is advisable to display or have available a simple map/diagram indicating the assembly point and possible escape routes.
- Vulnerable people, visitors, neighbours – Serious thought should be given to the procedures required to ensure the safety of people that may be more vulnerable in the event of an emergency e.g. children, wheelchair users, sight impaired, pregnant women, remote workers or people who may not know your site e.g. visitors, contractors and people not connected with your business e.g. neighbours, passers-by, local traffic, but may also be affected by a fire or explosion within or in the vicinity of your explosive store.
- Is everyone accounted for – provision should be made so that the number of people on your site at any one time is known and that they can be accounted for if needed.
- Emergency Services – who will call the emergency services and what information will they give i.e. type of emergency, location of emergency. Information should be easily accessible regarding the exact type and quantity of explosives within the store and the location of the store.
- When is it over? Re-entry after an incident, and the resumption of activities, should only be permitted when directed by a competent person appointed by the site operator. Where an incident involved calling out the fire and rescue service, re-entry to the premises should be prohibited until the fire and rescue service has given the all-clear. Any work involving potentially hazardous situations after an incident (for example dealing with smouldering explosives, opening vessels or sealed work equipment) should only be undertaken under the supervision and direction of a competent person and with due consideration of any investigation into the circumstances of the incident that may need to take place by regulatory bodies and the site operator. Learning why something happened is an appropriate measure for making sure it does not happen again.
- Emergency procedures – The license holder must ensure that they have a written set of procedures in case of fire and all staff trained in those procedures. The procedures should cover the common aspects described above, but there may be others. The action prescribed by a procedure will be site and personnel dependant.
The best way of protecting people is by removing the hazard or by removing the people from the hazard area. So…….
- Limit the numbers of people in a store at anyone time, only have the people there that are necessary.
- Limit the number of visitors around the store, including delivery/collection drivers. Bring products to customers rather than bring the customer to the store.
- Don’t overload the store, keep the quantity of explosives stored well within the limit of your license and to a known manageable quantity.
- Don’t over stack boxes. This reduces the potential for dropping boxes, generation of heat from pressure/weight of boxes and aids with manual handling.
- Have the appropriate equipment available for handling the explosives e.g. instead of people carrying armfuls of products which they may drop, use bags, trolleys or even wheelbarrows.
- Personal Protective Equipment (PPE) – This is the last line of defence, however in many cases needed. It is advised that all persons handling/dealing with or using Enola Gaye/EG pyrotechnics wear Gloves to prevent burns and cuts and safety glasses/goggles to protect eyes from sparks and foreign debris.
- Contractors – Contractors working on site whether they be couriers or trades people do present an additional hazard as they may be more interested in getting there job done rather than compliance with your safety procedures e.g. smoking, use of tools within an explosive store, alarms and evacuation. If their work does not take them near the explosive store then minimal supervision may be an option; however, working in or in the vicinity of an explosive store would require either supervision by a competent person or for long term working, training in the site procedures
The licence holder is ultimately responsible for the safety of their staff, but they also have a duty regards safety and security of the explosives they store. The license holder needs to ensure:
- Appropriate training and competence of their staff – All staff need to be suitably trained, training is recorded, monitored and updated where necessary. Training does not always have to be expensive and time consuming, it can be as simple as, running fire drills or training staff to carry out certain tasks; however on occasion suitable training may not be available in-house in these instances external training should be sought.
- The Hazards and Risks have been assessed and appropriate procedures have been written to safeguard personnel.
- The design and implementation of a procedure should include all staff involved with that procedure and not just the license holder. Involving staff in the design of a procedure helps to ensure that that procedure is simple, effective and more likely to be followed.
- The explosive stock is managed correctly, old stock used first (prevents potential decay and heat build up) and the quantity of stock known (a count kept of stock entering and exiting the store).
- Insurance – You should contact your insurance provider to ensure that the store is covered by insurance and the requirements of your insurance company have been met.
This guide is just a guide, our interpretation of the regulations for storing up to 250 Kg of Hazard Type 4 explosives. Not every situation can be covered by this guide nor can every example be given, so please carry out your own assessment and due diligence for your situation. We are here to help, if you do require further information or are unsure as to what you need to do to store HT4 explosives, please contact the Enola Gaye/EG office or please see below for some essential resources and reading.
The Explosive Regulations 2014 – http://www.legislation.gov.uk/en/uksi/2014/1638/made
Explosive Regulations 2014 Safety Provisions – Guidance on Regulations – http://www.hse.gov.uk/pUbns/priced/l150.pdf
HSE Explosives Inspectorate – http://www.hse.gov.uk/explosives/index.htm
Explosives Industry Group of the CBI – http://www.eig.org.uk
Find Your Local Authority – http://local.direct.gov.uk/LDGRedirect/Start.do?mode=1
Trading Standards – http://www.tradingstandards.gov.uk