Enola Gaye Pyrotechnics – Updated UK Pyrotechnic Storage Guidance for UK – October 2014+
If you are reading this then you either currently deal with Enola Gaye Pyrotechnics or are going to. Pyrotechnics e.g. smokes, bangs, flashes, paint and frag grenades from Enola Gaye or any other manufacturer are classed as explosives; yes people, you are dealing with explosives so there bound to be some rules and regulations 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. For the detailed rules and regulations please follow one of the links at the bottom 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.
Since our last set of storage guidance the powers that be have been working on new Explosive Storage and Manufacture Regulations with a view to simplify the current regulations surrounding the Manufacture and Storage of Explosives, to revoke outdated legislation and to streamline current legislation. To this end from October 2014 the Manufacture and Storage of Explosives regulations 2005 (MSER 2005) are revoked and replaced by “The Explosive Regulations 2014”.
So, how does this affect me I hear you ask? Well in essence the changes that have been made do not majorly affect those storing Enola Gaye pyrotechnics or other Hazard Type 4 Explosives (HT4). The main change for HT4 is the removal of explosive store registration; if you wanted to store less than 250 Kg NEC then you could apply for a simple registration from your local authority. Now, all explosive stores greater than 5 Kg NEC will need a storage licence.
Firstly, my previous advice still stands, once you receive your pyrotechnics; whatever you do Don’t stick them under your bed!
Recap of Hazard Types
For those explosives that have been 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 dependent on the packaging and 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 EG Pyrotechnics and other explosives in the packaging they are supplied in.
Re-cap of Net Explosive Content (NEC).
You will hear or have heard people banging on about NEC which is the weight of hazardous /pyrotechnic material within the devices or outer shipping carton. NEC can also sometimes be referred to as Net Explosive Quantity (NEQ) or Net Explosive Weight (NEW) but they all mean the same thing. The NEC of EG products are shown in Table 1 below.
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 Hazard Type 4 Enola Gaye products up to a maximum of 250 Kg NEC. “Storage” includes all explosive articles on the storage site whether they are in transit, being loaded, unloaded packed, dispatched or actually in the store.
Short Term Storage (less than 5 days)
The Explosive Regulations 2014 permits the following quantities of Hazard Type 4 explosives to be store for a limited period of time without a licence.
– 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 of less than 5 Kg NEC in Total
If in total you are storing less than 5 Kg NEC of Enola Gaye 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.
Table 1 shows what 5 Kg and 250 Kg NEC relates to for EG pyrotechnics.
Storage of other HT4 Pyrotechnics, HT4 Fireworks and HT4 explosives is allowed so long as the TOTAL NEC does not exceed 5Kg.
Now that local authority registration for HT 4 explosives up to 250Kg has been removed from the regulations, anyone wishing to store more than 5Kg and up to a maximum of 2000Kg of HT4 explosives will need to have a license. You can apply to your local licensing authority covering the area where the store is located.
The local licensing authorities in:
Metropolitan counties (West Midlands, Merseyside, Greater Manchester, Tyne and Wear, South, and West Yorkshire), as well as in Cornwall is the 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 the administer licensing on its behalf.
Explosive Storage License Application
Applications should be made using form ER1 (https://www.hse.gov.uk/forms/explosive/er1-specimen.pdf).
When you apply you will need to include the following information along with the application form:
1. 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).
2. If the store is subject to separation distances (5-250 Kg separation distance is 0m) you will also need to provide an 1:1250 scale Ordnance Survey Site plan (or similar) map showing the location of the store and distances to any neighbouring buildings.
3. 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.
4. 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.
5. The application fee will also need to be submitted with the application. The fee is dependent 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 at www.hse.gov.uk/explosives/licensing/fees.htm (Fees for licences granted by local licensing authorities) or contact your licensing authority for advice.
Licences for storing 5 – 250Kg of HT4 Explosives
There is no restriction on the type of store you should have. Everything from metal shipping containers, brick buildings, wooden sheds, Garages and segregated areas within buildings are all permitted to be registered stores.
The regulations surrounding the storage of more than 5Kg NEC of HT4 explosives, is dependent 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, 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, however I would avoid petrol stations!
Licences for storing 250.1Kg – 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 250-2000Kg NEC are more involved. Our advice is that if you want to store more than 250Kg NEC, contact our office and we can help you through the process or contact your local authority directly, they are there to help.
General Guidance for all Stores.
All persons who store Enola Gaye 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 storing EG pyrotechnics and/or other HT4 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!
– 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, a garage next to a dwelling.
– No person under 16 years of age may work in the storage facility or handle Enola Gaye or other HT4 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, heating when products become damp).
– Smoking must not be allowed anywhere near the store.
– Explosive articles should be stored in there 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.
– The registered store MUST NOT be used for other purposes e.g. re-packaging, demonstration, office work, canteen, toilet etc. It’s a licenced store; the clue is in the name.
– No Food or drink should be taken into or consumed within the store or whilst handling/dealing with pyrotechnics.
The Explosive Store
– DO NOT situate the store in the path of a fire exit or escape route.
– Ensure that all exit routes are easily accessible and are kept clear at all times. All doors of a store locked for security reasons must be unlocked when in the store is in use.
– Must be suitably weather proof. 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 wet.
– Explosive stores cannot be situated within a dwelling. Garages connected to dwellings may be used as long as all other factors are adhered to and that there is sufficient fire protection between the garage and dwelling.
– Explosive stores should ideally be in a separate building from areas used for packing/dispatch/selling etc. Other activities within a store unnecessarily increase the risk of fire and may increase the number of persons at risk. If necessary the use of walls and doors creating enclosed rooms or spaces to segregate the areas is advised.
– Temperature within Stores – Stores should be kept above freezing and humidity should be kept below 70% – successive freezing and thawing will damage the pyrotechnic products. At times of elevated temperatures e.g. height of summer ventilation may be considered. At times of very low temperatures e.g. winter heating the store may be considered.
– Heating Stores – 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 suitable protected against dust and emission of sparks. A tamperproof thermostat should used to prevent the temperature increasing too much.
– Lighting in Stores – Electric Lights (if present) should be dust tight (IP54) or at the very least, only covered fluorescent tube lights should be used. Electrical connections must be covered / sealed and securely made so as to prevent sparks.
– Electrical Power in Stores – Electric Sockets (if present) should be sealed or at very least blanked off. Electrical connections must be covered / sealed and securely made so as to prevent sparks.
Follow this link for further information “CBI EIG Guidence on Electrical installation Explosive Manufacturing and Storage”
– Surface finish – The surfaces (walls, floor, shelving etc) within the store should be smooth and easy to clean to prevent the build-up any pyrotechnic dust.
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. House keeping surrounding explosive stores also includes:
– Regular removal of dust to prevent build up on heating surfaces e.g. oil filled radiators, light fittings, shelves, window sills, 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?
– Fire fighting – 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.
– Fire fighting 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 maybe 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 or diagram indication 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 of 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 above common aspects, but there maybe others. The action prescribed by a procedure will be site and personnel dependent.
Protection of people
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 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.
– Stock Management – 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.
Follow the above guidelines and suggestions you should be good to go, however if you require further information or are unsure as to your duties as a license holder, please see below for some essential resources and reading.
The Explosive Regulations 2014
Explosive Regulations 2014 Safety Provisions – Guidance on Regulations
HSE Explosives Inspectorate
Explosives Industry Group of the CBI
Find Your Local Authoruity