Classification by analogy

Explosives may sometimes be classified based on the results of tests carried out on other similar explosives. This is called analogy.

This route can be used in applications from the company holding the classification document for the analogous explosive.

It is for the applicant – not HSE – to demonstrate the analogy and provide the necessary technical justification, ie full details of the construction, packaging and test history of the original.

To establish an analogy the applicant will have to demonstrate similarity in terms of behaviour, explosive type, packaging, composition, net explosive mass (NEM), design features (if an article), method of packing, and density of explosives in the package (also called the explosives packing density).

Applying for classification by analogy

When applying for classification by this route, an analogy table, supported by a well-argued technical case, should be submitted to demonstrate that the claimed analogy is sound. Where the table is not supported by a technical case, HSE reserves the right not to process the application.

The analogy should  be based on an explosive previously classified by a Competent Authority of a Contracting Party to ADR[56], ie HSE or the Ministry of Defence's Explosives Storage and Transport Committee (ESTC), on the basis of UN test data.

Where the new item contains a new explosive then evidence should be provided to show that the new explosive is comparable to the analogy in terms of sensitivity, stability, energy, burning rate, performance etc.

Where net explosive mass (NEM) exceeds that in the analogous article, a valid technical justification must be provided to demonstrate that the hazard of the new article, as packaged for transport, is not increased.

The applicant is expected to have sufficient understanding of the products and the available technical resources to provide a credible technical justification in support of their application.

Presenting the information

The information should be presented in a clear and logical format to avoid the need for additional questions and to shorten the time taken to process the application.

The information supporting an application should allow a direct comparison of the new and analogous item, for example, by use of a table and technical explanation.

Examples

Two examples of possible formats for information submitted for classification by analogy are given below. The first is for a hypothetical gas generator and the second is for a pyrotechnic article.

Example 1 Hypothetical gas generator

Submission in support of an application for the classification of a Mk 49 Widget on the basis of analogy with the Mk 47 Widget.

No column header New explosive Analogous explosive
No column header Mk 49 Widget Mk 47 Widget
Original classification To be agreed UN No 0277, 1.3C – HSE Ref XI/5015/111/22
Basis of classification analogy UN Series 6 tests
Description see drawing xxx supplied see drawing yyy supplied
NEM 10 g 15 g
Explosive Acme Propellant 769 Acme Propellant 769
Packing method 6 units in fibreboard box, internal 6 units in fibreboard box, internal
Including packing instruction fibreboard furniture. P130 fibreboard furniture. P130
NEM per box 60 g 90 g
Explosive density 0.29 kg/m3 0.44 kg/m3

A technical discussion of the table contents should be included in the technical justification to describe, compare and contrast the analogous item with the previously tested item. The aim of this discussion is to show that the new explosive, when incorporated in its transport pack, would not increase in hazard if it were involved in a fire during carriage.

Example 2 Pyrotechnic article

Notes regarding application reference ####
Application by analogy

The application is for the classification of a new product called New Widget. We are applying for a classification of 1.4G, UN0431 by analogy to the Widget (HSE Ref: XI/ABCD/E/F).

Pyrotechnic article - widget
Example 2 Pyrotechnic article
Widget Criteria New Widget
Articles Pyrotechnic Proper shipping name Articles Pyrotechnic
0431 UN number To be determined
1.4G HSE Ref XI/ABCD/E/F Classification To be determined
UN Series 6C Tests Basis of classification Analogy
See above Design See above
XXXXXXXX % Propellant (Example) YYYYYYYY %
Component A XX.X% Composition (Example). Additional compositions should be attached to a separate sheet Component A YY.Y%
Component B XX.X% Component B YY.Y%
Component C XX.X% Component C YY.Y%
Component D XX.X% Component D YY.Y%
Component E XX.X% Component E YY.Y%
Component F XX.X% Component F YY.Y%
0.016 kg Max. NEM per device 0.0045 kg
10 Devices per inner box 10
230 Devices per outer carton (Transport Pack) 230
3.68 kg Max. NEM per Transport Pack 1.035 kg
0.0514 m3 Volume of Transport Pack 0.0514m3
71.5 kg/m3 Net Explosive Packing Density 20.1 kg/m3
8.5 kg Max. gross mass of Transport Pack 6.5 kg
XYZ Packaging reference
(Drawings attached)
XYZ

A technical discussion of the table contents should be included in the technical justification to describe, compare and contrast the analogous item with the previously tested item. The aim of this discussion is to show that the new explosive, when incorporated in its transport pack, would not increase in hazard if it were involved in a fire during carriage.

Link URLs in this page

  1. Explosiveshttps://www.hse.gov.uk/explosives/index.htm
  2. Explosives Regulations 2014 (Amendment) Regulations 2016https://www.hse.gov.uk/explosives/regulations2016.htm
  3. Overview - The Explosives Regulations 2014https://www.hse.gov.uk/explosives/new-regulations.htm
  4. Guidance structurehttps://www.hse.gov.uk/explosives/guidance-structure.htm
  5. Subsector guidancehttps://www.hse.gov.uk/explosives/new-regs-subsector.htm
  6. Explosives Legislative Reviewhttps://www.hse.gov.uk/explosives/explosives-legislative-review.htm
  7. Getting startedhttps://www.hse.gov.uk/explosives/getting-started.htm
  8. Overview - Authorisations/licensinghttps://www.hse.gov.uk/explosives/licensing/index.htm
  9. Hazard type https://www.hse.gov.uk/explosives/licensing/hazard-classification.htm
  10. Safety requirementshttps://www.hse.gov.uk/explosives/licensing/safety-requirements.htm
  11. Separation distanceshttps://www.hse.gov.uk/explosives/licensing/separation/index.htm
  12. Building and construction typehttps://www.hse.gov.uk/explosives/licensing/separation/separation-distance-tables.htm
  13. Applying for a licencehttps://www.hse.gov.uk/explosives/licensing/how-to-apply.htm
  14. Local authority assenthttps://www.hse.gov.uk/explosives/licensing/local-authority-assent.htm
  15. Explosives in portshttps://www.hse.gov.uk/explosives/licensing/licensing-explosives-in-ports.htm
  16. Information for enforcing authoritieshttps://www.hse.gov.uk/explosives/licensing/enforcing-authorities.htm
  17. Refusals and revocations of authorisationshttps://www.hse.gov.uk/explosives/licensing/refusals-revocations.htm
  18. Safeguarding planshttps://www.hse.gov.uk/explosives/licensing/safeguarding-plans.htm
  19. Manufacturinghttps://www.hse.gov.uk/explosives/manufacturing.htm
  20. Securityhttps://www.hse.gov.uk/explosives/licensing/storage/storage-security.htm
  21. Storing explosiveshttps://www.hse.gov.uk/explosives/licensing/storage/index.htm
  22. Overview - Classification for transporthttps://www.hse.gov.uk/explosives/classification/index.htm
  23. UN test resultshttps://www.hse.gov.uk/explosives/classification/un-test-results.htm
  24. UN test series FAQshttps://www.hse.gov.uk/explosives/classification/faq-conducting-un-test-series-6.htm
  25. Analogyhttps://www.hse.gov.uk/explosives/classification/analogy.htm
  26. Non-contracting partyhttps://www.hse.gov.uk/explosives/classification/non-contracting-party.htm
  27. UN default scheme for fireworkshttps://www.hse.gov.uk/explosives/classification/un-default-scheme-fireworks.htm
  28. How to applyhttps://www.hse.gov.uk/explosives/classification/how-to-apply.htm
  29. Overview - Fireworkshttps://www.hse.gov.uk/explosives/fireworks/index.htm
  30. Firework displayshttps://www.hse.gov.uk/explosives/fireworks/using.htm
  31. Storing and selling fireworkshttps://www.hse.gov.uk/explosives/fireworks/industry.htm
  32. Transfer of explosiveshttps://www.hse.gov.uk/explosives/transfer-of-explosives.htm
  33. Overview - Ammonium nitratehttps://www.hse.gov.uk/explosives/ammonium/index.htm
  34. Ammonium nitrate and COMAHhttps://www.hse.gov.uk/explosives/ammonium/comah.htm
  35. Storage of ammonium nitrate blasting intermediate (ANBI)https://www.hse.gov.uk/explosives/ammonium/storage-ammonium-nitrate.htm
  36. Notification thresholdhttps://www.hse.gov.uk/explosives/ammonium/notification-threshold.htm
  37. High nitrogen contenthttps://www.hse.gov.uk/explosives/ammonium/high-nitrogen-content.htm
  38. Land use planninghttps://www.hse.gov.uk/explosives/ammonium/land-use-planning.htm
  39. Discarding and disposalhttps://www.hse.gov.uk/explosives/disposal.htm
  40. Reporting losshttps://www.hse.gov.uk/explosives/reporting-loss.htm
  41. Placing civil explosives on the markethttps://www.hse.gov.uk/explosives/ce-marking/index.htm
  42. Market surveillancehttps://www.hse.gov.uk/explosives/market-surveillance.htm
  43. Record keeping requirementshttps://www.hse.gov.uk/explosives/record-keeping.htm
  44. Manufacture, storage and carriage of thermiteshttps://www.hse.gov.uk/explosives/manufacture-storage-carriage-of-thermites.htm
  45. Overview - Other topicshttps://www.hse.gov.uk/explosives/other.htm
  46. Exemptionshttps://www.hse.gov.uk/explosives/exemptions/index.htm
  47. Record of explosives incidentshttps://www.hse.gov.uk/explosives/eidas.htm
  48. Identification and traceability https://www.hse.gov.uk/explosives/traceability-itoer.htm
  49. Applying for a Site Identification Codehttps://www.hse.gov.uk/explosives/applying-for-site-identification-code.htm
  50. Overview - Resourceshttps://www.hse.gov.uk/explosives/resources.htm
  51. Formshttps://www.hse.gov.uk/forms/explosive/index.htm
  52. Publicationshttps://www.hse.gov.uk/explosives/publications.htm
  53. Useful linkshttps://www.hse.gov.uk/explosives/useful-links.htm
  54. Contactshttps://www.hse.gov.uk/explosives/contact.htm
  55. The UK has left the EU, and some rules and procedures have changed from 1 January 2021https://www.hse.gov.uk/explosives/ce-marking/index.htm
  56. ADRhttps://www.unece.org/trans/danger/publi/adr/adr2019/19contentse.html

Is this page useful?

Updated 2024-06-12