Classification for transport

Explosives: update

The UK has left the EU, and some rules and procedures have changed from 1 January 2021.

Explosives are dangerous goods.

All explosives must have been assigned a classification by the Competent Authority of a Contracting Party to the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR) before they are consigned for carriage by road in Great Britain.

Chapter 2.2 of ADR describes the requirements for the classification of explosives, as interpreted by the 2011 amendments introduced at Regulation 3 of the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG).

This section describes the role of HSE as the Competent Authority for Great Britain, and explains the responsibilities of any person, eg importer or manufacturer, wanting to transport explosives in Great Britain, and the additional duties under the European Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (the CLP Regulation or CLP) and the European Registration, Evaluation, Authorisation & restriction of Chemicals Regulation (REACH).

Who are the Contracting Parties to ADR?

The Contracting Parties are published on page 'vi' in the Foreword section of ADR.

What is classification?

'Classification' is a technical process that identifies and considers the hazards posed by explosive substances and articles as packaged for transport.

The Competent Authority of a Contracting Party to ADR must assign the classification of explosive materials before they can be transported by road within Great Britain. The process involves assessing an explosive to determine whether or not there is a danger of fire/explosion that would jeopardise safe transport in terms of:

thermal stability ie the response to heat and flame
sensitiveness towards mechanical stimuli ie the response to impact and friction
response to dropping an unpackaged article, packaged article or packaged substance from a height of 12 metres.

The final stage of the process is to assign the explosive to – or exclude from – Class 1 of the UN classification scheme for the transportation of dangerous goods by assessing its behaviour in terms of:

mass explosion of a single package
propagation potential towards other packages or from a non-packaged article to another
mass explosion, dangerous projections, radiant heat, violent burning or other dangerous effect when packages are involved in a fire
hazardous effects outside the package arising from accidental ignition or initiation of contents

An explosive assigned to Class 1 is given an appropriate UN Serial Number, hazard division and compatibility group, depending on its composition, type, and hazard.

A Competent Authority is a body designated or recognised to carry out duties under transport of dangerous goods regulations. In Great Britain:

HSE is the Competent Authority for the classification of non-military explosives
Military explosives, ie explosives under the control of and/or in connection with the execution of contracts for the Secretary of State for Defence are classified by the Explosives Storage and Transport Committee (ESTC) of the Ministry of Defence

Once the Competent Authority has agreed the classification, it issues a Competent Authority Document (CAD).

For further detail see the Industry Guide and Code of Practice on the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (as amended) (CDG).

What is HSE's role in classification?

As Competent Authority, HSE:

assigns classification of non-military explosives where a CAD does not exist
recognises the classification of explosives whose classification has been assigned by the Competent Authority of a country that is not a Contracting Party to ADR
issues a CAD, which records the classification granted, and any appropriate conditions

How are explosives classified?

Explosives may be assigned a classification by one of the following methods:

on the basis of UN test results and information supplied
by analogy with a similar explosive previously classified by HSE or the Explosives Storage and Transport Committee (ESTC)
technical argument through documentary evidence
by recognising the classification assigned by the Competent Authority of a country that is not a Contracting Party to ADR.
for fireworks that are manufactured in Great Britain or a country that does not have a Competent Authority – UN default classification scheme

What does the importer / manufacturer have to do?

The importer / manufacturer is responsible for either:

holding a valid CAD from Competent Authority of a Contracting Party to ADR. A copy of the original CAD, that clearly identifies the item, should be kept and be available on demand
completing the appropriate application form and submitting it to HSE with the required documentation, and supporting evidence for a proposed classification. This should clearly identify the hazards associated with the explosives as packaged for transport
Find out how to apply for classification

CLP and REACH

Explosive substances and articles must also be classified under CLP.

CLP requires manufacturers and suppliers to provide their customers with information about the hazards associated with their products and to package them safely.

REACH requires safety data sheets (SDSs) to be provided. REACH is a European system for regulating chemicals imported into the EU in quantities greater than 1 tonne.

The detailed CLP and REACH requirements are separate to the explosives classification process.