UK: Carriage of military and commercial explosives

UK Maritime and Coastguard Agency issued a Marine Guidance Note concerning the carriage of military and commercial explosives.

This note was published on 23 May 2024.

This is a notice to all Operators, Shipowners, Agents, Charterers, Managers, Masters, Ship’s Officers, Cargo Packers, Cargo Consolidators, Consignors, Hauliers, Freight Forwarders, Shippers, Port Authorities, Maritime Administrations, Terminal Operators, and other parties involved in the transportation of military and commercial explosives by sea.

This notice should be read with the Merchant Shipping (Carriage of Dangerous Goods and Harmful Substances) (Amendment) Regulations 2024.

Introduction:

1.1 To transport dangerous goods meeting the description of Chapter 2.1 of the IMDG Code for Class 1 (explosives), they must be classified in accordance with the UN Manual of Tests and Criteria.

1.2 Prior to transport, the classification of all explosive substances and articles, together with the compatibility group assignment and the Proper Shipping Name under which the substance or article is to be transported, shall have been approved by the competent authority of the country of manufacture.

1.3 The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 describe the role of the Health and Safety Executive (HSE) as the Competent Authority for Great Britain and explains the security and carriage responsibilities for the transport of explosives.

Military Explosives:

1.4 Military explosives as defined at paragraph 1.1 of Annex A of this document are classified by the Secretary of State for Defence, devolved to The Defence Ordnance, Munitions and Explosives Safety Regulator (DOSR). All other explosives, including military munitions that do not meet the definition of military explosives as defined at paragraph 1.1 of Annex A, are either classified by the HSE or the Competent Authority in the IMDG Code. Certain specific provisions detailed in Annex A apply solely to military explosives.

The Merchant Shipping (Carriage of Dangerous Goods and Harmful Substances) (Amendment) Regulations 2024:

2.1 The Merchant Shipping (Carriage of Dangerous Goods and Harmful Substances) (Amendment) Regulations 2024 (“the 2024 Regulations”) entered into force on 11 June 2024, substantially replacing the Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997.

2.2 The 2024 Regulations implement the requirements for the carriage of dangerous goods and harmful substances in packaged form, giving effect to the IMDG Code. The IMDG Code sets out in detail the requirements applicable to each individual substance, material, or article, providing instruction on classification, consignment and carriage including packing, stowage, labelling and the segregation of incompatible substances transported by sea.

Government Authorised Explosives Representative (GAER):

3.1 The GAER is a member of the Armed Forces, or a Civil Servant appointed by the Ministry of Defence (MoD) and is required for the loading and unloading of military explosives to a vessel and has overall responsibility for ensuring that all military explosives are received and despatched to and from the port. The GAER understands the hazards and risks from the different military explosive natures and is present to ensure correct procedures are adhered to during the handling and stowage of military explosives. Appendix 1 to Annex A lists the duties of the GAER.

3.2 The GAER should liaise with the port prior to the arrival of the military explosives, so all those involved are aware of the plans for the handling and stowage of the military explosives.

The Annex A outlines the Ministry of Defence requirements regarding the handling and transportation of military explosives. It defines "military explosives" and provides specific conditions for their movement, including restrictions on mixed loading with commercial explosives and the requirement for a Government Authorised Explosives Representative (GAER) to be present during handling.

The Appendix 1 to Annex A details the duties of the GAER, including ensuring safe movement of military explosives, pre-planning with the Harbour Master, checking stowage arrangements, verifying firefighting and emergency plans, and ensuring compliance with packaging and documentation requirements. The GAER is also responsible for reporting any concerns or violations observed during the movement of military explosives.

All regulations can be found at legislation.gov.uk

For more information, please see the document below (available only to subscribers):