Explosives and desensitised explosives

Under the Explosives Regulations 2014, explosive means:

(a) any explosive article or explosive substance which would —

if packaged for transport, be classified in accordance with the United Nations Recommendations as falling within Class 1; or
be classified in accordance with the United Nations Recommendations as —
- being unduly sensitive or so reactive as to be subject to spontaneous reaction and accordingly too dangerous to transport, and
- falling within Class 1; or

(b) a desensitised explosive, means:

a solid explosive substance which has been wetted with water or alcohol or diluted with one or more other substances; or

a liquid explosive substance which has been dissolved or suspended in water or one or more other substances, to form a homogeneous mixture so as to suppress its explosive properties and which, without that treatment, would be classified in accordance with the United Nations Recommendations as falling within Class 1.

Those wishing to obtain and use explosives may need to apply for an explosives certificate and a licence and should notify the Regulatory compliance team of their intent. Also, before the expiration of the licence, the responsible holder is further expected to notify the Regulatory Compliance Team of the necessary licence renewals.

Certificates are issued by the Police and are used to confirm that a person is fit to acquire or to acquire and keep explosives. Licences grant permission to manufacture or store explosives and are issued by a number of authorities. In most cases, licences to store at the University will be issued by either the Police or the Greater Manchester Fire and Rescue Service or Health and Safety Executive (HSE); see the HSE licence application guidance page for more information.

Please note that there are some exemptions to the need for certification and for storage of licences:

The maximum amount that can be kept without a licence refers to an individual's possession and NOT the cumulative possession by a building or by a School / Department.
Schedule 2 to the regulations lists the substances that do not need a certificate to acquire or keep. The schedule is in two parts, part one is a list of explosives not requiring an explosives certificate and although similar to the old Schedule 1 of COER there are some differences. The second part of the schedule entails further list of explosives and it is a more descriptive account of explosives not requiring an explosives certificate.

The most relevant sections for University staff are likely to be:

Any desensitised explosive acquired, in a quantity not exceeding 5 grams, for the purposes of —

(a) research, analysis or testing at a University

A solution of the explosive substance 2,4, 6-Trinitrophenol (picric acid) in a concentration no greater than 2% weight per volume intended for use as an analytical reagent, stain, dye or fixative.

Exceptions to the need for a manufacturing licence can be found in Regulation 6 of the 2014 regulations

Exceptions for storage licences are described in the HSE website:

Storage exemptions are typically short-term, and depend on the hazard type of the explosive. Hazard type is not an inherent property of a substance, as it depends on a number of factors such as the quantity of substance, how it is packaged, and how it is stored. Guidance on determining hazard type is available online from the HSE. One of the more important exemptions for University staff is that no more than 5kg of hazard type 3 or 4 substances which are in Schedule 2 can be kept without a licence indefinitely.

A HSE certificate of exemption is available for the storage of 2,4-Dinitrophenylhydrazine (commonly known as 2,4-DNP or 2,4-DNPH, which has the chemical formulation C₆H₃(NO₂)₂NHNH₂) providing that the following conditions are met:

(a) the explosive (2,4-Dinitrophenylhydrazine) is –

(i) wetted with not less than 30% water, by mass and allocated in accordance with the United Nations Recommendations the U.N. No 3380; or

(ii) dissolved in ethanol and sulphuric acid and allocated in accordance with the United Nations Recommendations the U.N. No 3379; or

(iii) dissolved in ethanol and phosphoric acid and allocated in accordance with the United Nations Recommendations the U.N. No 3379; and

(b) the total quantity of the explosive (2,4-Dinitrophenylhydrazine) must not exceed 25 grams when –

(i) wetted with not less than 30% water; or

(ii) dissolved in ethanol and the permitted acid for preparation of an analytical reagent; and

(c) the explosive (2,4-Dinitrophenylhydrazine) may only be acquired and kept by, and at, relevant educational institutions to be used only for chemical testing purposes as part of an educational activity.

Please remember – an exemption from the need to obtain a certificate does not automatically mean that a licence is not needed, and vice versa. The licencing and certification streams run in parallel, but are used for different purposes and in many cases both will be required.

Explosives guidance

HSE's guidance has been issued, and the HSE also has documents available on safety and security. Subsector guidance is also available, but higher education-specific guidance has yet to be issued.

What legislation applies?

Issued: 22 May 2017; Last reviewed: May 2025 Next review: May 2026