Explosive License for UK offshore disposal operations

I work for a German EOD/UXO company and have been asked to seek guidance/information if the German company work within UK territorial waters what  explosive license is required to carry out disposal operations offshore? Can the German (EU) state explosive license be accepted or will I have to apply for the license as a UK citizen and company representative. The German company will not require a storage or transportation license as this area of concern will be covered by a third party licensed UK company.

If the third party UK licensed company were to be in attendance during the offshore UXO disposal operations will this suffice as regulatory compliance?

7 answers

  1. Answered by Mark Weatherbe

    I believe that the correct answer is that anyone working for a holder of an RCA, (Recipient Competent Authority), which is the UK explosives holding license. Can use the explosives that are listed on the RCA, i.e. det cord, dets, devices, etc.

    Transport is a separate matter as is insurance, but UK law only requires the RCA for the employer of operator if they are a soul trader.

    Anyone who wants to correct me if I’m wrong please feel free to jump in here…

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  2. Answered by Michael Archer

    Along with the above there needs to be a Marine Management Organisation licence issued to cover the scope of the disposal.

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    • Mark Rogers

      Where/Whom do I apply for the Marine Management Organisation licence Michael?

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  3. Answered by G C Sen

    I have no knowledge in that area. Sorry

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  4. Answered by Mark Ribbands

    This is a difficult one. If you don’t need storage or transport of, for example, new-stock explosives for demolitions, I suspect that legally it would depend on whether you are actually taking possession of any EO you find (if it’s an EOD task).
    If you have a partner UK company who have their own Explosives Certificate to acquire and keep then you should be able to operate as a ‘servant’ of the UK company, in much the same way that firearms legislation operates. You allude to this in your final paragraph. I suspect that if an investigation of regulatory compliance was to occur (unlikely) then much would depend on the contractual arrangement in existence between the two parties.
    BTW, all this has nothing to do with the ‘RCA’ mentioned earlier; that’s a historic EU requirement to permit the transfer of explosives between parties, now automatically issued as a rubber-stamp exercise on the back of all UK Explo certs, and is very much secondary thereto. An RCA alone (and I’m not sure it’s possible to be issued with one alone) does NOT, at least in the UK, permit anyone to have possession of explosives.
    Good luck!
    Mark
    Ribbands Explosives, Norfolk, UK.

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  5. Answered by Anthony Slate

    To a certain degree it depends upon how you intend to organise the work. There is an approach relative to shipping your explosives direct from the EU to the place of use in territorial waters and a different one if the explosives to be used for the EOD work are brought to the UK and then shipped offshore to be used. I am assuming the work is of this nature and not relating to activities which are currently carried out in inshore waters. It would be helpful in formulating an answer if you could elaborate on the activity. If that is not possible, then I can only lay out for you the different scenarios and that may be a lengthy piece which may not suit the amount of space available here.

    Regards
    Tony

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  6. Answered by Mark Rogers

    Thank you to all respondents.
    The company vessel would arrive empty of explosives and load within a UK port via a registered UK company providing explosives etc under their own UK licence, I would apply for the Acquire & Keep licence for the offshore UXO disposal operations. DNVL explosive storage containers will be used and the MCA will be informed of vessel and operating areas governed by the contract of works. The vessel will have a licence to carry explosives. No UXO found on the seabed will be recovered to the deck of the vessel.
    Do I need to do more?

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