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The identification and traceability of civil explosives in Europe

By Ashley Haslett, Dangerous Goods Tracking Ltd

In the latter part of 2004, following a number of high-profile terrorists attacks within Europe, political opinion emphasized the need for greater control over access to explosives. The European Commission (EC) initiated discussions with the Federation of European Explosives Manufacturers (FEEM) to improve the security of explosives within the European Union (EU). With the support of the FEEM executive, a FEEM Security Working Group was established, with many of its members nominating personnel to participate in the future development of security in the industry.

At the outset, the EC sought to limit terrorists’ access to explosives by:

  • Considering marking/tracking of explosives.
  • Implementing greater control of ex-military explosives.
  • Determining the extent of risk.
  • Improving the detectability of explosives/detonators.

As support grew, an EC working group was established – the Explosives Security Experts Task Force – comprising representatives from many European countries, eg national authorities, security agencies and industry. Over a period of months, this group made a total of 55 proposals, one of which became the European Directive entitled: ‘The Identification and Traceability of Explosives for Civil Uses’. This article relates solely to how this Directive is being met, its transposition into national legislation throughout the EU and its interpretation by the industry and individual companies.

The Directive on the identification and traceability of explosives came into effect on 4 April 2008. It is intended to establish a harmonized system for the unique identification and traceability of all packaged explosives, detonators, reels of detonating cord and primers used in civil applications across the EU. The Directive was to have been adopted into the national legislation of each EU member state by 5 April 2009, with compliance achieved throughout Europe by 5 April 2012. In reality, however, many of the national authorities failed to achieve the target date of April 2009, illustrating the difficulty many countries faced in drafting, consulting and implementing the requirements within the short time frame. This in turn placed greater pressure on the industry to meet the implementation date of April 2012, and so, in October 2010, an application was made to the EC for an extension of the implementation date. At the time of writing, no decision has been reached on the extension, or on any conditions that may be associated with it, but it is likely that the date will be extended until at least 2015.

The requirements of the Directive apply to all civil explosives manufactured, used and imported into the EU from the implementation date. In summary, the Directive requires:

  • Unique, readable identification for each explosives article.
  • A means of recording information on each uniquely identified article throughout the supply chain and life cycle.
  • Retention of all information relating to the unique article during its life cycle for a period of 10 years.
  • Regular testing of the data collection to ensure the effectiveness of the storage system and quality of the data recorded.
  • Competent authorities to be provided with information on any unique article upon their request.
  • Appointment and disclosure of contact details of a person who can provide information on any unique article outside of working hours.

Unique readable identification

The European legislation states that all packaged explosives for civil uses must be uniquely identified and tracked at every stage throughout their life cycle. This requires every explosives cartridge, detonator, reel of detonating cord and primer manufactured or sold within Europe to have a visible and readable unique number either on a label or printed directly on to the item, with a barcode or RFID tag and an associated data-capture/recording/reporting system as of April 2012.

It is obvious, however, that a label on an explosives article can be easily removed, ending the possibility of any further traceability from that point onwards. Therefore, the question arises as to why implement such a solution when it is evidently fundamentally flawed. There are two responses to this, one being that this legislation is politically motivated, such that measures must be implemented to demonstrate that actions have been taken. The second is that, in the past, labels have not always been removed from commercial explosives that have been acquired and used by terrorists. The terrorists expect the explosives devices to initiate and thus leave no evidence of the unique number.

Moreover, the fact that an identifiable explosives article is discovered within a terrorist explosives device does not provide clear evidence for a conviction. Commercial explosives have been recovered by chance in misfired muckpiles and misappropriated by persons not engaged in work on the site. Regardless of whether or not readers agree with this aspect of the effectiveness of the Directive, it is legislation and must be complied with.

The label attached to each explosives article, or printed on it, must bear a unique number. The Directive does not specify the structure of the number other than a requirement that the first two digits must indicate the country of manufacture or where first imported into the European Union, eg UK, AT, FR etc, and the third, fourth and fifth digits must indicate the manufacturing site within the country indicated by the first two (this number is allocated by the national authority, eg 001). From this point onwards, within the number applied, it is for each company to design and implement a system of unique numbers for its own products, down to individual item level.

Recording information – traceability of articles

At the most basic level, it is conceivable that the data-capture system is nothing more than a pen and paper, maintaining a record of which explosives are present in a magazine at any time and when each article is used. As transactions and volumes increase, however, this quickly becomes unworkable and some other technological solution for data-capture becomes necessary. Two forms of technology are immediately apparent, the first being radio frequency identification (RFID). While this has many significant advantages, the major disadvantage of cost per unit overrides the advantages at the cement time. Industry is required to self-fund the legislative requirements and therefore RFID would become cost-prohibitive unless it was mandatory for all companies to adopt it, but this is not the case. A hybrid system using RFID at pallet/container level with barcoding at case and unit level could be adopted.

An alternative technology is barcodes. These are widely used on a daily basis and the structure of such a code system initially appears relatively easy. Other industries use them to move products in their millions, across continents and between different industries. Barcodes generally include fields such as date of manufacture, product code, batch number, pallet number and case number. However, what the European explosives industry is being required to do – ie traceability at individual item level – is not what barcodes are normally used for. They are generally used for ‘batch’ traceability.

The implementation of barcodes for traceability is easy when the entire supply chain is within one environment or database structure. Difficulties arises, however, because customers generally purchase from a range of suppliers, all using different code structures that are incompatible with each other. The customer in this situation would have to operate a different database for each supplier, resulting in a chaotic and unworkable system. If an in-house IT expert were available, with ongoing changes the system could be made to work but it would be labour intensive.

The solution to barcode harmonization between all companies and supply chains has been achieved with the adoption of ‘application identifiers’. In effect, these are prefixes prior to fields of information that allow databases to recognize the information and place it in the appropriate location in the database. The European Explosives Code Structure allows the harmonization of explosives coding throughout Europe.

Having created a Standard of application identifiers (AIs), systems can then be developed and implemented to capture data at the point of manufacture, allocate storage locations, change storage locations, book stock out to customers, track material in transit, implement point of receipt proof etc. All of this can be done in real time, in batches or a combination of the two. Reports can be generated to provide all the information needed to meet the legislative requirements, but opportunities to improve existing quality-control systems, inventory management, factory licence compliance and monitoring of efficiency also arise.

The format of the type of barcode used (either one dimensional or two dimensional) is optional, but in reality a two-dimensional (matrix) barcode is more likely to be adopted, given that it can contain a significantly greater quantity of data within a small area. A one-dimensional barcode containing five or six different fields and application identifiers will be too long for a practical sized label. Two-dimensional barcodes also have the advantage of being more reliable to read.

Should an article be recovered from a terrorist device, if the label is available, the country and number of the manufacturing site (the first five digits of the code) will allow the authorities to commence their investigation. They would then progress down the supply chain records to determine the last point at which the article with the unique number was known to have been secure.    

Retention of information

It is a requirement that the records of every uniquely identified article are maintained and available for inspection for a period of 10 years. In effect, this means that every European company receiving explosives after 5 April 2012 will have an obligation to maintain details on every article that they have received after that date, for a period of 10 years. With software updates being a regular occurrence nowadays, it becomes imperative for each company to ensure that after each upgrade it can continue to access the information dating back 10 years. This has not always been possible in the past, but will be a requirement for the future.

This requirement may have another effect in that small sites with magazines may decide to cease storing material altogether. If they reach an agreement with their explosives supplier that all explosives supplied will be used or destroyed on the day of delivery, the explosives supplier’s records will spare them the onerous task of retaining the records themselves. If a company ceases trading, it is likely that the national authority will have to assume responsibility for the retention of a database up until the point of closure. The Directive does not specify how this should be done, but national legislation will define the requirements.

Testing of data

There is an obligation on every company handling explosives articles to ensure that the data relating to all transactions is available and kept safe. This will require procedures to be implemented that regularly backup all data, verify that the data can be retrieved and restored and that the backups cannot be destroyed, and that these are available if necessary. The Directive specifies that the data must be protected from accidental or malicious damage, indicating that a robust process is required. The Directive does not specify a timeframe for regular testing of the data, but national legislation may do so.

Availability of information

Each company handling explosives will be required to provide contact details of a person capable of providing information on any article handled over a 10-year period. In effect, the Directive specifies that a 24h helpline must be available. Whether this is ever actually used remains to be seen, as any investigation after an explosives find is unlikely to progress so quickly that it would require an out-of-hours contact. 

Implications for the quarrying industry

Prior to the implementation date, quarry sites will receive packaged explosives items bearing a unique identification number. From the implementation date there will be an obligation to maintain a record of where the explosives are at all times. If there is no on-site storage, it may be permissible to rely on the suppliers’ records, but this has yet to be clarified by the Health and Safety Executive. With a storage facility, there will be an obligation to maintain comprehensive records of receipt of each item. As items are packaged, it is unlikely that the quarry staff will be prepared or permitted to unpack the items in order to capture the data relating to each item.

Stock management systems have been developed that will allow all of the data down to individual item level to be e-mailed to the quarry via electronic data interface files. Upon receipt of the actual delivery, the number of cases would be confirmed via a signature on either a delivery docket, as currently, or by proof of delivery on a PDA or similar item of equipment. The case numbers would then be scanned to a storage location or, alternatively, using the electronic file, the item-level data uploaded to the customer’s own database, populating the actual storage locations where the material is being stored. As material is moved for use, stock movements could be initiated either by the use of barcode scanning equipment or by manual adjustment of the database to maintain full traceability of the stocks.

Each label on every item will bear a readable code and also a two-dimensional barcode. The code itself consists of many fields, of which the visible code will only contain two of these fields. The European Explosives Code Structure was developed by DG Tracking, in association with the main European explosives manufacturers and latterly FEEM. This allows the data from any manufacturer to be recognized and uploaded into a common database. It uses application identifiers that have been agreed as a common standard for the industry.

The readable number will start with five digits, the first two being letters to indicate the country of manufacture, while the following three numeric digits indicate the site within the country from where the product originated. If the item is found, it is at this location that the police will check the database and identify where the item was dispatched to. They will follow the chain of dispatch to the last known point to determine how it was misappropriated. 

The stock-management system used by the quarries will also have the capability to allow items that have been scanned to a particular shotfirer, to be returned, either in an existing numbered case or a newly labelled case, permitting true traceability at item level on a day-to-day basis and allowing material to be quarantined, moved between stores or returned to the supplier.

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