WorldWide Drilling Resource

ATF Answers Questions for the Drilling Industry Adapted from Information by the U.S. Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) Question : When referring to the transfer from the drilling company to the geophysical company, does this refer to when the geophysical company takes control of the buried charges to begin setting up to detonate the materials? Answer : Yes. When a geophysical company arrives at a site and takes con- trol of a site, or a portion of it, the company receives the materials. This change of control over the explosive material is a distribution and requires the drilling company have a dealer’s license and maintain records of distribution as required under 27 CFR § 555.124. Question : Does each employee of a drilling company need their own separate dealer’s license? Answer : No. The drilling company would maintain a federal explosives license (FEL) and the individual drilling profession- al/employee would work as an Employee Possessor (or Responsible Person) under the license. Question : We have been operating under our company’s User Permit for our drilling operations, do we need to change this to a dealer’s license now? Answer : You typically would need a dealer’s license to conduct these explosives distributions. However, because the ATF (Bureau of Alcohol, Tobacco, Firearms, and Explosives) only recently clarified this issue, ATF is not requiring drilling companies with permits immediately acquire a license instead. Rather, companies may wait until the next renewal to make the change. However, you should immediately begin to maintain the records required under 27 CFR § 555.124. Question : After we drill the shot hole and load the material at the bottom, the void is plugged and filled. The drilling company then tests the detonator wires, but there are times when the geophysical company comes back later to detonate the charge and discovers the detonator will not initiate the charge, or the path to the detonator has been damaged. What do the regulations require the geophysical company do with the charge that will not initiate? Answer : The regulations don’t specifically address charges that don’t initiate. However, ATF provided some guidance on How to Address a Loss in the December 2014 ATF Explosives Industry Newsletter. It reads, in part, Explosives licensees and permittees must complete and send an ATF Form 5400.5, Report of Theft or Loss - Explosive Materials to ATF as well as notify the local authorities, under the following examples . . . If the materials cannot be retrieved be- cause they are inaccessible, and all attempts to retrieve and/or destroy the materials ATF Answers cont’d on page 34. 25 WorldWide Drilling Resource ® JUNE 2017 WWDR photo.