WorldWide Drilling Resource

Northern Plains Chapter of the ISEE President: Ron Eastman Tel: 307-680-8805 www.npcisee.org 29 WorldWide Drilling Resource ® AUGUST 2013 Most Frequent Explosives Violations Adapted from information provided by the Bureau of Alcohol, Tobacco, Firearms, and Explosives Although most in the explosives in- dustry make every effort to comply with Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) regulations, vio- lations do occur. Violations discovered during inspections provide an opportu- nity for companies to evaluate their pro- cedures and implement changes to improve operations. It also gives ATF investigators the chance to work with industry members to suggest better ways to secure and account for explosives. The following are the six most fre- quently-cited violations during ATF in- spections from 2006-2011: At the top of the list is failing to maintain accurate explosives magazine inventory records vital to explosives accountability in the event of a theft or loss . This accounted for approximately 25% of the total violations cited in 2011, down from 37% in 2007. The second also pertains to record- keeping, failing to maintain accurate ex- plosives acquisition records critical to ensuring traceability of explosives in the event of theft or loss . Coming in third is failing to meet housekeeping requirements that ensure explosives storage magazines, in part, are kept clean, dry, and free of volatile materials within 50 feet . Failing to report changes to respon- sible persons (RPs) or employee posses- sors (EPs) was the fourth most citedATF violation. New RPs and EPs must be re- ported to the Federal Explosives Licensing Center within 30 days. The last two on the list pertain to magazines and explosives storage. Failing to ensure sufficient distance between ex- plosives storage magazines and inhabit- ed buildings, public highways, passenger railways, and other magazines . The table of distances can be found in 27 CFR, Part 555, Subpart K. Unlawful storage is also among the top six most frequently-cited violations. Remember, explosive materials must be kept in appropriate magazines meeting specified construction, locking, house- keeping, and table of distance require- ments. The only exceptions are: it is in the process of being manufactured; being physically handled in the operating pro- cess; being used; or being transported to a place for storage or use. Here are some tips for keeping your explosive materials safe and avoiding ATF violations. Educate employees on federal ex- plosives regulations and requirements. Many times, the employees responsible for day-to-day operations have not attend- ed the most recent industry conference, or visited the ATF Web site for regulatory updates. It is up to you to pass along any new information to those in your organ- ization responsible for explosives oper- ations. Most Frequent cont’d on page 30.