Bulletin # 53

June 2009

Safety and Security Plan for Sellers of Ammonium Nitrate

The purpose of this bulletin is to provide guidance to sellers of ammonium nitrate for complying with section 22(2) of the Restricted Components Regulations (RCR).

Section 22(2): A seller must have a written safety and security plan that identifies the emergency procedures and the person who is responsible for carrying out each procedure, for all major risk events including security-related events. The plan must be updated every 12 months.

The safety procedure requirements are generally well understood by the sellers and are already in place and covered in their emergency response plans. This emergency response plan is usually shared with local police and fire departments.

Specifically, this bulletin provides guidance on the minimum requirements that must be met to achieve compliance with the security portion of the overall safety and security plan for sellers of ammonium nitrate. There is no obligation under the RCR to make this plan available outside the seller’s premises.

Overall requirements for the safety and security plan

• When an emergency response plan addressing the safety emergency procedures is already in place, there is no need to duplicate it in the safety and security plan specific to ammonium nitrate. However, a reference to it must be made.
• Assign the person who will be responsible for carrying out each procedure in the safety and security plan.
• The safety and security plan for ammonium nitrate must be updated every 12 months. If the safety procedures are part of a broader emergency response plan, they still must be updated every 12 months.
• All revisions made in the annual updates must be documented.

Minimum requirements for the security portion

The six sections below set out the minimum requirements for ammonium nitrate security and the related records (both paper and electronic) for the security portion of the safety and security plan for ammonium nitrate.

• Control access to product – s.23 (b): Determine who must have access to the ammonium nitrate and describe why, how and to what extent you control access.
• Control access to sales records – s. 30(2): Determine who must have access to the records (both paper and electronic), and describe why, how and to what extent you control access.
• Control keys that provide access to product – s.22 (1): Describe how you secure the ammonium nitrate. Determine how many keys/passwords must be available and to whom, how these keys/passwords are assigned, and how and where they are protected and by whom. Include what is done in the case of departures, changes in authority, and loss of keys.
• Control keys that provide access to sales records – s.30 (2): Describe how you secure these records (both paper and electronic). Determine how many keys/passwords must be available and to whom, how these keys/passwords are assigned, and how and where they are protected and by whom. Include what is done in the case of departures, changes in authority, and loss of keys.
• Stock control – s.25 & 26: Describe your stock management system, including who is assigned to perform the annual inventory. Determine who will perform and keep records of the weekly inspections, and determine where the records describing the reasons for any loss of ammonium nitrate will be kept. Describe your process in the event of theft, tampering or attempt to steal, and since these events must be reported immediately to local police and to the Chief Inspector of Explosives in writing within 24 hours, add their contact information (phone number for police and address for Chief).
• Sales control – s.27: Describe how you will prevent sales a) if the quantity is not proportional to the purchaser’s needs, or b) if you have reasonable grounds to suspect that the product will be used for criminal purposes. As all refusals to sell must be reported to local police and to the Chief Inspector of Explosives within 24 hours, add their phone numbers.

* For more information, consult the Restricted Components Regulations on the Explosives Regulatory Division site at http://laws-lois.justice.gc.ca/eng/regulations/SOR-2008-47/index.html

Chris Watson, Ph.D.
Chief Inspector of Explosives