Explosives

Natural Resources Canada and the Explosives Act in the Context of Canadian Environmental Assessment Act

Natural Resources Canada’s involvement in environmental assessment among others, results from the application of certain Acts under the authority of the federal Minister of Natural Resources. One of these Acts that can trigger the Canadian Environmental Assessment Act is the Explosives Act which regulates the manufacturing, testing, sale, storage, transportation and importation of explosives as well as the use of fireworks.

Specifically, by virtue of this Act, Natural Resources Canada (NRCan) could become involved in the environmental assessment (EA) of projects by issuing, if required, a licence for the manufacture (i.e., factory) and/or storage (i.e., magazine) of explosives (Section 7(1)(a) of the Explosives Act).

The issuance of such a licence could be subject to federal EA requirements under the Canadian Environmental Assessment Act (CEAA). Under CEAA, an EA requires that all environmental effects of a project be taken into consideration before a decision is made concerning its implementation.

Steps 1 and 2 of this questionnaire are intended to assist project proponents and NRCan in determining whether a licence under Section 7(1)(a) of the Explosives Act is required and whether this triggers an EA under the CEAA. Step 3 provides additional guidance on NRCan’s EA requirements should one be required.

Step 1

Will explosives be used?

Yes No

If the answer is “Yes” please proceed to Step 2 by answering the following questions on explosives which would help NRCan determine its responsibilities under the CEAA:

Step 2

  1. Identify the project title, location and proponent name.
  2. Description of the production of explosives.
  • Is a factory to make explosives required at or near the site? Please explain a
  • Will this project use an existing factory license for its operations? Please explain a
  • Will a temporary explosives factory be used for the project? Please explain b
  • Description of the storage of explosives
    • Is a magazine(s) to store explosives required at or near the site? Please describe (i.e., footprint, type of storage structure, site access, other ancillary works) c

    Based on the answers to the above questions, NRCan may require an environmental assessment under CEAA for the project before issuing a licence for the manufacture and/or storage of explosives. THE PROPONENT WILL BE INFORMED BY NRCAN OR ANOTHER FEDERAL AUTHORITY ON WHETHER AN EA WILL BE REQUIRED FOR THE EXPLOSIVE FACTORY/MAGAZINES.

    If an EA is required, please proceed to Step 3 for explosive–related information that will need to be included in the environmental assessment.

    Step 3

    Environmental Assessment Information Requirements

    The following information is required for completing the environmental assessment of the factory/magazines:

    • Explosives to be manufactured (typically ammonium nitrate fuel oil (ANFO) and/or emulsion/watergel). Note that if the proponent initially specifies ANFO and decides to add emulsion as the project proposal is further developed, the potential environmental effects of the project are not likely to be affected, as effluents and other aspects relevant to the assessment will not change.
    • Maximum quantity of explosives at each facility.
    • Infrastructures for manufacturing or storing explosive should be identified and include: explosives and innovation systems magazines, fuel storage, ammonium nitrate storage, maintenance/wash area, process vehicles and their parking area, any offices, warehouses, buildings, etc.
    • Specified location (i.e., detailed site plan) of the various components of the facilities, with distances to vulnerable features such as dwellings, roads, camps, railways, bodies of water, etc. The proponent needs to demonstrate that safety distances required by the Explosives Regulatory Division (ERD) of NRCan have been considered and met.
    • Fuel and ammonium nitrate storage plans. Storage of ammonium nitrate is to be in conformance with ERD guidelines.
    • Liquid effluent disposal plans.
    • Evaluation of worst case scenario (i.e. accidental explosion).
    • Spill contingency plans.
    • Details on any temporary explosive facilities to be used for starting the project must be provided, giving the same information requirements above. The temporary installations are often required before the other facilities can be put in place and as such are often more problematic for location, containment, etc.

    Please refer to the NRCan Explosives Regulatory Division website for information on licensing, minimum distances requirements, etc., at www.erd.nrcan.gc.ca.

    a An Explosive Factory Licence is required for manufacturing facilities for explosives. A licensed facility can be a fixed site for the manufacture of blasting explosives, ammunition or fireworks, etc., or, in the case of bulk explosives, it can be the base of operations with the facilities necessary to clean, decontaminate and repair vehicles that mix and or deliver explosives directly down the borehole. If there is an existing licensed explosive factory that can serve as the base of operations for the project, then a new factory licence is not required.

    b Temporary factory sites are licensed factory sites that move with the construction of roads, hydro lines or pipelines, or are of short duration, such as some construction projects (e.g., air fields). Such sites must be supported by existing, licensed base factories equipped to properly service the process vehicles that would be located at the temporary site. A licence for a temporary factory is granted when the proponent has provided evidence that the site is truly temporary in nature.

    c A magazine is defined under the Explosives Act as any building, storehouse, structure or place in which any explosive is kept or stored. Please see the Explosives Act for exceptions.