Comment on Explosives Regulations Amendment 2017

DOL explosives specialist, Rudzani Ramabulana.
DOL explosives specialist, Rudzani Ramabulana.

The Department of Labour called for comment on the draft Explosives Regulations Amendment 2017, including some changes in the required skills.

At a consultation workshop in late August 2016 at Unisa Florida campus, the DOL, SAPS, relevant Approved Inspection Authorities (AIAs), and the explosives industry forum, National Institute for Explosives Technology (Nixt), announced that;

  • Consultation is open, and a formal period of 90 days would follow soon.
  • Employers would have to inform and “thoroughly train employees in safe work procedures, and risks of shock, friction, fire, static electricity, and the Explosives Regulations”.
  • Explosives safety training providers would be accredited against SAQA standards.
  • Explosives handlers would re-apply on a new form, already available on the Internet, in terms of Reg4(4)(f).
  • Explosives Managers would be certificated by the chief inspector, and appointed by employers. The DOL would appoint SAQA-accredited trainers, and examiners to test their skills.
  • Employers would have to appoint one or more trained and experienced people.

Explosives risk assessments standard

Explosives risk assessments (Ex-RAs) and reports, would be standardised by SANAS TR 71-05, to include:

  • descriptions, hazard identifications, mitigation or treatment measures, and recommendations;
  • regarding buildings, processes, equipment, personnel;
  • and any of these elements that may be planned, or foreseen;
  • integrating radiation data;
  • taking account of research into past incidents on other sites;
  • in a written report;
  • available on site.

Ex-RAs would have to be signed off by and AIA (in terms of Regulation 18), or by a foreign AIA if recognised by the DOL. Emergency plans would have to provide for evacuation, and be tested yearly.

Regulation of pumpable emulsion explosives would be better standardised by the Amendment.
Regulation of pumpable emulsion explosives would be better standardised by the Amendment.

Ex-radio frequency exposure management

Radio frequency (RF) exposure of explosives would be managed by new standards. The risk of detonation by two-way radios, cellphones, scanners, vehicles, PCs, laptops, trackers, cameras, wifi, and other devices, had grown.

The safe distance for two-way radios is 12.2m; and for cellphones is 7.7m. Employers would have to set up exclusion zones. The inspector may approve of certain exemptions.

Explosives are immune to radio frequency fields of 1V/m2. Background radio fields in buildings is typically about 0.3V/m2. Some operators will have to test their plant for resistance against UHF signals

Transport of explosives would remain under SAPS enforcement, which would amend its regulation in 2017. Some aspects of explosives law would remain under the Department of Mineral Resources (DMR). The amendment would be followed by a DOL guideline in 2017, which would be legally binding.

Some South African explosives are exported to Malaysia and elsewhere.
Some South African explosives are exported to Malaysia and elsewhere.

Explosives industry to set guidelines

Nixt chairperson Dr John Cummins said the guide would include ammonium nitrate, PPAN, PGAN, TGAN, as well as pumpable emulsions, supply chain, and manufacturing waste disposal, thus a cradle to grave approach.

In the hierarchy of management (of policy, standards, guidelines, and procedures), guidelines are general and generic, but important in translating principles into practice.

Nixt would start drafting guidelines at its conference in October 2016, in Stellenbosch, themed on explosives testing and analytical methods.

The industry body shares incident investigation results, and Sheq issues, on a non-collusive basis between the six south African explosives manufacturers; BME, Sasol, AELMS, Maxam, Safex, RDM, and PMP. The African manufacturer Arica had joined as an associate.

Nixt offers awareness training, and guides universities on relevant process safety modules. It is involved in the international Chief Inspectors of Explosives conference in 2018 (contact

A typical explosives training kit, containing inert components.
A typical explosives training kit, containing inert components.

Explosives industry better governed than construction

DOL CEM director Pumi Maphaha thanked the industry for their co-operation in self-governance. The amendment took six years to reach draft stage. He complained that the construction industry was not as co-operative.

Despite industry agreement on professionalising construction health and safety some time ago, “Construction Health and Safety Agents are still nowhere to be found, and some construction sites do not have an engineer on site.”

DOL chief inspector Tibor Szana also criticised the legislative process: “Too often regulations come out with flaws that have to be corrected later.”

He may have been referring to the Construction Regulations Amendment, also long in the making. The C-Regs remain under public criticism for some impracticalities, such as the construction health and safety registration scheme, versus the legacy of poor OHS training, and low level appointments.

A typical bulk explosives delivery and charge scene.
A typical bulk explosives delivery and charge scene.

Long route to better health and safety laws

The regulation amendment had proceeded from an industry request, due to new technology, and procedural changes; to the DOL chief inspector; to the minister of Labour’s Advisory Council on Occupational Health and Safety (ACOHS); to the National Explosives Council; to a technical committee; to the state law advisor; to the national language services; to the minister of Labour. The same route would be repeated after public comments may be accounted for.

Unisa is the leading trainer of explosives managers, and offer CPD courses.

Among the delegates at the amendment consultation workshop were:

DOL explosives specialist Rudzani Ramabulana

DOL OHS chief inspector Tibor Szana

DOL construction and CEM director Pumi Maphaha

DOL major hazardous installation specialist ms R Aphane

SAPS col Jurie van Staden

Nixt chairperson Daniel Mynhardt

Nixt Ernest Hudson

SANDF gen Mandane

SANDF col Corrie Ferreira

Mining Roger de Villiers

DMR Willem Welding

DMR Hannes Jooses

DMR Anthiony Coutinno

DMR Kevin Hweston

Unisa CEMS quality and management sciences exec dean prof Thomas Mogale

Unisa prof H Schenk

Sanas Eben Smit

RDM ms M van Emmenis

ITC Callie Fouche

Ishecon AIA D Rademeyer

Railway Safety Regulator (RSR) Links Mudale

Fedusa Alwyn van Heerden

Cosatu Lenox Mekuto


Fire and emergency bodies were invited to comment, and to join Nixt.

Comment contact details

DOL Explosives specialist:

DOL explosives secretary:

Explosives industry body Nixt:


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