Manufacturing weapons and ammunition is one of the most tightly controlled activities in the metal-products sector. You cannot make firearms first and seek authority afterwards — the controls have to be in place before any manufacture begins. Three regimes stack up: firearms and section 5 authority, the explosives manufacture and storage licence, and the Control of Major Accident Hazards (COMAH) duties that apply once your holdings of explosives or propellant cross the threshold.
These are predominantly Great Britain regimes administered by the police, the Home Office and the Health and Safety Executive (HSE). Northern Ireland has its own firearms and explosives legislation, administered by the Police Service of Northern Ireland and HSENI — the guidance below points to the NI instruments where they apply. Work through the regimes in order.
A. Register as a firearms dealer and get section 5 authority
A person who, by way of trade or business, manufactures firearms or ammunition must be a registered firearms dealer under section 3 of the Firearms Act 1968, registering with the firearms licensing department of the police force for the area. Manufacturing prohibited weapons additionally requires the authority of the Secretary of State under section 5. You must keep records of manufacture, transfer and disposal. In Northern Ireland the equivalent regime is the Firearms (Northern Ireland) Order 2004, administered by the PSNI.
B. Get your explosives manufacture and storage licence
Manufacturing ammunition, propellants, primers and other explosives requires a licence under the Explosives Regulations 2014. HSE licenses manufacture and the larger stores; the local licensing authority or police license smaller stores. Your duties include assigned hazard types, separation distances, security of explosives and notification. HSE is the regulator in Great Britain; Northern Ireland operates a separate explosives regime. Manufacture also reads across to the security controls on explosives precursors.
C. Meet COMAH major-accident duties at threshold quantities
Ammunition, propellant and explosives manufacture and bulk storage can exceed the COMAH named-substance thresholds, making your site lower- or upper-tier COMAH. You must have a major-accident prevention policy and give notification; upper-tier sites must also produce a safety report and an on-site emergency plan. COMAH is enforced jointly by HSE and the environmental regulator acting as the Competent Authority — the Environment Agency in England, Natural Resources Wales in Wales, SEPA in Scotland. The equivalent regime in Northern Ireland is the COMAH Regulations (Northern Ireland) 2015. Only establishments holding qualifying quantities are caught.
-
1
1. Register as a firearms dealer
Apply to the police firearms licensing department for your force area before you manufacture any firearm or ammunition; in NI, register under the Firearms (NI) Order 2004 with the PSNI.
-
2
2. Get section 5 authority if you make prohibited weapons
Apply for the authority of the Secretary of State under section 5 of the Firearms Act 1968 before manufacturing any prohibited weapon.
-
3
3. Apply for your explosives licence
Get an Explosives Regulations 2014 licence from HSE (manufacture and larger stores) or the local authority/police (smaller stores) before production.
-
4
4. Assess your COMAH tier
Work out whether your explosives and propellant holdings put you below threshold, lower-tier or upper-tier COMAH, and notify the Competent Authority accordingly.
-
5
5. Build major-accident and security controls
Put your major-accident prevention policy, security of explosives, separation distances and (upper-tier) safety report and emergency plan in place.
What to do next
These specialist controls sit on top of the workplace duties every metal fabricator carries. Make sure your health and safety, COSHH, work equipment and fire arrangements are in place with Set up and run a safe metal fabrication workshop, then confirm the whole picture with the fabricated metal manufacturer compliance checklist.
Official sources
Authoritative guidance on firearms, explosives and major-accident control.