U.S. Department of Justice

Bureau of Alcohol, Tobacco, Firearms and Explosives

Safety and Security Information For Federal 

Explosives Licensees and Permittees

ATF Publication 5400.15

March 2007
 Safety and Security Information for Federal 

Explosives Licensees and Permittees

ATF Office/Hotline Telephone Numbers and Addresses......................................................... 3

Security Reminder

What ATF Is Doing.............................................................................................................. 4

The ISEE and IME’s Commitment .......................................................................................5

Voluntary Security Checklist ....................................................................................................7

Procedures to Follow When Explosives Are Taken in a Crime ............................................... 9

(e.g., Theft)

Procedures to Follow When Explosives Are Missing From Inventory...................................10

(e.g., Disposition Unrecorded/Unknown)

Federal Stolen Explosives Laws and Regulations................................................................... 11

Regulatory Program Provisions (27 CFR, Part 555)...............................................................12

Licensee/Permittee Responsibility..........................................................................................13

Reporting Changes .............................................................................................................13

Responsible Persons vs. Employee Possessors........................................................................14

Identification of Explosives in Business Records ...................................................................15

Recordkeeping Requirements.................................................................................................15

Explosives Storage Requirements...........................................................................................18

Guide to Recording Suspicious Person Description................................................................19

Table of Contents
Safety and Security Information for Federal 

Explosives Licensees and Permittees



ATF 24-Hour Hotline............................................................................Toll Free 800-800-3855

U.S. Bomb Data Center (M-F, 8 a.m. to 5 p.m. e.s.t.)........................... Toll Free 800-461-8841

Toll Free Fax 866-927-4570

Stolen Explosives Hotline .....................................................................Toll Free 888-283-2662 

(After hours, weekends)...............................................................................(888-ATF-BOMB)

Local ATF Office Telephone Number (*see our Website for contact information)

ATF Website (For Updates and to Download Forms)............................................www.atf.gov

U.S. Bomb Data Center (Repository): USBDC@atf.gov

Bureau of Alcohol, Tobacco, Firearms and Explosives

U.S. Bomb Data Center 

P.O. Box 50980

Washington, D.C. 20091

Explosives Industry Programs Branch (EIPB) Mailing Address: EIPB@atf.gov

Bureau of Alcohol, Tobacco, Firearms and Explosives

Explosives Industry Programs Branch 

650 Massachusetts Avenue, NW.

Room 5000

Washington, D.C. 20226

ATF Distribution Center ......................................................................................703-455-7801

Important Telephone Numbers:

ATF Office/Hotline Telephone Numbers 

and Addresses

Contact Telephone Fax
 Safety and Security Information for Federal 

Explosives Licensees and Permittees

This program was expanded in 1998 to include 

“Be Secure for America,” which encouraged the 

agriculture industry 

to take extra security 

measures at production 

and distribution 

facilities. It was further 

updated in 2004 as 

part of the “America’s 

Security Begins with 

You” initiative. Each of 

these initiatives sought to 

raise industry members’ 

awareness about potential 

security vulnerabilities 

relating to ammonium 

nitrate and give them 

ideas on how to fix 

potentially dangerous problems.

After September 11, 2001, ATF initiated an ambitious 

outreach program to meet with every explosives industry 

member to address their concerns, to develop contacts, 

and to encourage the use of extra security measures. 

ATF was very successful in this initiative and will 

use this information for developing future outreach 

programs.

The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), in partnership with the Institute 

of Makers of Explosives (IME) and the International Society of Explosives Engineers (ISEE), 

would like to take this opportunity to once again remind all members of the explosives industry 

of the vital importance of employing security safeguards over explosive materials. Whether the 

explosive materials are in the process of manufacture, in storage, or in use, we urge everyone to 

use all necessary measures to safeguard explosive materials and prevent them from falling into 

the hands of those who may use them in criminal or terrorist acts.

The purpose of this booklet is to provide you, the industry member, with useful tips, techniques, 

and tools developed by ATF, the ISEE, and the IME for properly securing explosive materials.

In past advisories to explosives industry members, ATF has requested that you report any 

suspicious behavior or unusual activity to ATF and local law enforcement authorities. Keeping 

explosives secure requires more than that, however. It requires preparing and implementing a 

security plan. We urge each member of the explosives industry to adopt a security program. If 

you already have a security plan, please take this opportunity to re-evaluate your plan and ensure 

that it provides both safeguards and an action plan in the event of an emergency situation.

Security Reminder

What Is ATF Doing to Support the Explosives 

Industry in Keeping Explosives Secure?

ATF is committed to 1) keeping explosives out of the 

hands of those with criminal intent and 2) prosecuting 

those who illegally obtain or misuse explosives. While 

ATF is primarily concerned with law enforcement and

regulatory duties, we also strive to work with and 

consult with the industries we regulate, or the businesses, 

agencies, and groups that affect the industry. By doing 

this, we hope to develop more efficient, more effective, 

and less burdensome programs, policies, and procedures.

For example, immediately following the 1995 bombing 

of the Murrah Federal Building in Oklahoma City, ATF 

formed an alliance with The Fertilizer Institute (TFI) 

and other agriculture industry members to put forward a 

program called “Be Aware for America.” 

This program encouraged agriculture industry members 

to report any suspicious activities or thefts of ammonium 

nitrate, a precursor chemical often sought after by those 

with criminal intent, to ATF.
Safety and Security Information for Federal 

Explosives Licensees and Permittees



The IME and ISEE have also provided exceptional 

guidance to ATF in the development of this booklet. 

These organizations and ATF intend this guide to be 

useful for both industry members and ATF personnel. 

The IME has compiled and formulated excellent industry 

standards in the securing of explosive materials. In IME 

Standard Library Publication 27 (SLP 27), they outline 

guidelines that industry members should use in securing 

their explosives. While the suggestions for safety and 

security outlined in SLP 27 are voluntary, adoption 

of these guidelines would be highly beneficial to all 

explosives industry members. Copies of this and other 

SLPs are available from the IME at 202-429-9280 or by 

visiting their Website at www.ime.org. A copy may also 

be obtained through the ISEE Blaster’s Library at 

www.isee.org/publications, or 440-349-4400.

The following list, taken directly from the IME’s SLP 

27, is an example of the minimum general concepts IME 

recommends should be included in any security program.

1. Limit public disclosure of information on 

quantities and locations of explosives storage on a 

need-to-know basis. Of course, public safety 

authorities (such as fire, police, and local emergency 

management) should be in possession of specific 

information regarding the quantities and location of 

explosives storage facilities.

2. Get to know your local law enforcement and local

emergency planning committee (LEPC) personnel 

and get them to know you. An “open house” held

every year at your facility is an excellent method to 

accomplish this. This not only provides first-hand

familiarity to law enforcement of your site, but

provides invaluable face-to-face interaction with

these authorities. If you cannot get law enforcement

or LEPC personnel to visit your site, visit them.

Request a meeting so that you can introduce and

explain your operation. Specifically request in

writing that law enforcement pay special attention to

any suspicious activity around your site(s).

Whenever the country’s threat level is raised in response 

to the Department of Homeland Security’s advisories, 

ATF has contacted industry members through the ISEE, 

the IME, and other explosives organizations. These 

organizations get in touch with their own members to 

urge them to provide extra security at their facilities 

and report anything suspicious to ATF or other law 

enforcement authorities. 

ATF personnel often meet locally with representatives of 

the explosives industry in their area to discuss safety and 

security, and we encourage industry members to contact 

their local ATF office to arrange these meetings. ATF 

personnel also attend and give presentations on security 

at industry seminars and conferences. Those ATF 

representatives who attend these events enjoy meeting 

with industry members to discuss ideas on making the 

industry safer and more secure and on making ATF 

more effective at keeping explosive materials out of the 

hands of criminals.

Finally, ATF’s personnel, using agency resources 

such as the U.S. Bomb Data Center (USBDC), the 

Explosives Technology Branch, and the Forensic Science 

Laboratories, remain dedicated to the aggressive pursuit 

and prosecution of those who divert explosives into the 

illegal market, those who steal explosives, and those who 

illegally possess or misuse explosive materials. It was 

this dedication that led to the successful prosecution of 

domestic terrorist Eric Rudolph. 

The ISEE and IME’s Commitment to the 

Promotion of Explosives Safety and 

Security

The ISEE and IME have always had zero tolerance for 

the theft or illegal possession of explosive materials 

in any quantity and support the criminal prosecution 

of persons who commit such acts. Security and 

safety topics are often discussed at the ISEE’s annual 

conventions and at IME’s meetings. 

Security Reminder
 Safety and Security Information for Federal 

Explosives Licensees and Permittees

5. Establish a predetermined action plan for

implementation of increased security measures

brought on by a declaration of threat level higher

than “Yellow” or “Elevated” by DHS. How to deal

with shipments, production, and blasting operations

in progress should be well understood by all 

employees beforehand. In the event of an Orange or

Red Alert, additional security measures should be

considered for implementation on a site-specific basis,

in view of the type and scope of the specific alert.

6. Disseminate increased security alerts and security

recommendations such as these to your customers

and suppliers throughout the industry. Facilitate

their understanding of these alerts and 

recommendations.

7. Control official documents and information.

Prevent documents such as licenses, permits, route

plans, shipping schedules, and other authorizations

from reaching unauthorized individuals. Information

related to shipping, inventory, production schedules,

and processes should be kept secure and provided on

a need-to-know basis.

8. Conduct a safety and security review of all outside 

contractors or service providers who have access

to areas where explosives are present and are not

escorted before their services are used. Include a

security element in contractor or service provider

indoctrination training.

9. Develop security plans and conduct vulnerability

assessments for your entire operation.

Security Reminder

3. Instruct all employees to report any unusual or

suspicious activity immediately to appropriate 

authorities. Such activity could include:

• An attempt to purchase explosives by an 

unfamiliar or seemingly inexperienced individual;

•	 An individual who is reluctant to provide 

identification or information on their operation or 

intended use of explosives;

•	 Encountering an individual, either at work or on 

your own time, who seems very interested in your

occupation and details related to the accessibility 

of explosives;

•	 Out-of-place or repeat sightings of vehicles or 

individuals, especially individuals or vehicles at

gates or perimeter roads, and aerial over flights;

•	 Sighting unauthorized individuals inside a secure 

area; and

•	 Explosives-laden vehicles being followed.

If you encounter any such activity, write down 

information such as vehicle color, make, license number 

and State, and a physical description of suspicious 

individuals as soon as possible after noticing them. Take 

a photograph if possible. Retain and preserve papers or 

other items a suspicious individual may have touched for 

potential law enforcement processing. When witnessing 

known criminal activity, contact law enforcement 

immediately.

4. Designate an individual as your security 

coordinator. All employees should report suspicious 

or unusual activities to the security coordinator or, if 

the security coordinator cannot be contacted, their 

immediate supervisor. The security coordinator or

supervisor then reports the suspicious or unusual

activities to appropriate law enforcement personnel. 

The security coordinator should also establish

relationships with nearby chemical (or similar 

business) operations to share information. The 

security coordinator should maintain a log of unusual 

events.
Safety and Security Information for Federal 

Explosives Licensees and Permittees



1. Controlling Access to Keys

•	 Access to the keys for your storage magazines and 

for trucks loaded with explosives should be

restricted to essential personnel only. It also helps

to keep your keys in a secure, unmarked area,

preferably not in a central location at the premises.

•	 Having a logbook for essential personnel to sign in

and sign out keys can also enhance security and

can be useful in tracking down a missing set of 

keys. Alternatively, you could number or mark

keys and assign them to specific individuals.

•	 If you do not share keys, conducting an inventory 

of keys can help ensure that all keys are currently 

accounted for. You could conduct a yearly 

inventory of keys at the same time as your 

required inventory of explosive materials.

•	 You should change magazine locks if keys are 

missing or remain in the possession of terminated 

employees. This will help ensure that only your 

current employees have access to your magazines. 

You should create an internal policy for your 

company that instructs employees with access to 

keys to refrain from duplicating the keys without

authorization. 

2. Securing Your Magazine

•	 Although ATF recognizes that most licensees and 

permittees are already keeping their magazines in 

secure locations and are complying with the

Federal requirement to visually inspect their

magazines once every 7 days, you may want to

consider inspecting readily accessible magazines

on a daily basis. These inspections will allow you

to assess and correct any security or safety

vulnerability that may be present.

•	 Even if the current locations of explosives 

magazines meet the requirements of the table of 

distances, licensees and permittees may want to 

reassess their magazine locations to ensure that 

the magazines are placed in the most secure

locations.

Voluntary Security Checklist

Note: This checklist provides voluntary suggestions that industry members can use to make their businesses more 

secure. These suggestions are not required by ATF, but are only to serve as a helpful guide for securing explosive 

materials.

•	 Consider using locks with “forcing” and 

“surreptitious entry” ratings of at least “five” in 

the American Society for Testing Materials’ 

(ASTM) F883-97, Standard Performance 

Specification for Padlocks. For referenced ASTM

standards, visit the ASTM Website, www.astm.org,

or contact ASTM Customer Service at

service@astm.org. For the Annual Book of ASTM

Standards volume information, refer to the 

Standards Document Summary page on the ASTM

Website.

•	 Licensees and permittees may also consider the 

need to conduct regular inventories more often

than once per year to ensure that there have been 

no thefts/losses of explosive materials. 

•	 This booklet provides you with a clearly defined 

plan of action for recording and reporting lost or

stolen explosive materials. It is also recommended 

that you obtain all applicable Federal, State, and 

local agency telephone numbers in order to make 

a report. 

3. Securing the Storage Site

•	 Limit access to sites where explosive materials are 

being stored to essential personnel only. Restricting 

unauthorized personnel from these sites will 

prevent further exposure of the magazines to theft 

or tampering.

•	 Consider installing fences, floodlights, alarms, 

security cameras, locked gates, or other security 

devices at the site to better monitor the location. 

Alarm monitoring signs could be posted in highly 

visible places to deter unauthorized access.

•	 Contacting your local law enforcement agency and 

establishing a rapport with the officers who 

routinely patrol your area could be beneficial to

your security. Familiarize them with your business

hours so they can alert you when people are present

during off hours.
 Safety and Security Information for Federal 

Explosives Licensees and Permittees

Voluntary Security Checklist

6. Knowing Your Customer

•	 Although all persons ordering or receiving 

explosive materials must be licensed or permitted, 

licensees should also be alert to the following 

suspicious activities:

•	 The customer insists on paying in cash.

•	 The customer acts nervous or behaves in an 

unusual manner.

•	 The customer knows little about the product 

he/she is buying or its use.

Note: ATF has provided a Guide to Recording 

Suspicious Persons Description in the back of 

this booklet. This guide may be useful for 

recording descriptive information on any 

suspicious individual. Suspicious activities can be 

reported to ATF’s 24-hour hotline listed in the 

front of this book or your local law enforcement 

authority.

•	 Follow-up phone calls to your customer(s) may 

be useful to ensure that the customer(s) received 

the correct amount of explosive materials when 

a common or contract carrier is used to deliver 

the materials.

•	 Be cautious with unsolicited e-mail inquiries 

involving explosive materials, properties, 

blasting techniques, tunneling, etc. Please 

provide any suspicious e-mails to ATF if you 

believe further investigation is required.

•	 Training your employees is essential to securing 

your explosives. Employees should be trained to 

recognize what constitutes a suspicious customer 

or an unusual transaction. They should also be 

trained to respond to thefts, losses, or emergencies 

involving explosive materials.

•	 Other agencies such as the Occupational Safety 

and Health Administration (OSHA), the Mine 

Safety and Health Administration (MSHA), or 

State agencies may have additional rules and 

requirements for securing storage sites. It is 

recommended that you contact these agencies for

information on their requirements.

4. Updating Employee Backgrounds

•	 The best way to know who is working for you is to 

frequently update your list of responsible persons 

and employee possessors. Your company could 

establish an internal program to review these 

checks and update them as required.

5. Getting to Know and Recognize Your Vendors

•	 To the degree possible, encourage your employees 

to recognize which vendors service your facility.

Have the vendor’s telephone number(s) readily 

available to help your employees contact a vendor 

if they need to verify any unknown individual

who claims to be from the vendor.

•	 You should have vendors check in and receive an 

identification badge while at your facility. 

Escorting vendors throughout your facility is also 

recommended.
Safety and Security Information for Federal 

Explosives Licensees and Permittees



•	Contact Local Law Enforcement Authorities

Local Law Enforcement Telephone Number:

Contacting the local law enforcement authorities is 

essential to the quick recovery of explosives taken 

in a crime.

•	Contact Local ATF Office

Local ATF Office Telephone Number:

The local ATF office will work with the local law 

enforcement authorities investigating the theft. 

They can also assist in the preparation of the Theft/

Loss Report for submission to the U.S. Bomb Data 

Center.

•	Contact U.S. Bomb Data Center

Telephone Numbers: 1-800-461-8841 or 

1-888-283-2662 (ATF-BOMB)

•	Ensure Safety and Preserve Evidence

You are first and foremost responsible for making 

sure that you and your employees are safe! Do 

not enter a crime scene until law enforcement 

authorities indicate that it is safe. Do not disturb 

the crime scene until law enforcement authorities 

have completed evidence gathering. Unless you 

are asked to assist, avoid the temptation to assess 

damage/losses until they are finished.

•	Prepare ATF Report of Theft or Loss

(ATF F 5400.5)

A Report of Theft or Loss—Explosive Materials 

must be prepared when a theft of explosives from 

a licensee or permittee’s inventory occurs. Submit 

the original to ATF and keep a copy for your 

records. Although the U.S. Bomb Data Center 

should be notified as soon as possible, Federal 

law requires notification within 24 hours of the 

discovery. 

•	Notify ATF of Any Recovered Explosives

It is not uncommon to find that explosive 

materials initially thought to have been part of a 

group of stolen materials were in fact sold lawfully 

or are still in inventory. If explosive materials 

are inaccurately reported as stolen, it hampers 

law enforcement’s ability to solve the crime or 

may jeopardize prosecution. Please immediately 

correct inaccurate reports.

Procedures to Follow When Explosives Are 

Taken in a Crime (e.g., Theft)
10 Safety and Security Information for Federal 

Explosives Licensees and Permittees

Procedures to Follow When Explosives Are Missing 

From Inventory (e.g., Disposition Unrecorded/Unknown)

•	Notify the Local Law Enforcement Authority 

Local Police Telephone Number:

Although this notification is a requirement for all 

Federal explosives licensees and permittees, it 

should be made clear to the authorities that there is 

no evidence of a crime and that the disposition of 

these explosive materials is unknown/unrecorded. 

No local police report number is required to be 

placed in the disposition records because many 

departments will not issue a police report if no 

crime has occurred.

•	Contact U.S. Bomb Data Center

Telephone Numbers: 1-800-461-8841 or 

1-888-283-2662 (ATF-BOMB)

•	Notify ATF of Any Recovered Explosives

It is not uncommon to find explosive materials that 

initially could not be accounted for or located. It 

is extremely important that these discoveries be 

reported to the U.S. Bomb Data Center so that the 

list of explosives reported missing from inventory 

can be corrected.

•	Prepare ATF Report of Theft or Loss

(ATF Form 5400.5)

A Report of Theft or Loss—Explosive Materials 

must be prepared when it is discovered that 

explosive materials are missing from inventory. 

Submit the original to the U.S. Bomb Data Center 

and keep a copy for your records. The form can be 

obtained from the ATF Distribution Center or from 

www.atf.gov.

Although the U.S. Bomb Data Center should be 

notified as soon as possible, Federal law requires 

notification within 24 hours of the discovery. 

A full inventory check is also highly recommended 

(but not required) to locate missing explosives and 

to prevent future inventory losses.
Safety and Security Information for Federal 

Explosives Licensees and Permittees

11

Statutory Program Provisions 

(18 U.S.C. Chapter 40)

Title 18 U.S.C. 842(h). Title 18 U.S.C. 842(h) states 

“It shall be unlawful for any person to receive, possess, 

transport, ship, conceal, store, barter, sell, dispose of, 

or pledge or accept as security for a loan, any stolen 

explosive materials which are moving as, which are 

part of, which constitute, or which have been shipped 

or transported in, interstate or foreign commerce, either 

before or after such materials were stolen, knowing or 

having reasonable cause to believe that the explosive 

materials were stolen.” 

Title 18 U.S.C. 842(k). Title 18 U.S.C. 842(k) states, 

“It shall be unlawful for any person who has knowledge 

of the theft or loss of any explosive materials from his 

stock, to fail to report such theft or loss within twentyfour hours of discovery thereof, to the Attorney General 

and to appropriate local authorities.”

Title 18 U.S.C. 844(k). Title 18 U.S.C. 844(k) states, 

“A person who steals any explosive materials which are 

moving as, or are a part of, or which have moved in 

interstate or foreign commerce shall be imprisoned for 

not more than 10 years, fined under this title, or both.”

Federal Stolen Explosives Laws and Regulations

Title 18 U.S.C. 844(l). Title 18 U.S.C. 844(l) states, 

“A person who steals any explosive material from a 

licensed importer, licensed manufacturer, or licensed 

dealer, or from any permittee shall be fined under this 

title, imprisoned not more than 10 years, or both.”

Title 18 U.S.C. 844(p). Title 18 U.S.C. 844(p) discusses 

the theft reporting requirement. It states “(1) In general. 

A holder of a license or permit who knows that explosive 

materials have been stolen from that licensee or 

permittee, shall report the theft to the Attorney General 

not later than 24 hours after the discovery of the theft. 

(2) Penalty. A holder of a license or permit who does not 

report a theft in accordance with paragraph (1), shall be 

fined not more than $10,000, imprisoned not more than 

5 years, or both.”
12 Safety and Security Information for Federal 

Explosives Licensees and Permittees

Regulatory Program Provisions (27 CFR, Part 555)

27 CFR 555.30(d). Reporting theft or loss of explosive 

materials. This regulation states, “A carrier of explosive 

materials who has knowledge of the theft or loss of any 

explosive materials shall, within 24 hours of discovery, 

report the theft or loss by telephoning 1-800-800-3855 

(nationwide toll free number). Theft or loss shall also be 

reported to appropriate local authorities. Reports of theft 

or loss of explosive materials by carriers shall include 

the following information, if known:

(1) The manufacturer or brand name.

(2) Quantity (applicable quantity units, such as pounds 

of explosives, number of detonators, etc.).

(3) Description (United Nations (UN) identification 

number, hazard division number, and classification 

letter, e.g., 1.1D) as classified by the U.S. Department 

of Transportation at 49 CFR 172.101 and 173.52.”

27 CFR 555.34. Replacement of stolen or lost ATF Form 

5400.30 (Intrastate Purchase of Explosives Coupon 

(IPEC)). This regulation states, “When any Form 

5400.30 is stolen, lost, or destroyed, the person losing 

possession will, upon discovery of the theft, loss, or 

destruction, immediately, but in all cases before 

24 hours have elapsed since discovery, report the matter 

to the Director by telephoning 1-888-ATF-BOMB 

(nationwide toll free number). The report will explain in 

detail the circumstances of the theft, loss, or destruction 

and will include all known facts that may serve to 

identify the document. Upon receipt of the report 

the Director will make such investigation as appears 

appropriate and may issue a duplicate document upon 

such conditions as the circumstances warrant.”

27 CFR 555.165(a). Failure to report theft or loss. This 

regulation states, “Any person who has knowledge of the 

theft or loss of any explosive materials from his stock 

and fails to report the theft or loss within 24 hours of 

discovery in accordance with 555.30, shall be fined not 

more than $1,000 or imprisoned not more than one year, 

or both.”

27 CFR 555.165(b). On and after January 24, 2003, 

any licensee or permittee who fails to report a theft of 

explosive materials in accordance with 555.30 will be 

fined under Title 18 U.S.C., imprisoned not more than 

5 years, or both.

27 CFR 555.28. Stolen explosive materials. This 

regulation states, “No person shall receive, conceal, 

transport, ship, store, barter, sell, or dispose of any 

stolen explosive materials knowing or having reasonable 

cause to believe that the explosive materials were stolen.”

27 CFR 555.30(a). Reporting theft or loss of explosive 

materials. This regulation states, “Any licensee or 

permittee who has knowledge of the theft or loss of any 

explosive materials from his stock shall, within 24 hours 

of discovery, report the theft or loss by telephoning 

1-800-800-3855 (nationwide toll free number) and on 

ATF Form 5400.5 (formerly Form 4712) in accordance 

with the instructions on the form. Theft or loss of any 

explosive materials shall also be reported to appropriate 

local authorities.”

27 CFR 555.30(b). Reporting theft or loss of explosive 

materials. This regulation states, “Any other person, 

except a carrier of explosive materials, who has 

knowledge of the theft or loss of any explosive materials 

from his stock shall, within 24 hours of discovery, 

report the theft or loss by telephoning 1-800-800-3855 

(nationwide toll free number) and in writing to the 

nearest ATF office. Theft or loss shall be reported to 

appropriate local authorities.”

27 CFR 555.30(c). Reporting theft or loss of explosive 

materials. This regulations states, “Report of theft or 

loss of explosive materials under paragraphs (a) and (b) 

of this section must include the following information, if 

known:

(1) The manufacturer or brand name.

(2) The manufacturer’s marks of identification (date and 

shift code).

(3) Quantity (applicable quantity units, such as pounds 

of explosives, number of detonators, etc.).

(4) Description (dynamite, blasting agents, detonators, 

etc.) and United Nations (UN) identification number, 

hazard division number, and classification letter, e.g.,

1.1D, as classified by the U.S. Department of 

Transportation at 49 CFR 172.101 and 173.52.

(5) Size (length and diameter).”
Safety and Security Information for Federal 

Explosives Licensees and Permittees

13

Licensee/Permittee Responsibility

Reporting Changes in Responsible Persons 

and Employee Possessors

The Safe Explosives Act requires 1) all explosives 

licensees, permittees, and new applicants to provide 

information on employee possessors to ATF; and 2) for 

responsible persons to provide fingerprints and photographs to ATF, along with other required information, as 

part of the application process. This is to allow ATF

to conduct background checks on new responsible 

persons and employee possessors as noted in 27 CFR 

555.57(c). These provisions help ensure that explosives 

do not get into the hands of persons who may use them 

in criminal or terrorist acts. 

Some licensees and permittees have asked when these 

provisions must be met. As noted in 27 CFR 555.57(b): 

“For all licenses or permits issued on and after May 24, 

2003, each person holding the license or permit must 

report to the Chief, Firearms and Explosives Licensing 

Center, any change in responsible persons or employees 

authorized to possess explosive materials. Such reports 

must be submitted within 30 days of the change and 

must include appropriate identifying information for 

each responsible person. Reports relating to newly hired 

employees authorized to possess explosive materials 

must be submitted on ATF F 5400.28 for each employee.”

For licensing purposes, “changes” in responsible persons 

and employee possessors refers to those persons hired 

by the licensee or permittee after the submission of the 

application or renewal application form to the Federal 

Explosives Licensing Center.
14 Safety and Security Information for Federal 

Explosives Licensees and Permittees

Responsible Persons vs. Employee Possessors

Constructive Possession: 

This exists when an employee lacks direct physical 

control over explosive materials but knowingly has the 

power and intention to exercise dominion and control 

over the explosive materials, either directly or indirectly 

through others.

Examples:

•	 An employee at a construction site who keeps the 

keys for the explosives magazines.

•	 An employee who directs the use of explosive 

materials by other employees.

Please Note: An employee possessor must be an 

employee of the licensee or permittee. Workers not on 

the licensee’s or permittee’s payroll are not employees or 

employee possessors.

Any further questions on these requirements should be 

addressed to the Explosives Industry Programs Branch 

in ATF Headquarters at 202-927-2310, or the Federal 

Explosives Licensing Center in West Virginia at 

1-877-283-3352. 

Responsible Persons: A responsible person is an 

individual who has the power to direct the applicant’s 

management and policies pertaining to explosive 

materials.

Examples: 

•	 Explosives facilities site managers.

•	 Corporate directors and officers, as well as

stockholders who have the power to direct 

management and policies pertaining to explosives.

Employee Possessors: An employee possessor is an 

individual who has the actual or constructive possession 

of explosive materials during the course of his/her 

employment.

Actual Possession: 

This occurs when a person physically handles explosive 

materials as part of the production process; handles 

explosive materials in order to ship, transport, or sell 

them; or uses explosive materials.
Safety and Security Information for Federal 

Explosives Licensees and Permittees

15

Identification of Explosives in Business Records 

Daily Summary of Magazine Transactions

Date Name or Brand Name

of Manufacturer Quantity In Quantity Out Balance

Refer to 27 CFR 555.127

Accurate identification of explosive materials is 

critical to the safety and security of the public. The 

regulation at 27 CFR 555.109 requires each licensed 

manufacturer or importer of explosive materials to 

use legible marks to identify all explosive materials 

manufactured or imported for sale or distribution. The 

marks of identification include the importer’s location 

(city and State), the manufacturer’s location (city and 

State/country) and the date and shift of manufacture 

(including the date/shift for explosives manufactured 

overseas). The licensed importer or manufacturer 

must place these marks on each cartridge, bag, or 

other immediate container of explosive materials 

manufactured for sale or distribution. The marks 

of identification must also be placed on the outside 

container, if any, used for their packaging.

Federal explosives licensees and permittees 

receiving explosives must record the importer’s 

and manufacturer’s marks of identification in 

their acquisition and disposition records. Please be 

careful when identifying explosives and recording 

the identifying information. Commercial explosives 

manufacturers use an alphanumeric series called a 

date shift code that provides the location, date, and 

shift of manufacture. The date shift code is printed on 

the product or package. The date shift code is not to 

be confused with other alphanumeric codes that may 

appear on packages of explosives. These include U.S. 

Department of Transportation (DOT) classification 

codes, UN numbers, and DOT exemption numbers. 

Accurately identifying explosives in your acquisition and 

disposition records ensures that explosives can be traced 

in the event that they are lost, stolen, or recovered in a 

crime.

Recordkeeping 

Requirements

The regulations at 27 CFR 555, Subpart G, require 

explosives licensees and permittees to keep permanent 

records of the acquisition, disposition, and inventory of 

explosive materials. ATF relies on explosives licensees 

and permittees to make accurate and timely entries into 

their records. These records are essential in accounting 

for explosives inventory and identifying lost or stolen 

explosives. They are also an extremely important source 

of information for law enforcement during a criminal 

investigation. Persons holding multiple licenses or 

permits are required to prepare and maintain records for 

each license or permit. The information entered into the 

records is dependent upon the type of explosives license 

or permit. The regulations do not require a specific 

record format; however, ATF has provided the following 

samples to guide you when preparing your permanent 

records of acquisition, disposition, and inventory.
16 Safety and Security Information for Federal 

Explosives Licensees and Permittees

Recordkeeping Requirements

Dealer of Explosives Record of Acquisition

 Date of 

Acquisition 

Name or Brand Name

of Manufacturer and 

Importer (if any)

Manufacturer’s 

Marks of

Identification 

Quantity Description Name, Address and License or

Permit Number of Distributor

Refer to 27 CFR 555.124(b)

Dealer of Explosives Record of Disposition

Date of 

Disposition

Name or Brand Name

of Manufacturer and 

Importer (if any)

Manufacturer’s 

Marks of

Identification

Quantity Description License or Permit

Number of Distributee

Refer to 27 CFR 555.124(c)

Importer of Explosives Record of Acquisition

Date of Importation or

Other Acquisition

Name or Brand Name and 

Country of Manufacturer 

Manufacturer’s 

Marks of Identification Quantity Description

Refer to 27 CFR 555.122(b)

Importer of Explosives Record of Disposition

Date of 

Acquisition

Name or Brand 

Name and Country of 

Manufacturer

Manufacturer’s 

Marks of

Identification

Quantity Description License or Permit 

Number of Distributee

Refer to 27 CFR 555.122(c)
Safety and Security Information for Federal 

Explosives Licensees and Permittees

17

Manufacturer of Explosives Record of Acquisition

Date of Manufacture or

Other Acquisition

Manufacturer’s 

Marks of Identification Quantity Name, Brand Name orDescription and Size

Refer to 27 CFR 555.123(b)

Manufacturer of Explosives Record of Use

Date of Use Quantity Description

Refer to 27 CFR 555.123(d)

Refer to 27 CFR 555.125(b)

User of Explosives Record of Acquisition

Date of 

Acquisition

Name or Brand Name

of Manufacturer

Manufacturer’s 

Marks of

Identification

Quantity Description Name, Address and License or

Permit Number of Distributor

Refer to 27 CFR 555.125(c)

User of Explosives Record of Disposition (Surplus Stock)

Date of 

Disposition

Name or Brand Name

of Manufacturer and 

Importer (if any)

Manufacturer’s 

Marks of

Identification

Quantity Description License or Permit Number

of Distributee

Recordkeeping Requirements
18 Safety and Security Information for Federal 

Explosives Licensees and Permittees

Explosives Storage Requirements

When none of the above conditions apply, this section 

mandates that explosive materials must be kept in 

magazines that meet the construction and table of 

distance requirements of Subpart K. Any divergence 

from these requirements requires prior approval by the 

Director, ATF, in accordance with the provisions of 27 

CFR, Part 555.22. Persons with questions on this issue 

should contact the Explosives Industry Programs Branch 

in ATF Headquarters at 202-927-2310 or through e-mail 

(EIPB@atf.gov).

The Federal explosives regulations at 27 CFR, Part 555, 

Subpart K, outline the storage requirements for explosive 

materials. Section 555.205 specifies that all explosive 

materials must be kept in locked magazines meeting the 

standards in Subpart K unless they are:

(a) In the process of manufacture;

(b) Being physically handled in the operating process of a 

licensee or user;

(c) Being used; or

(d) Being transported to a place of storage or use by a 

licensee or permittee or by a person who has lawfully 

acquired explosive materials under Sec. 555.106.

Please note that “exempted” items (items that have 

received a specific exemption from ATF) are also exempt 

from the storage requirements outlined in Subpart K.
Safety and Security Information for Federal 

Explosives Licensees and Permittees

19

Guide to Recording Suspicious Person Description
U.S. Department of Justice

Bureau of Alcohol, Tobacco, Firearms and Explosives

99 New York Avenue, NE

Washington, DC 20226

For more information visit:

www.atf.gov